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BEST WESTERN INTERNATIONAL, INC. PRIVACY POLICY

LAST UPDATED: September 2020

This policy describes how Best Western International, Inc. and its subsidiaries including SureStay, Inc. (“BWI,” “we,” or “us”), collect, use, and share personal information.  Please note that Best Western® branded hotels and properties (“Licensed Hotels”) are independently owned and operated and are not owned, managed, or controlled by BWI.  In addition, outside of the United States, companies that are not owned by BWI are sometimes permitted to license the Best Western® brands.  Although these companies are referred to by BWI as “Affiliates” they are not under our ownership or control.  When you provide information to a Licensed Hotel or to an Affiliate, those companies may have their own privacy practices and policies.

You can select among various topics by clicking on the following options below:

Use and Processing of the Information We Collect

Sharing of Information

Your Choices

How We Protect Personal Information

How Long We Retain Information

Countries Used for Processing

Miscellaneous

Contact Information 

Use and Processing of the Information We Collect

The following chart provides examples of the type of information that we collect from you and how we use that information. 

Context

Types of Information

Primary Purpose for Collection
and Use of Information

Room Reservations

We collect your contact information, payment information, reservation information, and accommodation preferences.  That information is collected directly from you when you make a room reservation.  In a small number of cases we collect information about a guest’s health.  For example, a guest may voluntarily choose to provide information about a disability as part of a request for an accommodation preference.

We use your information in order to perform our contractual obligations, fulfill your requests for a reservation, and to take steps in anticipation of those obligations.  In some jurisdictions we also need your information to comply with legal obligations to collect and maintain information about guests.  We also have a legitimate interest in analyzing trends and patterns among guests.  In the rare circumstances in which we collect information about a guest’s health, that information is collected only for the purpose of accommodating a guest’s needs and is used for no other purpose.

Best Western Rewards® (“BWR”)

BWR is Best Western’s loyalty rewards program.  We collect your contact information, communication preferences, reservation history, redemption details, and partner loyalty program elections.  Information is collected when you register for BWR, redeem reward points, make a hotel reservation, update your BWR account, or link your BWR account to a partner loyalty program.

We use your information in order to perform our contractual obligations to you.  For example, we use the information to allow you to earn and redeem rewards, points, or credits in connection with loyalty programs.  We also have a legitimate interest in marketing to you and analyzing trends and patterns among our rewards members.  Per your express election and consent, store payment-related information for future reservations.  For complete BWR program terms see www.bestwesternrewards.com.

Best Western Travel Card®

We collect your contact information and payment information when you purchase a Best Western Travel Card®.  

We use your information in order to perform our contractual obligations to you.  We also have a legitimate interest in marketing to you and analyzing trends and patterns among our Best Western Travel Card holders. 

For complete Best Western Travel Card terms and conditions see www.travelcard.bestwestern.com.  

Cookies and First Party Tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed.

We have a legitimate interest in making our website operate efficiently and analyzing trends and patterns among our website visitors.

Cookies and Third Party Tracking

We participate in behavior-based advertising.  This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that it can provide advertising about products and services tailored to your interests on our website or on other websites. 

We have a legitimate interest in engaging in behavior-based advertising.

Email Interconnectivity

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, or make reservations.

We have a legitimate interest in understanding how you interact with our communications to you.

Customer Care

If you contact us with an issue we will collect your name and e-mail address, as well as any other content that you send to us in order to reply.

We have a legitimate interest in receiving and acting upon the information that you provide to us concerning issues that you raise.

Communications List

When you opt-in or sign up to receive communications, we collect your email address, postal address, or phone number for text messaging.   

We share information about our products and services or the products and services of other companies, if you consent to receive that information.  We also have a legitimate interest in sharing information with you about our services and those of our partners.

Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our websites or applications.

We have a legitimate interest in identifying unique visitors and in understanding how users interact with us on their mobile devices.

Partner Promotion

We collect information that you provide as part of co-branded promotions with other companies.  For example, we collect information if you apply for a Best Western co-branded credit card.

We have a legitimate interest in fulfilling our promotions. That interest includes sharing your information with our partners to, among other things, determine your eligibility for a promotion.

Surveys

When you participate in a survey we collect information that you provide through the survey. 

We have a legitimate interest in understanding your opinions and collecting information relevant to our organization to improve our services.

Sweepstakes, Promotions or Contests

When you participate in a sweepstakes, promotions, or a contest we collect information about you that includes contact information to notify you if you are selected.

We have a legitimate interest in operating sweepstakes.  In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.

