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Submitted URL: http://www.ihg.com/hotels/us/en/global/customer_care/privacy_statement
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Effective URL: https://www.ihg.com/content/us/en/customer-care/privacy_statement
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PRIVACY STATEMENT
Book With Us Advantage
Worldwide Reservation Offices
--------------------------------------------------------------------------------
Who we are
Information we collect and how we use and share it
The legal basis for processing your personal data
Data Transfer
Using our websites, mobile applications and other technology
Cookies and other tracking technologies
Use of WI-FI services (IHG Connect)
Using Personal Information to create profiles
How we secure your information
Managing your preferences and information
Links to other sites
Children
Retaining your information in our systems
How to contact us
Additional Information for UK/EU/EEA, California, Nevada, PEOPLE’S REPUBLIC OF
CHINA and Brazil
Additional Information for U.S. Consumers
Additional Information for California Consumers
California Consumer Rights
California Notice of Financial Incentive
Additional Information for The People’s Republic Of China (excluding for the
purposes of this statement Hong Kong SAR, Macau SAR And Taiwan) (“PRC”)
BRAZIL DATA SUBJECTS RIGHTS UNDER BRAZIL DATA PROTECTION LAW
Changes to this Privacy Statement
The privacy and security of your information is very important to us. Whether
you are visiting our website, using our app, booking a room, or are a member of
one of our loyalty programs, we want you to trust the way that we manage your
information and to keep you informed about how we use that information.
We have prepared this Privacy Statement to explain more about who we are, how we
collect and manage your information (whether through our website, mobile apps
and other IHG® Hotels & Resorts-branded digital channels (e.g., our branded IHG
Connect WiFi), our social media pages, or offline) and the choices you have
about how we use your information. Specific additional rights may apply if
required by applicable law. For example, please view our additional disclosures
directed to residents of the United States and California and the UK and
European Economic Area (EEA) and Nevada and the People’s Republic of China
(Excluding for The purposes of this statement Hong Kong Sar, Macau Sar and
Taiwan) (“PRC”) and Brazil in this Privacy Statement.
--------------------------------------------------------------------------------
WHO WE ARE
This Privacy Statement is issued by the InterContinental Hotels Group of
Companies (collectively referred to as "IHG”, “IHG® Hotels & Resorts”, "we”,
"us” or "our” in this Privacy Statement), which includes the direct and indirect
subsidiaries of InterContinental Hotels Group PLC and covers information that we
collect and use in the course of our business. When we mention "IHG", “IHG®
Hotels & Resorts”, "we", "us", or "our", we are referring to the relevant
company in the InterContinental Hotels Group that processes your personal
information. Your information may also be collected and used by IHG® Hotels &
Resorts-branded hotels. In most cases, these hotels are independently owned, and
their use of your information is covered by their own privacy notices, not this
one. If you would like to learn more about IHG and our relationship with our
IHG® Hotels & Resorts-branded hotels, click below.
ABOUT IHG
We are a global hospitality company operating in more than 100 countries. We
predominantly franchise our brands to, and manage hotels on behalf of,
independent owners. We also operate a number of programs that are related to our
hotel business such as IHG® One Rewards, which is our core loyalty program.
ABOUT OUR IHG-BRANDED HOTELS
We franchise our brands to, and manage hotels on behalf of, independent owners
(“IHG® Hotels & Resorts-branded hotels” or “IHG-branded hotels”). Most hotels
operating under IHG’s brands are independently owned and operated by parties
that have entered into a franchise agreement with IHG that allows them to use an
IHG brand for the purposes of operating a hotel. If you make a reservation
through us to stay at an IHG-branded hotel, we will disclose your information
with that hotel in order to enable the performance of your hospitality request.
However, as IHG-branded hotels are not owned or controlled by IHG, their use of
your information will generally be governed by their own privacy practices.
--------------------------------------------------------------------------------
INFORMATION WE COLLECT AND HOW WE USE AND DISCLOSE IT
We collect personal information directly from you, about you from other
persons/entities/online channels, and automatically as you use our website,
mobile application or other IHG-branded digital channels, and through certain
offerings or services available at IHG-branded properties (such as IHG Connect
WI-FI). We provide more detail in the sections below. In particular, we collect
and use information about you if you (or someone on your behalf) makes a
reservation to stay at an IHG-branded hotel or property offered through IHG
reservations, participate in one of our loyalty programs such as IHG® One
Rewards, or interact with us through our corporate site, mobile app or other
IHG-branded digital channels. You do not have to provide us with your personal
information in order to use our website or mobile app; in some cases, however,
we may not be able to provide services to you without your personal information
(for example, we would not be able to complete a requested booking or enroll you
in our rewards program). To learn more about how we collect, use and disclose
your information, and how you can opt out, please click the relevant section
below.
IF YOU MAKE A RESERVATION OR STAY AT AN IHG-BRANDED HOTEL
Information we collect:
Directly From You: We collect information from you when you make a booking
through our reservation system or stay at an IHG-branded hotel. Information
collected during the course of the reservation and during your stay may include:
* Your name, email address, home and business address, phone number,
nationality and payment card information;
* Information relating to your membership in one of our services or programs or
those of our program partners such as your IHG® One Rewards number or
frequent flier number; and
* Information such as stay and room preferences made during the course of your
reservation such as your preferred room type and specific requests to the
hotel.
If you provide personal information to us about other persons when making a
booking or during your stay, for example, family members or colleagues, we ask
you to make sure they are happy for their personal information to be disclosed
with us and to direct them to read this Privacy Statement if they want to find
out more about how we use their information.
From Other Sources: We also collect reservation information about you from other
persons/entities, including, travel agents, websites not owned and operated by
IHG, persons booking on your behalf (e.g., a family member, company
representative), your employer, or other entity. If you make a reservation
directly with one of our IHG-branded properties, we typically receive a copy of
that reservation. We also may collect information about you (indirectly) from
airlines and other travel providers connected with your reservation; for
example, we may learn your arrival time from a travel partner and use this
information to contact you about early check-in options. We may obtain
information about you from social media pages; for example, if you make a
comment on IHG’s social media page or if you comment about IHG on a public
social media feed. We use this information to improve our services to you and to
other customers.
Automatically: We collect information about you automatically as you use our
website, mobile app, our social media sites, interact with our other digital
channels, and, in some instances, when we correspond with you through email. In
these instances, information such as your country information, internet protocol
(“IP”) address, medial access control address, your interactions with these
channels, and other characteristics about your system or device may be
automatically collected. This information is collected for functional purposes
as well as to improve your experience when using these services. This
information may also be used for aggregated trend and statistical analysis, and
for showing you more relevant advertisements and messages. More information on
these practices can be found in the Using our websites, mobile applications, and
other technologies section below. We do not typically associate an IP address
with your IHG® One Rewards profile.
Special Hotel Programs/Biometrics: At IHG, we are always seeking more ways to
enhance your experience with us. A limited number of properties now offer a
biometrics check-in process to eliminate your need to stand in line. Some
properties also may allow room access through the collection of biometric
information. These programs are opt-in only, and any information that we collect
through your participation will be used solely for the program as described in
the notice provided to you at the time of the opt-in.
How we use this information: We use your information from you primarily to
fulfill your hotel reservation and to provide and manage our IHG® One Rewards
program. This may include communicating with you (e.g., sending a confirmation
email) in advance of your stay. Following your stay, we may also send you
post-stay communications and satisfaction surveys to get feedback on your
experience. When you stay at a hotel, we do not receive all of the information
about your stay; for example, if you book a spa visit, that spa service may be
provided either by the IHG-branded hotel (not IHG) or by a local entity.
In some instances, and where we have your consent or where permitted under
applicable law, we may send you marketing communications (which may include text
messages or calls placed using autodialer technology) for products and services
that we believe would be relevant for you. We also may use information related
to your stay to display targeted advertisements on our websites, mobile apps,
our other digital channels or on non-affiliated websites or mobile apps, or to
send you more relevant messaging. Additionally, we aggregate your information
with other guest information to complete trend and statistical analysis, which
we use to evaluate and improve our products and services, plan new hotel
locations and services, and for other market research.
We will indicate whether the requested information is mandatory; the failure to
provide such information may impact our ability to and/or prevent us from
providing certain services to you.
Who we disclose your information with: We disclose your reservation information
as follows:
* Properties: We disclose reservation information with the property you are
staying at to fulfill your reservation. Please note that we do not disclose
all of your information with the property location; for example, we disclose
your reservation details (such as name, dates of stay, and certain of your
IHG® One Rewards information if you are a member such as whether you are a
member and your member tier).
* Service Providers: We will disclose your information with service providers
to provide services in relation to our business as well as to help us improve
our products and services. For example, we might use a service provider or a
service provider’s product for the purposes of market research and data
analytics, or disclose data with online partners we work with, so we, or our
online partners on our behalf, can communicate with you and serve
advertisements through their platforms or on other websites or platforms. In
certain instances, subject to local consent requirements, our service
providers may also assist us with various marketing campaigns. These
companies are authorized to use your personal information only as necessary
to provide these services to us.
