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Privacy Notice
Effective: January 1, 2023
Last updated: January 6, 2023
Sonesta International Hotels Corporation (collectively with our subsidiaries,
“Sonesta,” “we,” “us,” “our”) provides this Privacy Notice (“Privacy Notice”)
describing important information about how we collect, use, and disclose your
personal data in the following circumstances:
* \Through the websites or mobile applications we own and control that link to
this Privacy Notice (the “Online Services”),
* Through the social media pages we control, emails that we send, and other
direct marketing activities (“Marketing Activities”),
* Through our interaction with business contacts in the context of their
relationship with us (“Business Contact Activities”),
* When you visit one of the properties we own, operate, franchise, or license
and through other in-person interactions with you (“Offline Activities”).
When we use the term “Services” in this Privacy Notice, we collectively refer to
the Online Services, Marketing Activities and Offline Activities.
When we use the term “Guests” in this Privacy Notice, we mean the users of and
visitors to the Services. Employees, contractors, and job applicants who are
California residents receive a supplemental privacy notice that applies to their
relationship with Sonesta in the context of their employment, engagement, or job
application. In the event of any conflict with this Privacy Notice, the terms of
the supplementary employee notice will control.
When we use the term “personal data” we mean any information that identifies an
individual person or reasonably relates to an identifiable individual.
What Personal Data We Collect
1. Personal data – We collect personal data about our Guests so that we can
provide an experience that is responsive to your needs and to enhance our
offerings to you and our other customers, including:
* Name
* Postal address
* Email addresses
* Telephone numbers
* IP Address and other online identifiers
* Credit card information and other payment data
* Financial information, in limited circumstances
* Account information, such as username and password
* Gender or gender expression
* Health information, from Guests with particular health concerns that they
have shared with us
* Lifestyle information, such as room preferences and other information
necessary to fulfill special requests (e.g., medical conditions that require
room accommodations)
* Date of birth
* Nationality, passport, visa, or other government-issued identification
information
* Visual information captured through CCTV cameras at our facilities
* Job title and employment affiliations
* Employer details
* Travel itinerary, tour group, or activity data
* Guest preferences and personalized data, such as your communications and
language preferences, travel habits and preferences, food and beverage
preferences, interests, activities, hobbies, prior stays or interactions,
goods and services purchased, special service and amenity requests, and
important dates (such as birthdays, anniversaries and special occasions)
* Social media account ID, profile photo, and other data publicly available, or
data made available by linking your social media and loyalty accounts
* Information about family members and companions, such as names and ages of
children
* Images, video, and audio data via security cameras and security personnel
body cameras
* Geolocation information
2. Other Data – We collect other data about you, including:
* Information regarding your use of our Online Services, including browser and
device data, and data collected through cookies, pixel tags, and other
technologies (these practices are more fully described below in the “Cookie
Notice” section)
* Demographic data and other data provided by you
* Aggregated data relating to your stays
How We Collect Personal Data
1. Online Services and Marketing Activities – We collect Personal Data through
our Online Services and Marketing Activities when you:
* Research and book a reservation
* Purchase products or services
* Make a customer service request
* Respond to a survey
* Subscribe to our newsletters
* Register for our loyalty program
* Update your contact information
* Participate in a competition, promotional activity, or sweepstakes
* Provide a testimonial, story, review, or comment
* “Like,” “Follow,” or otherwise connect with or post to one of our social
media pages
* Interact with an email we send
2. Offline Activities – We collect Personal Data during your visits to
properties we own, operate, franchise, or license, and through other in-person
interactions when you:
* Purchase or use on-site products and services, such as restaurants and bars,
fitness centers, and concierge services
* Attend promotional events that we host or in which we participate, or when
you provide your personal data to facilitate an event.
3. Business Partners – We collect Personal Data from companies with whom we
partner to provide you with products, services, or offers based upon your
experiences at our properties or that may be of interest to you. These business
partners are independent from Sonesta. Examples of our business partners
include:
* Owners, franchisees, and licensees
* On-property retail and food and beverage outlets
* Travel agents and tour operators
* Time share partners
* Rental car providers
* Travel booking platforms
4. Other Sources – We collect personal data from other sources, such as public
databases, joint marketing partners, Guest devices that are connected to Wi-Fi
we provide, and other third parties.
