Privacy Policy

Privacy Policy

Effective Date: January 1, 2020

Aimbridge Group Holdings, LP and its subsidiaries and affiliates (collectively, the “Company” or “we” or “us” or “our”) are a group of independent hotel management companies that operate websites and provide other services on behalf of the owners of properties you may visit. Hotel owners entrust us to operate their hotels and to provide exceptional service to guests of both franchise-branded and independent hotels, resorts, and other hospitality services. We are delighted that you are visiting this website and have an interest in our Company, the hotels we manage and the services we provide.

This privacy policy (“Policy”) contains details about how our Company handles information we collect from you or that you may provide at certain locations online. To make it easier for you to navigate this Policy, you may click on any of the following links to jump to one of the sections addressed below:

1. Scope of this Privacy Policy
2. Changes to this Privacy Policy
3. Introduction and Contact Information
4. Information We Collect on this Site
5. Cookies and Other Tracking Technologies
6. How We Use the Information We Collect
7. Sharing Your Personal Information
8. Your Choices About How We Use and Share Your Information
9. Securing and Retaining Your Personal Information
10. Children’s Privacy
11. Legal Issues
12. Terms of Use

1. Scope of this Privacy Policy

Before proceeding you should be aware of what this Policy applies to and what it does not. This Policy explains how the Company collects, uses, shares and stores the personal information you choose to entrust to us:

• On the websites we own, on the independently owned websites we manage, and on any other website where this Policy is posted (collectively, the “Site(s)”);
• In email, texts and other electronic messages between you and the Site;
• Through mobile and desktop applications you download from the Site, which provide dedicated non-browser-based interaction between you and the Site; and
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

This Policy does not apply to information you send to the Company offline or by any other means. Other Company sites and other online locations may have their own privacy policies, and you should consult those accordingly.

This Site may contain links to external websites for specific hotels that are managed by the Company. In most instances, these websites are owned and/or operated by the associated hotel brands (e.g., Hilton Worldwide, Marriott International, Inc.). The Site may also contain links to other external third-party websites, applications or content (including embedded advertising or sponsored content), which are not controlled by our Company. This Policy does not address, and our Company is not responsible for, the data collection, data use practices or privacy policies on external hotel brand websites or other non-Company websites that you may accessed from this Site or that have directed or connected you to the Site. You should consult the privacy policies of such external third-party websites for details on how those websites handle your personal information.

In addition, if you choose to engage with our Company on a social media platform such as Facebook, LinkedIn, You Tube or Google+, this activity is conducted at your own risk as the Company does not control these third-party platforms. Also, the Company cannot control the actions of other users of any social media platform and is therefore not responsible for any content or submissions contained on such services and platforms. Please consult the privacy policies of these social media service providers before using them to make sure you are comfortable with the level of sharing.

This Policy covers the Site(s) as described above, and may be used by the individual hotels, resorts and conference centers that we manage within the United States. This Policy also explains how you can exercise any rights or choices you may have regarding our collection, use and sharing of your personal information. Please read this Policy carefully to understand our practices and procedures regarding your information and how we will treat it. If you do not agree with our practices as set forth in this Policy, you should stop using this Site. To the extent permitted by applicable law, by accessing or using any of the Sites, you agree to the terms of this Policy.

If you are within or are a resident of a member nation of the EUROPEAN ECONOMIC AREA (the “EEA,” which includes the 27 European Union Member States, Iceland, Lichtenstein and Norway), Switzerland or the United Kingdom (“UK”) (collectively, the “EU”), you are not authorized to use this Site. Instead, please visit the Company’s Europe website at https://www.interstatehotels.co.uk/, and click here to learn about how we collect, share and use your personal data, and how you can exercise your privacy rights.

If you reside in the State of California, please review the PRIVACY NOTICE FOR CALIFORNIA RESIDENTS found at https://oag.ca.gov/privacy/ccpa to learn more about additional rights you may have regarding our handling of your personal information.

2. Changes to this Privacy Policy

We may change this Policy from time to time, and any changes will be posted on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Site’s home page. The “Effective Date” at the top of this Policy indicates when the Policy was last revised. Any changes will be immediately incorporated into this Policy, and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.