* Partners: Where permitted by applicable law, or where we have your consent,
we may also disclose your information with other parties, including our IHG®
One Rewards partners and others, to extend special offers about their own
products and services to you. In an effort to offer you a more seamless
travel experience, we have partnered with other companies that may be
involved in your travel plans (e.g., airlines, rental car companies) through
a common service provider and may, where permitted by law, disclose certain
information about your upcoming travel. We use this information to try to
customize our products and services to you (e.g., late/early check-in) or for
you to receive offers related to your travel from other companies. You have
options about whether you wish to receive these communications and offers;
please log into the IHG® One Rewards preference center at any time to view
and exercise your communications choices. In addition, certain U.S. state
residents may have the option of clicking on the “Do Not Sell or Share My
Personal information” link, which would eliminate the sharing that might
constitute a sale under applicable law. Other requests may be directed to one
of our global customer care offices or the Privacy Office.
We also disclose your stay information with other entities, which may include
law enforcement, professional advisors, and other persons, in circumstances such
as:
* when we believe in good faith that the disclosure is required by law or to
protect the safety of hotel guests, employees, the public or IHG property;
* when disclosure is required to comply with a judicial proceeding, court
order, subpoena, warrant or legal process; or
* in the event of a merger, asset sale, or other related transaction.
IF YOU JOIN ONE OF OUR LOYALTY PROGRAMS
Information we collect: We collect information from you during the course of
your membership in any of our loyalty programs and services, including our core
loyalty program, IHG® One Rewards. Information collected during the course of
your enrollment and participation in these programs may include:
* Your name, email address, home and business address, phone number,
nationality, birthday and payment card information;
* Your membership number and pin or password as well as details of your
memberships with any of our program partners such as our airline or car
rental partners;
* Information that you choose to provide in your loyalty profile, such as your
personal stay and destination preferences; and
* Marketing preferences, including how you prefer to be contacted by IHG as
well as what types of information you are interested in hearing about.
* Your stays at IHG-branded properties, including the property name, dates of
stay, and, in some circumstances, the total dollar amount of your stay (and,
in some circumstances, an itemized breakdown of your spend at the property).
We may collect this information from you, other sources, and automatically.
From You/Other Person acting on Your Behalf: We collect your information
through our global reservation and customer care offices, through our websites,
through our mobile applications or through our other digital channels.
Properties: We receive information about your stay from IHG-branded hotels and
other properties within the IHG network so that we can honor the program.
Service Providers: We may also collect information about you from other sources,
including entities that assist us in confirming the accuracy of your mailing
address; in some circumstances, we do not receive the updated address
verification from the vendor; rather, the vendor may simply update our mailing
with the address that it believes is aligned with the postal service
requirements.
Other Sources: We may obtain information about you from social media pages; for
example, if you make a comment on IHG’s social media page or if you comment
about IHG on a public social media feed. We use this information to improve our
services to you and to other customers. We do not typically append this
information to your rewards profile. We also obtain demographic information from
entities, which typically is in aggregated form. We may use this information in
combination with information in your profile to identify relevant opportunities
about which to notify you.
Your Friends: We may obtain information about you from friends if they refer
you to us, where necessary with consent or another appropriate legal basis.
Automatically: We collect information about you automatically through our
website, mobile app, our emails, and social media sites. In these instances,
information such as your country information, internet protocol (“IP”) address,
medial access control address, and other characteristics about your system or
device may be automatically collected in accordance with an appropriate legal
basis. This information is collected for functional purposes as well as to
improve your experience when using these services. This information may also be
used for aggregated trend and statistical analysis, and for showing you more
relevant advertisements and messages. More information on these practices can be
found in the Using our websites, mobile applications, and other technologies
section below, and in our Cookies and other tracking technologies section. We do
not typically associate an IP address with your IHG® One Rewards profile.
How we use this information: We use your information to operate and provide
services in connection with our loyalty programs. We also use your information
to improve our products and services. Where permitted by applicable law, or
where we have your consent, we also may disclose your information with other
parties, including our loyalty partners and others, to extend special offers
about their own products and services to you.
This may include:
* Enrollment in the loyalty program;
* The order and delivery of merchandise that you have redeemed online,
including merchandise and services offered by our IHG® One Rewards partners;
* Sending you updates, account statements and other information relating to
your participation in one of our programs or services;
* Sending you marketing communications (which may include text messages or
calls placed using autodialer technology), with your consent where required
by applicable law, in relation to the products and services offered by IHG or
our IHG® One Rewards partners or other partners or affiliates;
* Providing you with personalized advertisements or communications for IHG
and/or other products or services that we believe may be relevant for you;
and
* Analytics, statistical analysis and other research.
Although provision of much of the information requested is voluntary, the
failure to provide certain information may impact and/or prevent our ability to
offer you certain services.
We occasionally run promotions where we ask IHG® One Rewards Members to refer a
friend to the IHG® One Rewards with consent or other appropriate legal basis. In
these cases, we always ask members to make sure anyone they refer consents to
their personal information to be passed to us, and to direct friends to read
this Privacy Statement if they want to find out more about how we use their
information.
How you can manage your marketing preferences: You can manage your preferences
and decide what marketing communications you would like to receive from us in
our online preference center. You can visit our Preference center or find out
more information in the Managing your Preferences and information section.
In addition, you can opt out of collection of your personal information for use
in targeted advertising. Please see Managing cookies and opting out for more
information on how to do this.
We also recommend you routinely review the privacy notices and preference
settings that are available to you on any social media platforms as well as your
preferences within your IHG® One Rewards account. In addition, certain U.S.
state residents may have the option of clicking on the Do Not Sell or Share My
Personal Information link, which would eliminate the sharing that might
constitute a sale under applicable law.
Who we disclose your information with: During the course of your participation
in our loyalty programs, we disclose your information as follows:
* Loyalty partners: to provide you with the products and services that you have
requested and, where permitted by law, for the partner to offer its own
products and services to you. We also may choose to partner with another
company to offer a product, such as a co-branded credit card. You have
options about how we disclose your information; please log into the
preference center at any time to view and exercise your choices. In addition,
certain U.S. state residents may have the option of clicking on the Do Not
Sell or Share My Personal Information link, which would eliminate the sharing
that might constitute a sale under applicable law.
* Service providers: for the purposes of operating the program and to provide
you with the products and services that you have requested. We also use
service providers to assist us with managing, carrying out and improving our
advertising. These companies are authorized to use your personal information
only as necessary to provide these services to us.
We also will disclose your information in the following circumstances:
* When we believe in good faith that the disclosure is required by law or to
protect the safety of hotel guests, employees, the public, or IHG property;
* When disclosure is required to comply with a judicial proceeding, court
order, subpoena, warrant, or legal process in any jurisdiction; or
* In the event of a merger, asset sale, or other corporate transaction.
IF YOU INTERACT WITH US THROUGH OUR CORPORATE SITES
Information we collect: We collect information from you when you sign up to
receive corporate news or shareholder documents, participate in surveys, submit
reviews, contact customer service, or otherwise provide feedback to us or
through social media or our other digital channels.
Corporate News: Information collected may include:
* Information relating to your registration for corporate news such as your
name, email address, profession, country/region and email service preferences
for news; and
* Information relating to the receipt of shareholder documents such as your
initials, surname, postcode, shareholder account number, email address and
password for shareholder communications.
We collect this information directly from you when you sign up for corporate
news or shareholder documents on our corporate site.
Competitions or sweepstakes: We collect contact information from you when you
sign up for a competition or sweepstake; we do not necessarily include this
information as part of your IHG® One Rewards profile. In these instances, we
will collect information from and about you for running and administering the
respective competition, sweepstakes or service that you have elected to
participate in. The information collected may include personal details such as
your name and address as well as certain demographic information that you choose
to provide. In each case, we will collect, use and secure your information in a
manner consistent with the general principles set out in this Privacy Statement
unless we tell you otherwise.
Other Collections: We also collect information from you when you sign up to
receive our newsletters or other special offers and promotions, download one of
our mobile applications, or participate in one of our other services. The type
of information that we collect from you depends on your interaction with our
site and services.
Automatically: We also collect information about you when you browse our
website, use our mobile app, interact with our emails or use our social media
sites. In these instances, information such as your country information,
internet protocol (“IP”) address, media access control address and other
characteristics about your system or device may be automatically collected. This
information is collected for functional purposes as well as to improve your
experience when using these services. This information may also be used for
aggregated trend and statistical analysis, and for showing you more relevant
advertisements and messages. More information on these practices can be found in
the Using our websites, mobile applications and other technology section below.
We do not typically associate an IP address with your IHG® One Rewards profile.
How we use this information: We use your information to provide you with
corporate news and shareholder documents for which you have signed up. For
corporate news, you may change your communication preferences in accordance with
the Managing your communication preferences section below.
If you sign up for a promotion, we may associate that promotion with your
account (e.g., if related to an IHG® One Rewards program.). If you sign up for a
contest or sweepstakes, we will use your information for the purpose of that
contest or sweepstakes. Please be advised that there may be additional rules for
the sweepstakes or contest, and those rules may provide additional information
about how we will use your information collected for any event that you choose
to enter.
