Introduction to this
Privacy Notice
Wyndham Hotel Group, LLC (“WHG”) cares about privacy
issues and wants you to be familiar with how we collect, disclose, and
otherwise use (“Process”)
information about you. This privacy notice (“Privacy Notice”) describes our practices in connection with the
information we collect through our websites (the “Websites”), social media pages that we control (“Social Media Pages”), and software
applications that we make available for use on or through computers and mobile
devices (the “Apps”), that include a
link to this Privacy Notice, and through any of our offline activities, such as
when you provide your information on the telephone via our call centers or in
person (“Offline Activities”)
(collectively, including the Websites, Apps, Social Media Pages, and Offline
Activities, the “Services”).
This Privacy Notice does not apply for hotels operated by
franchisees (independently owned and operated hotels) of WHG. and/or its
subsidiaries or that are managed but not owned by WHG and/or its subsidiaries
(“Hotels”). For example, Hotels may use e-mail and other methods of marketing
communications to contact their guests and they are solely responsible for
these campaigns. Please read each Hotel’s privacy notice to understand how it
will treat your Personal Information.
Our privacy practices may vary among the countries in
which we operate to reflect local practices and legal requirements, such that
our practices may be more limited in such jurisdictions.
Please read the following to learn more about our
privacy practices.
What Information Is Collected and How It Is Collected?
1.
We may collect “Personal
Information” (information that identifies you or relates to you as an
identifiable person) about you such as your:
·
Name
·
Postal address (including billing
and shipping addresses)
·
Phone number
·
Email address
·
Credit or debit card number
·
Financial information in certain
circumstances
·
Social media account information
·
Stay or trip information and
preferences, such as your preferred location/facilities, dates and number of
people/children traveling with you
·
Special needs or conditions that
may impact your stay
·
Driver’s license, government-issued ID, or passport
·
Geolocation information
·
Communication, product, service or
other preferences
·
Demographic information
·
IP address
·
Account or Membership ID
2.
We may collect information
from you when you interact with us such as when you:
·
Register for, use, or make a payment for a product or service
·
Contact us with a question or request
·
Use our Services
·
Make a reservation
·
Stay at one of our properties
·
Provide a testimonial or story, or submit a review or comment
·
Participate in a competition, promotional activity or
sweepstakes
·
Participate in any loyalty or other programs
·
“Like”, “Follow” or otherwise connect with or post to one of
our Social Media Pages
3.
Other information we
collect about you:
·
Cookies: Our Services may use “cookies” and similar
technologies (collectively, “cookies”). Cookies are small text files that this
Website sends to your computer for record-keeping purposes and this information
is stored in a file on your computer’s hard drive. Cookies make web surfing and
browsing easier for you by saving your preferences so that we can use these to
improve your next visit to our Website.
o
One of the purposes of cookies is to simplify the use of the
Website. A cookie may save a user’s login details for example, so that the user
does not need to login every time.
o
Cookies may be either “persistent” or “temporary” (or
“session”) cookies. A persistent cookie retains user preferences for a
particular Website allowing those preferences to be used in future browsing
sessions and remains valid until its set expiry date (unless deleted by the
user before the expiry date). A temporary cookie, on the other hand, will
expire at the end of the user session, when the web browser is closed.
o
Cookies are also used for statistical or marketing purposes,
to determine how the Website is used. These cookies are provided by us or by
third parties (e.g., advertising partners). While we do not control or have
access to the advertiser cookies we do permit them to be used on this Website
to facilitate tailored advertising and monitor patterns of buying specific
goods or interest in - for example, holidays or hobbies. These cookies run
advertisements tailored to the user based on his online buying habits. Please CLICK HERE for a current list of advertising
partners who use cookies on this Website and to opt-out of these types of
advertisements on this Website.
o
Google Analytics: We use Google Analytics
to help us get a better understanding of how visitors use this Website and to facilitate interest based advertising associated with
your Google Account and other devices you use. The information generated by the
Google Analytics cookie about your use of this Website is transmitted to and
stored by Google. If you do not want your activity on this Website to be
tracked by Google Analytics, you may opt out by using this link: http://tools.google.com/dlpage/gaoptout?hl=en.
o
Adobe
Marketing Cloud Device Co-op: WHG
participates in the Adobe Marketing Cloud Device Co-op to better understand how
you use our Websites across the various devices you use, and to deliver
tailored promotions. Go to https://cross-device-privacy.adobe.com to learn more about how Adobe does this
and to manage your choices relating to this linking of devices.
·
Pixels, Beacons: We or third party ad
servers may use invisible pixels or beacons on this Website to count how many
users visit certain pages. This information is collected and reported in the
aggregate. We may use this information to improve our marketing programs and
content, and to target advertisements at this Website and/or on other sites.