Any change to this Policy is effective immediately. You are responsible for periodically visiting our Site and this Policy to check for any changes. Your continued use of the Site after any changes are made to this Policy constitutes your acceptance of the changes. If any of the changes are unacceptable to you, you should cease using the Site.

3. Introduction and Contact Information

We understand you may have questions about how we collect and use the information that you provide to us and the privacy of your personal information (“Personal Information”). To be clear, by Personal Information, we mean data that, by itself or in combination with other information, could be used to identify or contact you, including, for example, your name, address, telephone number, e-mail address, username and password, IP address or other online identifiers, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, demographic information, biometric data (e.g., fingerprints), state and/or federal identification numbers (e.g., social security number), or any other type of information that, directly or indirectly, can be linked to or is reasonably capable of being associated with you.

The privacy of your Personal Information is very important to us. If you ever have any questions or concerns about this Policy or our privacy practices, please contact us via e-mail or postal mail at:

[email protected]

Aimbridge Hospitality

Attn: Privacy Department

5851 Legacy Circle, Suite 400

Plano, TX 75024

[email protected]

Interstate Hotels & Resorts

Attn: Privacy Department

2011 Crystal Dr., Suite 1100

Arlington, VA 22202

If you do not agree to the collection and use of your Personal Information as described in this Policy, please do not provide us with any information and cease using the Site.

4. Information We Collect on this Site

There are areas on the Site where you may be asked to provide the Company with Personal Information.

For example, we collect Personal Information (and other related data) about you such as your name, e-mail address, telephone number, physical address, company name and other professional or business information, or other types of information you choose to provide, depending on the nature of your interactions with and use of the Company’s services, when you:

• submit requests for information on services offered on or through the Site;
• fill in forms on the Site;
• book a stay or check-in with the property advertised on the Site;
• inquire on or through the Site about business development or hotel management opportunities;
• contact us with questions or comments, either on the Site or through social media;
• report a problem with the Site;
• participate in a promotion, contest or survey;
• sign up to receive Company newsletters, e-mail updates or other communications about services which may be of interest to you; and/or
• apply for employment.

All required and optional information is clearly indicated on any form presented to you. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

Certain areas of some of our Sites, particularly as a result of third-party agreements concerning any independently owned website the Company manages under this Policy, may seek information specific to your cell phone, tablet, or other mobile device, such as the precise GPS location of your mobile device.

5. Cookies and Other Tracking Technologies

There are also areas on this and other Sites where the Company may automatically collect certain pieces of Personal Information and other data as you navigate the Site, such as your IP address and other data about your internet connection, your operating system, browser type, and other services or equipment you use to access the Site, and usage data.

For example, this Site may use “cookie” technology for automatic data collection, which may include:

• Browser cookies. A browser cookie is a small file placed on the hard drive of your computer. The Site may use one or more persistent first-party browser cookies to recognize you when you return to the Site, which web pages you visited on the Site, and the sequence in which you accessed the web pages. First-party cookies are set directly by the Company. These cookies also collect traffic data, logs, other communication data, and the resources that you access and use on the Site. Persistent cookies remain on your computer hard drive until you delete them or they are otherwise removed upon expiration. Cookies do not corrupt or damage your computer, programs, or computer files. You may be able to manage your cookie preferences and block or delete them by consulting your web browser and/or computer instructions. Please note that any blocking or deletion of cookies could affect how the Site appears and/or operates for you. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to this Site.
• Flash Cookies. Certain features of this Site may use local stored objects (also referred to as Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, visit the Adobe Flash Player Help site at https://www.adobe.com/support/documentation/en/flashplayer/help/, click on the hyperlink for “Website Privacy Settings panel” on the left hand side of the screen, and follow the instructions for preventing third-party Flash content from storing data on your computer. Again, if you disable or refuse cookies, some parts of the Site may be inaccessible or not function properly.

Similar to many websites, our web server logs maintain a record of every device’s IP address, the type of device you are using, browser type (e.g., Internet Explorer, Firefox), and Internet Service Provider (ISP), which may be used to access this Site along with the date, time and length of time you spent on this Site.

