We use your personal information in order to fulfil our commitment to providing an unparalleled guest experience in connection with all of your interactions with hotel. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
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.
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:
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. We only process sensitive personal information in your jurisdiction if and to the extent permitted or required by applicable law.
When you agree to this policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to hotel that is considered to be sensitive personal information or financial information. Save to the extent required by law, you are not obliged to provide hotel 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 hotel.
Subject to applicable laws, we may collect, use, and disclose portions of your personal information in order to:
Hotel uses and retains 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.
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this section.
Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:
5.1 Our Agents, Service Providers and Suppliers
Like most hotel brands, 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 Hotel 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.
5.5 E-Folio Program
If you are an employee or independent contractor of a company that participates in Hotel’s E-Folio Program, and you use the corporate credit card that is provided to you by your employer (if you are an employee) or corporate client (if you are an independent contractor) to pay for your hotel bill at a Hotel property, then you may benefit from Hotel’s E-Folio Program.
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.
Like most international businesses, we have centralized certain aspects of our data processing activities in accordance with applicable laws, which, in many instances, will result in the transfer of your personal information from one country to another. For example, if you make a reservation and/or stay at one of the Hotel Locations outside of the United States, the personal information gathered in that process will be transferred to and processed in the United States, in accordance with Hotel’s binding corporate rules (where they apply to you - for more information about our binding corporate rules please see Section 12 below). Additionally, some of the third party suppliers to which we transfer your personal information may be based in different locations, some of which may have lower standards of data protection than in your home country. When we do transfer personal information to such third parties, we ensure appropriate safeguards are in place, and oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures. These third parties broadly fall into two groups: (i) locally-provided suppliers supporting individual Hotel Locations or groups of Hotel Locations, who may operate in any of the countries in which Hotel Locations operate; or (ii) centrally-procured service providers, supporting Hotel as a whole, who may be located in our major business locations, in particular the United States (where we are headquartered), Switzerland and Hong Kong.
If you access any Hotel website, you may wish to know the following:
7.1 You Can Browse Without Revealing Who You Are
You can always visit our websites without logging in or otherwise revealing who you are.
7.2 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.
7.3 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 websites, including the customization features associated with creating a user profile.
Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
7.4 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.
7.5 Creating a User Profile
You can create a user profile on a Hotel website to, among other things, facilitate your online transactions, and to tailor your experience on our websites to your interests. This allows us to make more appropriate recommendations to you. We may use the information you provide in your user profile to populate other databases maintained by us and our service providers, as applicable. By creating a user profile, you are agreeing that we may use the personal information you provide for these purposes.
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.
7.6 Links to Other Websites
If you visit a Hotel 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.
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.
7.8 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.
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.
Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.
In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail.