Imperial Hotel and Private Residences

Privacy Policy

Last Updated: 4/14/2025

Your privacy is important to us at Breckenridge Grand Vacations LLC and its affiliates and subsidiaries (collectively “BGV,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights.  This online privacy statement (the “Statement” or “Policy”) describes how we collect, use, disclose, and secure the personal information we gather about you through our website, https://www.imperialbreckenridge.com/, the “Site”), our applications and when you interact with us as a customer or otherwise (collectively, the “Services”).

For purposes of this Statement, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations.  It does not include data excluded or exempted from those laws and regulations.  Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to BGV generally or in any specific context.

This Policy expressly incorporates any privacy notices we may issue to supplement this Policy, for example if required by law.  Depending on your residency, a supplemental privacy notice may apply to you.

1. You Consent to This Statement

You should read this Statement carefully, so that you understand our privacy practices.  We recommend printing and retaining a copy for your future reference.  By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement.  If you do not agree to this Statement, you may not use the Services.

This Statement applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions, so that you are fully aware of how and why we are using your data.

Your use of our Services, and any dispute over privacy, is subject to this Policy and our Terms of Use incorporated by reference into this Policy.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

1. What Types of Information Do We Collect?

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties.  The categories of personal information that we collect and the purposes for which we collect that information are described below.

Categories of Personal Information We Collect

The following list describes the categories of personal information we collect and the purposes for which we may collect such information.

• Account Information includes name, company, title, zip code, email address, username, and password. We collect this information when you provide it directly to us. We collect this information for the purposes of account creation and management, analytics and research, customer service, marketing and advertising, newsletters and related communications, rental/purchase of goods, and website security and maintenance.
• Analytics Information. We collect certain analytics information automatically as you navigate our Services and the communications we may provide, such as emails.  This includes cookies, tracking pixels, tags or similar tools, such as session replay technologies, which may collect information about your browser, device, geolocation, and that may log how you interact with our Services.  For more information, please view the “How Do We Use “Cookies” and Other Tracking Technologies?” section below. We collect this information for the purposes of account creation and management, analytics and research, customer service, marketing and advertising, newsletters and related communications, rental/purchase of goods, and website security and maintenance.
• Contact Information includes name, title, zip code, email address, and phone number. We collect this information when you provide it directly to us such as signing up for newsletters, entering into a sweepstakes or giveaway, or otherwise filling out a form. We collect this information for the purposes of account creation and management, analytics and research, customer service, marketing and advertising, newsletters and related communications, rental/purchase of goods, and website security and maintenance.
• Commercial History includes information regarding the purchases you have made through our Services. We collect this information when you provide it directly to us. We collect this information for the purposes of account creation and management, analytics and research, customer service, marketing and advertising, newsletters and related communications, rental/purchase of goods, and website security and maintenance.
• Demographic Information includes name, email address, place of employment, type of employment, industry, household income, age, and gender. We collect this information when you provide it directly to us, as part of voluntary market research surveys or when you enter into a sweepstakes or giveaway. We collect this information for the purposes of account creation and management, analytics and research, marketing and advertising, newsletters and related communications, rental/purchase of goods, and website security and maintenance.
• Interests and Preferences includes vacation destination and timing preferences, locations of interest, and information regarding newsletters you would like to receive. We collect this information when you provide it directly to us. We collect this information for the purposes of analytics and research, customer service, marketing and advertising, and rental/purchase of goods.
• Payment Information includes name, address, phone number, and debit or credit card information. We collect this information when you provide it directly to us. We collect this information for the purposes of account creation and management, customer service, rental/purchase of goods, and website security and maintenance.
• Responses to Surveys and Questionnaires includes any information you provide to us when you voluntary market research surveys such as email address, name, phone number, and travel preferences. We collect this information for the purposes of analytics and research, customer service, marketing and advertising, newsletters and related communications, and rental/purchase of goods.
• Social Media Information includes information that you post by sharing on a blog or another social media platform. We collect this information when you provide it directly to us.  Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private. We collect this information for the purposes of analytics and research, marketing and advertising, and newsletters and related communications.
• User-Generated Content. If you post, upload, comment, or otherwise submit content on the Services such as through a comment or review, we may collect certain information about you.  Be aware that as a default, any information you post on the Services will be available to other users, so you should never share personal information you would like to keep private.  We collect this information when you provide it directly to us or when you post about our Services on other platforms.

Purposes for Collection of Personal Information

The following chart identifies the purposes for which we may collect your personal information, as well as information regarding our use and disclosure of that personal information.  Please note that we may not collect each category of information about each user of our Services.