5. Internet-Connected Devices – We collect personal data from internet-connected
devices available in our properties. For example, a smart home assistant may be
available for your use at one of our properties that you visit.
6. Physical & Mobile Location-Based Services – We collect personal data if you
download one of our mobile applications (for example, we may collect the precise
physical location of your device). We collect this data if you opt in through
the app, either during your initial login or later, to receive the special
offers and to enable location-driven capabilities on your mobile device. If you
have opted-in, the app will continue to collect location data when you are in or
near a participating property until you log off or close application, or if you
use your device’s setting to disable location capabilities for the app.
Why We Collect Personal Data
We collect the personal data above about our Guests so that we can provide an
experience that is responsive to your needs and to enhance our offerings to you
and our other customers. More specifically, we use the information in
connection with the following:
* Our business transactions with you, including, but not limited to:
* Fulfilling bookings
* Entering into a contract with you
* Responding to your inquiries and fulfilling your requests
* Sending administrative information to you (for example, information
regarding the Services or an event you are attending)
* Completing and fulfilling any purchases or requests for services
* Our legitimate business interests, including, but not limited to:
* Providing any other specific products, services, and information you
request from us (such as participation in our loyalty programs)
* Providing you our newsletter, surveys, and other marketing and
informational materials regarding our properties, products, and services
(subject to your opt out right described in the “Opt Out” section below)
* Personalizing your experience on the Services by presenting products and
offers tailored to you
* Allowing you to participate in sweepstakes, contests, and similar
promotions, and to administer these activities (each of which may have
additional rules and could contain additional information about how we
process your personal data)
* Facilitating social sharing functionalities of your social media accounts
* Carrying out data analysis, audits, fraud monitoring and prevention,
internal quality assurance, developing new products, enhancing, improving
or modifying our Services, identifying usage trends, auditing use and
functionality of our Services, helping enforce compliance with our Terms of
Use, helping protect our Services, determining the effectiveness of our
promotional campaigns, and operating and expanding our business activities
* Allowing you to send messages to a friend through the Services. By using
this functionality, you are telling us that you are entitled to use and
provide us with your friend’s name and email address
* Fulfilling any other purpose for which you provide your personal data or
which we disclose to you at the time of disclosure
* Any consent you may have provided, including, but not limited to
accommodating special requests due to health conditions.
* We will make it clear to you in advance that we are relying on your consent
(for example, when you sign up to our mailing list), and you have the right
to decline to provide your consent and, if consent is provided, to withdraw
your consent at any time
* As necessary or appropriate for legal reasons, including, but not limited to:
* To comply with our legal obligations
* To comply with legal process
* To respond to requests from public and government authorities, including
those outside your country of residence
* To enforce our terms and conditions
* To protect our operations or those of any of our affiliates and other third
parties
* To protect our rights, privacy, safety, or property, or that of our
affiliates, you, or other third parties, including to support and enhance
our data security
* To allow us to pursue available remedies or limit damages we, our
affiliates, or other third parties, may sustain
How We Share and Disclose Personal Data
1. To Whom We Disclose Personal Data for a Business Purpose
* In the course of processing your personal data in connection with fulfilling
bookings and providing other products and services you obtain from us, it may
be necessary to transfer your personal data to:
* Our affiliates (for example, we share loyalty program data)
* Our owners, franchisees, and licensees (for example, we share reservation
data)
* Payment processors and/or third-party service providers located in the
United States and throughout the world for the purposes outlined in this
Privacy Notice
* Business partners, sponsors, and other third parties
* Unless otherwise precluded or governed by legal requirements, we do not grant
permission to any of our affiliates, property owners, franchisees, licensees,
or third-party service providers that may receive your information to use
such information independent of use in connection with our products and
services, consistent with this policy.