Text Messages to Licensed Hotels

Some Licensed Hotels may provide guests with the ability to communicate by text message or through a text-message-based automated platform concerning a guest’s hotel stay.

Licensed Hotels that provide guests with the ability to communicate by text message or through a text-message-based automated platform concerning a guest’s hotel stay request consent from the guest before communicating with guests about their stays and responding to guest-initiated text communications.  Guests can ask the Licensed Hotel about its specific privacy practices.

Website Interactions

We use technology to monitor how you interact with our website. This may include the links you click on or information that you type into our online forms. 

We have a legitimate interest in understanding how you interact with our website to better improve it and to understand your preferences and interests in order to select offerings that you might find most useful.

Web Logs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We have a legitimate interest in monitoring our networks and the visitors to our websites.  Among other things, it helps us understand which of our services is the most popular.

WiFi Access

Although we do not provide WiFi networks at Licensed Hotels, we do provide access to WiFi at BWI offices (e.g., our headquarters).  We collect information about individuals that access those WiFi networks.

We have a legitimate interest in providing WiFi networks and in collecting information for fraud and security purposes.

Employment Candidates

If you apply to work for us we collect information necessary to evaluate your application. 

We use information about prospective employees in connection with our legal obligations and our legitimate interest in evaluating candidates.

Employees

If you are or were an employee of BWI we collect information necessary to your employment.

We use information about current employees in connection with our employment obligations.  In some contexts, we are also required by law to collect information about our employees and we have a legitimate interest in complying with those laws.  We also have a legitimate interest in using employment information to have efficient staffing and work force operations. 

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including business partners, BWR partners, Licensed Hotels, Affiliates, Travel Agents, Online Travel Websites, or publicly available sources.  For example, if you make a reservation at one of our Licensed Hotels, that hotel transmits information to us as part of our legitimate interest in, among other things, maintaining a global reservation system and providing for customer service and support.

In addition to the purposes and uses described above, we use information in the following ways:

·           For internal administrative purposes as well as to manage our relationships.

·           To conduct analytics.

·           To identify you when you visit our websites or Licensed Hotels.

·           To provide service to you and to improve our services and product offerings.

·           To respond to inquiries related to support, employment opportunities, or other requests. 

·           To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.

·           To streamline the reservation or checkout process.

·           For the safety and security of guests, staff, and other visitors.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose.  For example, if you make a room reservation we collect your information so that we, or so that a Licensed Hotel, can perform a contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your stay.  As a result, our collection and processing of your information may be based upon our need to perform a contract, our obligations under law, our legitimate interest in conducting our business, and/or your consent.

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

1.     Licensed Hotels and Affiliates. We share your information with the Licensed Hotels that will be fulfilling a reservation.  We also share your information with Affiliates in the geographic area of a Licensed Hotel in which you have stayed or you intend to stay.  Depending upon the context, Licensed Hotels and Affiliates use your information for a variety of purposes, including preparing for your stay, providing you with accommodations, marketing, or redeeming rewards points.

2.     BWR Partners.  We share information with independent companies that we have partnered with or that are participants in our BWR program to allow you to earn and redeem rewards, points, or credits in connection with your BWR membership and in accordance with your chosen earning and spending preferences.  For example, you may decide to select a particular airline partner through which you can earn BWR points.  We also share information with independent companies if you have selected that you would like to receive promotions and marketing material from Best Western’s third party-business partners.

3.     Partner Marketing and Promotions. We share information with independent companies if you have selected that you would like to receive promotions or marketing material from Best Western’s third party-business partners.  We also offer contests, sweepstakes, or other promotions with third party partners.  If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner, the information that you provide will be shared with us and with them.  Their use of your information is not governed by this privacy policy. 

4.     Travel Agents and Online Travel Websites.  We share your information with travel agents, and/or online travel websites that you use in order to process your reservation request and to comply with any requirements or needs of those entities.

5.     Service Providers.We share your information with service providers.  Among other things, service providers help us to administer our databases, websites, marketing, communications, and surveys; service providers provide us with technical and logistical support; service providers process payments on our behalf; and service providers assist in the fulfillment of reservations and orders.

6.     Public.  Some of our websites may provide the opportunity to post comments or reviews in a public forum.  If you decide to submit information on these pages, that information may be publically available.

7.     Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws or for national security requirements within the United States or the other jurisdictions in which we operate.  We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary. We also may share information with our corporate affiliates (e.g., subsidiaries, joint ventures, or other companies under common ownership or control).  In addition, if another company acquires or plans to acquire our company, business, or our assets, we will also share information with that company, including at the negotiation stage. 

