Universal Beijing Resort Personal Information Protection Policy
Published by:2020 / 01 / 15

This Personal Information Protection Policy (“Policy”) explains how Beijing International Resort Co., Ltd. and its affiliates (collectively “we” or “us”) which operates Universal Beijing Resort (as defined below, “UBR”), collect, use, and share information from or about you (a) when you participate in activities or events, and/or interact with us before and/or after you enter into the UBR; (b) when you use or visit websites, mobile applications (“App”), mini-programs, WeChat public accounts, or other web pages or accounts offered by or related to our services or products, (c) when you use connected devices such as theme-park devices or other digital devices to receive our services, or (d) when you receive our other services to which this Policy applies (the services or products mentioned in the foregoing item (a) through item (d) being collectively referred to as “Services”).

“Universal Beijing Resort” means a world-class international destination resort being developed in Tongzhou District of Beijing, China, which will initially contain and include the theme parks, CityWalk and their respective back of house support facilities and office buildings; the parking structures serving the entire resort, CityWalk and their support facilities; the hotels and their respective support facilities and parking structures; and the dormitory housing complex.

PLEASE READ THIS POLICY TOGETHER WITH OTHER APPLICABLE POLICIES CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. BY USING THE SERVICES, YOU ACKNOWLEDGE YOU HAVE READ AND UNDERSTOOD THIS POLICY AND THAT WE WILL COLLECT, USE AND SHARE YOUR INFORMATION AS SET FORTH BELOW.

Agent. In the event you are an agent agreeing to this Policy on behalf of other people, you represent and warrant that you have the legal capacity and authority to act for and on behalf of such people, and that such people have granted their permission for you to provide their information to us through the Services.

For detailed information, please refer to the relevant section in following index:

Index

I PERSONAL INFORMATION WE COLLECT AND PURPOSES OF COLLECTION

II WHEN WE SHARE YOUR INFORMATION

III PROTECTION OF CHILDREN PERSONAL INFORMATION

IV YOUR RIGHTS

V YOUR CHOICES

VI HOW WE PROTECT YOUR INFORMATION

VII HOW LONG WE KEEP YOUR INFORMATION

VIII INTERNATIONAL TRANSFER

IX UPDATES TO OUR PERSONAL INFORMATION PROTECTION POLICY

X CONTACT US

  • I PERSONAL INFORMATION WE COLLECT AND PURPOSES OF COLLECTION

    The tables below explain the information we collect under certain business scenarios and the purposes for which we use them. The collection and use of such information may vary under different scenarios.

    Please note that when you choose to receive certain UBR Services, you should provide us with or allow us to collect certain information that is necessary to achieve the major purpose or use the core function (collectively, the “Core Function”) of such Services or we will not be able to provide you with the Core Function.

    You may also be requested to provide us with certain additional information which enables us to provide you with better user experience. However, if you choose not to provide such additional information, you will still be able to use the Core Function, but may not be able to receive certain additional Services or enjoy better user experience thereunder.

    The tables below explain the categories of information we collect and the purposes for which we use them. Each UBR Service’s collection and use may vary. Please note that we may use any or all the information to comply with laws, detect or prevent fraud, or defend our legal rights. Further detail about each of the purposes is set out in the “Additional Information on Purposes” table below.

    Personal information (“PI”) means any information that is recorded, electronically or otherwise, that can be used alone or in combination with other information to identify a natural person or reflect the activity of a natural person, including such as name, date of birth, ID number, personal biometric information, residential address, contact information, communication records and content, username and password, property information, credit information, records of whereabouts, accommodation information, health and physiological information, transaction information of an individual.

    Sensitive personal information means the personal information that once leaked, illegally provided or abused, could endanger personal and property safety, or easily lead to damages to personal reputation, mental & physical health, or discriminatory treatment, etc., including such as ID numbers, personal biometric information, bank account information, communication records and content, property information, credit information, records of whereabouts, accommodation information, health information, transaction information, and PI of minors under the age of 14. Sensitive personal information under this Policy is in bold letters and underlined.