* Reservations made via our websites (but not our call centers) are processed
by Sabre, Inc., a third party. Personal data disclosed during the
reservation process via our websites will be subject to this Privacy Notice,
and, with respect to Sabre’s holding, use, and retention of such information,
shall be subject to Sabre’s privacy policy (as may be updated from time to
time) displayed on Sabre’s website, which is accessible
at http://www.sabre.com.
* Except for the disclosure noted above regarding affiliates, properties,
franchises and licenses, payment processors and third-party service
providers, and except as disclosed below, our practice is to not provide
access to, sell, rent, or otherwise give physical possession of your personal
data to other parties.
2. When We Disclose Your Personal Data – Situations in which we may disclose
your personal data, any communications sent to or received from you, and other
information that we may have relating to you, are:
* When we have received your consent to do so
* When a hotel or other property leaves the Sonesta system and access to your
personal data is necessary to facilitate business operations or meet
contractual obligations
* To comply with legal or regulatory requirements or obligations in accordance
with applicable law, including pursuant to a court order, subpoena,
discovery, investigation, or similar action
* In case of emergency, if we believe it helpful in order to safeguard the
life, health, or property of an individual
* If reasonably necessary to protect or enforce our property and rights,
including to prevent, investigate, identify persons or organizations
potentially involved in, or take any action regarding suspected fraud,
violations of our terms of service, or activity that appears to us to be
illegal or may expose us to legal liability, and
* In the event we merge with, or sell, or have a change of control of all or
part of our business to a third party, to the acquirer of such business.
3. If information is shared as mentioned above, we reasonably seek to limit the
scope of information that is furnished to the amount necessary for the specific
circumstances.
Cookie Notice
We collect other data using cookies and related data collection technologies
(“Cookies”) to provide our Online Services engage in Marketing Activities,
gather information when users navigate through our websites to enhance and
personalize the experience, to understand usage patterns, and to improve our
websites, products, and Services.
* Cookies on our websites are generally divided into the following categories:
* Essential Cookies: These cookies are strictly necessary to provide you with
services available through our Online Services and to use some of their
features, such as access to secure areas. Because these cookies are
strictly necessary to deliver the Online Services, you cannot refuse them
without impacting how our Online Services function.
* Performance and Functionality Cookies: These cookies are used to enhance
the performance and functionality of our Online Services but are
non-essential to their use. However, without these cookies, certain
functionality may become unavailable.
* Analytics and Customization Cookies: These cookies collect information that
is used to help us understand how our Online Services are being used or how
effective our marketing campaigns are, or to help us customize our Online
Services for you in order to enhance your experience.
* Targeting Cookies: These cookies record your visit to our Online Services,
the pages you have visited and the links you have followed to recognize you
as a previous visitor and to track your activity on our websites and other
websites you visit. These cookies qualify as persistent cookies, because
they remain on your device for us to use during a next visit to our
websites. You can delete these cookies via your browser settings. See
below for further details on how you can control third-party targeting
cookies.
* Pixels & Beacons: These technologies count how many people visit certain
web pages. Information collected from invisible pixels is used and
reported in the aggregate and does not contain personal data. We may use
this information to improve marketing programs and content.
* We also allow third parties to use Cookies on our Online Services to collect
information about your online activities over time and across different
websites you visit. This information is used to provide advertising tailored
to your interests on websites you visit, also known as interest-based
advertising, and to analyze the effectiveness of such advertising.
* How to control Cookies:
* You can review your Internet browser settings, typically under the sections
“Help” or “Internet Options,” to exercise choices you have for certain
Cookies. If you disable or delete certain Cookies in your settings, you
may not be able to use features of the Online Services.
* To learn more about the use of Cookies by Google for analytics and to
exercise choice regarding those Cookies, please visit the Google Analytics
Opt-out Browser Add-on.
* We support the Self-Regulatory Principles for Online Behavioral Advertising
of the Digital Advertising Alliance (“DAA”). To learn more about certain
third-party Cookies used for interest-based advertising, including through
cross-device tracking, and to exercise certain choices regarding such
cookies, please visit the Digital Advertising Alliance, Network Advertising
Initiative, Digital Advertising Alliance-Canada, European Interactive
Digital Advertising Alliance [MB1] or your device settings if you have the
DAA or other mobile app.