Other Ways We May Collect, Use, or Share the Information

We may also reserve the right to collect, use, or share personal information for the following purposes:

• For Legal Purposes. We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this site.  We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention.  We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information. If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
• To Present the Site. We will use personal information to present our Site and its contents in a suitable and effective manner for you and your device.
• To Provide the Services. We will use personal information to provide the Services, including to improve operations and for security purposes.
• Customer Service. We will use your personal information to provide you with customer service, troubleshoot issues, and respond to requests, questions or comments.
• Provide Information and Opportunities. We will use your personal information to advertise travel opportunities, promotions, products, events, or Services that we think may be of interest to you.
• Business Transactions or Mergers. We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.  Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence.  If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
• Bankruptcy or insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
• Information from our partners. We may collect information from our partners such as market research firms and our affiliates, subsidiaries, joint ventures, other companies under common control, timeshare exchange companies, and owners associations.  We may combine that information with other information we collect about you, but we will always use the information as described in this Policy.  We may also share information with affiliates, subsidiaries, joint ventures, or other companies under common control.

1. How Do We Use “Cookies” and Other Tracking Technologies?

We may send one or more cookies to your computer or other device.  We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services.  These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services.  This information allows us to understand how you use the Services.

What Are Cookies?

Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website.  When you access our Services, we use cookies and other tracking technologies to:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Services according to your individual needs;
• Contact you to provide you with information or services that you request from us;
• Advertise new content, events, and services that relate to your interests;
• Provide you with more personalized content that is most relevant to your interest areas; and
• Recognize when you return to our Services.

We set some cookies ourselves and others are set by third parties.  You can manage your Cookies preference as described in the “Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

The following chart lists the different types of cookies that we and our service providers use on the Services, examples of who serves those cookies and links to the privacy notices and opt-out information of those cookie servers.

We do not use Facebook Pixel or disclose information to any third party that identifies a specific person as having viewed specific video materials.

How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the Services until the end of that particular browsing session.  These cookies, which are called “session cookies,” expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser.  These cookies are called “persistent cookies” and the length of time they will remain on your device will vary from cookie to cookie.  Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies.  If you choose to block all cookies (including Essential cookies), you may not be able to access all or parts of the Services.

You can find out more about cookies and how to manage them by visiting www.AboutCookies.org.

Does the Site Respond to “Do Not Track” Signals?

There is currently no industry agreed-upon response to a Do Not Track signal.  At this time, our Site does not respond differently based on a user’s Do Not Track signal.

1. Colorado, Connecticut, Virginia, and Utah Users’ Rights

Colorado, Connecticut, Utah, and Virginia residents have certain rights with respect to their data.  These rights are established through the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”).  The chart below explains these rights and lists the states whose residents may exercise those rights.  To exercise any of the following rights listed in the chart below, please email us using the information set forth in the “Contact Us” section below.

Sensitive Information

Sensitive Data as defined in the CTDPA, UCPA and VCDPA includes precise geolocation information.  For the purposes of serving you relevant advertisements based on your location, we collect geolocation information to perform geofencing.  We will not collect this information from Connecticut and Virginia residents without first obtaining consent.  Utah residents have the ability to opt out of this processing, which they can do through the “Your Privacy Choices” page.

Exercising Your Rights

If you are a Colorado, Connecticut, Virginia, or Utah resident and wish to exercise one of the above rights and it applies to you, please visit our “Data Request” page.  In the request, please specify the right you wish to exercise.

If necessary, we may request additional information reasonably necessary to authenticate you and your request.

In certain circumstances, you may make a request on behalf of another such as if you are an authorized agent or the parent or guardian of a child on behalf of whom you wish to exercise their rights.

We will respond to these consumer requests, if applicable, within 45 days of receipt of the request and without undue delay.  If we need to extend this period, we will notify you of the delay and explain the reasonably necessary justifications for our delay.

We will provide responses to your requests free of charge unless certain exclusions apply, depending on the state in which you reside.  We may charge a fee in:

• Colorado, Connecticut, and Utah, if you make more than one request in a twelve-month period; and
• Connecticut and Virginia, if the request is manifestly unfounded or excessive, or repetitive in nature.

Appealing a Rights Request Decision

If you are a resident of Colorado, Connecticut, or Virginia, and we deny or fail to take action on your request to exercise your applicable consumer privacy rights, you may appeal our decision.  To do this, you may email us at press@breckgv.com.  In the email appeal, please specify the right(s) you requested to exercise and the date you made such a request.

We will inform you in writing within 45 days of any action taken or not taken in response to the appeal.  We will also provide a written explanation of the reasons for our decisions regarding your request(s).

Our Loyalty Program

We offer a loyalty program for certain Services, such as food and beverage purchases at our locations (“Loyalty Program”).  When you use our Loyalty Program, you may also receive special offers, discounts, and gift card rewards.  Please note that if you exercise your Right of Deletion, we will not be able to provide these benefits because we will not be able to track them without your account information.  In the course of providing our Loyalty Program, we will collect Analytics Information, Commercial History, and Contact Information.  This information may be processed for the purposes of targeted advertising.  We do not share this information with Third Parties as defined by the CPA.

1. Advertising and Marketing Choice

We respect your rights in how your personal information is used and shared.  If at any time you would like to unsubscribe from receiving future emails, you can email us at press@breckgv.com or follow the instructions at the bottom of each email, and we will promptly remove you from marketing correspondence.  Please note, however, that we may still need to contact you regarding other matters.