For online collected data, please see Online Channels and our Cookies and other
tracking technologies for additional information.
Who we disclose your information with: We may disclose your information with our
service providers who provide services on our behalf to help with our corporate
site and our shareholder functions. These services may include the provision of
shareholder documents and services related to management of our shareholder
register. These companies are authorized to use your personal information only
as necessary to provide these services to us.
We will also disclose your information in circumstances, such as:
* when we believe in good faith that the disclosure is required by law or to
protect the safety of hotel guests, employees, the public or IHG property;
* when disclosure is required to comply with a judicial proceeding, court
order, subpoena, warrant or legal process; or
* in the event of a merger, asset sale, or other related transaction.
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THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We are committed to collecting and using your information in accordance with
applicable data protection laws.
We collect, use and disclose your information where we have an appropriate legal
basis to do this.
This may be because:
* you have provided your consent to us using the personal information;
* our use of your information is necessary to perform our contract with you,
for example, making and managing your booking and operating and providing
services in connection with our Loyalty Program in accordance with the terms
of our agreement with you;
* our use of your information is necessary to meet responsibilities we have to
our regulators, tax officials, law enforcement, or otherwise meet our legal
responsibilities;
* our use of your information is in our legitimate interest as a commercial
organization, for example to operate and improve our services and to keep
people informed about our products and services (including for profiling and
targeted advertising) - in these cases we will look after your information at
all times in a way that is proportionate and respects your privacy rights
and, depending on the applicable law, you have a right to object to
processing as explained in To object to how we use your information.
If you would like to find out more about the legal basis for which we process
personal information please contact us (details found in the How to contact us
section). If you have provided your consent to our processing of your
information you can withdraw this consent at any time by contacting the IHG
Privacy Office (details found in the How to contact us section).
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DATA TRANSFER
As we operate via a global network of corporate offices, reservation and service
centers, data centers and hotels, it may be necessary to transfer your
information, for example, information collected in connection with making a
reservation or stay at an IHG-branded hotel, joining one of our loyalty programs
or interacting with us through our corporate site, websites, emails or our other
digital channels to a country outside of the country where it was originally
collected or outside of your country of residence or nationality. The
information that you provide us during the course of a reservation or through
the provision of any other services may be transferred to any of our IHG-owned
or affiliated entities and hotels around the world for the purposes of carrying
out or facilitating these services. It will also be necessary to transfer this
information to other entities, including, without limitation, our IHG-branded
hotels, partners and our service providers.
Where we transfer information which originates in the European Union ("EU") or
the United Kingdom (“UK”) or in Brazil to a country outside of the EU or UK or
Brazil, we will take steps to make sure such transfer is carefully managed to
protect your privacy rights:
* transfers within the IHG Group will be covered by an agreement entered into
by members of the IHG Group (an intra-group agreement) which contractually
obliges each member to ensure that your information receives an adequate and
consistent level of protection wherever it is transferred within the IHG
Group;
* where we transfer your data outside of the IHG Group including to other
companies providing us with a service, we will obtain contractual commitments
and assurances from them to protect your information. Some of these
assurances are well recognized certification schemes such as standard
contractual clauses;
* we will only transfer personal information to countries which are recognized
as providing an adequate level of legal protection or where we can be
satisfied that alternative arrangements are in place to protect your privacy
rights; and
* any requests for information we receive from law enforcement or regulators
will be carefully validated before personal information is disclosed, where
permitted by the applicable law.
When we otherwise transfer personal information between jurisdictions, we will
take such steps as required by local law in an effort to ensure that such
transfer is managed to protect your privacy rights.
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USING OUR WEBSITES, MOBILE APPLICATIONS AND OTHER TECHNOLOGY
We and our service providers use cookies, pixels, web beacons, tracking tools
and other similar technologies on our websites, mobile applications and in other
areas of our business to collect information and provide you with the services
that you have requested or participate in and to provide targeted advertising.
Subject to local consent requirements, we may use this and other information we
collect, such as a hashed email address, to help us and our service providers
identify other devices that you use (e.g., a mobile phone, tablet, other
computer, etc.). If you are using our mobile applications and have consented to
sharing your location information with us, this information might be collected
through GPS to enable us to provide certain personalized services to you such as
recommendation of hotels nearby, customized offers and promotions. Your location
preferences can be set or modified at the device level or through modifying your
settings with the relevant social media platform. This information also includes
personally identifiable information that you provide when you join one of our
loyalty programs to enable us to verify your membership. We, and our service
providers, also may use the cross-device tracking and other information we learn
about you to serve targeted advertising on your devices. We also use the
information that we collect to improve our products and services as well as your
experience when visiting our websites and using our mobile applications. If you
are using these third-party functions, you are also protected by the privacy
policies of these third parties. For more information on these subjects, please
click the relevant section below.
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COOKIES AND OTHER TRACKING TECHNOLOGIES
What is a cookie: A “cookie” is a small text file that is placed onto an
Internet user’s web browser or device and is used to remember as well as obtain
information about that party. You might be assigned a cookie when visiting our
websites or when using our mobile applications or other digital channels. In
some instances, where permitted under the applicable law, cookies may also be
used for the purposes of certain email campaigns.
What types of cookies we use and how we use them: We use three primary types of
cookies, which include:
* Functional Cookies – these cookies support the use of the website and
applications and enable certain features to enhance your experience. For
example, we use functional cookies to facilitate your reservation and to
remember your selections as you move from page to page. We also use
functional cookies for remembering things like your sign-in information and
hotel preferences to avoid you having to re-enter it.
* Performance Cookies – these cookies collect information needed to support the
website and our applications and allow us to improve our website and identify
any problems that you faced while visiting us. For example, performance
cookies may provide us with information about how you came to our website and
how you navigated around our website during your visit. We also use these
cookies to provide us with certain statistical and analytics information,
such as how many visitors came to our website or how effective our
advertising is.
* Targeting Cookies – these cookies are used to collect information from you to
help us to improve our products and services as well as serve you with
targeted advertisements that we believe will be relevant for you. We use
targeting cookies across our websites and applications for various marketing
initiatives and campaigns. For more information, please see the Targeted
advertising section below.
To learn more about cookies and how they are used, please visit:
http://www.allaboutcookies.org/.
Cookies: As described above, we use a number of service providers to help us
manage, carry out and improve our advertising. These parties set cookies at our
direction to help us collect information and provide you with advertisements
that we believe would be relevant for you. In some instances, these parties may
also assist us by providing certain statistical and analytics information in
relation to our marketing practices. We also may disclose information collected
through cookies (and other tracking technologies) with third parties to use for
their own analytics and marketing purposes. These third parties may serve
targeted advertising to you about IHG and non-IHG branded hotels. The scope of
information shared may include information collected through cookies, such as
your IP address/device ID, and information about the search that you performed
on our website (e.g., you were looking for a hotel in New York City), but would
not include your name or IHG® One Rewards information.
Managing cookies and opting out: You can change your cookie preferences in our
Cookie preferences tool, which is also available from the Privacy and Cookies
Center. You can choose to visit our web sites without cookies, but in some cases
certain services, features and functionality may not be available. To visit
without cookies, you can configure your browser to reject all cookies or notify
you when a cookie is set. Each browser is different, so check the "Help" menu of
your browser to learn how to change your cookie preferences. To manage Flash
cookies, please see Flash Player Help.
In relation to cookies placed by our service providers, we participate in the
Self-Regulatory Program for Online Behavioral Advertising managed by the Digital
Advertising Alliance (“DAA”). As part of this commitment, IHG has agreed to
comply with the standards and guidelines promulgated by the DAA. For more
information regarding targeted advertisements and/or to opt out of automatic
collection for these purposes, please visit http://www.aboutads.info/choices/ or
http://www.networkadvertising.org/managing/opt_out.asp. Within the EU, UK and
Canada the local DAA organizations operate a similar "ad choices" scheme: see
http://www.youronlinechoices.com (UK/Europe) and http://youradchoices.ca/
(Canada). If you opt-out of these targeted advertising cookies, your opt-out
will be specific to the web browser or mobile device from which you accessed the
opt-out. If you use multiple devices or browsers, you will need to opt out each
browser or device that you use.
Other technologies: Other technologies such as pixels and web beacons may also
be used on our websites, mobile applications, in email messages and in other
areas of our business. These technologies are used to improve our products and
services as well as our marketing efforts. We use pixels in our emails to help
us determine the success of our advertising campaigns, such as to give us
insight into whether you opened, deleted, or forwarded an email, or clicked on a
link contained in the email.
Targeted advertising: We and our service providers may serve targeted
advertisements through the use of first-party or third-party cookies, pixels and
web beacons when you visit our website, use our mobile applications, or visit
websites owned by other entities. In some instances, these cookies may be
persistent cookies. As described in the Using our websites, mobile applications
and other technology section above, we and our service providers may also use
cookie and other information to try to identify other devices and web browsers
that you may use so we and our service providers may serve targeted
advertisements to those devices. We do this to provide you with advertising that
we believe may be relevant for you as well as improve our own products and
services, including the functionality and performance of our websites and mobile
applications. To learn more about opting out of certain types of targeted
advertising, please see the Managing cookies and opting out section above.
