Privacy Policy

This Privacy Policy was last modified on Sept 6th, 2017 and is effective immediately.

  1. INTRODUCTION
  2. INFORMATION WE COLLECT ABOUT YOU
  3. HOW WE USE THE INFORMATION THAT WE COLLECT
  4. OPTING-OUT OF CERTAIN USES OF YOUR INFORMATION 
  5. SHARING AND DISCLOSURE OF INFORMATION WE COLLECT
  6. DATA COLLECTION FROM CHILDREN
  7. SECURITY
  8. SWEEPSTAKES, CONTESTS AND PROMOTIONS
  9. YOUR CALIFORNIA PRIVACY RIGHTS 
  10. INTEGRATION OF THIRD PARTY PLATFORMS AND SERVICES
  11. PRIVACY POLICY CHANGES
  12. ACCURACY 
  13. INTERNATIONAL USAGE
  14. CONTACT US
  15. SOLE STATEMENT

 

1.   Introduction.  

IT Operations LLC is committed to providing excellent service to all of our customers, including safeguarding the privacy of their information.  This Privacy Policy explains our privacy practices, including what types of information we collect from you and how we may use it, our rights to share and disclose such information to third parties and how you can review and modify information that you provide to us and your preferences regarding our use and disclosure of such information.  Please review our Terms of Service which governs your use of the Services.  Any capitalized terms that are not defined in this Privacy Policy shall have the meaning ascribed in the Terms of Service.

This Privacy Policy only applies to the information collected by IT Operations LLC and its affiliates (collectively, “we”, “our” or “us”) or any third parties acting with our authorization or otherwise provided to us by third parties about you, in each instance, in connection with your use of the Services.  This Privacy Policy applies regardless of the Device you use to access the Services and whether you are accessing the Services as a registered user or otherwise. 

By using or interacting with the Services, you are consenting to the collection and use of your information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, then please do not use the Services.  

 

2.   Information We Collect About You.

A. Registration Information.  In order to access and use certain features, content or functions of the Services, (e.g., account registration, reservations, communication/networking features, purchases, promotions, etc.), you may be asked to provide certain information, including your name, username, password, e-mail, date of birth, gender, address and other descriptive information.  

B. Payment Information.  If you make any purchase or reservation on or through the Services, your payment information (e.g., credit or debit card type, number and expiration date) and related information (e.g., physical address) may be collected by us and/or our third party payment processors.  

C. Information You Choose to Provide to Us.  We collect any information you provide on or through the Services or give us in any other way.  For example, we collect any information you provide when you update your user account and profile, participate in contests, surveys and other promotions relating to the Services, interact with customer service and sign up to receive newsletters and other communications regarding the Services and/or third-party products or services.  In addition, the Services may include features that rely on the use of information stored on, or made available through, your mobile Device.  We may also ask to collect or use the specific location of your mobile Device (e.g., by accessing your Device’s GPS). If you agree to allow access to your location, you agree that we and our service providers may collect such location-based information from your Device.  We may also collect other information based on your location and your Device’s proximity to “beacons” and other similar proximity systems, including, for example, the strength of the signal between the “beacon” and your Device and the duration that your Device is near the “beacon”.  The type of location data we collect depends on a number of factors, including the type of Device you are using (e.g., laptop, smartphone, tablet) and the type of connection enabled on your Device (e.g., Wifi, Bluetooth, broadband cable).  The Trump Apps or other features of the Services may rely on this location information in order to provide certain location-based services, such as promotional offers, merchandise offers, event information and other related content that may be of interest to you.  We may also use location information to improve the functionality of the Trump Apps and our other applications and services.  If you do not wish to have this location information collected and used by Trump, you may “opt-out” by disabling the location and Bluetooth features on your Device and/or in the Trump Apps.  As a general note, you can choose not to provide certain information, but you may not be able to access certain content or take advantage of certain promotions or features of the Services.  

Depending on the Device you are using, we may use third party services to provide mapping services. For example, Trump may use Google maps on certain Devices—you can learn more about the information that Google collects through its mapping services at http://www.google.com/privacy.html.