1. European Users’ Rights

Your Rights
You are entitled by law to access, correct, amend, or delete personal information about you that we hold.  A summary listing these rights appears below.  Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

To exercise these rights, please visit our “Data Privacy Request” page.  For your protection, we may need to verify your identity before responding to your request.  In the event that we refuse a request, we will provide you a reason as to why.

Asking us to access your personal information

You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this Policy.  You also have the right to ask us for copies of your personal information.  When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.

Asking us to rectify your personal information

You have the right to ask us to rectify information you think is inaccurate.  You also have the right to ask us to complete information you think is incomplete.

Asking us to delete your personal information

You have the right to ask us to erase your personal information if:

• We no longer need it for the purposes for which we collected it;
• We have been using it with no valid legal basis;
• We are obligated to erase it to comply with a legal obligation to which we are subject;
• We need your consent to use the information and you withdraw consent; or
• You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute.  Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities.  We will retain information in accordance with the “How Long Is Your Personal Information Kept” section below.

If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Asking us to restrict our use of your personal information

You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:

• You contest the accuracy of the information that we hold about you, while we verify its accuracy;
• We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
• We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
• You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

The right to transfer your personal information to another service provider

You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability).  This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.

The right to withdraw consent  

If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.

The right to lodge a complaint with a supervisory authority  

If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here:  EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner’s Office (ICO).

Rights related to automated decision-making  

To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

Right to object to processing

You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).  If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims.  You can object to the processing of your personal information by visiting our “Data Request” page.

Legal Bases for Processing Your Personal Information 

BGV collects your personal information to provide our products and Services to you; otherwise, we may not be able to process the transactions you request.  We will only process your personal information when we have a lawful basis for doing so.  If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information.  The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.

• Consent.  We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications.  You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.

• Children’s Consent. We do not knowingly process data of EU, EEA, UK, or Swiss residents under the age of 16 without reasonably verified parental consent.

• Our Legitimate Interests.  We may process your personal information if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests.  For example, our legitimate interests include but are not limited to when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Services.  Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.
• To Perform a Contract.  We may process your personal information to administer and fulfill contractual obligations to you.  We will also collect and process your personal information as necessary for the performance of a contract to which you are a party.
• To Enable Us to Comply With a Legal Obligation.  We may process your personal information to comply with legal obligations to which we are subject.  This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
• Necessary for the Exercise or Defense of Legal Claims.  If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.

Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland.  If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.

Cross-Border Transfers of Personal Information

Our Services are operated in the United States.  Personal information about you provide while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States.  The United States does not have an adequacy decision or adequacy regulation.  The GDPR permits such transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information.  The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located.  If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.

To obtain a copy of the safeguard(s), please contact us using the information provided in the “Contact Us” section below.

1. How Long Is Your Personal Information Kept

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided.  We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.

1. Our Commitment to Data Security

The security of your personal information is important to us.  We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.  If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

However, we cannot and do not guarantee complete security, as it does not exist on the Internet.

1. Third Party Links

BGV’s Services may contain links to third-party websites.  When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within.  It is important to note that this Statement only applies to BGV’s Services.  We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites.  We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

1. Children’s Privacy

Protecting the privacy of the very young is especially important.  Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13.  In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information.  If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the “Contact Us” section below.

1. Policy Changes

This Statement may change from time to time.  If we need to change this Statement at some point in the future, we will post any changes on this page.  If we make a significant or material change to this Statement we will notify you via email.  You should check these terms when you use the Site.  Your continued use of the Site constitutes acceptance of the most current version of this Statement.

1. Contact Us

If you have any questions about this Privacy Policy, please contact us by email at, press@breckgv.com, via phone at 970-547-8883, or at 100 S Main St, Breckenridge, CO 80424.

The Project is under development and is not yet complete. The depictions and design of the Project as shown are based on current development plans. Development plans and all improvements, features, land uses, amenities, and other information shown here or in any renderings, illustrations, photos, simulated views, graphic images, maps, or other visual depictions may be changed without notice. Imperial Hotel & Private Residences is not developed or affiliated with Vail Resorts or any of Vail Resorts’ subsidiaries. Any representation as to square footage is approximate. The square footage or floor areas are shown in any marketing or other materials may be more or less than the actual size and square footage of the residential unit, common area, or any other portion of the project. The developer/seller reserves the right to change features, amenities, and pricing without notice. Renderings, photography, illustrations, floor plans, amenities, finishes and other information described herein are representative only and are not intended to reflect any specific feature, amenity, unit condition or view when built. The actual condition of the project, amenity or unit, when and if completed, will control. There is no representation or warranty that any particular improvement or amenity will be constructed or constructed as shown. No representations and warranties are made with regard to the accuracy, completeness or suitability of the information published herein. The information presented is proposed and should not be relied upon as a basis for purchasing. Prices and availability are subject to change at any time without notice. Obtain and review the Colorado Disclosure Document for the Imperial Hotel & Private Residences project and the Residential Contract to Buy and Sell Imperial Hotel & Private Residences made available in accordance with Colorado law before signing anything.