We use your personal information in order to fulfil our commitment to providing an unparalleled guest service in connection with all of your interactions with our site (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
2 The Application of this Policy
This Policy applies to personal information regarding guests and the other individuals from the European Union, United Kingdom and Switzerland with whom we do business and to the use of that personal information in any form, whether oral, electronic and/or written.
This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various locations operating under or in connection with our brands
While this Policy is intended to describe the broadest range of our personal information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country/region may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.
3 Types of Personal Information We Collect
The term “personal information” in this Policy refers to information that identifies or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) include:
your name, nationality, contact details such as telephone and email, dates of travel, goods and services utilised, special requests made, observations about your service preferences, and any correspondence between ourselves and yourselves, your credit card details, payment method details information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests or promotional offers, or to our websites or apps and those of third parties; information collected whilst you access our website
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries or regions. Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation. In some very rare instances, financial records may constitute Sensitive Personal Information where you are located. If we rely on consent to process your Sensitive Personal Information, you have the right to withdraw that consent at any time. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.
Save to the extent required by law, you are not obliged to provide us with any of your Sensitive Personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from us.
4 How We Use Personal Information
Subject to applicable laws, we may collect, use and disclose portions of your personal information in order to:
provide and charge for goods and services;
provide you with a better or more personalized level of service, including information and services from a third party
fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers or your employer) and vendors (e.g., credit card companies, airline operators and third party loyalty programs);
conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions
When we process your personal information as one of our clients or someone else with whom we do business, we do so in our legitimate interests (as detailed above), because of legal obligations we are subject to or because the information is required to fulfil contractual obligations to you, anyone involved in making your travel arrangements (e.g., travel agents, group travel organizers or your employer) and vendors (e.g., credit card companies, airline operators and third party loyalty programs).
We use and retain your personal information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations and risk management guidelines. For example, reservation records are retained for a period of five (5) years following the year in which the reservation was made, and sales contracts are retained for a period of Statute of Limitations plus ten (10) years. Personal information in records may be maintained for longer periods if subject to a legal hold or specific country/region requirement.
5 Disclosures of your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law.
Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:
5.1 Our Service Providers and Suppliers
Like most agents, we may outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.
5.2 Consumer Insights
Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 12 below. Further information about how we conduct direct marketing may be found at Section 9 below.
5.3 Credit Authorization
When you request credit, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.
5.4 Business Transfers
As we continue to develop our business, we may sell hotels and other assets, or cease being the manager or franchisor of a location. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.
Once the personal information is transferred to the credit card network operator, credit card issuer, your employer or corporate client and/or their respective subcontractors, it is no longer subject to the protections described in this Policy, but rather your own arrangements with your employer or corporate client, the relevant credit card network operator and/or the relevant card issuer.
5.6 Legal Requirements
We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.
6 Information We Collect When You Visit Us Online
If you access our website, you may wish to know the following:
6.1 You Can Browse Without Revealing Who You Are
You can always visit our websites without logging in or otherwise revealing who you are.
6.2 Usage Information
When you visit our websites, we collect information about how you use those websites. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website. That information is not linked to you as an individual unless you create a user profile, but we may keep records of the type of device being used.
6.3 Cookies and Other Similar Technology
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our website. Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
6.4 Social Media
Our websites may also contain plug-ins and other features that integrate third party social media platforms into our websites. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
You can view, update or remove any personal information that you have provided to us for inclusion in your user profile emailing firstname.lastname@example.org . If you subsequently elect to remove your user profile, we reserve the right to use any personal information previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes (unless we are required by law to delete or cease to process or use your personal information). Even if you choose not to create a user profile, you can still use our websites to search for and purchase services.
6.6 Links to Other Websites
If you visit our website and decide, for example, to purchase a gift certificate, make an airline reservation, rent a car, submit award request forms or apply for a job online, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.
We as data collectors may use third-party data processors for analytics services to help understand the way our website visitors use our website. In particular, we may provide a limited amount of your information (such as page search, email address and name, should you provide these) to collect data for analytics purposes when you visit our website to book with us. As a data processor acting on our behalf, to analyse your use of our website and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. We may also use a Data Processer as a medium for communications through live chat or automated messages within our website. Additionally we may take payments through Data Processors. Sometimes our Data Processors also use third-party services, for processing such payments.
6.7 Minor Children
Our websites do not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our websites with the involvement of a parent or guardian.
6.8 Targeted Advertising
Where permitted by law, we may work with other companies to share advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own websites or apps or communications sent by us, or advertisements from us displayed on other companies’ websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our websites or third-party websites.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
If you provide us with your contact details (e.g., postal address, email address, telephone number etc), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. Additionally, where you have consented to us doing so, we will also share your personal information with our service provider to ensure that you receive the proper service your requested and this service provider may communicate directly with you.
8 Changes to this Policy
Just as our business changes constantly, this Policy may also change. Where the Policy changes, we will take appropriate steps to bring the amendment to your attention. To assist you, this Policy has an effective date set out at the end of this document.
9 Request for Access to Personal Information/Questions or Complaints
If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request to exercise your rights in relation to the personal information that we maintain about you, please contact us at email@example.com
10 Intellectual Property
All: (a)names, logos, and marks appearing under any domains and any subdomains except as otherwise noted are trademarks owned or used under licence.
(b) photographs, maps, designs or other images, are owned or used under license by
The use or misuse of these trademarks or any other content on this site, except as provided in these terms and conditions or in the site content, is strictly prohibited. We will take legal action against any person that seeks to use any trademark, photograph or other image owned by us, without our prior written approval. Nothing contained on the site shall be construed as granting, by implication, estoppel or otherwise, any license or right to use any trademark, photograph or other image without our prior written permission.
While we use reasonable efforts to include accurate and up to date information on this site, we make no warranties or representations about the accuracy or completeness of the content of this site or of the content of any sites linked to this site.
We assume no liability or responsibility for any errors or omissions in the content of this site. We have not reviewed all of the sites that might be linked to our site, and we are not responsible for the content of any of those sites.
Limitation of Liability
We provide the contents of our site for informational and convenience purposes only. We shall not be liable for any direct, incidental, consequential, indirect, or punitive damages arising out of access to or use of or reliance upon any content of this site or the content of any site or sites linked to this site.
Effective Date: June 2019