    Categories of PI we collect Purposes of use
    Information you provide to us:

    Contact information and account registration

    May include: name, email, mailing address, telephone number, account username and password, business contact information, and any information you may provide to us at an event or in person.

    • Provide UBR Services
    • Personalize your experience
    • Send you marketing communications
    • Provide seamless experience across platforms and devices
    • Protect our users, Services and properties
    • Build and manage business-to-business relationships
    • Market and advertise for third-parties

    Identification and demographics

    May include: government ID number, date of birth, gender, nationality, ethnicity, interests, lifestyle information, photos, social media credentials, including identification information about friends, contacts or referrals you provide.

    • Provide UBR Services
    • Personalize your experience
    • Send you marketing communications
    • Provide seamless experience across platforms and devices
    • Protect our users, Services and properties
    • Market and advertise for third-parties

    Transactional

    May include: credit/debit card details, purchase history, delivery address, membership information, reservations, and the personal details of any of your guests.

    • Provide UBR Services
    • Personalize your experience
    • Send you marketing communications
    • Provide seamless experience across platforms and devices
    • Protect our users, Services and properties
    • Market and advertise for third parties

    User-generated content

    May include: photos, videos, audios, and other information you may submit to us, such as comment on our forums.

    • Provide UBR Services
    • Personalize your experience
    • Send you marketing communications
    • Protect our users, Services and properties
    • Market and advertise for third parties

    Research and feedback

    May include: comment that you send to us through online forums and social media platforms, by email, over the phone, by mail, or in surveys.

    • Provide UBR Services
    • Personalize your experience

    Biometric identifiers

    May include: facial recognition data we collect at some of our theme parks or our offices.

    • Provide UBR Services
    • Personalize your experience
    • Protect our users, Services and properties

    Audio and video

    May include: audio recordings of guest service calls or security video footage if you visit one of our properties.

    • Provide UBR Services
    • Personalize your experience
    • Protect our users, Services and properties

    Device information and identifiers

    May include: IP address, cookie IDs, browser type and language, operating system, platform type, device type, and advertising and app identifiers.

    • Provide UBR Services
    • Personalize your experience
    • Provide seamless experience across platforms and devices
    • Protect our users, Services and properties
    • Market and advertise for third parties

    Connection and usage

    May include: domain names,browsing activity, scrolling and keystroke activity, advertisements viewed, forms or fields you complete or partially complete, search terms, whether you open an email, content you view and duration, quality of the service and interaction with the content, logs, and other similar information. If these events occur while you are offline, they may be logged and uploaded to us when you are connected next time.

    • Provide UBR Services
    • Personalize your experience
    • Provide seamless experience across platforms and devices
    • Protect our users, Services and properties
    • Send you marketing communications
    • Market and advertise for third parties

    Geolocation

    May include: city, province and ZIP code associated with your IP address or derived through Wi-Fi triangulation.

    We will ask for your permission before using your precise location from GPS-based functionality on your mobile devices.

    • Provide UBR Services
    • Personalize your experience
    • Provide seamless experience across platforms and devices
    • Protect our users, Services and properties
    • Market and advertise for third parties

    Categories of PI we collect Purpose of use Source of information
    Information we collect from third-parties:

    Information from public and commercial sources

    May include: demographic information including at a household level, contact information, inferences about your preferences, loyalty program membership, and purchasing data.

    • Provide UBR Services
    • Personalize your experience
    • Provide seamless experience across platforms and devices
    • Send you marketing communications
    • Build and manage business-to-business relationships
    • Market and advertise for third parties
    • Advertising providers
    • Analytics providers
    • Marketers
    • Partners (such as for sweepstakes partners)
    • Consumer data resellers
    • Public records databases
    • Related Companies

    Social Media Information

    May include: if you interact with us through social media service or log in using social media credentials, depending on your social media settings, we may have access to your information from that social media platform such as your name, email address, friends list, photos, age, gender, location, birthday, social media ID, current city, your comment about our Services, and people/sites you follow.

