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CALIFORNIA CONSUMER PRIVACY ACT STATEMENT

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Last Updated: January 11, 2023

Personal Data We Collect, Disclose, Share, and Sell
Sources of Personal Data
Use Of Personal Data
Retention Period
California Individual Rights
Changes To This CCPA Statement
Privacy Rights Request Metrics
Notice Of Financial Incentive
Contact Us




Pursuant to the California Consumer Privacy Act of 2018, as amended by the
California Privacy Rights Act (collectively, the CCPA), the Marriott Group is
providing the following additional details regarding the categories of Personal
Data (also called “personal information” under the CCPA) about California
residents that we collect, use, and disclose. This CCPA Statement supplements
the Marriott Group Global Privacy Statement.


PERSONAL DATA WE COLLECT, DISCLOSE, SHARE, AND SELL

The following chart details categories of Personal Data about California
residents we collect, as well as categories of Personal Data we have collected
and disclosed for operational business purposes in the preceding 12 months. The
chart also details the categories of Personal Data that we “sell” or “share” (as
defined in the CCPA), including within the preceding 12 months.

For purposes of this CCPA Statement, “sold” or “sale” means the disclosure of
Personal Data for monetary or other valuable consideration but does not include,
for example, the transfer of Personal Data as an asset that is part of a merger,
bankruptcy, or other disposition of all or any portion of our business. For the
categories below, Marriott “sells” or “shares” the data solely for the purposes
of Marketing and Promotion.

Categories of Personal Data Categories of Third Parties to Whom Personal Data
Has Been Disclosed for Operational Business Purposes Categories of Third Parties
to Whom Personal Data Has Been Sold Categories of Third Parties to Whom Personal
Data Has Been Shared for Cross-Context Behavioral Advertising

Identifiers, such as name, nationality, passport, visa or other
government-issued ID, and online identifiers

• Marriott Group

• Service Providers

• Franchisees

• Owners

• Homes and Villas Property Management Companies

• Authorized Licensees

• On-Property or Travel Partners

• Strategic Business Partners

• Third Parties (for purposes of approved Linked Accounts and Promotional
activities)

• Governmental Agencies (if required)

• Marriott Vacations Worldwide
• Credit Card Partners
(Name and Online Identifiers only)
• Advertising Partners

• Advertising Partners

Personal information, as defined in the California safeguards law, such as name,
contact information, government-issued ID, and financial information

• Marriott Group

• Service Providers

• Franchisees

• Owners

• Homes and Villas Property Management Companies

• Authorized Licensees

• On-Property or Travel Partners

• Strategic Business Partners

• Third Parties (for purposes of approved Linked Accounts and Promotional
activities)

• Governmental Agencies (if required)

• Marriott Vacations Worldwide
• Credit Card Partners

• Advertising Partners

Characteristics of protected classifications under California or federal law,
such as gender, age, medical conditions, primary language, national origin,
citizenship, and marital status

• Marriott Group

• Service Providers

• Franchisees

• Owners

• Homes and Villas Property Management Companies

• Authorized Licensees

• On-Property or Travel Partners

• Strategic Business Partners

• Third Parties (for purposes of approved Linked Accounts and Promotional
activities)

• Governmental Agencies (if required)

• Marriott Vacations Worldwide
• Credit Card Partners

• Advertising Partners

Commercial information, such as transaction information, purchase history,
financial details, payment methods, and membership or loyalty program data

• Marriott Group

• Service Providers

• Franchisees

• Owners

• Homes and Villas Property Management Companies

• Authorized Licensees

• On-Property or Travel Partners

• Strategic Business Partners

• Third Parties (for purposes of approved Linked Accounts and Promotional
activities)

• Governmental Agencies (if required)

• Marriott Vacations Worldwide
• Credit Card Partners

• Advertising Partners

Biometric information

• Service Providers
• Governmental Agencies (if required)

N/A – Marriott does not sell this data

N/A – Marriott does not share this data

Internet or network activity information, such as browsing history and
interactions with our and other websites and computer systems

