Privacy Policy

Halekulani Corporation dba Halepuna Waikiki by Halekulani values the privacy of the personal data of our guests and other individuals and is dedicated to protecting this information.

In this Privacy Policy, we provide you with details about how we collect, use, and disclose your personal data offline at our hotels and online.  The term “personal data” refers to any information that may be used to identify you as an individual. It may include, among other things, your name, social security number, birthdate, phone number, email address, postal address, age, gender, and details of your passport, driver’s license or other identification document.

You can access specific topics within this Privacy Policy, including information about the personal data we collect, the purposes for which we use and disclose such personal data, whether we sell or share personal data, and how long we retain such personal data and related subjects, by clicking on the relevant links below:

Personal Data We Collect
Use of Personal Data Collected
Disclosures of Personal Data
Rights Related to Your Personal Data
Cookies and Other Tracking Technologies
How We Protect Personal Data
Transmission of Data to Other Countries
Third-Party Applications/Websites
Data Retention
Children
Contact Information

Personal Data We Collect

Halepuna Waikiki by Halekulani collects personal data about you in order to operate effectively and provide you with the best customer service and most memorable guest experiences. We collect personal data about you from a variety of sources, including through our website and social media pages, from you or our third-party travel booking partners for reservations, when you contact our call centers, or when you otherwise voluntarily provide it to us. We also receive information about you from other third parties, business partners, our affiliates, and publicly available sources.

The following personal data may have been collected from or about you in the past 12 months:

  • Reservation information (such as name, email address, mailing address, phone number, fax number, and other personal data necessary to fulfill your reservation);
  • Payment information (including payment card numbers, billing address, bank account information, and in limited cases, we may collect credit status, through our third-party payment processors);
  • Guest Stay Information (including dates of arrival and departure, goods and services purchased; information necessary to fulfill special requests, such as health conditions that require specific accommodations);
  • Demographic data (such as age, gender, and location);
  • Copies of correspondence if you contact us. If you provide us feedback or contact us for support, we will collect your name and e-mail address and possibly other personal data, as well as any other content that you send to us in order to reply;
  • Information related to your use of and interaction with our website or social media pages;
  • When you sign up on our mailing list, offers or events, or partner promotions (as part of co-branded promotion with another company);
  • If you participate in a survey;
  • If you are required to submit an ID through Intelity for verification purposes and as permitted by applicable law, this app collects user uploaded images, such as your identification card, used when checking in via our mobile app;
  • Information collected through our closed-circuit television systems, card key and other security systems;
  • Job applicant information provided by you, such as name, gender, age, date of birth, email address, mailing address, telephone number, social media profiles, and in certain instances, identification documents, residency and work permit status, social security number (which may also be considered Sensitive Information) or other taxpayer/government identification number. This personal data also includes any professional qualifications, prior employment history, education history, additional information included in curriculum vitae, and references, as well as notes collected by interviewers and other professional assessment information.  If we offer you a job, we may collect additional background information, such as credit history and eligibility information (as permitted by law);
  • Links to Other Sites: If you receive email from us, we use certain tools to enable links to the websites of other companies or other companies’ social media sites that may contain a different privacy statement.  We recommend that you read the privacy statement of each website that you visit;
  • Mobile Devices: We collect information from your mobile device such as unique identifying information about your device when visiting our website or social media pages or when visiting one of our locations;
  • Third-Party Tracking: With your consent, we participate in behavior-based advertising. This means that a third-party may use technology (e.g., a cookie) to collect information about your use of our website or social media pages so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our websites, on other websites, or on our social media pages; and
  • Web Logs: We collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer or other device you are using when you use the Internet), domain name, social media account ID, click activity, referring website, and/or a date/time stamp for your visit.

If you voluntarily share “Sensitive Information” (e.g. personal data related to your health) with us, that information will only be used as necessary to fulfill special requests (e.g. health conditions that require specific accommodations).  For example, if you voluntarily convey a health-related need to us, we may store and use that information in order to provide a room with appropriate amenities.  We do not collect or store Sensitive Information unless it is voluntarily provided by you and only for the purposes that you have permitted us to use this Sensitive Information.

Additionally, if you apply for a job with us, we may collect information that is considered Sensitive Information. Such information provided by you, includes (where permitted and in accordance with applicable law): social security number, driver’s license number, racial or ethnic origin, health and medical information (including where required, drug screening results), and/or criminal history. We only collect and use this information as permitted by applicable law.