We may also use third-party analytics service providers, such as Google Analytics, to help us analyze how visitors use our Sites. This process uses third-party cookies to collect standard internet log information and visitor behavior information. The information generated by the cookie about your use of the Site, including your IP address, is transmitted to Google. This information is then used to evaluate visitors’ use of the Site and to compile statistical reports on Site activity for us. We do not use the statistical analytics tool to track or to link an IP address with the identity of a computer user. If you do not want any information to be collected and used by Google Analytics, you may be able to install an opt-out add-on to your web browser. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.

All of the above-referenced IP addresses and other data will be collected in an automated manner and we may maintain it or associate it with certain other Personal Information we collect in other ways or receive from third parties. This helps us improve our Sites, deliver better and more personalized services, estimate our audience size and usage patterns, store information about your preferences, and speed up your searches.

This automatically collected data, which may contain portions of your Personal Information, may also be managed by our marketing vendors in order to provide you with targeted ads based on what you appear to be interested in as a result of your activity online, both on our Sites and elsewhere. You can opt-out of receiving targeted ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting http://optout.networkadvertising.org/. You may opt-out of receiving targeted advertisements from other companies that perform targeted or interest-based advertising services, including some that we may work with, via the Digital Advertising Alliance (DAA) site at http://optout.aboutads.info/. Please note that when using these ad industry opt-out tools, you may need to execute opt-outs for each browser or device that you use, and that other companies’ opt-outs may function differently than our opt-out.

6. How We Use the Information We Collect

The Company may use the Personal Information and other data we collect from you so that we may:

• present the Site and related content to you;
• process and respond to your requests for information on Site-related services;
• administer bookings and reservations;
• contact you about hotel management and business development opportunities;
• respond to your questions and comments;
• send you newsletters and other e-mail updates;
• provide you with information on new products, services, promotions and other updates in which we think you may be interested;
• carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• notify you about changes to the Site or any products or services we offer or provide through it;
• use it in any other way we may describe at the point when you provide the information;
• for any other purpose to which you consent;
• communicate with you regarding additional uses of your Personal Information beyond the scope of this list;
• process applications for employment;
• deliver services through the Site;
• improve the content and general administration of the Site;
• perform internal Site operations (e.g., fraud prevention);
• troubleshoot software issues and operational problems with the Site;
• conduct data analysis and testing; and/or
• monitor Site usage.

By providing to the Company the Personal Information and other data referenced above, you agree the Company may use such Personal Information and other data in accordance with the terms of this Policy.

7. Sharing Your Personal Information

Except as noted herein, we do not sell or share your Personal Information with any person or entity outside of our Company.

We do not sell or otherwise make your Personal Information available to any third parties for their own use. We may share certain portions of Personal Information and other data with third-party service providers and other vendors in order to make the Site and Site-related services function properly. This may include sharing Personal Information with our:

• booking service providers to process your reservations;
• event registration vendors to allow you to register for meetings and events you wish to attend;
• hospitality vendors to provide you with pre-arrival amenities and other requested benefits;
• shipping providers to send packages and correspondence;
• e-mail service providers to send you communications with your permission; and
• additional third-party providers for purposes we will disclose to you at the point when you provide information to us.

These service providers are contractually prohibited from using any Personal Information for their own use. They were engaged to provide specific services and the use of any Personal Information they have access to will be dictated by us.

Certain areas on the Site may integrate with social media sharing services which will let you share content from the Site with other online services. Your use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the relevant social sharing service. Please review the privacy policies of those social media services for more information about how such services handle the information you provide to or share through them.

We may also share your Personal Information in the following circumstances and the receiving party will assume the rights and obligations regarding your Personal Information as described in this Policy:

• To third parties that you authorize to receive such information.
• With our affiliates, subsidiaries, joint ventures, or other companies under a common control (collectively, our “Affiliates”), in which case we will require our Affiliates to honor this Policy.
• In connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.

In the event of insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset.

In addition, we may disclose your Personal Information without your permission if the Company reasonably believes we are:

• compelled by law, court order or other legal process to do so;
• contractually obligated, including for billing and collection purposes;
• required or elect to notify you of a security breach; or
• directed by a government or law enforcement entity to provide Personal Information to support an investigation and we believe in good faith that providing the information is necessary to investigate or protect against harmful activities to or by our customers, Site visitors or property.