·
From Other Sources: We may receive your Personal Information from
other sources, such as public databases, joint marketing partners, data firms,
social media platforms, from people with whom you are friends or otherwise
connected on social media platforms, as well as from other third parties. For
example, if you elect to connect your social media account to your Website
account, certain Personal Information from your social media account will be
shared with us, which may include Personal Information that is part of your
public profile or your friends’ public profiles.
·
Mobile Devices: When you use or access
our Services from a mobile device, we may collect information such as your
unique device ID and your location. If you download and use an App, we and our
service providers may track and collect App usage data, such as the date and
time the App on your device accesses our servers and what information and files
have been downloaded to the App based on your device number, as well as any
other Personal Information specified by the App in its terms or notices.
·
Do Not Track
Signals: At this time, we do not respond to browser ‘do not track’
signals, as we await the work of interested stakeholders and others to develop
standards for how such signals should be interpreted. Third parties, including
our service providers, may collect information about your online activities
over time and across different websites, including when you visit our website.
You can learn about how to exercise choice regarding the collection of
information about your online activities over time and across third-party
websites or online services by visiting www.aboutads.info and www.networkadvertising.org.
·
Internet Based Advertising: We may use third-party advertising companies to serve
advertisements regarding goods and services that may be of interest to you when
you access and use our Services and other websites, apps or online services,
based on information relating to your access and use of our Services and other
websites, apps and services on any of your devices, as well as information
received from third parties. To do so, these companies may place or recognize a
unique cookie on your browser (including through the use of pixel tags). They
may also use these technologies, along with information they collect about your
online use, to recognize you across the devices you use, such as a mobile phone
and a laptop. If you would like more information about this practice, and to
learn how to opt out of it in desktop and mobile browsers on the particular
device on which you are accessing this Privacy Notice, please visit www.aboutads.info and www.networkadvertising.org to opt out in mobile apps. You may also opt out in Twitter
by going to your account privacy settings and unchecking the box next to
“Tailor ads based on information shared by ads partners.”
·
Other
Non-Personal Information: In addition to any Personal Information or other
information that you choose to provide to us on the Services, we and our
third-party service providers may use a variety of technologies, now and
hereafter devised, that automatically collect certain website usage information
whenever you visit or interact with the Services. This information may include
browser type, operating system, the page served, the time, the source of the
request, the preceding page view, and other similar information. We may use this
usage information for a variety of purposes, including to enhance or otherwise
improve the Services. In addition, we may also collect your IP address or some
other unique identifier for the particular device you use to access the
Internet, as applicable (collectively, referred to herein as a “Device
Identifier”). A Device Identifier is a number that is
automatically assigned to your device, and we may identify your device by its
Device Identifier. When analyzed, usage information helps us determine how our
Services are used, such as what types of visitors arrive at the Services, what
type of content is most popular, what type of content you may find most
relevant and what type of visitors are interested in particular kinds of
content and advertising. We may associate your Device Identifier or web site
usage information with the Personal Information you provide, but we will treat
the combined information as Personal Information.
We use non-personal information in a variety of ways, including to help analyze
site traffic, understand customer needs and trends, carry out targeted
promotional activities and to improve our services. We may use your
non-personal information by itself or aggregate it with information we have
obtained from others. We may share your non-personal information with our
affiliated companies and third parties to achieve these objectives and others,
but remember that aggregate information is anonymous information that does not
personally identify you. We may provide our analysis and certain non-personal
information to third parties (who may in turn use this information to provide
advertisements tailored to your interests), but this will not involve
disclosing any of your personally identifiable information.
As aggregated or anonymized information
does not constitute Personal Information, we may use it for any purpose. If we
combine anonymized or aggregated data with Personal Information, we will treat
the combined information as Personal Information according to this Privacy
Notice.
Why and How We Use Your Information
We may
Process Personal Information in connection with any of the following:
1. Our
business transactions with you, including, but not limited to:
·
To enter into or perform a contract with you
·
To respond to your inquiries and fulfill your requests
·
To send administrative information to you, for example,
information regarding the Services or an event in which you are attending
·
To complete and fulfill any purchases or requests for
services
2. For our legitimate
business interests, including, but not limited to:
·
To personalize your experience on the Services by presenting
products and offers tailored to you
·
To allow you to participate in sweepstakes, contests, and
similar promotions, and to administer these activities (each of which may have
additional rules and could contain additional information about how we Process
your Personal Information)
·
To facilitate social sharing functionalities of your social
media account(s)
·
To carry out data analysis, audits, fraud monitoring and prevention,
internal quality assurance, developing new products, enhancing, improving or
modifying our Services, identifying usage trends, auditing use and
functionality of our Services, helping enforce compliance with our Terms of
Use, helping protect our Services, determining the effectiveness of our
promotional campaigns and operating and expanding our business activities
·
Subject to your marketing preferences (which may include
consent to marketing under applicable law), to send you newsletters or
marketing communications we believe may be of interest to you, for our own
products and services, and on behalf of our Affiliates or selected third
parties, via postal mail, email, telephone or text messaging
·
To allow you to send messages to a friend through the
Services. By using this functionality, you are telling us that you are entitled
to use and provide us with your friend’s name and email address
3. In accordance with any
consent you may have provided. You have the right to decline to provide your consent and,
if consent is provided, to withdraw your consent at any time.