    • Provide UBR Services
    • Personalize your experience
    • Send you marketing communications
    • Provide seamless experience across platforms and devices
    • Social media networks
    • Partners of social media networks

    Additional information we collect for business relationships only
    Categories of PI we collect Purpose of use Source of information

    Business contact information

    May include: company name, your name, email address, and job.

    • Build and manage business relationships
    • You
    • Your company
    • Trade associations
    • Social media
    • Business data resellers

    Due diligence information

    May include: contact information, nationality, job title, age, date of birth, gender, country of residence, employment and education information, public,religious, political or trade union roles, personal and professional affiliations, connections to criminal activities or offences related to money laundering.

    • Compliance and risk management activities for business relationships
    • Your or your company’s responses to our due diligence questions
    • Third-party compliance screening tools and databases we purchase

    Additional information on purpose of use

    Provide UBR Services, for example:

    • responding to your requests or inquiries, including technical support
    • sending you service-related communications
    • providing ticketing, hotel booking, payment services, mapping guidance, and offers
    • displaying content you generate, such as video or comments
    • carrying out research and analytics for uses including improving our Services and developing new Services
    • processing your information for promotional campaigns such as sweepstakes and contests, and for surveys of online and offline panels and focus groups

    Personalize your experience, for example:

    • providing you with customized product experiences, including personalized newsletters, viewing and other content recommendations from UBR, our partners and other organizations
    • providing you with advertising based on your activities and interests including at a household level
    • creating and updating profiles and audience segments that can be used for analytics, interested-based advertising and marketing on the UBR Services, third-party services and platforms, mobile apps and/or websites, connected devices and offline
    • using inferences about your preferences and interests for any and all of the above purposes
    • When we provide above personalized information to you based on your activities, interests and preferences through our algorithm, we will also provide you with an opt-out option

    Send marketing communications (with consent if required), for example:

    • sending you newsletters, surveys and information about products, services and promotions offered by UBR

    Provide seamless experience across platforms and devices, for example:

    • identifying you when you log into the UBR Service on multiple devices or web browsers to provide continuity and match your interests across devices for the purposes of analytics, advertising, reporting and to improve Services
    • identifying you if your devices have attributes suggesting that they may be used by the same individual or household for purposes of analytics, advertising, reporting and to improve Services

    Build and manage business relationships, for example:

    • pursuing potential business opportunities, including identifying and contacting the correct person within the company
    • sending communications for business purposes
    • sending event invitations, marketing emails and campaigns, and tracking the effectiveness of such communications
    • providing business contacts with access to our systems, and managing such access

    Market and advertise for third-parties (with consent if required), for example:

    • send you newsletters, promotional emails, surveys and information about products, services and promotions offered by our partners and other organizations we work with (with consent if required)
    • customize content that our third-party partners deliver on the Services (e.g., personalized third-party advertising)
    • create and update inferences about you and audience segments that can be used for interested-based advertising and marketing on the Services, third party services and platforms, and mobile apps
    • create profiles about you, including adding and combining information we obtain from third-parties and matching your interests across devices, which may be used for third-party marketing and advertising on UBR Services, third-party services and platforms, mobile apps and/or websites, connected devices and offline

    Compliance and risk management activities for business relationships, for example:

    • compliance with laws and regulations
    • managing third-parties and other risks to our business
    • protecting the reputation of our businesses
    • following the principles of ethical business conduct set out in our code of conduct

    Protect our users, Services, and properties, for example:

    • protecting the safety and security of users and visitors to UBR Services
    • protecting our digital and physical properties
    • detecting and preventing other activities that may be illegal or in violation of our Terms of Services for the respective UBR Services

    We may combine all the information we collect from or receive about you for the outlined purposes. We may anonymize your information and may use, share, rent or sell such information which cannot identify you for any purpose as permitted by law, and such information is not subject to this Policy.