Other than what is referenced above, the Personal Information and other data collected from you is not shared with nor sold to any person or entity outside of our Company.

8. Your Choices About How We Use and Share Your Information

You may be entitled to certain choices in connection with the Company’s collection, use and sharing of your Personal Information, depending on where you reside and the purposes for which we process your information.

If you would like to access, review, edit, delete or have us properly dispose of any copies of the Personal Information that our Company collected about you , or if would like to opt-out of receiving further information or limit what we share (subject to any applicable legal exceptions), please contact us at [email protected]. . For your protection, we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.

The Company will do its best to accommodate any request to delete or properly dispose of any copies of your Personal Information, but we cannot guarantee we can eliminate all Personal Information from the specified uses. We often need to retain certain data for recordkeeping purposes or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons.

Therefore, please be as specific as possible in any request to delete or dispose of copies of your Personal Information. If you choose to delete certain portions of your Personal Information, it may affect your ability to use certain services or elements of the Site. If the request relates to information the Company needs to make the Site function properly for you, you may no longer be able to use the Site.

The Company reserves the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your Personal Information.

If you would like to opt-out of receiving promotional e-mails from the Company, please follow the opt-out instructions at the bottom of the e-mail or send us a detailed e-mail at [email protected]. We will try to comply with your request as soon as reasonably practicable. If you opt-out of receiving marketing e-mails from us, we may still send you important administrative messages, from which you cannot opt-out.

This Site does not support or respond to “do not track” or similar technical requests you may activate through your computer or browser settings. To learn more about how to opt-out of certain kinds of targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific.

9. Securing and Retaining Your Personal Information

We understand that the security of your Personal Information is important. We use, implement and maintain a variety of industry-standard administrative, technical and physical controls designed to protect your information from loss, unauthorized access, or disclosure, both in storage and in transmission.

While the Company takes the issue of protecting your Personal Information seriously, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we use reasonable efforts to protect your Personal Information, we cannot guarantee its absolute security as the transmitted information may be intercepted by others before it reaches our Company. You should exercise discretion in what information you disclose and/or transmit on or through the Site. If you are concerned about sending information to us over the internet, please send the information by mail or call us to make other arrangements. Our Company is not responsible for the security of information sent over the internet.

The Company retains Personal Information only for as long as necessary to fulfill the stated purpose for which the Personal Information was collected or otherwise processed, and thereafter for a variety of legitimate legal or business purposes. These may include retention periods that are: (i) mandated by law, contract or similar obligations applicable to the Company’s operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate organizational and financial records. We will delete your Personal Information as soon as the respective purpose for its use is not applicable anymore and no legal obligation to retain such data exists.

10. Children’s Privacy

This Site is intended for individuals 18 years of age and older located in the United States.

The Site is not directed at, marketed to, nor intended for, use by children under 16 years of age. The Company does not knowingly collect any Personal Information from children under 16 years of age. Anyone under the age of 16 is prohibited from using this Site. If you are under 16, do not use or provide any information on this Site or on or through any of its features. If the Company learns that any information was provided on or through the Site by a person younger than 16 years of age, the Company will delete the information immediately. Any minor, or the parent(s) or legal guardian(s) of such minor, who wishes to request the removal of the minor’s information should submit their request to [email protected]. Any removal of content by the Company does not ensure or guarantee complete or comprehensive removal of the content in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.

11. Legal Issues

This is a United States Site subject to laws of the United States and is not intended for users outside of North America. However, if you are located outside of North America, by visiting the Site and providing us with Personal Information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Policy. If you provide information on or through the Site from outside of the United States, you do so at your own risk. If you are outside of the United States, you are responsible for complying with any local laws regarding your use of the Site, and related data collection. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your Personal Information you consent to such international transfer.

12. Terms of Use

The Terms of Use for this Site is incorporated by reference into this Policy. The Terms of Use can be found at https://www.aimbridgehospitality.com.

2.11 12/30/2019, 2:16:07 PM