Privacy Policy

Privacy Policy

Gray Collection, its subsidiaries and the entities in which it holds an interest, including the hotels, restaurants and spas forming part of its portfolio of brands (collectively “Gray Collection”, “we”, “our”, or “us”), are committed to protecting the privacy and security of the personal information of our guests, partners and users.

This Privacy Policy describes how we collect, use, disclose and protect your personal information when you:

  • visit our website
  • make a reservation
  • stay at one of our properties
  • visit our restaurants or spa
  • attend events hosted by us
  • contact us
  • subscribe to our newsletter
  • interact with us on social media.

It also explains your rights regarding your personal information and how you may exercise those rights.

This privacy policy (“Policy”) describes how we collect, use and disclose your personal information and how this personal information can be consulted and corrected when necessary, whether collected from you as a website user, an email subscriber, a hotel guest, an event attendee, a visitor to our restaurants or spas, or a customer or partner of Gray Collection. This Policy also explains how cookies are used on our Website.

By visiting this website or by registering for an account via this website (collectively the “Website”), contacting us or agreeing to receive emails from Gray Collection, you accept the terms and conditions of this Policy.

This Policy does not extend to websites operated by third parties. Gray Collection is therefore not liable for their privacy policies, procedures and practices.

1. Personal Information We Collect

We collect your personal information in several ways, including when you enter information on our Website, make a reservation, register for an account, apply for a job, contact us by telephone or by email, post on our social media accounts, etc. Depending on the circumstances, personal information may include your first name, last name, email address, phone number, postal address, resume, username and password. If you choose to withhold any personal information requested by us, it may not be possible for you to gain access to certain parts of the Website.

 

We may collect the following categories of personal information:

 

Identification Information

  • first and last name
  • email address
  • phone number
  • mailing address

Reservation Information

  • stay details
  • guest preferences
  • reservation history
  • special requests

Payment Information

Certain transactions may require the collection of payment information, which is processed securely by specialized third-party providers.

Professional Information

  • résumé or curriculum vitae
  • job application information.

Technical Information

When you visit our website, we may collect:

  • IP address
  • device type
  • browser type
  • pages visited
  • date and duration of visit.

 

The legal bases for our processing of personal information are primarily that the processing is necessary for providing the Website and that the processing is carried out in our legitimate interests, which are further explained in the “Use and Communication of Information” section. We may also process personal information upon your consent, asking for it as appropriate.

2. Cookies and Similar Technologies

Our website uses cookies and similar technologies in order to:

  • ensure the proper functioning of the website
  • measure website traffic
  • improve user experience
  • personalize certain communications.

The categories of cookies used may include:

 

Essential Cookies

Necessary for the operation of the website (language preference, security, session management).

 

Analytical Cookies

Used to analyze website usage (e.g., Google Analytics).

 

Marketing Cookies

Used to deliver personalized offers or content.

You may manage your cookie preferences through our cookie consent banner.

3. Legal Basis for Processing

We process personal information on the following legal bases:

 

  • performance of a contract (e.g., processing reservations)
  • compliance with legal obligations
  • our legitimate business interests (such as improving our services)
  • your consent when required by law.
4. Use of Personal Information

We use personal information for the following purposes:

 

  • operating and improving our website
  • processing reservations and providing our services
  • responding to inquiries or requests
  • sending marketing communications where permitted
  • analyzing usage trends
  • developing new services and offerings
  • complying with legal obligations.
5. Disclosure of Personal Information

We may disclose personal information in the following circumstances:

 

Within Gray Collection

Among our affiliated entities, subsidiaries or corporate group members.

 

To Service Providers

Including providers of:

  • reservation platforms
  • technology services
  • website hosting
  • newsletter distribution services (e.g., Mailchimp, GetResponse)
  • analytics tools (e.g., Google Analytics)
  • marketing partners (e.g., Adviso).

These providers only receive the information necessary to perform their services and are required to maintain confidentiality.

 

To Public Authorities

Where required by applicable laws or legal processes.

 

In Business Transactions

In connection with mergers, acquisitions, or asset sales.

6. International Data Transfers

Your personal information may be transferred to and processed in countries other than your country of residence.

 

When such transfers occur to jurisdictions with different privacy laws, we implement appropriate safeguards, including:

 

  • standard contractual clauses
  • contractual confidentiality obligations
  • technical security measures.
7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

 

Type of Data

Retention Period

Customer and reservation data

up to 7 years

Marketing communications

up to 3 years

Analytics data

up to 14 months

Job applications

up to 2 years

 

These retention periods may be extended where required by law.

8. Security of Personal Information

We implement appropriate physical, administrative and technological safeguards to protect personal information against:

 

  • unauthorized access
  • loss
  • alteration
  • disclosure.

However, no method of transmission over the Internet can be guaranteed to be completely secure.

9. Privacy Incidents

In the event of a privacy incident involving personal information that presents a risk of serious harm, we will:

 

  • notify affected individuals
  • inform relevant regulatory authorities where required
  • take appropriate steps to mitigate the risks.
10. Your Rights

Depending on applicable laws, you may have the right to:

 

  • access your personal information
  • request correction of inaccurate information
  • request deletion of certain data
  • restrict processing
  • object to certain uses of personal information
  • receive your personal information in a portable format
  • withdraw consent where processing is based on consent.

You may also file a complaint with the relevant data protection authority.

11. Children's Privacy

Our website is not intended for children under the age of 16.

 

We do not knowingly collect personal information from children without parental consent.

12. Changes to this Policy

We may update this Privacy Policy from time to time to reflect legal, operational or technological changes.

 

The most current version will always be available on our website.

13. Privacy Officer

For questions regarding this Privacy Policy or to exercise your rights:

 

Gray Collection
Privacy Officer
425 Saint-Jean-Baptiste Street, Suite 200
Montréal, Québec H2Y 2Z7

info@graycollection.com
+1 514-866-8080