* The opt-outs described above are device- and browser-specific and may not
work on all devices. If you choose to opt-out through any of these opt-out
tools, this does not mean you will cease to see advertising. Rather, the
ads you see will just not be based on your interests.
Other Information
1. Links to Other Web Sites – In some cases, our Online Services contain links
to websites operated and maintained by third parties over which we have no
control. When you connect to such website, you leave our Online Services. You
should always read the privacy policy on these sites prior to transmitting any
personal data since we cannot verify or be responsible for information not
maintained by us. You connect to these sites at your own risk.
2. Social Media Sites – We are not responsible for the collection, usage, and
disclosure policies and practices (including data security) of other
organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app
developer, app provider, social media platform provider, operating system
provider, wireless service provider, or device manufacturer, including any
personal data you disclose to other organizations through or in connection with
our mobile applications or our Marketing Activities.
3. Protecting Minor Children – Except as noted below, we do not seek to obtain
nor do we wish to receive personal data directly from minors; however, we cannot
always determine the age of persons who access and use our Online Services. If
a minor (as defined by applicable law) provides us with their data without
parental or guardian consent, we encourage the parent or guardian to contact us
to have this information removed and to unsubscribe the minor from our future
marketing communications.
Exceptions to this are:
* The names and ages of minors staying in rooms under reservations booked by an
adult, whose names are recorded
* Our properties have, from time-to-time, programs and services directed at
children, such as our “Just for Kids” and similar supervised children's
services, for which email, contact information, and age may be acquired from
minors aged 13 and over (such minimum age subject to appropriate adjustment
in each jurisdiction to comply with law)
4. Information Provided on Someone Else’s Behalf – If you provide us with
information about someone else, please ensure you have the person’s permission
to do so for the purposes detailed in this Privacy Notice.
Communications, Opt In, and Opt Out
1. Our intention is that you should only receive email communications that you
request, or that you will find useful. We may periodically contact you to
provide information on:
* Upcoming or past reservations
* Travel Pass account information
* General hotel or corporate informational updates
* To ask for your feedback on our service
2. This communication is typically via email, though it may be by phone or
direct mail (particularly with respect to upcoming reservations). We may also
send promotional emails with special offers that may be of interest to you
(unless you have opted out).
3. Through various means, you may opt in or sign up to receive promotional
emails from us. All of our promotional emails give you the option to opt out at
any time by clicking on a link at the bottom of the email. You may also opt out
of any future promotional emails by emailing your request
to: emailoptout@sonesta.com. Please allow 10 business days for your email opt
out request to take effect.
4. You may choose not to submit your personal data by submitting your request by
calling our Compliance Hotline at 855.251.0649. However, doing so may cause
certain transactions to become affected. For example, not providing a name will
prevent the processing of reservations.
Security
We seek to take steps to protect the information you provide us from loss,
misuse, and unauthorized access, disclosure, alteration, and destruction. We
have implemented physical, electronic, and managerial procedures to help
safeguard and secure your information from loss, misuse, unauthorized access or
disclosure, alteration, or destruction. Unfortunately, no security system is
100% secure, thus we cannot guarantee the security of all information you
provide to us via the Services.
Your Rights; Region-Specific Disclosures
Individuals in certain jurisdictions may have certain rights with respect to
their personal data. These may include the right to access your personal data,
to request corrections to your personal data if it is inaccurate, to ask us to
erase your personal data, or to restrict or object to the processing of your
personal data.
If you make a request related to personal data about you, we may need to verify
your identity. You may submit a request using the means described under the
“Contact Us” section below.
If you are a resident of the European Economic Area, the United Kingdom, or the
state of California or Virginia, please follow the below links for additional
information:
1. European Economic Area or United Kingdom – For individuals in the European
Economic Area or the United Kingdom, please click here for additional detailed
disclosures (“EEA and UK Disclosures”).
2. California and Virginia – For California and Virginia residents, please click
here for additional detailed disclosures (“State Privacy Disclosures”).