Use of Personal Data Collected

Halepuna Waikiki by Halekulani has collected your personal data in the past 12 months for the following purposes:

  • To fulfill reservations and other purchases at our property (including hotel accommodations, food & beverage, Spa, Boutique, Concierge services, or other requested products or services);
  • To communicate with you;
  • To improve service to our customers and to track, process, and respond to customer care inquiries and to enhance and improve the customer’s experience;
  • To respond to your inquiries related to support, employment opportunities, or other requests;
  • To send marketing and promotional materials, including information relating to products, services, sales, or promotions;
  • For internal administrative purposes, as well as to manage our relationship with you;
  • To process your application for employment; and
  • For additional uses of personal data as described when you provide such information to us or for other purposes with your consent.

Legal Basis for Processing Personal Data
Where required by applicable law, we rely on the following legal grounds for the collection, processing, and disclosure of your personal data:

  • As necessary to provide a service or perform a transaction (such as when we respond to your requests);
  • Consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or the use of certain digital tracking tools);
  • As necessary for our legitimate interests (such as when we act to maintain our global business generally, including maintaining the safety and security of the website); and
  • Compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.

The provision of your personal data is partly a statutory requirement and partly a contractual obligation.

Disclosures of Personal Data

In addition to the specific situations discussed elsewhere in this Privacy Policy, in the past 12 months we may have disclosed personal data in the following situations:

  • Service Providers. We disclose your personal data to service providers.  Among other things service providers help us to administer our website, conduct surveys, provide technical support, process your financial information, and assist in the fulfillment of orders.
  • Public. Some of our websites and social media pages provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit comments or reviews on these pages, that information may be publicly available.
  • Partner Promotion. We may offer contests, sweepstakes, or other promotions with third-party partners.  If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third-party partner, the information that you provide will be disclosed to us and to them.  Their use of your personal data is not governed by this privacy policy and rather will be governed by the privacy policy of such third-parties.
  • Affiliates and Acquisitions. We disclose your personal data with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).  We may also disclose your personal data if another company acquires our company, business, or our assets.
  • Other Disclosures with Your Consent. We may ask if you would like us to disclose your personal data with unaffiliated third parties who are not described elsewhere in this Privacy Policy.
  • Other Disclosures without Your Consent. We may disclose personal data in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We also may disclose your personal data in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.

Rights Related to Your Personal Data

Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials, as well as targeted offers from third parties.  You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  Although we will remove your name from our mailing list after receiving your request within the timeframe permitted by law, you may still receive mailings from us that had been initiated prior to your name being removed.  If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, to ask you to rate the product you purchased, or other service-related communications.

Promotional Mailings.  If at any time you do not want to receive offers from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of them being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.

Other Rights.  Depending on where you are located (e.g., California, European Union, United Kingdom) and the types of personal data at issue, you may have certain rights with respect to your personal data. Please note that many of these rights are subject to exceptions and limitations.

  • Right of access: You have the right to request information regarding whether your personal data is being processed, and, where that is the case, to request access to, including a copy of, the personal data undergoing processing.
  • Right to correction: You have the right to request that we correct or supplement any inaccurate or incomplete personal data we process about you.
  • Right to deletion: You have the right to request that we delete your personal data or as applicable anonymize your personal data.
  • Right to data portability: You have the right to request that we provide the personal data that you provided to us in a structured, commonly used and machine-readable format; and you have the right to transmit such personal data to another entity.
  • Right to prohibit the sale or sharing of Personal Data: We do not sell or share your personal data, as such terms are defined under applicable law.
  • Automated Processing: Under certain circumstances, you have the right to opt-out of the use of automated decision-making technology when it is used for significant decisions concerning you or for extensive profiling. We do not currently use automated decision-making technology for these purposes.
  • Right to limit the processing of your Sensitive Information: We do not currently use or disclose Sensitive Information for purposes other than those which cannot be limited under applicable law.

If you choose to assert any of these rights under applicable laws, we will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations. If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. Under local law, you may be entitled to lodge a complaint with your local data protection authority or your state Attorney General’s Office.

Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfil a request. In such a case, your request may not be fulfilled.

We do not discriminate against individuals who exercise any of the rights described in this Privacy Policy. However, we may require use of your personal data to provide you access to our services. Therefore, when you exercise your deletion right, in particular, you may lose access to certain aspects of the services that require your personal data.

Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. If you designate an authorized agent to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.

Your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal data or an authorized representative of that person; and (ii) describe the request with sufficient detail.  We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  To exercise your rights, please contact us as stated in the “Contact Information” section of this Privacy Policy.  If we cannot validate the identity of you and/or your authorized agent or obtain proof that you have given your authorized agent permission to act on your behalf, we will attempt to contact you to inform you.