D. User Posts.  You may have the ability to use the Services to communicate with other users of the Services and post comments to or otherwise interact with certain aspects of the Services that are available to the public and/or other users.  We may collect any information you submit, post or provide in the course of such activities.

E.   Usage Data and Technical Information.  The Services include features that automatically collect certain information, which may include the unique Device identifier assigned to your Device, Third Party Platform anonymous identifiers, and other information regarding your use of the Services to, among other things, assist us in authenticating your usage and/or Device, keeping track of your preferences, creating a more tailored user experience and better serving your particular interests and needs. The Services and/or third parties may use "cookies" (which are small data files containing information about you that is stored on your hard drive), "embedded scripts", "pixel tags" and other similar tracking technologies (collectively, "Tracking Technologies") to collect information automatically as you interact with the Services.  Such information may include "clickstream" data, the domain name of the service providing you with Internet access, your Device type and attributes, Internet protocol (IP) address, network connection type (e.g., WiFi, 3G, LTE), browser type and version, operating system and platform, the average time spent on the Services, pages viewed, content searched for, access times and other relevant statistics, and your interactions with  playlists, audiovisual content, other users of the Services, advertising, and products and services which are offered, linked to or made available on or through the Services.  Such information may be collected by us and/or our third-party service providers and partners.  Certain Tracking Technologies enable us to customize your experience on the Services and provide tailored recommendations, promotions, advertisements and other content relating to your specific interests.  Other Tracking Technologies are used to make login to the Services easier (such as by remembering your user ID) and allow us to collect non-specific location information.  You can learn more about the use of cookies and other Tracking Technologies on the Services in Section 4.D below.

F. Third Party Platform Information.  If you access the Services via your Third Party Platform account (e.g., by logging in to the Services using your Third Party Platform account credentials) and/or integrate your Trump account with your Third Party Platform account, we may collect certain information from the Third Party Platform, such as your username and other information you provided to the Third Party Platform in connection with your account (e.g., name, country, date of birth, gender and e-mail address).   You can learn more about adjusting your settings and preferences with respect to Third Party Platforms in Section 4.A below.

G. Advertising Service Providers. The Services may also use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Advertising Service Providers”) to, for example, serve advertisements on the Services, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on or in connection with the Services. Such services may enable us to display advertisements based on your use of the Services and other websites, services and platforms you have visited or used. Such services also enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. These Third Party Advertising Service Providers may use their own Tracking Technologies to collect similar information.  Trump does not control these Third Party Advertising Service Providers and/or their use of Tracking Technologies, which is instead governed by the privacy policies of any such Third Party Service.  

Please see Section 4.E below for more information on how to opt-out of the collection and use of information collected via certain automatic collection technologies.

 

3. How We Use Information That We Collect.

A. Except as prohibited by the terms and conditions of any applicable Third Party Platform (e.g., Facebook, etc.) and subject to Section 4, we may use information we collect for, among other things, the following purposes:

  • Sending you marketing, promotional, e-mails, messages and other correspondence and notifications regarding the Services and the services of third parties we believe may be of interest to you;
  • To notify you about new features and offerings of the Services, including, but not limited to, promotions, events, discounts, news about our hotels, products and services, and/or special offers;
  • Delivery of features, content, services and products available to you through the Services based on your location;
  • Allowing affiliates, service providers, contractors, agents, sponsors and other third parties to assist us in providing and managing the Services;
  • Contacting you regarding the administration of any features or functions of the Services you have registered to use;
  • Sending you information about your relationship or transactions with us;
  • Marketing and promoting the Services, including, without limitation, promotions and other initiatives and activities, as well as products and services of affiliates and third parties that we believe would be of interest to you; 
  • Where you order goods or services, performing credit checking or other authentication;
  • For the prevention and detection of fraud or infringement of our or any third party’s rights;
  • Responding to your questions or other requests; 
  • In connection with an actual or possible reorganization, merger or amalgamation with another entity, or an actual or possible sale of all or a portion of the assets of Trump’s business;
  • Tailoring your experience on the Services and/or otherwise customizing what you see when you visit and use the Services; 
  • Enabling Third Party Advertising Service Providers to deliver customized, localized and/or interest-based advertising on the Services and third party websites and services, as further described in Section 4 below;
  • Saving your User Account, registration and profile data or other information (so you do not have to re-enter it each time you visit or use the Services); 
  • Tracking your return visits to and use of the Services; 
  • For other purposes disclosed at the time you provide us with the information or which are reasonably necessary to provide the Services or other related product and/or service requested; 
  • For research purposes, for marketing/promotional purposes and/or to provide anonymous reporting for internal and external clients, business partners, licensees, third party organizations, etc.;
  • Accumulating and reporting aggregate, statistical information in connection with the Services and user activity;
  • Determining which features and services users like best to help us operate the Services, enhance and improve our services and the Services and display advertising and marketing information; and
  • Saving certain information for your ongoing use of the Services.