  • II WHEN WE SHARE YOUR INFORMATION

    1. When we share your information

    We will not share your personal information with any company, organization or individual, except under the following circumstances:

    (1) Related Companies

    Our related companies include Beijing Shouhuan Cultural Tourism Investment Co., Ltd., Universal (Beijing) Consulting Co. Ltd., and their respective affiliates (“Related Companies”). We may share your personal information with our Related Companies to help better tailor and provide the Services, products, marketing, and advertising to you and to other existing and potential customers. We may share identification and demographics, device information and identifiers, and research and feedback for purposes such as improving and tailoring the Services. In addition, business information may be shared for business operational purposes.

    (2) Service Providers

    We may engage vendors to perform business purposes on our behalf and share information with them to enable them to provide us with such business purposes, including research and analytics, hosting, transaction and payment processing, promotion administration, fraud prevention, identity management, acquisition and other services. Service providers may use such information for their operational purposes in order to provide their services to us.

    (3) Advertisers, Advertising Networks, and Other Third Parties

    We may share information about how you use UBR Services and interact with content or ads to better tailor the Services, products, marketing and advertising on our Services and third-party platforms. To enable these purposes, we may share certain demographics information, user-generated content, device information and identifiers, connection and usage data, geolocation data, public and commercial information, and social media information. These third-parties may use their own tracking technologies to collect or request information about you, please see our Cookies and Tracking Technologies Policy.

    (4) Partners

    We may share your information with third-party partners. For example, if you enter a contest or sweepstakes sponsored by a third-party, we may share the information you provide for such entry with the sponsor. Depending on the partnership, we may share certain information including contact information (at your direction), identification and demographic information, transactional information, user-generated content that you provide, research and feedback, device information and identifiers, connection and usage information, public and commercial information, and social media information.

    (5) Search Engines

    Depending on the UBR Service, you may be able to engage with other members of the Services or the public. This may make the name and photo associated with your profile and any comments or user-generated content you provide visible to other members of that Service or the general public. If the information is available to the general public, it may also be searchable by search engines.

    (6) Law Enforcement, Regulators, Anti-fraud Coalitions and other groups

    We share any of the categories of information we collect, as appropriate, with these third-parties in order to: protect and enforce the legal rights, privacy, and safety of ourselves and our visitors; protect against possible fraud or other illegal activity or for risk management purposes; respond to inquiries or requests from government, regulatory, law enforcement, or public authorities; permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain; and otherwise comply with the law including legal process.

    (7) Third party SDK

    Part of the services in our App or mini-program are provided by or with the support from third-party service partners. For this reason, our App or mini-program needs to integrate with third-party software development kit (“SDK”) or other similar tools. We will conduct security test on such SDK, enter into agreement with the providers of such SDK and require them to use, process and protect your personal information in accordance with this Policy and their respective applicable personal information protection policy.

    We may need to adjust the third-party SDKs we integrate with in order to provide more services, ensure service stability and quality, or upgrade related functions. We will inform you of the latest status of such third-party SDKs on this page.

    Third Party SDK List


    SDK Name: Bugly SDK

    SDK Provider: Tencent Inc.

    Scenarios: UBR App IOS & Android version

    Type of collected personal information: Users’ device information

    Purpose of collecting personal information: Identifying and reporting bug issues for trouble shooting

    SDK Provider’s privacy policy (may be updated from time to time by such SDK Provider): https://privacy.qq.com/


    SDK Name: Tencent Map SDK

    SDK Provider: Tencent Inc.

    Scenarios: UBR App iOS & Android version, and WeChat Mini-program

    Type of collected personal information: Users’ location

    Purpose of collecting personal information: Providing location services such as navigation

    SDK Provider’s privacy policy (may be updated from time to time by such SDK Provider): https://privacy.qq.com/


    SDK Name: Tencent QCloudAIVoice SDK SDK

    SDK Provider: Tencent Cloud Computing (Beijing) CO., LTD.