Policy Changes
At times our Privacy Notice may be changed and any updates will be posted to
this site. If material changes are made to this Notice, we will post a notice to
the revised policy on the homepage of this site for at least thirty (30) days.
Any changes that are made will go into effect when posted on the site and they
will apply to all users of our Services. We encourage you to check this policy
periodically for updates.
Contact Us
If you have any questions about this Policy, or any concerns or complaints with
regard to the administration of the Policy, please contact us by any of the
following means:
* by calling our Compliance Hotline at 855.251.0649
* by mailing a written description of your concern or complaint to:
Sonesta International Hotels Corporation
Chief Compliance Officer,
400 Centre Street
Newton, MA 02458
* by emailing to privacyinquiries@sonesta.com
APPENDIX A: ADDITIONAL INFORMATION FOR EEA AND UK RESIDENTS
These disclosures (the “EEA and UK Disclosures” or “Disclosures”) supplement the
Sonesta Privacy Notice.
The Disclosures apply only to our processing of personal data within the scope
of the General Data Protection Regulation and/or the UK GDPR and the UK Data
Protection Act 2018 (together, the “GDPR”) from one or more of the European
Union Member States plus Iceland, Lichtenstein, and Norway (together known as
the “European Economic Area” or “EEA”) or the United Kingdom (“UK”), as
applicable.
Data Retention
1. We will retain your personal data for the period necessary to fulfill the
purposes outlined in the Sonesta Privacy Notice unless a longer retention period
is required or permitted by law.
2. 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)
* 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)
International Transfers
We are an international company and we may, subject to applicable law, transfer
your information to our affiliates or selected third parties outside the country
where you are located and where information protection standards may differ
(e.g., your information may be stored on servers located in other
jurisdictions). We will utilize appropriate safeguards governing the transfer
and usage of your personal data, such as an adequacy decision by the European
Commission, Standard Contractual Clauses, or other applicable adequacy
mechanisms. If you would like further detail on the safeguards we have in
place, you can contact us directly as set forth in the “Contact Us” section
below.
Data Subject Rights
Individuals whose personal data we process subject to the GDPR have certain
rights, where applicable, as required by law, including the right of access,
erasure, and data portability, as well as the right to rectification, to
restrict processing, to withdraw consent, and to object to processing as
follows.
1. Access – Individuals have the right to know if we are processing personal
data about them and, if so, to access and obtain a copy of personal data about
them, as well as information relating to the processing of that data.
2. Rectification – Individuals have the right to have us correct or update any
personal data about them that is inaccurate or incomplete without undue delay.
3. Restriction – Individuals have the right to restrict or limit the ways in
which we process personal data about them where the accuracy of the personal
data is contested by them, where data has been obtained by us unlawfully, where
the individual has objected to our processing of the data (see right of
objection below) and we are considering whether to cease processing, or where we
no longer need to process the personal data.
4. Objection – Individuals have the right to object to our processing of their
personal data where we are relying on legitimate interests as our legal basis
and their rights override our legitimate interests in processing their personal
data. Individuals also have the right to object to our processing of their
personal data for direct marketing purposes.
5.Withdrawal of Consent – Where we rely on consent as the basis for processing
personal data, individuals have the right to withdraw their consent.
6. Erasure – Individuals have the right to request deletion or erasure of their
personal data in a number of circumstances where required by law. These include
where we no longer require the personal data for the purposes for which it was
collected, the individual has withdrawn consent, or where we are relying on
legitimate interests as a legal basis and the individual’s rights override our
legitimate interests.
7. Portability – Individuals have the right to obtain a copy of the personal
data we hold about you in a structured machine-readable format and to have it
transmitted to another controller. This right only occurs where we are relying
on your consent or performance of a contract as our legal basis and the
processing is carried out automatically.
8. Make a Complaint – Individuals also have the right to make a complaint about
our personal data handling practices to their local Supervisory Authority. We
would, however, appreciate the opportunity to address your concerns directly if
possible, and ask you to please contact us in the first instance.