 

4. Opting-Out of Certain Uses of Your Information.

A. User Account Privacy Settings.  You also may be able to adjust certain privacy, permission and user account settings by responding to request alerts or notifications that may be presented to you on your Device prior to or following the collection of the relevant information or by navigating to the settings, account or privacy section (as the case may be) of your Device or the applicable Third Party Platform and limiting certain Service functionality (e.g., location services, etc.).  Please be aware that if you limit the collection of certain information, you may not be able to use all of the features and functionality of the Services.

B. Marketing and Promotional Communications.  At times, you may be presented with the option of whether to receive, or automatically entered to receive, certain marketing and promotional communications from us and others that we think will be of interest to you. Recipients of such communications can unsubscribe by either following the specific instructions included in such communications or you may “opt-out” of receiving marketing and promotional e-mails from us at any time by or by sending an email to us at privacy@ivankatrump.com detailing your privacy request. Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings. Additionally, you should be aware that any information provided to third parties prior to your election to opt-out or unsubscribe cannot be retrieved or rescinded by us unless required by applicable law, and you cannot retroactively opt-out or unsubscribe with respect to such third parties.  Also, please note that in order to keep you informed about the operation of our Services and related services, we may always send you emails and announcements that are needed for the proper functioning and administration of our Services, including for the purposes described in Section 3 above, in connection with your use of such Services. We may also have features that allow you to submit information, questions or feedback to us. In those instances, we may retain your emails and other information you submit to us for our internal purposes, and to help us to serve you better.

C. Privacy Preferences. You may also change certain privacy preferences (e.g., choose to cease receiving certain communications or ask us not to share your personal information with a particular third party) by sending an email to us at privacy@ivankatrump.com detailing your privacy request.  If you ask Trump to stop using your personal information, we will honor that request, provided that we may retain a record of such information as necessary to comply with applicable law and we may continue to use your contact information to contact you about your Services-related transactions and to respond to your requests, as well as your IP address to determine the country in which you are accessing the Services. Other privacy preferences (e.g., deactivating your user account, etc.) may be made by modifying your user account settings on the Services, your Device and/or the applicable Third Party Platform. You always have the right to access, review and correct the personal information you have provided and generally you may review, update or delete certain information collected by the Services at any time by accessing your user account as described herein or by contacting us as described in Section 14.

D.   Use of Information Collected by Third Party Advertising Service Providers.  We may collect and share with Third Party Advertising Service Providers, and allow Third Party Advertising Service Providers to directly collect, certain information about you and your interaction with the Services. These Third Party Advertising Service Providers may also use Tracking Technologies that enable them to collect information regarding your interaction with third party websites, services and platforms. Such information may include your email address, browser and operating system type and version, IP address, location-based information, Device type and other Device identifiers, web pages and browsing activity, interaction with advertisements and your other online activities over time and across different websites, applications and Devices. This information may be used by us and third parties for analytics, attribution and reporting purposes and to show you targeted advertisements for products and services that you might be interested in on the Services and on unaffiliated websites, applications and platforms. If you would like to learn more about how Third Party Advertising Service Providers collect and use your information or find out how you can opt-out from allowing these Third Party Advertising Service Providers to gather this information or use it to display targeted ads, please see Section 4.E below. 