Do-Not-Track: Currently, our systems do not recognize browser “do-not-track”
signals. You may, however, disable certain tracking as discussed in this section
(e.g., by disabling cookies); you also may opt-out of targeted advertising by
following the instructions at the DAA and the Network Advertising Initiative
websites.
LOCATION INFORMATION AND SERVICES
In some jurisdictions, and where permitted by applicable law or with your
consent, we may receive information about your location during the course of and
for the purpose of providing you the services described above through your use
of our websites and mobile applications. For example, if you are using our
mobile applications and have consented to sharing your location information with
us, this information might be collected through GPS or Bluetooth technologies to
enable us to provide certain services to you such as customized offers and
promotions. In addition to your use of our websites, mobile applications and
other digital channels, we may also receive location information from wireless
networks or cellular towers in proximity to your mobile device, through your
Internet protocol (“IP”) address or through your use of other services we
provide at our hotels. We may also have access to location information that you
provide to us through your use of social media, such as when you “tweet” your
location. We do not maintain this information as part of your IHG® One Rewards
profile, and we typically use this information at the point in time at which you
provide it to satisfy your request. Your location preferences can be set or
modified at the device level or through modifying your settings with the
relevant social media platform.
MOBILE APPLICATIONS
We receive information about you when you use our mobile applications. Some
information such as your device manufacturer, type and operating system version,
are collected automatically, while other information is only collected if you
choose to provide it and where permitted by applicable law, such as your precise
geolocation information. We do not typically associate your precise geolocation
information obtained through your use of our mobile apps with your IHG® One
Rewards Account. It may sometimes be necessary to associate your geolocation
information with your account to support your participation in a particular
program or feature that we may offer, but we do not otherwise retain your
geolocation information in a way that identifies you as an individual.
If you use our mobile app, we also send you push notifications from time-to-time
in order to update you about any events or promotions that we may be running. If
you no longer wish to receive these types of communications, you may turn them
off at the device level. To ensure you receive proper notifications, we will
need to collect certain information about your device such as operating system
and user identification information.
We use mobile analytics software to allow us to better understand the
functionality of our mobile applications on your phone. This software may record
information such as how often you use the application, the events that occur
within the application, aggregated usage, performance data, and where the
application was downloaded from.
ONLINE CHANNELS AND OTHER INFORMATION SOURCES
We may use information from online sources, such as websites, social media and
information sharing platforms. This information may be used to help tailor and
improve our services and communicate with you effectively, as we know many of
our customers use a range of media channels to communicate and disclose
information.
We may use various social media features such as the Facebook “Like” button on
our websites and mobile applications. We collect certain information about you
through your use of these features in conjunction with our services and
programs. Subject to your account and privacy settings, we may also be able to
see information that you post when using these social media platforms whether or
not you are using one of our services. In some instances, depending on the
circumstances, we may contact you on these social media platforms. The
information you post on social media sites as well as the controls surrounding
these disclosures are governed by the respective policies of the social media
site.
Where we use information from these sources, we will respect any permissions you
have set about how you would like your information to be used for each source.
We do not associate the information that we collect through these platforms with
your IHG® One Rewards account.
We recommend you routinely review the privacy notices and preference settings
that are available to you on any social media platforms To learn more about
opting out of certain types of targeted advertising, please see the Managing
cookies and opting out section above.
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USE OF WI-FI SERVICES (IHG CONNECT)
When you use the IHG Connect WI-FI service (IHG Connect), we may collect and
process certain additional information.
WHAT INFORMATION WE COLLECT
* Registration and User-Provided Information: When you register to use IHG
Connect, we may collect personal information about you including your last
name, IHG® One Rewards number, room number and, depending on your location
and applicable law, other personal information (such as mobile phone number).
You may also provide us with personal information about you in various ways
when you use IHG Connect, for example, when you send us customer
service-related requests.
* Device Identifiers. In the course of providing IHG Connect, we may
automatically collect a device identifier (such as your IP address, MAC
address, or device name or other unique identifier) for the computer, mobile
device, technology or other device you use to access IHG Connect. A device
identifier is a number that is automatically assigned to your device when you
access IHG Connect, and we may identify your device by its device identifier.
When you use IHG Connect, we may view your device identifier and use this
information to enhance our service. We may associate your device identifier
with other information about you, such as your IHG® One Rewards number.
* Other device information: We may also automatically record certain
information from your device including, device type, the web pages, apps or
sites that you visit, and the dates and times that you visit, access, or use
IHG Connect (Internet activity information). While generally this information
is pseudonymous and/or aggregated, this information may be associated with
your IHG® One Rewards number and/or other IHG service account information or
persistent identifiers. This data helps us to manage our networks and
provides us with information about the use of IHG Connect. We do not,
however, collect and process the contents of email communications or other
electronic communications you send or receive when using IHG Connect.
* Location information: We may collect information about your location through
your use of the WI-FI services we provide at our hotels to enable us to
improve our service and provide certain services to you such as customized
offers and promotions.
HOW WE USE THE INFORMATION WE COLLECT
We use personal information only for the purposes described in this Privacy
Statement, except if otherwise disclosed to you at the time the data is
collected or otherwise authorized by law or by you. We use the personal
information that we collect through IHG Connect:
* to operate, maintain, enhance and provide all features of the service, to
provide services and information that you request, to respond to comments and
questions and to provide support to users.
* to understand and analyze the usage trends and preferences of our users, to
improve the IHG Connect service, and to develop new products, services,
features, and functionality. If you provide your contact information or your
IHG® One Rewards number, we may (with your consent or where permitted by
applicable law) send you personalized offers based on your web usage and
location. You can opt out of receiving these offers when signing in to use
the IHG Connect service or at any time within your IHG® One Rewards account.
Please see the 'Managing your preferences and information' section below.
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USING PERSONAL INFORMATION TO CREATE PROFILES
Our goal is to create a personalized and customized experience for you when you
stay at an IHG-branded property. In order to determine appropriate advertising
and to customize your experience, as described in the section above in relation
to cookies, we have relationships with companies such as Google and Facebook
which enable us to serve targeted advertising. In addition to the activities
described under the heading Targeted Advertising above, we also match Facebook
and Google users across sites and devices which enables us to better understand
your interests. We use this information to enable us to tailor our marketing
communications to you so we can make sure we tell you about things which are
most likely to be of interest to you. You have options about how we disclose
your information; please log into the preference center at any time to view and
exercise your choices. In addition, certain U.S. state residents may have the
option of clicking on the Do Not Sell or Share My Personal Information link,
which would eliminate the disclosure that might constitute a "sale"/"share"
under applicable law.
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HOW WE SECURE YOUR INFORMATION
We are committed to protecting the confidentiality and security of the
information that you provide to us. To do this, technical, physical and
organizational security measures are put in place to protect against any
unauthorized access, disclosure, damage or loss of your information. The
collection, transmission and storage of information can never be guaranteed to
be completely secure, however, we take steps to ensure that appropriate security
safeguards are in place to protect your information.
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MANAGING YOUR PREFERENCES AND INFORMATION
We want to ensure that you have the necessary tools at your disposal to control
the information that you provide to us, including how we communicate with you.
It is also important that you contact us to update your information if any of it
is inaccurate or changes. Please click the relevant section below to learn more
about how to control how we communicate with you and how to update, modify and
delete your information. EU and UK Data Subjects, please see also the EU and
UK-specific section. U.S. residents, please see also the U.S.-specific section.
Californians, please see also the CA-specific section. Data Subjects located in
Brazil, please see also the Brazil-specific section. Data Subjects located in
PRC, please see also the PRC-specific section.
MANAGING YOUR COMMUNICATION PREFERENCES
Through the provision of the services described above, we, and in some instances
our IHG-branded Hotels, IHG® One Rewards partners, and service providers may
communicate with you in relation to a reservation, as a member of any of our
loyalty programs, through online digital services (e.g. online advertising,
social media communications), or to support any other services that we provide.
In some instances, especially if you are a member of IHG® One Rewards or an
InterContinental Ambassador, you can go to your account, sign in and click on
the “Communication Preferences” section to revise your communication
preferences. IHG® One Rewards members can also contact any of our IHG® One
Rewards Service Centers. Additionally, the option to unsubscribe from marketing
communications will be included within the communication itself. In all other
cases, or if you are having difficulties with unsubscribing from any particular
communication, please contact one of our global customer care offices or the IHG
Privacy Office (details found in the How to contact us section).
Please be aware that unsubscribing from one type of communication may not
unsubscribe you from another type. Likewise, unsubscribing from our
communications may not mean that you are unsubscribed from certain
communications carried out independently by our IHG-branded hotels.
MANAGING YOUR INFORMATION
In the event any information that you provide to us is inaccurate or changes,
you can let us know by contacting one of our global customer care offices. In
some instances, especially if you are an IHG® One Rewards or InterContinental
Ambassador member, you can update certain aspects of your personal information
by going to your account, signing in and clicking on the “Personal Information”
section to update and amend your personal information. For all other cases,
please contact the IHG Privacy Office (details found in the How to contact us
section). We will respond to your request within a reasonable timeframe.