Cookies and Other Tracking Technologies

Every time you come to the website, our website’s web server automatically collects information, including, in some instances, personal data, through cookies, web beacons, and other similar tracking technologies (collectively “cookies”). Cookies are small text files that are placed on your computer or mobile device when you visit a website. Cookies help the website remember information about your visit, which can make it easier to visit the website again and make the website more useful to you. Some cookies are deleted once you close your browser (session cookies), while other cookies are retained even after you close your browser so that you can be recognized when you return to a website (persistent cookies). More information about cookies and how they work is available at www.allaboutcookies.org.

Cookies on our website are generally divided into the following categories:

Essential Cookies. These are cookies that our website needs in order to function and that enable you to move around and use the website and features. Without these essential cookies, the website will not perform as smoothly for you as we would like it to, and we may not be able to provide the website or certain services or features you request. Examples of where these cookies are used include: to determine when you are signed in, to determine when your account has been inactive, and for other troubleshooting and security purposes.

Analytics Cookies. Analytics cookies provide us with information regarding how visitors navigate and interact with our website. Such cookies allow us to understand, for example, more about how many visitors we have to our website, how many times they visit us and how many times a user viewed specific pages within our website. Among other Analytics cookies, we use Google Analytics cookies for these purposes. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services,” which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time.

Advertising Cookies. Advertising cookies may be placed by us or third parties to enable third-party ad networks to recognize a unique cookie on your computer or mobile device. The information that is collected and shared by these types of cookies may also be linked to the device identifier of the device you are using to allow us to keep track of all the websites you have visited that are associated with the ad network. This information may be used for the purpose of targeting advertisements on our website and third-party sites based on those interests.

We may use the information collected through cookies and related tracking technologies for the following purposes:

  • To make our website easier to use and generally improve its performance.
  • To gather metrics about how you interact with our website.
  • For security reasons.
  • To provide personalized content. For example, we may store user preferences, your default language, device and browser information, your profile information, which includes the level of your usage of the website, which pages you visit, so we can identify you across devices and personalize the content you see.

If you disable cookies, your ability to use some features of the website may be limited. For mobile devices, you may be able to manage certain cookies using your built-in mobile device settings and controls. Any choices concerning cookies are browser and/or device specific. If you clear your cookies from your browser on any of your devices, your choices will need to be reset. You should check how to do this on your device(s) and operating systems.

We only use advertising cookies with your consent. You can also change your cookie choices in our cookies manager by clicking on the “Your Privacy Choices” button found in our website footer.

Global Privacy Control Signal
We generally recognize certain commercially recognized opt-out preference signals (e.g., Global Privacy Controls).  Recognition of this signal applies only to the specific device and/or browser that communicates the signal and does not apply to other devices/browsers you use to access our website and services. At this time, our website is not currently configured to respond to a browser’s “do not track” signals.

How We Protect Personal Data

We use reasonable administrative, organizational and technical safeguards to protect your personal data; however, no method of transmission over the Internet, or method of electronic storage, is fully secure. We will notify regulators of a security incident as required by law.  In the event that we are required by law to inform you of any unauthorized access to your personal data, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Transmission of Data to Other Countries

Your personal data may be processed in the United States or other countries, where privacy laws may be less stringent than the laws in your country. By submitting your personal data to us you agree to the transfer, storage and processing of your information in the United States. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in other countries may be entitled to access your personal data. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to personal data when it goes to another jurisdiction, you can contact us using the contact information below.

Third-Party Applications/Websites

We may provide links to other third-party websites through the services solely as a convenience to you. However, such linking does not mean, and should not be interpreted to mean, that we endorse, are affiliated with or make any representations concerning such third-party websites. Halepuna Waikiki by Halekulani shall not be liable for any consequences arising from use of any third-party websites to which the services link.

Data Retention

How long we retain your personal data depends on the context in which, and purposes for which, we collected it. We generally retain personal data for as long as necessary for achieving the purposes for which it was collected or processed, unless a different retention period is required by applicable law.

When we have no ongoing business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Children

Our services are not directed toward children under the age of thirteen, and we do not knowingly collect any personal data from children under the age of thirteen. If a child provided this website with personal data, we ask that a parent or guardian send us a written request to the address listed below and we will promptly delete the child’s personal data from our records. Additionally, we do not sell the personal data of children under the age of 16.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or would like to ask for access, rectification, or deletion of your personal information, please contact us at the address below.  We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.

Email:
myprivacy@halepuna.com

Mail:
2233 Helumoa Road
Honolulu, Hawaii, USA 96815
Fax:（+1）808-931-6639
Toll Free Phone Number: 888-487-3572

If you are not satisfied with our response and are in the European Union you may have a right to lodge a complaint with your local supervisory authority.

Changes To This Privacy Policy
We may change or update our Privacy Policy and practices from time to time. When we do change or update our Privacy Policy, we will post the revised version on this website with a new “Last Updated” date.

Effective: May 11, 2026
Last Updated: May 11, 2026