E. Opting-Out of Use of Certain Information That May be Collected by Tracking Technologies. 

  • Third Party Advertising Service Providers: For more information about Third Party Advertising Service Providers and similar entities that use tracking technologies, see www.aboutads.info/consumers, and to opt-out of such Third Party Advertising Service Providers interest-based advertising practices, go to www.aboutads.info/choices. Note that, in order to opt-out of the collection of data in connection with your use of the Trump Apps for interest-based advertising purposes, you may need to adjust your mobile Device’s settings.
  • Tracking Technologies: Most browsers are initially set to accept cookies (other than Flash cookies) and allow local storage, but you should be able to change your settings to notify you when a cookie is being set or updated, local storage is being used, and/or to block cookies and/or the use of local storage altogether.  Please consult the "Help" section of your browser for more information. Please note that by blocking any or all cookies you may not have access to certain features, content and/or other personalization available through the Services.
  • Flash Cookies: Users can manage the use of Flash technologies, with the Flash management tools available at Adobe’s website, see http://www.adobe.com/products/flashplayer/security/privacy_policy/faq.html.  
  • Do-Not-Track Signals: Certain browsers transmit "do-not-track" signals to the websites in which such browsers communicate with; however, this feature, and how it is used and activated, varies from browser to browser.  Therefore, it is not clear whether the signals are intentionally transmitted by a user, or whether a user is even aware of this.  Despite current efforts, there is still disagreement amongst leading Internet standards organizations, industry groups, technology companies and regulators, concerning what, if anything, websites should do when they receive such signals and no standard has been adopted to date.  Trump takes privacy and security very seriously.  With respect to “do not track signals”, we currently do not take action in response to these signals, but, if a standard is established and accepted, we may reassess how to respond to these signals.  

 

5. Sharing and Disclosure of Information We Collect.

A.   Disclosure to Third Parties.  We reserve the right to use, share, exchange and/or disclose to third parties any of your information for any lawful purpose, including, but not limited to, as may otherwise be described in Section 3 above.  You can choose to opt-out of certain such uses at the time such information is collected or by subsequently changing your preferences, as further described in Section 4 above.

B. Co-Branded Services and Features.  The Services may offer co-branded services and features, such as activities, events, initiatives, promotions and selected products and services provided by us and/or our affiliated entities or other third party partners, and that may be made available on the Services and/or our co-branded partner's platform, website or service.  If you wish to opt-out of a co-branded partner's future use of your information for marketing or other purposes, you will need to contact the co-branded partner directly.  Please note that the use of such information by co-branded partner is subject to co-branded partner's privacy policy.

C. Disclosure of Certain Information in User Postings Intended to Be Disclosed. Certain information associated with a User Posting may be intended for disclosure, such as your username. We will disclose any such information in connection with the display of, and other services relating to, such User Posting and by submitting a User Posting on or in connection with the Services you affirmatively consent to the distribution of your information as described herein. 

D. Service Providers, Owners and Licensees.  We may provide and disclose your information to affiliates, operators, service providers and other third parties, including, without limitation, Developers (as defined below), managers and other affiliated parties, for the purpose of providing, offering, supporting, administering and maintaining the Services, and providing the full range of content, activities, services, features and functions offered on or in connection with the Services.

E. Additional Disclosures.  There may be instances when IT Operations LLC may access or disclose information without providing you a choice in the following circumstances: (i) to protect or defend the legal rights or property of Trump, our affiliated companies or their employees, agents and contractors (including enforcement of our agreements), (ii) to protect the safety and security of our Services and users, (iii) protect against fraud or for risk management purposes, (iv) if we believe your actions violate this Privacy Policy or Terms of Service or (v) to comply with law or legal process.  In addition, in connection with a possible or actual sale, merger or transfer of all or part of Trump’s or any of its affiliate’s businesses or assets, Trump may transfer your information to the party or parties involved in the transaction as part of that transaction who may use that information for the purposes set forth in this Privacy Policy.