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LINKS TO OTHER SITES
Our websites and applications contain links to websites that are maintained
and/or controlled by non-affiliated parties. In some instances these websites
may be co-branded and display our logos or other trademarks. You can always tell
whether you are on one of our websites by checking the uniform record locator
("URL”) on the page that you are visiting. We encourage you to review the
privacy policies of these websites as their privacy practices may differ from
ours.
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CHILDREN
Our websites are not intended for children and we do not intentionally solicit
or collect personal information from individuals under the age of 18. If we are
notified or otherwise discover that a minor’s personal information has been
improperly collected, we will take all commercially reasonable steps to delete
that information. In limited instances, we may have a campaign or program
targeted toward children. In these instances, details on the information
practices will be presented within the terms and conditions of the program or
campaign.
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RETAINING YOUR INFORMATION IN OUR SYSTEMS
We generally only keep your information for as long as is reasonably required
for the purposes explained in this privacy policy. In some cases we keep
transactional records (which may include your information) for longer periods if
necessary to meet legal, regulatory, tax or accounting needs. We will also
retain information if we reasonably believe there is a prospect of litigation.
We maintain a data retention policy which we apply to the records we hold.
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HOW TO CONTACT US
For any questions or concerns regarding this Privacy Statement or our data
privacy practices, please contact us:
* By email: privacyoffice@ihg.com
* By post:
InterContinental Hotels Group
Attn: Privacy Office
Three Ravinia Drive
Atlanta, Georgia 30346
InterContinental Hotels Group
Attn: Privacy Office
Broadwater Park
Denham, UB9 5HR, United Kingdom
GDPR main establishment in the EU:
InterContinental Hotels Group
Attn: Privacy Office
Thurn-und-Taxis-Platz 6
60313 Frankfurt am Main
Germany
* By phone: 1-770-604-8347
* By fax: 1-770-604-5275
You may also contact our Data Protection Officer by
emailing privacyoffice@ihg.com.
To the extent permitted under the local law, you may also use the above contact
details to request access to, correct, or (in certain circumstances) delete, any
of your personal information that is held by IHG, or, where we have relied upon
your consent to process your personal information, to withdraw your consent to
such processing of your personal information. These requests will be reviewed
and processed in line with the local law.
You also may have a right under the local law to lodge a complaint with us or
with your local data protection supervisory authority at any time. However, we
ask that you please try to resolve any issues with us first before referring
your complaint to the supervisory authority.
In the EU, IHG’s GDPR lead supervisory authority is the Hessen supervisory
authority that can be contacted at:
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit (The
Commissioner for Data Protection and Freedom of Information of Hesse)
Gustav-Stresemann-Ring 1
65189 Wiesbaden
Germany
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ADDITIONAL INFORMATION FOR UK/EU/EEA, U.S., CALIFORNIA, NEVADA, PEOPLE’S
REPUBLIC OF CHINA AND BRAZIL
EU AND UK DATA SUBJECTS RIGHTS UNDER EU AND UK DATA PROTECTION LAWS
EU and UK data subjects have legal rights under EU and UK data protection laws
in relation to your personal information. Click on the links below to learn more
about each right you may have. To exercise any of your rights please use the
forms available in our Privacy and Cookie Center or contact our Data Protection
Officer by emailing privacyoffice@ihg.com.
* To access personal information
You can ask us to confirm whether or not we have and are using your personal
information and for a copy of your information.
* To correct / erase personal information
You can ask us to correct any information about you which is incorrect. We
will be happy to rectify such information but would need to verify the
accuracy of the information first.
You can ask us to erase your information if you think we no longer need to
use it for the purpose we collected it from you. You can also ask us to erase
your information if you have either withdrawn your consent to us using your
information (if we originally asked for your consent to use your
information), or exercised your right to object to further legitimate use of
your information, or where we have used it unlawfully or where we are subject
to a legal obligation to erase your personal information.
We may not always be able to comply with your request, for example where we
need to keep using your information to comply with our legal obligation or
where we need to use your information to establish, exercise or defend legal
claims.
* To restrict how we use personal information
You can ask us to restrict our use of your information in certain
circumstances, for example:
* where you think the information is inaccurate and we need to verify it;
* where our use of your information is not lawful but you do not want us to
erase it;
* where the information is no longer required for the purposes for which it
was collected but we need it to establish, exercise or defend legal claims;
or
* where you have objected to our use of your personal information but we
still need to verify if we have overriding grounds to use it.
We can continue to use your information following a request for restriction
where we have your consent to use it; or we need to use it to establish,
exercise or defend legal claims, or we need to use it to protect the rights
of another individual or a company.
* To object to how we use your information
You can object to any use of your information which we have justified on the
basis of our legitimate interest, if you believe your fundamental rights and
freedoms to data protection outweigh our legitimate interest in using the
information. If you raise an objection, we may continue to use your
information if we can demonstrate that we have compelling legitimate
interests to use the information.
You can also require us to stop using your data for direct marketing
purposes.
* To ask us to transfer your information to another organization
You can ask us to provide your personal information to you in a structured,
commonly used, machine-readable format, or you can ask to have it transferred
directly to another data controller (e.g. another company).
You may only exercise this right where we use your information in order to
perform a contract with you, or where we asked for your consent to use your
information. This right does not apply to any information which we hold or
process that is not held in digital form.
* Right to obtain a copy of personal information safeguards used for transfers
outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which
your personal information is transferred outside of the European Union or the
UK.
We may redact data transfer agreements to protect commercial terms.
We may ask you for proof of identity when making a request to exercise any of
these rights. We do this to make sure that we only disclose information where we
know we are dealing with the right individual. We will not ask for a fee, unless
we think your request is unfounded, repetitive or excessive. Where a fee is
necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us
longer if the request is particularly complicated or you have made several
requests. We will let you know if we think a response will take longer than one
month. To help us respond more quickly, we may ask you to provide more detail
about what you want to receive or are concerned about.
We may not always be able to do what you have asked, for example if it would
impact the duty of confidentiality we owe to others, or if we are otherwise
legally entitled to deal with the request in a different way.
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ADDITIONAL INFORMATION FOR U.S. CONSUMERS
VIRGINIA CONSUMERS
Certain U.S. states including Virginia grant consumers certain rights and impose
restrictions on particular business practices. This section should be read in
conjunction with the information provided in the rest of this Privacy Statement,
and the rights under this section will apply to you to the extent the law
permits and as and when these laws go into effect.
How We Use and Disclose Information We Collect About You
The categories of personal information we collect about U.S. consumers can be
found in the Information we collect and how we use and disclose it section.
Please note our data collection practices set forth below are not different than
those described above; rather, applicable U.S. law specifies that we must
address how these categories are processed in further detail. This section
should therefore be read in conjunction with the further information provided in
the rest of this Privacy Statement.
Please note that the definition of sale differs across states. Given this, when
we use the term “sale,” we mean “the exchange of personal data for monetary
consideration” in Virginia.
Under certain state laws, the manner in which we use cookies may constitute a
“sale.” You may have the right to opt-out of the sale of personal information
depending on how your state defines “sale.”
Consumer Rights
Do Not Sell or Share My Personal Information. Consumers in Virginia have the
right to opt-out of our sale of their personal information. We do not knowingly
collect personal information about consumers that are younger than 18 years nor
do we have actual knowledge that we sell personal information about consumers
that we know are younger than 18 years old.
To exercise your opt-out rights, please visit our Do Not Sell or Share My
Personal Information page. You may also submit a do not sell or share request by
clicking on the link in the footer of this website, or by contacting the Privacy
Office. If you use an authorized agent to submit a do not sell or share request,
we will ask your agent to provide information to demonstrate the agent has your
authorized consent to submit a request. Proof of authorization evidenced by your
signed permission should be submitted to PrivacyOffice@ihg.com. We may also ask
you to provide information to verify your identity directly with us.
Requests for Copy, Deletion and Right to Know. Subject to certain exceptions,
consumers in certain US states including Virginia have the right to make the
following requests, at no charge.
Deletion: the right to request deletion of their personal information that we
have collected about you, subject to certain exemptions. To submit a request to
delete, please fill out the form here.
Copy: the right to request a copy of the specific pieces of personal information
that we have collected about them. To submit a request for a copy of the
specific pieces of personal information we have collected about you, please fill
out the form here.
Right to Know (Collection): where we have collected their personal information,
the right to request that we disclose certain information about how we have
handled their personal information, including: the categories of personal
information collected; categories of sources of personal information; business
and/or commercial purposes for collecting and selling their personal
information; and the categories of third parties/with whom we have disclosed or
shared their personal information. To submit a request to know (collection),
please fill out the form here.