• Marriott Group
• Service Providers
• Governmental Agencies (if required)
• Geolocation data, such as device location and IP location



• Advertising Partners

• Advertising Partners

Geolocation data, such as device location and approximate location derived from
IP address

• Marriott Group
• Service Providers
• Governmental Agencies (if required)

• Advertising Partners

• Advertising Partners

Audio, electronic, visual and similar information, such as images and audio,
video or call recordings created in connection with our business activities

• Marriott Group
• Service Providers
• Governmental Agencies (if required)

N/A – Marriott does not sell this data

N/A – Marriott does not share this data

Inferences drawn from any of the Personal Data listed above to create a profile
or summary about, for example, an individual’s preferences and characteristics

• Marriott Group
• Franchisees
• Owners
• Homes and Villas Property Management Companies
• On-Property or Travel Partners
• Governmental Agencies (if required)

• Credit Card Partners
• Advertising Partners

• Advertising Partners

Sensitive Personal Data

• Personal Data that reveals an individual’s Social Security, driver’s license,
state identification card, or passport number; account log-in, financial
account, debit card, or credit card number in combination with any required
security or access code, password, or credentials allowing access to an account;
precise geolocation; racial or ethnic origin, religious or philosophical
beliefs, citizenship, immigration status, or union membership; the contents of
mail, email, and text messages unless the Marriott Group is the intended
recipient of the communication; genetic data;

• The processing of biometric information for the purpose of uniquely
identifying an individual;

• Personal Data collected and analyzed concerning an individual’s health;

• Personal Data collected and analyzed concerning an individual’s sex life or
sexual orientation

• Marriott Group
• Service Providers
• Governmental Agencies (if required)

N/A – Marriott does not sell this data

N/A – Marriott does not share this data

We may also disclose the above categories of Personal Data to a third party in
the context of any reorganization, financing transaction, merger, sale, joint
venture, partnership, assignment, transfer, or other disposition of all or any
portion of our business, assets, or stock (including in connection with any
bankruptcy or similar proceedings).


SOURCES OF PERSONAL DATA

Marriott acquires the Personal Data listed above directly from you, as well as
from other sources, including through Online Services, Property Visits and
Offline Interactions, Customer Care Centers, Owners and Franchisees, Homes and
Villas Property Management Companies, Authorized Licensees, Strategic Business
Partners, Internet Connected Devices, Public Databases, and Joint Marketing
Partners (Capitalized terms in this paragraph as used throughout this CCPA
Statement are further defined in the Marriott Group Global Privacy Statement).


USE OF PERSONAL DATA

Marriott collects, uses, sells, shares, or otherwise discloses the Personal Data
listed above (apart from Sensitive Personal Data) to operate, manage, and
maintain our business, to provide our products and services, for vendor
management purposes, and to accomplish our business purposes and objectives,
including, for example, using Personal Data to: develop, improve, and maintain
our products and services; personalize, advertise, and market our products and
services; conduct research, analytics, and data analysis; maintain our
facilities and infrastructure; undertake quality and safety assurance measures;
conduct risk and security control and monitoring; detect and prevent fraud;
perform identity verification; perform accounting, audit, and other internal
functions, such as internal investigations; comply with law, legal process, and
internal policies; maintain records; and exercise and defend legal claims.

We may use Sensitive Personal Data for purposes of performing services for our
business, providing goods or services as requested by you, ensuring security and
integrity, fulfilling short-term transient uses, such as displaying first party,
non-personalized advertising, order processing and fulfillment, servicing
accounts, providing customer service, verifying customer information, processing
payments, providing financing, and for activities relating to quality and safety
control or product improvement.

We do not knowingly “sell” or “share” the Personal Data, including the Sensitive
Personal Data, of individuals under the age of 16.


