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Updated and Effective May 2022

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
Choices
How We Protect Personal Information
How Long We Retain Information
Countries Used for Processing
Other Important Information
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.

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. We also share employee related information with human resource and benefits related service providers.
   
   
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 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 privacy@bestwestern.com 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. If you are a current employee of BWI please submit any requests relating to your personal information to the human resource department. If you are a former employee of BWI please use the email address or telephone number listed above.

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.
  
  BWI generally attempts to utilize the Standard Contractual Clauses approved by the European Commission for the transfer of personal information from Europe to countries that have not adopted similar data privacy laws. If Standard Contractual Clauses have not been adopted, or have been found insufficient, BWI transfers personal information outside of Europe based upon the following:
  
  
• Reservations made with BWI. By booking a reservation, or providing your information to BWI, you are transferring information directly to BWI in the United States, which is a form of processing that you are choosing to undergo, and you recognize that the United States may not offer the same level of privacy protections as your home country.
  
  
• Reservations made with Affiliates. Transferring personal information from an Affiliate in Europe to BWI in the United States (and onward to the location of your reservation) is necessary for the conclusion or performance of your contractual relationship with a Licensed Hotel.
  
  
• 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. When we make changes to the policy, we will change the "Updated and Effective” date at the beginning of this policy, and we will provide any other form of notice as may be required by law.   All changes shall be effective from the date we post the revised policy.
  
  
• 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.
   
• California Notice of Financial Incentive. Guests may enroll in BWR to obtain free hotel stays, promotions, and exclusive offers. When a guest signs up for BWR, we ask for their contact information and communication preferences. After a guest signs up we keep track of hotel stays, reservations, and point redemptions. Because BWR involves the collection of personal information, it might be interpreted as a “financial incentive” program under California law. The value of your personal information is related to the value of the free or discounted products, services, or hotel stays that you obtain when you redeem points. This value is based on the expense related to providing those free or discounted products, services, or hotel stays.
  
  You may withdraw from participating in BWR at any time by calling 1(800) 894-4365. Visit the BWR Terms and Conditions page to view full program rules, including how to join.

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.

Custserv@CS.Bestwestern.com
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.