Right to Know (Disclosure and Sale): where we have sold or disclosed for a
business purpose their personal information, the right to request that we
disclose certain information about how we have handled their personal
information, including: the categories of personal information collected;
categories of third parties to whom the consumer’s personal information has been
sold and the specific categories of personal information sold to each category
of third party; categories of third parties to whom personal information has
been disclosed; and the categories personal information that we have disclosed
or shared with a third party for a business purpose. To submit a request to know
(disclosure and sale), please fill out the form here.
Right to Correct: Residents of Virginia may request that we correct inaccurate
personal information that we maintain about you. Upon receipt of a verifiable
request to correct inaccurate personal information, we will take into account
the nature of the personal information and the purposes for which we process it.
We may require documentation from you in order to process your request where we
have reliable documentation showing the accuracy of the information. To submit a
request to correct, please contact the Privacy Office.
Submitting Requests. You can exercise your rights by visiting our Privacy and
Cookie Center or by contacting us at 1 877 424 2449 (toll free). We will respond
to your requests within 45 days, unless additional time is needed, in which case
we will let you know.
When you submit your request, we will take steps to attempt to verify your
identity. We will seek to match the information in your request to the personal
information we maintain about you. As part of our verification process, we may
ask you to submit additional information. Please understand that, depending on
the type of request you submit, to protect the privacy and security of your
personal information, we will only complete your request where we are satisfied
that we have verified your identity to a reasonable degree of certainty.
Authorized Agents. Consumers may designate an authorized agent to exercise their
rights as applicable. If you use an authorized agent to submit a request, we
will ask your agent to provide information to demonstrate the agent has your
authorized consent to submit a request. Proof of authorization evidenced by your
signed permission should be submitted to PrivacyOffice@ihg.com. We may also ask
you to provide information to verify your identity directly with us.
Appeal. If you are a Virginia resident, and you would like to submit an appeal
about our decision to your request regarding your personal information, you may
contact us at PrivacyOffice@ihg.com. We respond to all appeal requests as soon
as we reasonably can and no later than legally required.
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ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS
Under the California Consumer Privacy Act (“CCPA”), we are required to notify
California consumers about our collection, use, disclosure, and retention of
their personal information (whether collected through this website or offline).
To view our retention policy, please see the Retaining your information in our
systems section. In this section of our Privacy Statement, 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 in the table 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 Privacy Statement applies as laws permit, or as these rights apply to you.
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 Statement.
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 (e.g.,
your IHG® One Rewards number if you choose to enroll in the program), IP
address (if you access our websites, emails or other digital channels), email
address 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 (which typically would be information provided to us by IHG-branded
hotels and not information that we collect directly from you).
* 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-branded hotels (that are independently owned and operated). In limited
circumstances, we may obtain this information from carefully selected travel
partners, including airlines and rental car agencies. With regard to internet or
other electronic information, we collect that information automatically as you
use our Site 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, manage your IHG® One Rewards account, 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, including at
your direction, to IHG-branded properties (e.g., if you make a reservation
through our central reservation department, then we disclose that information
with the applicable property so that they can fulfil your request). We also
disclose certain of your information to our carefully selected partners,
including airlines and rental car agencies, for the purpose of personalizing
your stay; for example, if we know that you are arriving early in the morning,
we may seek to offer you an early check-in. If you use our WiFi services at
IHG-branded properties, we disclose certain unique identifiers like your
device’s MAC address with our internet service providers to provide WiFi to you.
Sale and/or share: 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”. We also disclose your
information to carefully selected marketing partners, advertising technology
vendors and social media platforms through a central marketing/analytics
company. We direct which entities may have access to your information and the
scope of information to which they may access. This type of disclosure only
occurs in limited markets and California consumers may opt-out at any time
through our communications portal and by clicking on the Do Not Sell or Share My
Personal Information link on our website/in the mobile app.
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 the following circumstances, by way
of example only: IHG corporate offices and certain IHG-branded hotels use
closed circuit television for security purposes, and, the recordings may capture
such information by virtue of the recording. We do not obtain recordings from
the IHG-branded properties absent a unique situation (e.g., concern for security
at a particular property). You have the option of providing your age range when
you sign up for IHG® One Rewards, but we do not require you to disclose that
information. 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-branded hotels (that are independently owned and operated). In limited
circumstances, we may obtain this information from carefully selected travel
partners, including airlines and rental car agencies.
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 IHG-branded properties (e.g., if you
make a reservation through our central reservation department, then we disclose
that information with the applicable property so that they can 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 and interests of
other persons.
Sale and/or Share: We do not sell this information.
Biometric and Geolocation Information:
Information Collected: In an effort to enhance your stay with us and to provide
for a faster and easier check-in process, we may offer certain services on
property such as check-in and/or room entry through the use of biometric
identifiers at a limited number of IHG-branded properties. Any interested guest
must affirmatively opt-into the program; Where IHG is providing these services
we will provide information about the specific biometrics collected through the
program and the use and disclosure of those identifiers so that you can choose
whether you would like to participate in any particular program. With your
consent, we collect your geolocation information through our mobile application
and our website or from internet service providers through certain services we
offer on property such as IHG Connect (WiFi). We use this information for
analytics purposes (e.g., to determine the general area where our guests may
access our services from), to personalize your experience (e.g., suggest hotels
of interest), and, in certain limited markets, to provide special offers based
on your location.
Sources: We collect biometric information and geolocation information directly
from you and automatically as you use devices designed to collect biometric
information or, in the case of geolocation information, your own device.
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, we
use your information to create a faster check-in and/or room entry experience.
With regard to geolocation information, we also seek to offer you relevant
offers based on your location, where permitted.
Disclosure: Where this service is offered, we may disclose your biometric
information to service providers that assist us in validating your identity. We
may make available your biometric identifier to the IHG-branded property where
you are staying for the purposes of that particular stay.
Sale and/or Share: We do not sell your biometric information.
Inferences
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
properties the consumer prefers, how frequently the consumer travels, etc.). We
may purchase aggregated and deidentified data and append such data to your
profile (e.g., based on your age range) to assist us in determining relevant
marketing opportunities.
Sources: We draw inferences based on the data collection described in this
Notice, and from information received from data brokers.
Purposes of Collection: We use inferences to enhance your overall experience
with IHG. For example, we may use inferences to identify and to offer relevant
marketing opportunities.
Disclosure: We may disclose your information to carefully selected marketing
partners, advertising technology vendors and social media platforms to provide
relevant offers to you.
Sale and/or Share: We may “share” your personal information with data brokers to
better provide personalized service to you, as defined by the CCPA. We direct
which entities may have access to your information and the scope of information
to which they may access. This type of disclosure only occurs in limited markets
and California consumers may opt-out at any time through our communications
portal and by clicking on the Do Not Sell or Share My Personal Information
link on our website/in the mobile app.
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CALIFORNIA CONSUMER RIGHTS
California law grants consumers certain rights and imposes restrictions on
particular business practices as set forth below. California consumers have the
right to request that we disclose what personal information we collect, use,
disclose, and sell about you.
Do Not Sell or Share My Personal Information. California consumers have the
right to opt-out of our sale of their personal information. We do not knowingly
collect personal information about consumers that are younger than 18 years nor
do we have actual knowledge that we sell personal information about consumers
that we know are younger than 18 years old. To exercise your opt-out rights,
please visit our Do Not Sell or Share My Personal Information page. You may also
submit a Do Not Sell or Share My Personal Information request by clicking on the
link in the footer of this website, or by contacting the Privacy Office. If you
use an authorized agent to submit a do not sell or share request, we will ask
your agent to provide information to demonstrate the agent has your authorized
consent to submit a request. Proof of authorization evidenced by your signed
permission should be submitted to PrivacyOffice@ihg.com. We may also ask you to
provide information to verify your identity directly with us.
You may also opt out of the “sale” or “sharing” of your Personal Data via
“online tracking technologies,” such as pixels, web beacons, software developer
kits, third party libraries, and cookies through an opt-out preference signal.
To opt-out in this way, please download and use a browser supporting the Global
Privacy Control (GPC) browser signal. If you choose to use the GPC signal, you
will need to turn it on for each supported browser or browser extension you use.
IHG does not use your sensitive personal information to infer characteristics
about you.
Requests for Copy, Deletion and Right to Know. Subject to certain exceptions,
California consumers have the right to make the following requests, at no
charge, up to twice every 12 months. Please see Submitting Requests for
instructions about how to exercise your rights:
Deletion: the right to request deletion of their personal information that we
have collected about you, subject to certain exemptions. To submit a request to
delete, please fill out the form here.
Copy: the right to request a copy of the specific pieces of personal information
that we have collected about them in the prior 12 months. To submit a request
for a copy of the specific pieces of personal information we have collected
about you, please fill out the form here.
Right to Know (Collection): where we have collected their personal information,
the right to request that we disclose certain information about how we have
handled their personal information in the prior 12 months, including: the
categories of personal information collected; categories of sources of personal
information; business and/or commercial purposes for collecting and selling
their personal information; and the categories of third parties/with whom we
have disclosed or shared their personal information. To submit a request to know
(collection), please fill out the form here.
