Effective Date: __________, 2019
For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:
- Introduction and Contact Information
- Information We Collect on this Site
- Browsing this Site
- Cookies and Other Tracking Technologies
- How We Use the Information We Collect
- Sharing Your Personal Information
- Accessing Your Personal Information/Other Rights and Choices
- Securing and Retaining Your Personal Information
- Children’s Privacy
- Legal Issues
This Policy covers the Site as described above, and may be used by the individual hotels, resorts and conference centers that we manage within the United States. This Policy does not apply to the information you send to Interstate by other means. Other Interstate sites and other online locations may have their own privacy policies, and you should consult those accordingly.
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 Interstate 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.
This Site may contain links to external websites for specific hotels that are managed by Interstate. In most instances, these websites are owned and/or operated by the associated hotel brands (e.g., Hilton Worldwide, Marriott International, Inc.). This Policy does not address, and Interstate is not responsible for, the data collection, data use practices or privacy policies on external hotel brand websites or other non-Interstate websites that you may access from this Site or that have directed or connected you to this 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 Interstate on a social media platform such as Facebook, LinkedIn, You Tube or Google+, this activity is conducted at your own risk as Interstate does not control these third-party platforms. Also, Interstate 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.
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.
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. We respect the privacy of every individual who visits this Site and provides any Personal Information to us.
If you ever have any privacy questions or concerns please contact us via e-mail or postal mail at:
Interstate Hotels & Resorts
Attn: Privacy Department
2011 Crystal Dr., Suite 1100
Arlington, VA 22202
Information We Collect on this Site
There are areas on the Site where you may be asked to provide Interstate with Personal Information, or where such Personal Information or other data may be collected from you in an automated manner.
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, and/or other types of information you choose to provide, depending on the nature of your interactions with and use of Interstate’s services, when you:
- submit requests for information on services offered on or through 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 Interstate with questions or comments, either on the Site or through social media;
- participate in a promotion, contest or survey;
- sign up to receive Interstate 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 denoted 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.
Browsing this Site
Similar to many websites, our web server logs maintain a record of every device’s IP address, 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 will not associate this information with any other Personal Information about you. This information is used for Site usage analysis as described in the “Cookies and Other Tracking Technologies” section of this Policy.
Certain areas of the Site, particularly as a result of third-party agreements concerning any independently owned website Interstate 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.
Cookies and Other Tracking Technologies
There are also areas on the Site where Interstate may collect Personal Information such as your IP address and other data from you in an automated manner.
For example, this Site may use “cookie” technology. Cookies are strings of text a website stores on a user’s computer. This Site uses one or more persistent first-party cookies to know when you are a return visitor to this Site, which web pages you visited on the Site and the sequence in which you accessed the web pages. Persistent cookies remain on your computer hard drive until you delete them or are otherwise removed upon expiration. First-party cookies are set directly by Interstate and are not used for advertising or any other purpose than previously described. 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.
All of the above-referenced IP addresses and other data will be collected in an automated manner and 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 Site 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 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 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.
The Site may use cross-device tracking technologies to try and connect your activity on the Site across the various devices you use to access and use the Site. If you would like to opt-out of such cross-device tracking, please contact us at email@example.com.
How We Use the Information We Collect
Interstate may use the Personal Information and other data we collect from you so that we may:
- 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;
- 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 Interstate the Personal Information and other data referenced above, you agree that Interstate may use such Personal Information and other data in accordance with the terms of this Policy.
Sharing Your Personal Information
Except as noted herein, Interstate does not sell or share your Personal Information with any person or entity outside of Interstate.
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 sign you up 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; and
- e-mail service providers to send you communications with your permission.
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 subsidiaries, joint ventures, or other companies under a common control (“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 Interstate reasonably believes we are:
- compelled by law or court order to do so;
- required or elect to notify you of a security breach; or
- directed by a government 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 Interstate.
Accessing Your Personal Information/Other Rights and Choices
In connection with Interstate’s collection and use of your Personal Information, you have the right:
- to request access to or correction of the Personal Information in Interstate’s custody or control;
- to withdraw your consent to the collection, use, sale or disclosure of your Personal Information, subject to contractual and legal restrictions;
- to request details on the specific pieces of Personal Information that Interstate has collected about you;
- to request that Interstate delete or properly dispose of copies of Personal Information it has collected about you; and
- to not be discriminated against, in terms of the services and prices offered on or through our Site because you exercised these rights regarding the collection, use and sharing of your Personal Information.
If you would like to access, review, edit, delete or have us properly dispose of any copies of the Personal Information that Interstate collected about you (subject to any applicable legal exceptions), would like to opt-out of receiving further information or limit what we share, or if you would like to exercise the above rights in any other way, please contact us at firstname.lastname@example.org. 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.
You may be able to opt-out of Interstate sharing your Personal Information with the entities identified in this Policy by sending us an e-mail at the address above unless the sharing of your Personal Information is necessary to perform one of the following business purposes: to count ad impressions and evaluate their effectiveness; to detect, protect against, and prosecute security incidents; to debug or troubleshoot functional errors that may arise with the Site; to complete short-term tasks related to an existing interaction you have with Interstate; to maintain or service your account; to process payments and fulfill orders or other transactions you authorize; verify your customer information, and to ensure the safety and quality of the Site.
Please note that Interstate 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 and/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 that Interstate needs to make the Site function properly for you, you may no longer be able to use the Site.
Interstate 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 Interstate, please follow the opt-out instructions at the bottom of the e-mail or send Interstate a detailed e-mail at email@example.com. 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.
If you reside in the State of California, you have the right to request from us a list of Affiliates and third parties with whom we shared Personal Information about you for their own direct marketing purposes during the previous calendar year. Please note, however, we do not share Personal Information with unrelated third parties for their own use. If you have any questions, please contact us at firstname.lastname@example.org.
This Site does not support or respond to “do not track” or similar technical requests you may activate through your computer or browser settings.
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 Interstate 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 Interstate. 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 Interstate over the Internet, please send the information by mail or call us to make other arrangements. Interstate is not responsible for the security of information sent over the Internet.
Interstate 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 Interstate’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.
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. Interstate 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 Interstate learns that any information was provided on or through the Site by a person younger than 16 years of age, Interstate 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@example.com. Any removal of content by Interstate 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.
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.
If you are a resident of a member nation within the EEA, UK, or Switzerland as identified above, click here to learn about how we collect, share and use your Personal Information on or through the Interstate Europe website available at https://www.interstatehotels.co.uk/, and how you can exercise your privacy rights.