4. As necessary or
appropriate for legal reasons, including, but not limited to:
·
Under applicable law
·
To comply with legal process
·
To respond to requests from public and government
authorities, including those outside your country of residence
·
To enforce our terms and conditions
·
To protect our operations or those of any of our Affiliates
or other third parties
·
To protect our rights, privacy, safety or property, or that
of our Affiliates, you, or other third parties
·
To allow us to pursue available remedies or limit damages we,
our Affiliates, or other third parties, may sustain
When We Disclose Your Information
We may
disclose your information as follows:
·
Affiliates: To any other entity that
is, at the time you disclose your
Personal Information, directly or indirectly controlled by, or under common
control with us (“Affiliates”) for
the purposes described in this Privacy Notice, including under “Why and How We Use Your Information”, unless
otherwise prohibited by applicable law. You can find more information about our
primary operating Affiliates in our Annual Report as of the date the Annual
Report was published or by contacting us at the contact information set forth
below in the section titled “How Can You
Contact Us?”.
·
Vendors and Service
Providers: We may disclose your information to vendors
and service providers we retain in connection with our business such as: travel
services companies, financial services companies, property owners’
associations, vacation insurance companies, website
hosting, data analysis, payment processing, order fulfillment, information
technology and related infrastructure provision, customer service, email
delivery, credit card processing, tax and financial advisers, legal advisers,
accountants or auditing services.
·
Business Partners, Sponsors, and Other Third Parties: We may
disclose your Personal Information to business partners, co-sponsors of
promotions, and other third parties in order to provide you with services that
may be of interest to you. For example, we may share your Personal Information
with the owners and operators of affiliated and unaffiliated hotels and
resorts, airlines, car rental services,
retail stores, credit agencies and other third parties to facilitate
reservations, to offer you products or services, or in connection with our
loyalty program or a loyalty program of one of our partners. We may also co-sponsor
promotions, sweepstakes, or other events with a third party and may share your
Personal Information in connection with these events. Further, we may share
your Personal Information with third party providers located on-site at hotels
or resorts, such as time-share, spa, golf, concierge, and dining providers. If
you provide additional information to any of these third parties, such
information will be subject to such third parties’ privacy practices.
·
Third Parties: Subject
to your marketing preferences (which may include consent to marketing under applicable law), we may license, sell, or otherwise share
your Personal Information with selected
third parties for compensation for their own business purposes. Once we
share your Personal Information with a third party for such purposes, the
information shared becomes subject to such third party’s privacy practices.
·
Message Boards: We may make reviews,
message boards, blogs, and other such user-generated content facilities
available to users. Any information disclosed in these areas becomes public
information and you should always be careful when deciding to disclose your
Personal Information. We are not responsible for privacy practices of other
users including website operators to whom you provide information.
·
Merger or Acquisition: We may disclose your
Personal Information to a third party who acquires any part of our business or
the business of any of our Affiliates, whether such acquisition is by way of
merger, consolidation, divestiture, spin-off, or purchase of all or a
substantial portion of our assets.
·
Disclosure Permitted by
Law: We
may disclose your Personal Information to law enforcement authorities,
government or public agencies or officials, regulators, and/or to any other
person or entity having appropriate legal authority or justification for
receipt of your information, if required or permitted to do so by law or legal
process, to respond to claims, or to protect our rights, interests, privacy,
property or safety, and/or that of our Affiliates, you or other third parties.
How Do We Safeguard Your Information?
·
Security of Your
Information: We will take reasonable steps to protect the information you provide us
from loss, misuse and unauthorized access, disclosure, alteration and
destruction. We have implemented appropriate physical, electronic and
managerial procedures to help safeguard and secure your information from loss,
misuse, unauthorized access or disclosure, alteration or destruction.
Unfortunately, no security system is 100% secure, thus we cannot ensure the
security of all information you provide to us via the Services.
Other Important Information
·
Information Provided on
Someone Else’s Behalf: If you provide us with information about someone else,
please ensure you have the person’s permission to do so for the purposes
detailed in this Privacy Notice.
·
Links to Websites: The Services may have
links to other websites that are not operated by us. We have no control over
how these websites may collect your information and no liability for the
practices, policies and security measures implemented on these websites. You should
read the privacy notices on those other websites before you submit your
information through them.