    Scenarios: UBR App iOS & Android version, and WeChat Mini-program

    Type of collected personal information: voice messages uploaded by users

    Purpose of collecting personal information: Improving users’ experience by providing services such as translation, Q&As, etc. via voice recognition technology

    SDK Provider’s privacy policy (may be updated from time to time by such SDK Provider): https://privacy.qq.com/


    SDK Name: Gaode Map SDK

    SDK Provider: AutoNavi Software Co., Ltd.

    Scenarios: UBR Ali Mini-program

    Type of collected personal information: Users’location

    Purpose of collecting personal information: Providing location services such as navigation

    SDK Provider’s privacy policy (may be updated from time to time by such SDK Provider): https://lbs.amap.com/home/privacy/

    (8) Other Sharing

    We may share information about you along with a hashed or masked identifier, with third-parties so they may better personalize your experience with them and the offers they send to you.

    With regard to any companies, organizations or individuals we may share personal information with, we will sign strict confidentiality agreements with them, under which we will require them to follow our declaration, this Policy and any other relevant confidentiality and security measures in handling such shared personal information.


    2. When we transfer your information

    We will not transfer your personal information to any other company, organization or individual, except under the following circumstances:

    (1) Transferring information with explicit consent: we will transfer your personal information to other parties upon obtaining your explicit consent.

    (2) In the event that we or our Related Companies are involved in a merger, acquisition, transfer of control, bankruptcy, reorganization or sale of assets, or diligence associated with such matters, we may sell or transfer the information described in this Policy as part of such transaction.

    We will require the new company or organization that will hold your personal information to continue observing this Policy. Otherwise, we will require the new company or organization to ask for your authorization and consent separately.


    3. When we make public disclosure of your information

    We will publicly disclose your personal information (excluding personal biometric identifying information) only under the following circumstances:

    (1) After obtaining your explicit consent.

    (2) Disclosure according to applicable laws: we may publicly disclose your personal information as required by laws, under legal procedures, in lawsuits or upon compulsory requirements of competent governmental authorities.

  • III PROTECTION OF CHILDREN PERSONAL INFORMATION

    Most of UBR Services are intended for users of all ages. Information about practices of UBR Services directed to children under the age of 14 or where we have actual knowledge a child is under such age can be found in our UBR Children Personal Information Protection Notice.

    If you are a parent or guardian and believe your child under the age of 14 has provided us with personal information without consent, please contact us through the contact information specified in “CONTACT US” below.

  • IV YOUR RIGHTS

    In certain jurisdictions you may have the right to:

    • ask us to provide access to certain information we hold about you
    • update or correct your information
    • delete certain information
    • if we rely on consent, you have the right to withdraw the consent
    • restrict the use of your information
    • deregister your account
    • respond to your above-mentioned requests

    For security reasons, you may be required to submit written requests or prove your identity by other means. We may ask you to verify your identity before processing your request.

    We will respond within the time period required by applicable laws. If you are not satisfied, you may file a complaint by the contact information under the “CONTACT US” below. Please note that many of the above rights are subject to exceptions and limitations.

    We will not charge you for your reasonable requests in principle. However, a fee to reflect the cost will be imposed as appropriate on repeated requests beyond reasonable scope. As for repeated requests that are groundless and require excessive technological means (e.g. developing a new system or fundamentally changing the current practices) to fulfill, bring about risks to others’ legitimate rights and interests, or are downright impractical (e.g. involving information stored on a backup disk), we may reject.

    We will not be able to respond to your request under certain circumstances set forth in applicable laws.

    Some UBR Services can only be provided if we have your information, therefore deletion of your information will result in termination of such Services.