8.     Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

Choices

You can make the following choices regarding your personal information:

1.     Promotional Emails. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive.  If you decide not to receive promotional emails, we may still send you service related communications.

2.     Promotional Mailings.  If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with "NO SNAIL MAIL" in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.

3.     Promotional Text Messages.  If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”

4.     Access to Your Personal Information. You can request access to your personal information by completing and submitting a Request Form. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. 

5.     Changes to Your Personal Information. We rely on you to update and correct your personal information.  Most of our websites allow you to modify or delete your account profile.  Note that we may keep historical information in our backup files as permitted by law.  If our website does not permit you to update or correct certain information you can request that your information be changed by completing and submitting a Request Form.  Although BWI will attempt in good faith to respond to your request, we may not be able to change your information in all circumstances.  For example we may not be able to change your information if doing so would impose an undue burden or expense, or if it would require us to change information relating to another person.

6.     Deletion of Your Personal Information. You can request information about how long we keep a specific type of information by contacting us at the address described below.  You can request that your information be deleted by completing and submitting a Request Form. If required by law we will delete your personal information after such a request is made.  You should note that there are some situations in which we may decline to delete your information.  For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements. 

7.     Revoking Consent or Objecting to Processing.  You can revoke consent to processing (where such processing is based upon consent) or object to our processing by completing and submitting a Request Form.  If you revoke consent or object to further processing we may no longer be able to provide you services.  In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.

8.     Online Tracking.  We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.

9.     California Residents.  California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.  If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Contact Information” section below.

If you do not want to submit a request through our online web portal request form, please address written requests and questions about your rights to Den här e-postadressen skyddas mot spambots. Du måste tillåta JavaScript för att se den. or call us at 1-800-528-1238.  An authorized agent submitting a request on behalf of an individual must submit a request through our Request Form.

Note that if you submit a request, we will, as required by law, require you to prove your identity.  We will verify your identity by comparing the information you provide when submitting your request with the information in our database. Depending on your request, we may ask for additional information such as the email address you used to create your BWR  account, the phone number you used to book your room reservation, and your past stay history. We may also ask you to provide a signed declaration confirming your identity. 

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf.  In order to confirm that you have indeed authorized an agent to make the request on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf, including a copy of the signed permission you have given to the authorized agent and verification of your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must submit a request through our Request Form and affirm that you are an authorized representative of a California resident as defined by Section 17014 of Title 18 of the California Code of Regulations.  After receiving your request, we will contact you by e-mail with respect to the documentation and verification we require for submitting a request on behalf of someone else.   

How We Protect Personal Information

No method of transmission over the Internet or of electronic storage is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account.  When you do you will be prompted to create a password.  You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you.  You should notify us of any unauthorized use of your password or account.

How Long We Retain Information

We retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.  For example, we retain BWR information for as long as an individual remains a BWR member because BWR points do not expire and the information is needed in order to allow the individual to redeem their rewards.  We retain information in our reservation system, in full or in summary form, for three years following a guest’s departure in order to process your reservation, provide post-reservation customer support, and provide invoicing and recordkeeping.  We typically retain information in our customer care complaint system for three years after receipt, unless the information is needed for an ongoing purpose such as to address an open issue. 

Countries Used for Processing

BWI operates from the United States in accordance with the laws of the United States.  Individuals that provide information to BWI or visit BWI’s website should be aware that the laws of the United States may differ from those of your country of residence.  For example, there may be situations in which we are required to share your information with United States law enforcement personnel.  The following provides additional information for data received by BWI from other countries or transmitted by BWI to other countries:

·               Transmission of Information from the European Union.  If BWI transmits your information to a processor outside of the EEA, BWI will take steps to ensure that the processor complies with the substantive principles of the GDPR.  If you would like more information concerning the protections applied for a particular onward transfer you can contact us using the information below.  If you feel that BWI has mishandled your personal information, please contact BWI using the contact information below with a written description of your complaint. After receiving such written description, a representative from BWI's Customer Care Department will contact you to set up a time and manner to discuss your complaint. BWI is dedicated to addressing all legitimate complaints about its treatment of your personal information and will make a good faith effort to engage in communications to address such complaints.  

By booking a reservation, or providing my information to BWI, I understand that I am transferring my information directly to BWI in the United States, which is a form of processing that I am choosing to undergo, and that the United States may not offer the same level of privacy protections as my home country.