 

6. Data Collection From Children. 

We do not knowingly collect personal information from U.S. children under 13 without appropriate parental notice and consent. Please visit http://www.ftc.gov/bcp/edu/pubs/consumer/tech/tec08.shtm for information from the Federal Trade Commission about protecting children’s privacy online. 

 

7. Security. 

While no data transmission over the Internet is 100% secure from intrusion, we maintain reasonable physical, electronic and procedural safeguards to protect your information. However, it is possible that third parties may unlawfully intercept or access transmissions or private communications despite our efforts to prevent same and we therefore make no guarantees regarding the security of user information.

 

8. Sweepstakes, Contests and Promotions.  

From time to time, we may offer sweepstakes, contests, and other promotions (any, a "Promotion") through the Services that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you opt to enter a Promotion, your information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on list of the winners.

 

9.   Your California Privacy Rights. 

If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt-out (which we may sometimes refer to as “unsubscribe”) or opt-in for use of your information by third parties (such as Advertisers) for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that received your information for marketing purposes during the preceding year. If you are a California resident and wish to request information about how to exercise your third party disclosure choices, please submit your request at privacy@trump.com or by postal mail to The Trump Organization, c/o Privacy Administrator, 725 Fifth Avenue, New York, New York, 10022, Attn: Your California Privacy Rights.  All requests must be labeled “Your California Privacy Rights” on the email subject line or envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

 

10. Integration of Third Party Platforms and Services.  

The Services may be linked to, rely on and/or be integrated with websites, applications, interfaces, services and/or platforms operated by third party companies, including service providers, Third Party Platforms and developers/owners of certain Trump-branded properties (“Developers”).  The Services may also feature advertisements from other third parties. Trump is not responsible for the privacy practices of any websites, applications, interfaces, services and platforms operated by such third parties that are linked to, rely on and/or integrated with the Services, including those Trump-branded websites operated by Developers, or for the privacy practices of third party advertising companies. Once you leave this Services via such a link, access a third party application, interface, service, or platform, including Third Party Platforms and websites operated by service providers or Developers, or click on or navigate to an advertisement, you should check the applicable privacy policy of such third party to determine, among other things, how they will handle any personally identifiable or other information that they may collect from you.

 

11. Privacy Policy Changes.  

From time to time, we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, technology, our information collection and use practices or the features and functionality of the Services, and such modifications shall be effective upon posting.  When we change this Privacy Policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.  Your continued use of the Services after we post a revised Privacy Policy (and, where appropriate, notify you of same) signifies your acceptance of the revised Privacy Policy.  It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. We may also seek your affirmative consent to the terms of the updated Privacy Policy.   For example, we may ask for your consent before implementing new uses of the personal information that we’ve already collected from you, if such new use was not addressed by the privacy policy under which such information was collected. 

 

12. Accuracy. 

It is your responsibility to give us current, complete, truthful and accurate information, and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information, or you fail to update such information.  We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.

 

13. International Usage.  

The Services are controlled, operated and administered entirely within the United States. If you visit, access, interact with and/or otherwise use the Services from a location outside the United States, please be advised that any information you provide in connection with any such activity may be processed in and/or transferred to the United States of America and/or other territories and locations, where privacy protections may not be as comprehensive as those in the territory or location where you interact with or otherwise use the Services. By using the Services, you affirmatively consent to the transfer, use, disclosure, provision, and other administration of your information as described herein.

 

14.   Contact Us. 

If you have any questions about our privacy practices or any of the terms or conditions of this Privacy Policy, please feel free to contact us at: 

Email: privacy@ivankatrump.com

OR

Mail: IT Operations LLC

Attn: Privacy Matters 725 Fifth Avenue New York, New York 10022

 

15. Sole Statement. 

This document is the sole statement of the Services’ Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, without limitation, machine-generated, is valid.

Copyright © 2017 DTTM Operations LLC