  • V YOUR CHOICES

    1. Cookies and Similar Technologies

    We, and our service providers, advertisers, and other partners, use cookies and similar technologies (e.g., HTTP cookies, HTML 5, flash local storage cookies, web beacons, GIFs, embedded scripts, ETags/cache browsers, and software development kits) to recognize you and/or your device(s) on, off and across different UBR Services and devices. For more information about the use of cookies on the UBR Services (including your opt-out options), please see the Cookies and Tracking Technologies Policy.


    2. Mobile App and Connected Devices

    Depending on the device you use, you may be able to manage your advertising and location preferences through your device settings and as outlined in our Cookies and Tracking Technologies Policy. Many operating systems provide their own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable system operator allows you to manage personalized in-application advertisements. You should review your device manufacturer’s support materials and/or the device settings for the respective operating systems for more detail on how to manage such preferences.

    You can stop all collection of information by an App by uninstalling the App.


    3. Third-Party Online Services

    UBR Services may contain links to third-parties’ websites or services. These sites (even if branded as UBR) may collect information of you when you visit them and use such information in accordance with their own privacy policies and terms of use. We do not endorse or control those third parties’ policies or practices.

    Where UBR collects personal information on a co-branded website or service, we will provide a link to our Policy as appropriate.

  • VI HOW WE PROTECT YOUR INFORMATION

    We maintain organizational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use.

  • VII HOW LONG WE KEEP YOUR INFORMATION

    We will keep your information for only as long as it is necessary to fulfill the purposes described herein, unless a longer retention is required or permitted by law. We may delete or anonymize your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable laws. The retention period that applies to your information may vary depending on the UBR Services you use and how you interact with them. Some UBR Services may provide additional details on their data retention practices, and we encourage you to check the relevant terms and/or FAQs.

  • VIII INTERNATIONAL TRANSFER

    In principle, the information we collect and generate within the territory of People's Republic of China will be stored within the territory of People's Republic of China.

    The fact that we provide our products or Services through our worldwide resources and servers means that when we have obtained your authorization and consent, your personal information might be transferred to other jurisdictions outside the territory of the country or region where you use our products or Services, or be accessed by these jurisdictions. This is necessary to provide our Services and for the purposes outlined in this Policy. Data privacy laws vary from jurisdiction to jurisdiction and may not be equivalent to, or as protective as, the ones in your jurisdiction. We take steps to ensure that reasonable safeguards are in place with the aim to ensure an appropriate level of protection of your information, in accordance with applicable laws. These measures include data transfer agreements. By providing us with your information, you acknowledge any such transfer, storage or use.

  • IX UPDATES TO OUR PERSONAL INFORMATION PROTECTION POLICY

    We reserve the right to amend this Policy at any time to reflect changes to our practices or applicable laws. We will make the revised Policy accessible through UBR Services. Please check the UBR Services periodically for updates.

    The date at the top of the Policy indicates when it was last updated. If we make material changes to the way we collect or use your information, we will provide you with an appropriate notice, including but not limited to, by posting the updated Policy on this website, and providing notice in accordance with legal requirements. Any changes to this Policy will become effective when the revised Policy is posted. By continuing to use the UBR Services following any changes to this Policy, you acknowledge you have read and understood such updated Policy, and you understand that we will collect, use, and share the information as stated therein.

  • X CONTACT US

    We have set up a specific department in charge of protecting personal information (or specialists in charge of protecting personal information). If you have any concerns, opinions or advices on the Policy, other applicable policies or our personal information protection practices , you may contact us at UBRContactUs@universalbeijing.com or, BOH #805, 2F UBR Legal Department, 101121, Universal Beijing Resort, Liyuan Town, Tongzhou District, Beijing, Attn: UBR Personal Information Protection Working Group.

    We will reply to you within the time period required by applicable laws.

    If you are not satisfied with our reply, we would like to have an opportunity to address your concerns, please contact us.

    We have separate policies for workforce data. Please see our Candidate Personal Information Protection Policy to find out more about the information we collect during our recruitment process.