·               Transmission of Information to Other Countries. In addition to having your information transferred to the United States where BWI is located, if you are making a reservation at a Licensed Hotel in a foreign country your information will be sent to that hotel, as well as to any Affiliate associated with that hotel.  In addition, we may send your information to a vendor or partner in a foreign country for purposes of administering our BWR program and marketing efforts.

Other Important Information

The following additional information relates to our privacy practices:

·               Third Party Applications, Websites, and Social Media.  We have no control over the privacy practices of websites or applications that we do not own. Our websites or our communications may also contain plug-ins and other features that integrate third party social media platforms. If you interact with these, the third parties who operate these platforms may be able to identify you, determine how you use our website, and link and store this information with your social media profile.

·               Changes to This Privacy Policy.  We may change our privacy policy and practices over time.  To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy.  Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

  • Accessibility. If you are visually impaired, you may access this notice through your web browser’s audio readers.
  • Information for California Residents. California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are “sold” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a request to us using the information in the "Contact Information" section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

Contact Information 

We will attempt to respond to any questions, comments, or complaints concerning our privacy practices.  Please feel free to contact us using the following information:.

Den här e-postadressen skyddas mot spambots. Du måste tillåta JavaScript för att se den.

1-800-528-1238

Best Western International, Inc.

Customer Care Department

P.O. Box 10203

Phoenix, Arizona 85064

Attn: Customer Care

Best Western International, Inc.

Unit 7 Citylink Business Park

Old Nass Road

Dublin 12

Ireland

Attn: Legal Department

(BWI representative in the EU)

Please note that e-mail communications will not necessarily be secure; accordingly you should not include Payment Information or Sensitive Information in e-mail correspondence to us.

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

LAST UPDATED :  September 2020

EFFECTIVE :September 2020

California Information Sharing Disclosure

 California Civil Code 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicates that companies should disclose whether the following categories of information about California residents are collected or transferred.  Note that BWI does not sell the information that it collects about California residents.  Note that while a category may be marked that does not necessarily mean that we have information in that category about you.  For example, while we transfer bank account numbers for our business purpose in paying our employees (e.g., direct deposit) we do not collect or transfer bank account numbers of individuals that make a reservation or submit questions on our website’s “contact us” page.

 
Categories of Personal Information That We Collect To Whom We Disclose Personal Information for a Business Purpose
Customer identifiers – such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name,  BWR number, driver’s license number, passport number, or other similar identifiers  
  • Other Service Providers
  • Equipment manufacturer support
  • Product and service fulfillment companies
  • Internet service providers
  • Advertising Networks
  • Social Networks
  • Payment Processors and financial institutions
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
  • Data analytics providers
Professional/employment information– such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, social security number, driver’s license number, passport number, or other similar identifiers, occupation, and professional references.  
  • Other Service Providers
  • Internet service providers
  • Social Networks
  • Payment Processors and financial institutions
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
Financial information – such as bank account number, credit or debit card number, or other financial information.  
  • Other Service Providers
  • Payment Processors and financial institutions
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
Employee medical / health insurance information – such as information from a healthcare provider regarding an individual’s medical history, mental or physical condition, or treatment;  an individual’s insurance policy number or subscriber identification number, any unique identifier used by a health insurer to identify the individual, or any information in the individual’s application and claims history.   
  • Other Service Providers
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
Protected characteristics – such as race, gender, physical or mental disability, and religion.  
  • Other Service Providers
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
Commercial transaction information – such as information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  
  • Other Service Providers
  • Product and service fulfillment companies
  • Advertising Networks
  • Social Networks
  • Payment Processors and financial institutions
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
  • Data analytics providers
Network activity data– internet or other electronic network activity information, such as browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.  
  • Other Service Providers
  • Managed Security Service Providers
  • Equipment manufacturer support
  • Product and service fulfillment companies
  • Internet service providers
  • Advertising Networks
  • Social Networks
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
  • Data analytics providers
Geolocation data – such as precise physical location.  
  • Other Service Providers
  • Managed Security Service Providers
  • Internet service providers
  • Advertising Networks
  • Social Networks
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
  • Data analytics providers
Audio, electronic, visual and similar information  – such as pictures, a recording of a customer service call, security video surveillance footage).  
  • Other Service Providers
  • Government entities, law enforcement, lawyers, auditors, consultants and other parties as required by law
Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an customer’s preferences.  
  • Other Service Providers
  • Product and service fulfillment companies
  • Advertising Networks
  • Social Networks
  • Data analytics providers

 

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