RETENTION PERIOD

We retain Personal Data for as long as needed or permitted in light of the
purpose(s) for which it was collected.  The criteria used to determine our
retention periods include:  

• The length of time we have an ongoing relationship with you and provide the
Services to you (for example, for as long as you have an account with us or keep
using the Services and for as long as necessary to satisfy the terms of the
Bonvoy program) 

• Whether there is a legal obligation to which we are subject (for example,
certain laws require us to keep records of your transactions for a certain
period of time before we can delete them) 

• Whether retention is advisable considering our legal position (such as, for
statutes of limitations, litigation or regulatory investigations)


CALIFORNIA INDIVIDUAL RIGHTS

Overview of California Individual Rights

If you are a California resident, you may make the following requests:

Request to Know. You may request that we disclose to you the following
information: 

• The categories of Personal Data we collected about you and the categories of
sources from which we collected such Personal Data;

• The specific pieces of Personal Data we collected about you;

• The business or commercial purpose for collecting, selling, or sharing (if
applicable) Personal Data about you;

• The categories of Personal Data about you that we sold or “shared” and the
categories of third parties to whom we sold or “shared” such Personal Data (if
applicable); and

• The categories of Personal Data about you that we otherwise disclosed, and the
categories of third parties with whom we disclosed such Personal Data (if
applicable).

 

Request to Delete. You may request that we delete the Personal Data we collected
from you.

Request to Correct. You may request that we correct inaccuracies in your
Personal Data.

Request to Opt-Out of Sale and/or Sharing. You may request to opt-out of the
“sale” and/or “sharing” (for cross-context behavioral advertising purposes) of
your Personal Data.

How You Can Request to Know, Delete, Correct, or Opt-Out of Sale and/or Sharing
of Your Personal Data

To make a Request to Know, Delete, or Correct, please contact us via this form
or 1-800-218-9316. We may request information from you in order to verify your
request, such as your name, email address, postal address, phone number, or
loyalty number, and then use that information to match it with information we
already have. We may also ask you for additional identifiers such as your date
of birth or the last four digits of your credit card if we need additional
information to verify your identity. We will respond to your request consistent
with applicable law.

To make a Request to Opt-Out of Sale and/or Sharing, click here or call
1-800-218-9316.

You have the right to be free from unlawful discrimination for exercising your
rights under the CCPA.

Authorized Agents: If you would like an authorized agent to submit a request on
your behalf, the agent may do so by using the submission methods noted above.
Upon receipt of a Request to Know, Delete, or Correct by an agent, Marriott will
ask the California resident for written, signed permission that the agent has
been authorized by the resident to act on their behalf. Once written
authorization is provided, Marriott will open a request for the resident in the
portal. Marriott will respond directly to the individual email address provided
by the authorized agent regarding the fulfillment of the request, and not in a
platform or portal.


CHANGES TO THIS CCPA STATEMENT

We may change or update this CCPA Statement from time to time.  When we do, we
will post the revised CCPA Statement on this page with a new “Last Updated”
date. 



PRIVACY RIGHTS REQUEST METRICS


Between January 1 and December 31, 2021, Marriott received the following
requests from consumers identifying themselves as California residents:

Request Type Consumer
Requests
Received Verified
Consumer
Requests
Completed in
Whole or in Part Verified
Consumer
Requests Denied Mean Number of
Days to
Substantively
Respond to
Verified
Consumer
Requests
Requests to
Know
153
49
0
30
Requests to
Delete
316
78
0
18
Requests to Opt-
Out of Sale
143,337
39,108
0
1

 

NOTICE OF FINANCIAL INCENTIVE

The CCPA’s implementing regulations define a “financial incentive” as a program,
benefit, or other offering “related to the collection, deletion, or sale of
personal information.” Marriott International offers guests the opportunity to
participate in the Marriott Bonvoy Loyalty Program (the “Program”), which may
provide benefits, including discounted rates on stays, as well as the
opportunity to earn points that can be redeemed for discounted or free stays or
other items, to those who choose to join. Those benefits are described along
with other material terms and conditions here. Our collection of members’
Personal Information (including name, zip code, email address, and other
Personal Information as described above under “Information We Collect”) allows
Marriott to operate the Program and provide membership benefits. Marriott uses
the Personal Information of Program members, including their stay details, to
both award and redeem points. Otherwise, the types of Personal Information that
we collect from Program members are generally similar to the types of Personal
Information that we collect from individuals who are not Program members. The
amount of Personal Information that we collect from a member or non-member may
vary and is dependent on the level of interactions and engagement that the
member or non-member has with Marriott.