Changes to EEA and UK Disclosures
At times our EEA and UK Disclosures may be changed and any updates will be
posted to this site. If material changes are made to this Notice, we will post a
notice to the revised policy on the homepage of this site for at least thirty
(30) days. Any changes that are made will go into effect when posted on the
site and they will apply to all users of our Services. We encourage you to
check this policy periodically for updates.
Contact Us
To assert one of your legal rights described in these EEA and UK Disclosures, or
if you have any questions about these EEA and UK Disclosures or our data
handling practices, please contact us by any of the following means:
* by calling our Compliance Hotline at 855.251.0649
* by mailing a written description of your concern or complaint to:
Sonesta International Hotels Corporation
Chief Compliance Officer,
400 Centre Street
Newton, MA 02458
* by emailing to privacyinquiries@sonesta.com.
APPENDIX B: ADDITIONAL INFORMATION FOR CALIFORNIA AND VIRGINIA RESIDENTS
These disclosures (the “State Privacy Disclosures”) supplement the Sonesta
Privacy Notice. If you are a California or Virginia resident, then this section
of our Privacy Notice may apply to you. This section is intended to describe our
practices under the California Consumer Privacy Act of 2018 as amended by the
California Privacy Rights Act of 2020 (together, the “CCPA”) and the Virginia
Consumer Data Protection Act (the “VCDPA”). It applies to personal information
of California and Virginia residents, as applicable.
Categories of Personal Information Collected
California law requires us to provide additional information about the personal
information we collect with reference to specific categories of information. For
additional information about our sources of personal data, how we use personal
data, and how we disclose personal data, refer to the Sonesta Privacy Notice.
Within the last twelve months, we have collected the following categories of
personal information from California residents:
Category
Examples
IdentifiersName, postal address, Internet Protocol address, email address,
account name, driver's license number, passport number, IP address, or other
similar identifiers.Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e))A name, signature,
address, telephone number, passport number, driver's license or state
identification card number, employment, employment history, bank account number,
credit card number, debit card number, or any other financial
informationProtected classification characteristics under California or federal
lawAge (40 years or older), citizenship, marital status, sex (including gender,
gender identity, or gender expression)Commercial informationProducts or services
purchased, obtained, or consideredInternet or other similar network
activityInformation on a consumer’s interaction with a website, application, or
advertisementGeolocation dataPhysical location, which may be identifiable based
on IP addressAudio, visual, or other sensory informationVisual or similar
information, including information captured via CCTV camerasProfessional or
employment-related informationJob, title, employer detailsSensitive Personal
InformationPayment card and other financial information, account login
information including username and password, information concerning health,
gender, gender identity, or gender expressionInferences drawn from other
personal informationProfile reflecting a person’s preferences and
characteristics (e.g., transaction preferences)
“Sales” and “Sharing” of Personal Information/Targeted Advertising
We do not sell your personal information for monetary consideration; however, we
may disclose certain information for our Marketing Activities or in relation to
our co-branded credit cards. Under the CCPA, some of these disclosures may be
considered “sales.” In relation to these disclosures, we may share identifiers,
commercial information, other financial information, and internet or other
similar network activity. As disclosed above, we use cookies and other
similar technologies, including for marketing purposes, and disclosures through
such technologies could be deemed “sharing” for purposes of cross-context
behavioral advertising under the CCPA. Information we “sell” or “share” may
also be disclosed to marketing and co-branded credit card partners. Some of
these activities may further constitute “targeted advertising” under the VCDPA.
In order to opt-out of these disclosures or processing, you may use the contact
information below or use this link: Do Not Sell or Share My Personal
Information.
We do not knowingly “sell” or “share” personal data of children under 16 years
of age.
Privacy Rights
1. Privacy Rights –California residents may have certain privacy rights,
including the rights to: (i) request additional disclosures about the Personal
Information we collect, use, and disclose, i.e., a “Request to Know (Categories
of Information)”; (ii) obtain a copy of Personal Information, i.e., a “Request
to Know (Specific Pieces of Information),” sometimes called the Right to Access;
(iii) request deletion of Personal Information, i.e., a “Request to Delete
Information,” sometimes called the Right to Be Forgotten; (iv) request the
correction of Personal Information; and (v) opt out of the sale of Personal
Information, sharing of Personal Information for purposes of cross-context
behavioral advertising, and targeted advertising, i.e., a “Request to Opt Out.”