·
Social Media Sites: Please note that we are
not responsible for the collection, usage and disclosure policies and practices
(including data security) of other organizations, such as Facebook, Apple,
Google, Microsoft, RIM or any other app developer, app provider, social media
platform provider, operating system provider, wireless service provider or
device manufacturer, including any Personal Information you disclose to other
organizations through or in connection with the Apps or our Social Media Pages.
·
Changes to Our Privacy
Notice: From time to time we may revise this Privacy
Notice and/or use Personal Information for new, unanticipated uses not previously
disclosed to meet changes in the regulatory or business environment, or to
satisfy the needs of our customers and service providers. Updated and date
stamped versions will be posted on the Services. Unless otherwise required
under applicable law (e.g. obtaining consent from you for the relevant material
changes) the revised Privacy Notice will take effect immediately upon such
posting.
·
Minors: We do not knowingly
collect, maintain or use Personal Information from individuals under 18 years
of age in connection with, and no part of our Websites, Social Media Pages, and
Apps is directed to, individuals under the age of 18. If we do incidentally collect or maintain
Personal Information from individuals under 18 years of age, you may request
deletion of such information by contacting us as set forth under “How Can You Contact Us?” below.
·
International Transfers: We are an international
company and we may, subject to applicable law, transfer your information, to
our Affiliates or selected third parties outside the country where you are
located and where information protection standards may differ (e.g., your
information may be stored on servers located in other jurisdictions). We will
utilize appropriate safeguards governing the transfer and usage of your Personal
Information, such as an adequacy decision by the European Commission, Model
Clauses or other applicable adequacy mechanisms. If you would like further
detail on the safeguards we have in place you can contact us directly as set
forth in “How Can You Contact Us”
below.
·
Retention Period. We will retain your Personal Information for the
period necessary to fulfill the purposes outlined in this Privacy Notice unless
a longer retention period is required or permitted by law.
Your Choices and Rights
·
Changes to Your Marketing
Preferences: You can opt-out from receiving future marketing communications from us
at any time by:
o
Using the unsubscribe function in the email you receive from
us; or
o
Contacting us as set forth under “How Can You Contact Us?” below.
·
Withdrawing Your Consent: You may withdraw any
consent that you have provided to us to Process your information at any time.
·
Accessing your
Information: In accordance with applicable law, you may access the Personal
Information we Process about you.
Any request to access or
obtain copies of your Personal Information must be made in writing by
contacting us as set forth under “How
Can You Contact Us?” below. We may, depending on the applicable law in your
country, be entitled to charge a nominal fee to cover some of our
administration costs in connection with the provision of such information. We
may also ask you to verify your identity and to provide further details
relating to your request.
·
Correcting your Information: We will take reasonable steps to ensure
the accuracy of the Personal Information we retain about you. It is your
responsibility to ensure you submit true, accurate, and complete information to
us, and timely update us in the event this information changes. You may request
that any inaccurate or incomplete Personal Information held by us or on our
behalf is corrected, by contacting us as set forth under “How Can You Contact Us?” below.
·
Deleting your Information: Under certain
circumstances, you may request we delete Personal Information we hold about you
by contacting us as set forth under “How
Can You Contact Us?” below. We will assess your request and determine,
under applicable law, whether we are required to delete this information.
·
Objecting to Processing: If you would like us to
stop Processing your Personal Information, you can request this by contacting
us as set forth under “How Can You
Contact Us?” below. We will assess your request and determine, under
applicable law, whether we have any justification for the continued Processing.
·
Transferring your
Information: Under certain circumstances, you may receive your Personal Information
in a format that allows you to send it to another company or to direct us to
transfer it directly to another company.
Notice to California
Residents:
Your California Privacy Rights: If
you are a resident of California, California Civil Code Section 1798.83 allows
you to request information regarding the Personal Information we collected and
third parties to whom we disclosed your Personal Information for the third
parties’ direct marketing purposes during the preceding calendar year. To make
such a request, please send an email to privacy.policy@wyn.com or send a letter
to: 22 Sylvan Way, Parsippany, New Jersey 07054, Attn: Legal Privacy.
How Can You Contact Us?
·
Contact Information: If after reviewing this
Privacy Notice, you have any questions, complaints or privacy concerns, or
would like to make any requests in relation to your Personal Information, or
obtain further information on safeguards used for international transfers
please send an email to privacy.policy@wyn.com or send a letter to:
Wyndham Hotel Group
22 Sylvan Way
Parsippany, New Jersey 07054, USA
Attn: Legal Privacy
If you have a complaint or
concern about how we are Processing your Personal Information then we will work
to address such concern(s). You may also direct your complaint/concern to the
applicable data protection authority.