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I. Information Collected
Information You Provide to Us. When you use our Website, such as to ask us for more information or to reserve a room with one of our member hotels, we, or our service providers (acting on our behalf), collect “personal information” (which is information that, on its own or when combined with other information, can be used to identify you) that you provide to us, such as your first and last name, email address, telephone number(s), postal address, and (when you make a reservation online) payment card information. We also collect more specific information that you provide, like travel behavior and lifestyle. Some of this more specific information is collected on our Website, and some is collected from sources like business reply cards that are bound into various trade publications.
Information We Collect from You Automatically. When you use the Website, we or our service providers will also collect information about your use of the Website and the device you use to access the Website (e.g., your computer, tablet, phone, etc.) such as your IP address and country location, browser information (including browser type, capabilities, and language), operating system, the date and time you accessed the Website, and Website usage information, including the paths taken as you move from one webpage to another webpage (i.e., your “click stream” activity).
Information from third Parties. We also receive data from outside sources, and we combine this information with other information about you to facilitate more relevant, targeted communications as well as develop products and services that better suit our customers’ needs.
II. Our Legal Basis for Using Your Information
If you are accessing our Website in the European Economic Area (“EEA”), then applicable law requires us to ensure that we only process your personal information where we have a legal basis to do so. We will only process your personal information where at least one of the following applies:
- If it is in our legitimate interests or the legitimate interests of others (such as our member hotels) to use your personal information. For example, it is in our legitimate interests to use your personal information to improve our Website, and to share your personal information with third parties who provide services to us relating to our Website. If you would like further information about how we decide when a particular use is in our legitimate interests, you may contact us using the contact details set out below.
- We need to use your personal information to perform our responsibilities under a contract we have with you (including, for example, processing your reservations).
- Sometimes we may ask for your consent to use certain types of personal information (e.g. by asking you to tick an online box). In these circumstances, your consent will be our legal basis for processing your personal information. If you have provided consent, you may withdraw it at any time. You may do this by “opting out” where we give you the opportunity to do so, or by contacting us using the contact details below.
Cookies. We use cookie technology as part of the Website’s statistical reporting and for other purposes related to making the Website available to you. A cookie is a small piece of information sent by a website that is saved on your hard disk by your computer’s browser. It holds information a website may need to personalize your experience, including by determining whether you are logged in to your account.
If you prefer, you can configure your browser to reject all cookies, or to notify you when a cookie is set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie and privacy preferences. For more information about HTTP cookies and how to disable them, or restrict the categories of cookies you wish to accept, you can consult the information at www.allaboutcookies.org/manage-cookies/. However, if you reject cookies, your use of the Website may be impaired.
Web Beacon. A web beacon is an electronic image, also called a single-pixel or clear GIF, placed in the code of a webpage or in emails. The Website uses web beacons and similar technologies to track traffic patterns of users as they navigate from one page to another. This information may help us improve our users’ browsing experience. We also use web beacons through a third party website analytics provider, as well as standard web server log files, to help us count visitors and evaluate the Website’s technical capacity. This information tells us how many people visit the Website and helps us decide how to arrange pages in the most user-friendly way.
IV. How We Use Your Information
We (and our service providers) will use your personal information for the following purposes:
- To provide the features and functionality of the Website to you.
- To facilitate your hotel reservation.
- To inform you about special promotions that run throughout the year.
- To identify you as the sender of, and to process, your emails.
- To respond to questions and comments.
- To improve, enhance, and tailor the Website for you (for example by providing content or features that match your interests), and to improve and enhance the overall experience for all users of the Website.
- To send you emails or postal mail about special offers or promotions ,if you have consented to this.
- To introduce you to additional value-added services offered by our partners that we feel may be of interest to you, if you have consented to this.
We may anonymize your information (for example by aggregating it with other individuals’ personal information so that it no longer identifies you) and use it for other purposes in anonymized form.
V. How We Share Your Information
We will share your personal information for the following purposes:
- Business transfers: If a third party acquires all or substantially all of our assets, your personal information, and any other information that we have collected in connection with the Website, will be transferred to such third party as part of our business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered part of our assets and may be sold or transferred to third parties.
- Service providers: We use third parties to perform services on our behalf, such as payment processing, email marketing, and customer service. These service providers will access your personal information as necessary for them to perform their duties. For example, we will share bank details and credit card information with payment processors when you provide a credit card in connection with a reservation.
The Website is intended for use only by persons who are at least 18 years of age. Accordingly, we do not and will not knowingly collect personal information from anyone whom we know to be under 18 years of age. If you are under the age of 18, you may not use the Website unless your parent or guardian has provided us with their consent for your use of this Website.
VII. Do Not Track
We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
VIII. Transfers and Storage of Your Information
If you are in a country other than the United States of America, you should be aware that the data that we collect from you will be transferred to, and stored in the USA. The laws of the United States may not protect the privacy of your information at the same level as provided by the laws of your country. In an effort to safeguard individual privacy, we will only transfer personal information from the EEA to the USA if one of the following applies: We have entered into an agreement using standard contract clauses (approved by the European Commission or a data protection authority) with our service provider or Affiliate regarding the transfer; the service provider that transfers the data is certified under the EU-US Privacy Shield Framework; or you give your express consent to the transfer.
If you have any questions about our transfer of personal information to the USA, or would like further information, please contact us using the details below.
IX. Your Rights Regarding Your Information
If you are in the EEA, you have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise them, please contact us using the contact details below at any time. You have the right to request that we:
- provide access to any personal information we hold about you;
- update any of your personal information which is out of date or incorrect;
- delete any personal information which we are holding about you;
- restrict the way that we process your personal information;
- prevent the processing of your personal information for direct-marketing purposes;
- provide your personal information to a third party provider of services;
- provide you with a copy of any personal information which we hold about you; or
- consider any valid objections which you have to our use of your personal information.
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
You may ask us to stop using your personal information for advertising or marketing purposes at any time. If you wish to do this, please follow the removal instructions in any communication you receive, or contact us using the information below.
X. Data Retention
We will generally store information associated with your account until it is no longer necessary to provide services to you, until you ask us to delete it, or until your account is deleted, whichever comes first; but there are some exceptions to this general rule. We will retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements, and take other actions permitted by law. For more information, contact us using the details below.
XI. Third Party Websites, Content, and Resources
We will take reasonable steps to protect the security and integrity of all personal information provided to this Website. However, please note that we cannot guarantee that any information transmitted through the Internet or stored on our system or otherwise in our care will be absolutely safe from prohibited intrusion by others. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after the transmission or storage of your personal information.
XIV. Contact Us
If you have any questions or comments regarding our privacy practices, you may contact us using the following details:
Post: Historic Hotels Worldwide
1420 New York Ave NW, Suite 200
Washington, DC 20005
In addition, if you are in the EEA and you have any complaints about how we use your Personal Information, you have the right to lodge a complaint with the data protection authority in your country or seek a remedy through local courts if you believe your rights have been breached. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
Effective Date: May 25, 2018