2. How to Exercise Privacy Rights – If you wish to exercise any of these rights
please email privacyinquiries@sonesta.com or call us at 855.251.0649. The rights
described herein are not absolute and we reserve all of our rights available to
us at law in this regard. Additionally, if we retain your personal data only in
de-identified form, we will not attempt to re-identify your data in response to
a Data Subject Rights request.
We will not discriminate against you for exercising any of these rights, for
example, by charging you a different price or offering a different level of
service; however, we may be unable to provide certain Services, such as if you
ask us to delete information required to deliver the Service.
If you make a request related to personal data about you, we will need to verify
your identity. To do so, we will request that you match specific pieces of
information you have provided us previously. If it is necessary to collect
additional information from you, we will use the information only for
verification purposes and will delete it as soon as practicable after complying
with the request. For requests related to particularly sensitive information, we
may require additional proof of identification. If you make a request through an
authorized agent, we will require written proof that the agent is authorized to
act on your behalf. We will process your request within the time provided by
applicable law.
3. Additional Privacy Rights for California Residents (California Shine the
Light)
If you are a California resident, California Civil Code Section 1798.83 permits
you to request information about our practices related to the disclosure of your
personal information to certain third parties for their direct marketing
purposes. You may be able to opt-out of our sharing of your personal information
with unaffiliated third parties for the third parties’ direct marketing purposes
in certain circumstances. Please send your request (along with your full name,
email address, postal address, and the subject line labeled “Your California
Privacy Rights”) by email at privacyinquiries@sonesta.com.
4. California Notice at Collection for Online Sources
California law requires us to provide certain disclosures before our collection
of personal information from California residents. The below Notice at
Collection applies to our collection of personal information from California
residents through our Online Services and Marketing Activities (described
further above).
Category of Personal InformationPurpose for Collection and UseIs the personal
information sold or shared?How long is the personal information retained?A.
Identifiers: a real name, alias, email address, postal physical address,
telephone number, fax number, unique personal identifier, online identifier,
Internet Protocol address, email address, account name, or other similar
identifiers
To deliver the Services and provide the content and functionality of our Sites
and social media accounts;
To further develop, customize, and improve our Sites, social media accounts,
other services, and your user experience;
To contact and communicate with you, including for marketing purposes;
To support and enhance our data security.
Yes, for Marketing Activities.
No longer than necessary to fulfill the specified purposes for collection and
use (or a reasonable time thereafter) or other compatible purposes including
satisfying legal requirements
B. Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)): a name, address, telephone number,
education, employment, employment history
To deliver the Services and provide the content and functionality of our Sites
and social media accounts;
To contact and communicate with you, including for marketing purposes;
To support and enhance our data security;
To otherwise operate our business.
In the past 12 months, we have not sold this information to any third parties,
and we have disclosed this information only as set forth above under the heading
“Disclosure of Information”.No longer than necessary to fulfill the specified
purposes for collection and use (or a reasonable time thereafter) or other
compatible purposes including satisfying legal requirementsD. Internet or other
similar network activity: Browsing history, search history, information on a
consumer's interaction with a website, application, or advertisement (e.g.,
visitor domain name, IP address, web browser, operating system, internet service
provider, the pages visited, clickstream data, and time and date of visit)
To deliver the Services and provide the content and functionality of our Sites
and social media accounts;
To further develop, customize, and improve our Sites, social media accounts,
other services, and your user experience;
For advertising and marketing purposes;
To support and enhance our data security;
To otherwise operate our business.
Yes, for Marketing ActivitiesNo longer than necessary to fulfill the specified
purposes for collection and use (or a reasonable time thereafter) or other
compatible purposes including satisfying legal requirementsE. Geolocation data:
Geographic location information about a particular individual or device,
specifically IP address
IP address, which we collect, can reveal information about your location. We
collect such information to:
To deliver the Services and provide the content and functionality of our Sites
and social media accounts;
To further develop, customize, and improve our Sites;
To support and enhance our data security;
For advertising and marketing purposes;
To otherwise operate our business
Yes (IP address), for Marketing ActivitiesNo longer than necessary to fulfill
the specified purposes for collection and use (or a reasonable time thereafter)
or other compatible purposes including satisfying legal requirementsF.