Marriott seeks to ensure that both members and non-members have a memorable and
enjoyable experience when staying at a Marriott hotel. For this reason, in
connection with a hotel stay, Marriott may collect information from both members
and non-members related to their personal preferences, as described in the
section titled “The Data We Collect” in the Marriott Group Global Privacy
Statement. Program members have the ability to organize their Personal
Information and preferences as part of their Program profile. For example, a
Program profile may include address, phone, month and day of birth, and gender,
as well as room options, stay preferences, and communication preferences. 

Marriott may also collect Personal Information about Program members through its
Partner Programs, as defined in Marriott’s Loyalty Program Terms & Conditions,
as well as through Linked Accounts, such as with airline frequent flyer programs
or retail or cruise partners, as explained in the Marriott Group Global Privacy
Statement. When a Program member engages with a Partner Program or has a Linked
Account, Marriott receives information necessary to facilitate point redemptions
or earnings.

Marriott "sells," as the term is defined under the CCPA, Personal Information of
both Program members and non-members to Marriott Vacations Worldwide (MVW) and
to third party marketing partners for the purposes of online advertising, as
disclosed above in this California Consumer Privacy Act Statement. Marriott also
“sells” the Personal Information of Program members (but not non-members) to its
co-branded credit card partners for purposes of marketing. The categories of
Personal Information sold to these third parties are disclosed in
Marriott’s California Consumer Privacy Act Statement, above, under the section
titled "Category of Personal Information Sold."

When a Program member purchases a timeshare property from MVW, Marriott receives
information from MVW so that the MVW Owners can receive various program
benefits, including Elite Status Upgrades, Elite Night Credits for their
timeshare stays, and the ability to convert their timeshare interest into
Program points. In addition, Personal Information received from Marriott’s
credit card partners may include information for servicing and facilitating the
Program member’s point earnings through use of the credit card. Marriott may
also receive the member’s category level spend (e.g., how much the member spent
on groceries) and information that may assist in presenting relevant ads to our
members and non-members.     

If you are a California resident and opted out of our “sale” of your Personal
Information before you joined the Program, you will need to opt out again once
you are a member, if you do not wish for Marriott to “sell” your Personal
Information. To do so, click on “Your Privacy Rights” or call 1-800-218-9316.

We estimate the value of a member’s Personal Information to Marriott
International, solely for purposes of the CCPA and pursuant to the valuation
options mandated by the CCPA regulations, to be on average approximately $0.42
per consumer in 2021. This estimate is not specific to any individual consumer
and varies per consumer. We have based this good-faith estimate on the value
that arises from our commercial relationships and the collection and retention
of the Personal Information of consumers who have voluntarily signed up and
chosen to remain in the Program. The value of Program benefits to members varies
significantly as individual members take advantage of Program benefits to
varying degrees.

You may join the Program on our website, at a participating property, or through
another enrollment channel in line with the Bonvoy Program Terms & Conditions.

Members who are California residents may exercise their CCPA rights (i.e., the
rights to know, to request deletion, and to opt out of the sale of Personal
Information) without any effect on their membership status or eligibility to
receive rewards, and Program members who exercise their privacy rights under the
CCPA receive the same benefits as members who do not. A member may also choose
not to receive marketing updates or offers at any time without any effect on
their membership status or eligibility to receive Program benefits.

You may cancel your membership at any time by notifying Member Support at:

Marriott Guest Services
910 West Legacy Center Way, Suite 100
Midvale, UT 84047

Or by fax to: 1-801-468-4033.
Or by visiting: How Can I Cancel My Marriott Bonvoy® Account


CONTACT US

If you have questions or concerns about this Privacy Statement, you may contact
us at privacy@marriott.com, or by mail:

Marriott International, Inc.
Global Compliance, Privacy
7750 Wisconsin Avenue
Bethesda, MD 20814



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