Right to Know (Disclosure and Sale): where we have sold or disclosed for a
business purpose their personal information, the right to request that we
disclose certain information about how we have handled their personal
information in the prior 12 months, including: the categories of personal
information collected; categories of third parties to whom the consumer’s
personal information has been sold and the specific categories of personal
information sold to each category of third party; categories of third parties to
whom personal information has been disclosed; and the categories personal
information that we have disclosed or shared with a third party for a business
purpose. To submit a request to know (collection), please fill out the
form here.
Right to Correct: California consumers have the right to request that we correct
inaccurate personal information that we maintain about you. Upon receipt of a
verifiable request to correct inaccurate personal information, we will take into
account the nature of the personal information and the purposes for which we
process it. We may require documentation from you in order to process your
request where we have reliable documentation showing the accuracy of the
information. To submit a request to correct, please contact the Privacy Office.
Submitting Requests. You can exercise your rights by visiting our Privacy and
Cookie Center, by contacting us at 1 877 424 2449 (toll free). We will respond
to your Copy, Delete, Right to Know, and Correct requests within 45 days, unless
additional time is needed, in which case we will let you know.
When you submit your request, we will take steps to attempt to verify your
identity. We will seek to match the information in your request to the personal
information we maintain about you. As part of our verification process, we may
ask you to submit additional information, use identity verification services to
assist us, or if you are an IHG® One Rewards member, we may ask you to sign in
to your account as part of our identity verification process. Please understand
that, depending on the type of request you submit, to protect the privacy and
security of your personal information, we will only complete your request where
we are satisfied that we have verified your identity to a reasonable degree of
certainty.
Authorized Agents. The CCPA allows California consumers to designate an
authorized agent to exercise their rights under CCPA. If you use an authorized
agent to submit a request, we will ask your agent to provide information to
demonstrate the agent has your authorized consent to submit a request. Proof of
authorization evidenced by your signed permission should be submitted to
PrivacyOffice@ihg.com. We may also ask you to provide information to verify your
identity directly with us.
Incentives and Discrimination. The CCPA prohibits discrimination against
California consumers for exercising their rights under the CCPA and imposes
requirements on any financial incentives offered to California consumers related
to their personal information.
Discrimination: if consumers exercise their rights under CCPA, businesses may
not discriminate against them including by denying or providing a different
level or quality of goods or services or charging or suggesting that a business
will charge different prices or rates or impose penalties, unless doing so is
reasonably related to the value provided to the consumer by the consumer’s data.
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CALIFORNIA NOTICE OF FINANCIAL INCENTIVE
The IHG® One Rewards program (“Program”), which includes InterContinental®
Ambassador and IHG® Business Rewards, is a loyalty program offered by Six
Continents Hotels, Inc. and its subsidiaries and affiliates, all of which are
referred to herein as IHG.
IHG® One Rewards program. IHG offers guests the opportunity to participate in
the Program which may provide benefits, including free internet, as well as the
opportunity to earn points that can be redeemed for discounted or free stays or
other items, as described in the IHG® One Rewards member benefit chart to those
who choose to join. These benefits may be considered to be financial incentives
under the CCPA and are described along with other material terms and conditions
here.
Information we collect. To join the Program, IHG collects at a minimum, your
first name, last name, address, email address, country/region, city, and zip
code.
IHG may also collect the following additional information from you during the
course of your membership in the Program.
* Your name, email address, home and business address, phone number,
nationality, birthday and payment card information;
* Your membership number and pin or password as well as details of your
memberships with any of our Program partners such as our airline or car
rental partners;
* Information that you choose to provide in your loyalty profile, such as your
personal stay and destination preferences;
* Marketing preferences, including how you prefer to be contacted by IHG as
well as what types of information you are interested in hearing about; and
* Your stays at IHG-branded properties, including the property name, dates of
stay, and, in some circumstances, the total dollar amount of your stay (and,
in some circumstances, an itemized breakdown of your spend at the property).
How we use the information. We use your information to operate and provide
services in connection with our Program in accordance with our IHG® One Rewards
Membership Terms and Conditions. We also use your information to improve our
products and services. Where permitted by applicable law, or where we have your
consent, we also may disclose your information with other parties, including our
loyalty partners and others, to extend special offers about their own products
and services to you.
This may include:
* Enrollment in the loyalty program;
* The order and delivery of merchandise that you have redeemed points for
online, including merchandise and services offered by our IHG® One Rewards
partners;
* Our co-branded credit card partners and Holiday Inn Club Vacations;
* Sending you updates, account statements and other information relating to
your participation in one of our programs or services;
* Sending you marketing communications (which may include text messages or
calls placed using autodialer technology), with your consent where required
by applicable law, in relation to the products and services offered by IHG or
our IHG® One Rewards partners or other partners or affiliates;
* Providing you with personalized advertisements or communications for IHG
and/or other products or services that we believe may be relevant for you;
and
* Analytics, statistical analysis and other research.
Who we disclose your information with: During the course of your participation
in our loyalty programs, we disclose your information as follows:
* Loyalty partners: To provide you with the products and services that you have
requested and, where permitted by law, for the partner to offer its own
products and services to you. We also may choose to partner with another
company to offer a product, such as a co-branded credit card.
* Service providers: for the purposes of operating the program and to provide
you with the products and services that you have requested. We also use
service providers to assist us with managing, carrying out and improving our
advertising. These companies are authorized to use your personal information
only as necessary to provide these services to us.
We may also disclose your information in other circumstances, as fully described
under “If you join one of our loyalty programs” in our Privacy Statement.
Our members can opt-out of sharing their personal information with our partners
for offers and rewards through Communication Preferences in their accounts. Our
California members can also opt-out of the sale of their personal information by
using our Do Not Sell or Share My Personal Information link. If you opt-out, we
will no longer disclose your information with our loyalty partners where such
sharing could be construed as a “sale” under the CCPA.
Opt-in to IHG® One Rewards program. You may opt-in to our Program online,
through the IHG website or mobile app, or when you book a reservation. You may
also be offered to join the Program at the time of check-in.
Value of Consumer’s Data. Solely for the purposes of the CCPA and pursuant to
the valuation methods listed in the CCPA regulations, a good faith estimate of
the value of our consumers’ (members’) data (personal information) to IHG is US
$0.36. This estimate is calculated by dividing the annual value of the revenue
generated from the commercial relationships we have with our loyalty partners
with respect to consumer data, by the number of US members in our Program. This
estimate is not specific to any individual consumer. The actual value to the
consumer of becoming a member of the Program may vary significantly as this will
depend on an individual member’s engagement with the Program.
Withdraw from the IHG® One Rewards program. You have the right to withdraw from
the Program at any time. You may do so by notifying IHG® One Rewards Customer
Care Centre.
Under the CCPA, our California members have the right to delete their personal
information. However, for the purposes of administering the Program benefits to
you, IHG may not be able to delete all of your personal information as long as
you are a member of the Program. To delete your account information, you would
first have to withdraw from the Program.
Metrics on California Consumer Rights Handling
Metrics, such as the number of requests we received, complied with, denied, and
the median or mean number of days within which we substantively responded to
requests, where required for the previous calendar year, will be published here.
Your California Privacy Rights under California’s Shine-the-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California
residents who provide us certain personal information are entitled to request
and obtain from us, free of charge, information about the personal information
(if any) we have shared with third parties for their own direct marketing use.
Such requests may be made once per calendar year for information about any
relevant third party sharing in the prior calendar year. If you are a California
resident and would like to make such a request, please submit your request in
writing to PrivacyOffice@IHG.com. In your request, please attest to the fact
that you are a California resident and provide a current California address.
Contact Us
If you have questions about our privacy practices, would like to make a
complaint, or to request a printable version of this Privacy Statement, please
contact us at PrivacyOffice@ihg.com. This California privacy notice is effective
from January 1, 2020 and was last updated on June 8, 2022.
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NEVADA
Nevada privacy law grants residents of Nevada certain rights and imposes certain
restrictions on particular business practices. To exercise your individual
rights under the Nevada laws, please contact the Privacy Office.
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ADDITIONAL INFORMATION FOR THE PEOPLE’S REPUBLIC OF CHINA (EXCLUDING FOR THE
PURPOSES OF THIS STATEMENT HONG KONG SAR, MACAU SAR AND TAIWAN) (“PRC”)
If there is any inconsistency between the below and the above Privacy Statement,
the following shall prevail in respect of the PRC.
Data controller
For the PRC, Intercontinental Hotel Groups (Shanghai) Co., Ltd., Registered
office: 22nd Floor, Citigroup Tower, No. 33 Huayuanshiqiao Road, China
(Shanghai) Pilot Free Trade Zone, is the data controller. For questions or
concerns related to your personal information or related to the Privacy
Statement, please contact privacyoffice@ihg.com.
Consent
We will obtain your consent (where applicable, separate consent) to collect,
use, share, transfer (including but not limited to overseas transfer), disclose
or otherwise process your personal information if and to the extent required by
the applicable laws.
Sensitive personal information
Certain of the types of personal information described in this Privacy Statement
are considered "sensitive" and, depending on your jurisdiction of work or
residence and applicable law, additional rules will apply in respect of this
personal information. References to personal information in this Privacy
Statement shall be deemed to include reference to sensitive personal information
(if any) where applicable.