Professional or employment-related information: Employer and job title
To deliver the Services, including our job application Site offered through our
vendor;
To contact and communicate with you including for marketing purposes;
To support and enhance our data security;
To support the Marketing Activities;
To otherwise operate our business.
In the past 12 months, we have not sold this information to any third parties,
and we have disclosed this information only as set forth above under the heading
“Disclosure of Information”.No longer than necessary to fulfill the specified
purposes for collection and use (or a reasonable time thereafter) or other
compatible purposes including satisfying legal requirementsG. Education
Information
To deliver the Services, including our job application Site offered through our
vendor;
To support and enhance our data security;
To otherwise operate our business.
In the past 12 months, we have not sold this information to any third parties,
and we have disclosed this information only as set forth above under the heading
“Disclosure of Information”.No longer than necessary to fulfill the specified
purposes for collection and use (or a reasonable time thereafter) or other
compatible purposes including satisfying legal requirementsH. Inferences drawn
from other personal information
To provide the content and functionality of our Sites, social media accounts,
and other services;
To further develop, customize, and improve our Sites, social media accounts,
other services, and your user experience;
To contact and communicate with you, including for marketing purposes;
To support and enhance our data security.
In the past 12 months, we have not sold this information to any third parties,
and we have disclosed this information only as set forth above under the heading
“Disclosure of Information”.No longer than necessary to fulfill the specified
purposes for collection and use (or a reasonable time thereafter) or other
compatible purposes including satisfying legal requirementsI. Sensitive
Information: Payment card and other financial information.
To process your transaction when you make a purchase on the Sites;
To accommodate special requests due to health conditions;
To comply with applicable laws and regulations;
To otherwise operate our business.
Yes, in the case of our co-branded cards, card number, or other financial
information may be disclosed to our partner in ways that could constitute
“sales”.No longer than necessary to fulfill the specified purposes for
collection and use (or a reasonable time thereafter) or other compatible
purposes including satisfying legal requirements
When we say we may use our Personal Information “to otherwise operate our
business,” we mean uses that can include:
* To comply with our legal obligations
* To comply with legal process
* To respond to requests from public and government authorities, including
those outside your country of residence
* To enforce our terms and conditions
* To protect our operations or those of any of our affiliates and other third
parties
* To protect our rights, privacy, safety, or property, or that of our
affiliates, you, or other third parties, including to support and enhance our
data security
* To allow us to pursue available remedies or limit damages we, our affiliates,
or other third parties, may sustain
Sensitive Personal Information
We may collect information that is considered “sensitive” under the CCPA, such
as payment card or other financial information, account login information such
as username and password, and data concerning health that we may collect from
Guests with particular health concerns. When we do so, we use such information
only for lawful purposes in compliance with the CCPA and other applicable
privacy laws, such as to perform the services or provide the goods requested by
you and to resist malicious, deceptive, fraudulent, or illegal actions. We do
not use such information to infer characteristics about individuals.
Changes to State Privacy Disclosures
At times our CCPA Disclosures may be changed and any updates will be posted to
this site. If material changes are made to this Notice, we will post a notice to
the revised policy on the homepage of this site for at least thirty (30) days.
Any changes that are made will go into effect when posted on the site and they
will apply to all users of our Services. We encourage you to check this policy
periodically for updates.
Contact Us
To assert one of your legal rights described in these State Privacy Disclosures,
or if you have any questions about these CCPA Disclosures or our data handling
practices, please contact us by any of the following means:
* by calling our Compliance Hotline at 855.251.0649
* by mailing a written description of your concern or complaint to:
Sonesta International Hotels Corporation
Chief Compliance Officer,
400 Centre Street
Newton, MA 02458
* by emailing to privacyinquiries@sonesta.com.
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