Under the California Consumer Privacy Act (“CCPA”), we are required to notify California consumers about our collection, use, and disclosure of their personal information (whether collected through our website or offline). In this section of our Notice, and in accordance with the CCPA, “personal information” includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
This Notice does not apply to applicants for job positions.
Categories of Personal Information that We Collect, Disclose, and Sell
Below we identify the categories of personal information that we collect about California consumers and households, the purposes for which we use each category, and whether we disclose or sell information within each category. Please note our data collection practices set forth below are not different than those described above; rather, the CCPA specifies particular categories of data that we must address, and, in this section, we aim to describe some of the information already provided above in accordance with the categories as outlined by the CCPA. This section should therefore be read in conjunction with the further information provided in the rest of this Privacy Notice.
Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation.
Identifiers and Similar Data:
Collection: We collect:
Identifiers: your real name, alias, postal address, unique identifier), IP address (if you access our website), email address, social security number, driver’s license number, passport number, or other similar identifiers.
Signature, physical characteristics, telephone number, financial information (e.g., payment information for your reservation). We typically do not collect medical information from our guests absent an emergency situation or specific request.
Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Sources: We collect the information directly from you, from other persons/entities making a reservation on your behalf (e.g., travel agent, a member of your travel party, someone making the booking on your behalf), from IHG. With regard to internet or other electronic information, we collect that information automatically as you use our website and services.
Purposes of Collection: The primary purpose of our collection and use of this information is to fulfil your reservations and enhance and personalize your experience with us. In particular, we use your information to fulfil your reservation, and to provide services at our hotel, direct marketing to you (in connection with your preferences), targeted and personalized advertising to you, and as otherwise required by applicable law.
Disclosure: We disclose this information for business purposes.
Sale: We use third party targeted advertising companies that collect certain information about you through website cookies (and similar technologies designed for mobile applications). These third parties may collect information about you that they then aggregate with data collected about you through cookies placed on other websites/mobile apps. Under the CCPA, this type of sharing of information could be deemed a “sale”.
Protected Classifications/Audio/Visual Data:
Collection: We do not request information about protected classifications under California law such as race, sex, age, religion, national origin, disability, citizenship information, or genetic information. Nonetheless, we may capture information related to these categories in certain circumstances, by way of example only: our hotel uses closed circuit television for security purposes, and, the recordings may capture such information by virtue of the recording. You have the option of requesting an accessible room.
Sources: We collect the information directly from you, from other persons/entities making a reservation on your behalf (e.g., travel agent, a member of your travel party, someone making the booking on your behalf), from IHG.
Purposes of Collection: The primary purpose of our collection and use of this information is to enhance and personalize your stay with us, in particular, to provide you with the specific room type requested. We may use video surveillance for security purposes and to protect their rights and interests as well as the rights and interests of other guests.
Disclosure: We disclose any information about special requests for business purposes, including at your direction, to fulfil your request). If we obtain CCTV footage, we do not disclose such data except as necessary to protect our rights and interests and the rights or interests of other persons.
Sale: We do not sell this information.
Biometric and Geolocation Information:
Information Collected: We do not collect Biometric and Geolocation Information.
We may draw (or use service providers to draw) inferences from any of the information identified above to create or enhance a profile about a consumer reflecting the consumer’s preferences and tendencies (e.g., what types of room the consumer prefers, how frequently the consumer travels, etc.).
Sources: We draw inferences based on the data collection described in this Notice.
Purposes of Collection: We use inferences to enhance your overall experience at our hotel. We may use inferences to identify and to offer relevant marketing opportunities.