“Sensitive personal information” as defined under PRC laws and regulations which
we may collect and use for the purposes described in the above Privacy Statement
may include information relating to:
* payment card information;
* stay records;
* biometric information;
* pin or password;
* your precise geolocation;
* web browsing history
Share and disclose your personal information with another controller
With your consent, we may share and disclose your personal information with
another data controller as explained in the section “Information we collect and
how we use and disclose it” in the Privacy Statement.
International data transfers
As IHG is a global hospitality group, for the purposes described in this Privacy
Statement and in order to provide you with privileged and quality service
worldwide, we may, with your separate consent (if required by applicable laws),
transfer your personal information to IHG affiliated entities outside of
mainland China, such as Six Continents Ltd (UK) (“IHG Foreign Affiliated
Entity”), who will process your personal information for the purposes and in the
manner as described in this Privacy Statement. IHG will take appropriate
measures to ensure that cross-border data transfer and the processing of your
personal information by IHG Foreign Affiliated Entities comply with the
requirements of applicable laws and that such mechanisms are aimed at ensuring
an adequate level of protection as regards your personal information under the
applicable laws. If you wish to exercise your rights with respect to your
personal information with any IHG Foreign Affiliated Entity, you can contact
such entity through the means described in “How to Contact Us” section.
How we store and protect your personal information
We will store your personal information for as long as necessary to achieve the
purposes described in this Privacy Statement and for as long as you use our
services, and as otherwise required by applicable law. We take reasonable
security measures to protect your personal information in accordance with
industry standards and are committed to using various technologies and
initiatives to protect your personal information from unauthorized access, use,
modification, disclosure and damage, such as the use of encryption technology to
protect your personal information. We will deal with personal information
security incidents in accordance with applicable laws and regulations, and
conduct training and dissemination of personal information protection to
relevant personnel to enhance their awareness of the importance of personal
information and responsibilities related to personal information protection.
SDKs and other similar software technologies made available by non-affiliated
entities
Under the PRC laws, IHG is required to disclose SDKs. As a practical matter, the
information described below is captured elsewhere in the privacy statement,
including, in particular, in our description of IHG’s use of cookies. If you
have any questions about which trackers listed in our cookie policies are SDKs,
please contact the Privacy Office.
We use software known as software development kits (SDKs) and other similar
technologies made available by non-affiliated entities on our mobile
applications and mini programs to ensure their stable operation and to provide
the services as described in this Privacy Statement. Please see our SDK list for
more information about our integrated SDKs.
If you are using these features and plug-ins provided by non-affiliated
entities, the privacy policies of these entities may also apply to you. Some of
these entities may collect data from you for their use and processing and may
obtain your consent prior to doing so. In any case, we recommend you read the
privacy policies of these non-affiliated entities to understand how they collect
and process your data before using their features and plug-ins.
Personalized marketing
In order to provide you with personalized advertising, we may collect your
personal information.
You can turn off personalized advertising in our App in “Account”-“Personalized
recommendations”. Once you turn off it, you will not receive any personalized
advertising, including promotional offers and special offers.
Mobile device permissions
If you choose to use certain functions using our mobile app we will ask you for
related permissions to use features on your mobile device to enable this.
When you add a payment method to book a hotel, we will ask you for camera
permission if you choose to add payment information by scanning your payment
card using the camera.
If you choose to add the booking to your calendar after the booking is made, we
will ask you for calendar permission to help you add the booking to your
calendar.
If you choose to use the voice search function when booking a hotel, we will ask
you for microphone permission to allow dictation on your device to enable this.
If you choose to use the function to search for hotels near your location we
will ask you for permission to access your location to enable this.
Your rights
In addition to the rights mentioned in the Privacy Statement, you have the
following rights where permitted by the PRC data protection laws:
* To access your personal information and obtain a copy
You have the right to access or obtain a copy of the personal information we
hold about you.
* To transfer your personal information
You have the right to request transferring your personal information to
another data controller where permitted by the applicable laws.
* To deregister your account
You also have the right to ask us to deregister your loyalty program account
by contacting one of our global customer care offices
* Rights to request deletion and rectification
You can ask us (details found in the How to contact us section) to correct
any information about you which is incorrect. We will be happy to rectify
such information but would need to verify the accuracy of the information
first.
You can ask us to erase your information if you think we no longer need to
use it for the purpose we collected it from you. You can also ask us to erase
your information if you have either withdrawn your consent to us using your
information (if we originally asked for your consent to use your
information), or exercised your right to object to further legitimate use of
your information, or where we have used it unlawfully or where we are subject
to a legal obligation to erase your personal information.
We may not always be able to comply with your request, for example where we
need to keep using your information to comply with our legal obligation or
where we need to use your information to establish, exercise or defend legal
claims.
* Rights to withdraw consent to use mobile device permissions
You can withdraw your authorization or withdraw your consent for mobile
device permissions in your device settings.
To exercise any of your rights above, you may also contact us by emailing
privacyoffice@ihg.com as well.
We aim to respond to all valid requests to exercise the above rights within 15
working days upon verifying your identity. To help us respond more quickly, we
may ask you to provide more detail about your inquiry.
We may not always be able to do what you have asked, for example if it would
impact the duty of confidentiality we owe to others, or if we are otherwise
legally entitled to deal with the request in a different way.
Purchasing product vouchers through IHG WeChat Mini Program
When you purchase a product voucher through our IHG WeChat Mini Program, we will
collect your WeChat OpenID, UnionID, membership number and purchase, redemption,
and refund records. We process your information primarily to attribute your
purchases to you, to show you the status of product redemptions or refunds
status, and to notify you of necessary product information changes. You can
check purchase, redemption, and refund records at any time. We will share your
information with the hotel providing the product voucher to provide you with the
services described in the product voucher. If you decline to provide such
personal information, we will not be able to provide you with the abovementioned
services.
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BRAZIL DATA SUBJECTS RIGHTS UNDER BRAZIL DATA PROTECTION LAW
Brazil data subjects have legal rights under Brazil’s Federal Law nº 13.709/2018
(LGPD), as well as any other applicable laws in relation to your personal
information. To exercise any of your rights please use the forms available in
our Privacy and Cookie Center or contact our Data Protection Officer by emailing
privacyoffice@ihg.com.
* To access personal information
You can ask us to confirm whether or not we have and are using your personal
information and for a copy of your information.
* To correct personal information
You can ask us to correct any information about you which is incorrect,
inaccurate or outdated. We will be happy to rectify such information but
would need to verify the accuracy of the information first.
* To erase / anonymize personal information
You can ask us to erase, anonymize or block your information if you think we
no longer need to use it for the purpose we collected it from you, or if such
data are excessive or are processed in violation of applicable law. You can
also ask us to erase your information if you have withdrawn your consent to
us using your information (if we originally asked for your consent to use
your information).
We may not always be able to comply with your request, for example where we
need to keep using your information to comply with our legal obligations or
where we need to use your information to establish, exercise or defend legal
claims.
* To object to how we use your information
You can object to any use of your information which we have justified on any
legal bases other than consent only in case of infringement of the applicable
law. If you raise an objection, we may continue to use your information if we
can demonstrate that we have a legal basis to continue to use the
information.
* To ask us to transfer your information to another organization
You can ask us to provide your personal information to you or you can ask to
have it transferred directly to another data controller (e.g. another
company.
* Other rights
You may at any time revoke your consent to the processing of your personal
data, whenever you have given it.
You may file a claim before the competent governmental authorities, such as
the national data protection authority.
You can ask us to provide information of any public and private entities with
which we have shared your data.
You may request a review of decisions taken solely on the basis of automated
processing of personal data that affects your interests, including decisions
intended to define your personal, professional, consumer and or aspects of
your personality.
We may ask you for proof of identity when making a request to exercise any of
these rights. We do this to make sure that we only disclose information where we
know we are dealing with the right individual.
We aim to respond to all valid requests within 15 (fifteen) days. It may however
take us longer if the request is particularly complicated or you have made
several requests. We will let you know if we think a response will take longer
than 15 (fifteen) days. To help us respond more quickly, we may ask you to
provide more detail about what you want to receive or are concerned about.
We may not always be able to do what you have asked, for example if it would
impact the duty of confidentiality we owe to others, or if we are otherwise
legally entitled to deal with the request in a different way.
If there is any inconsistency between the rights above and this Privacy
Statement, the above specific rights shall prevail in respect of Brazil.
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CHANGES TO THIS PRIVACY STATEMENT
In some instances, we may have to change, modify or amend this Privacy Statement
in order to comply with the evolving regulatory environment or the needs of our
business. Subject to any applicable legal requirements to provide additional
notice, any changes to this Privacy Statement will be communicated through our
websites and mobile applications. However, if there will be changes made to the
use of your personal information in a manner different from that stated at the
time of collection we will take appropriate steps to notify you, such as by
posting a notice on our website for 30 days prior to the changes taking effect
or by emailing you. We will obtain your consent to such changes where required
to do so by applicable law.
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Effective Date: December 14, 2022
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