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HILTON GLOBAL PRIVACY STATEMENT
Last Updated: Sep 4, 2024
* Introduction
* Collection of Personal Information – Generally
* Collection of Personal Information – Notice at Point of Collection
* Reservations with Hilton Partner Accommodations
* Cookies and Other Technologies
* Analytics and Interest-Based Advertisements
* Changing and Accessing Your Personal Information
* How We Protect Personal Information
* Disclosure Pursuant to Legal Obligations or to Protect the Safety and
Security of People and Property
* Marketing Communications Choices
* International Transfers of Personal Information
* Data Retention Periods
* Changes to this Statement
* Contact Information for Questions or Concerns
* Additional Provisions Applicable to California Consumers
* Additional Provision Applicable to Nevada Consumers
* Additional Provision Applicable to French Residents
* Additional Provision Applicable to Hong Kong Consumers
* Additional Provision Applicable to Korean Data Subjects
* Appendix A: Additional Provisions Applicable to Processing of Personal
Information of Residents of Certain Countries and U.S. States
* Appendix B: Additional Provisions Applicable to Processing of Personal
Information of Data Subjects in Türkiye
* Appendix C: Additional Provisions Applicable to Processing of Personal
Information of China Residents/Citizens
* Appendix D: Additional Provisions Applicable to Processing of Personal
Information of Brazil Residents or Citizens
* Appendix E: Additional Provisions Applicable to Processing of Personal
Information of Data Subjects of Monaco
INTRODUCTION
Hilton's mission is to be the most hospitable company in the world. We're
passionate about delivering exceptional guest experiences, and we look forward
to welcoming you to our hotels so we can share the light and warmth of
hospitality with you.
We pledge to deliver the highest level of customer service, which includes
respecting your privacy and protecting your personal information. In this
privacy statement ("Statement"), we provide you with details about how we
collect, use, and disclose your personal information.
This Statement applies to Hilton Worldwide Holdings Inc., its subsidiaries, and
all of the hotels within the Hilton Portfolio of Brands (collectively, "Hilton,"
"we," or "us"). Our Portfolio of Brands includes Waldorf Astoria Hotels &
Resorts, LXR Hotels & Resorts, Conrad Hotels & Resorts, Canopy by Hilton, Signia
by Hilton, Hilton Hotels & Resorts, Curio Collection by Hilton, DoubleTree by
Hilton, Tapestry Collection by Hilton, Embassy Suites by Hilton, Tempo by
Hilton, Motto by Hilton, Hilton Garden Inn, Hampton by Hilton, Tru by Hilton,
Spark by Hilton, Homewood Suites by Hilton, Home2 Suites by Hilton, LivSmart
Studios by Hilton, Graduate by Hilton, and NoMad.
By using any of our products or services and/or by agreeing to this Statement,
e.g. in the context of registering for any of our products or services, you
understand and acknowledge that we will collect and use personal information as
described in this Statement.
Please note that this Statement does not apply to our processing of personal
information on behalf of and subject to the instructions of third parties such
as airlines, car rental companies and other service providers, companies that
organize or offer packaged travel arrangements, marketing partners, or certain
corporate customers.
1 Hilton Domestic Operating Company Inc. is the Hilton entity that is the data
controller for all guest data and operates, among other things, Hilton's
marketing activities. Hilton Domestic Operating Company Inc. is a subsidiary of
Hilton Worldwide Holdings Inc.
The Hilton Portfolio of Brands includes managed, franchised, and joint venture
hotels. Franchised hotels are operated by entities that are separate from
Hilton. Joint venture hotels are operated by entities that are partially owned
and/or controlled by Hilton. In addition to Hilton Domestic Operating Company
Inc., those entities are also independent data controllers for guest data.
Hilton Grand Vacations (HGV) operates timeshare and fractional resorts. HGV is a
third-party partner whose privacy statement is available at
https://www.hiltongrandvacations.com/en/privacy-policy.html.
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COLLECTION OF PERSONAL INFORMATION - GENERALLY
The following summarizes the categories of personal information we have
collected in the past 12 months, the sources for those categories of personal
information, the business or commercial purposes for which the information was
collected, the categories of third parties with whom the information may have
been shared, as permitted by law, and whether the information was sold to a
third party for a business or commercial purpose within the past 12 months.
Certain categories of personal information collected are required in order for
us to provide you with the requested products or services, and if you choose not
to provide us with such information, we may not be able to provide you with
these products or services. If consent is required, we will obtain your consent
before selling or sharing your personal information.
We have collected the following categories of personal information in the past
12 months:
We have obtained this personal information from the following sources:
We collected this personal information for the following business or commercial
purposes:
We have shared this personal information with the following categories of third
parties:
This information was sold to a third party within the past 12 months
* Name
* Directly from consumers themselves
* From third party partners such as credit card providers
* From demographics companies
* Fulfill guest reservations
* Send guests communications relating to their reservations
* Administer membership and activity in the Hilton Honors loyalty program
* Provide customer service and support
* Verify identity
* Send marketing communications via email, direct mail, and social media
* Perform analytics in order to provide guests with personalized offers and
content
* Perform analytics to improve business operations
* Determine guests' eligibility for special or promotional rates
* Process payments, including conducting strong customer authentication (SCA)
when required by law
* Process transactions with partners
* Administer contests and sweepstakes
* Optimize our websites and mobile apps
* Detect and prevent fraud
* Service providers who perform tasks on behalf of Hilton, which may include
those who send marketing communications on our behalf
* Hilton Grand Vacations, Hilton's third-party partner
* Payment card issuers and payment processors
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* Entities that have arranged a special rate plan with Hilton and/or organized
an event and/or room block with Hilton
* The third-party booking platform or travel agent through which a guest made a
reservation
* Government agencies pursuant to legal requirements in some countries
* Third-party advertisers, for optimization and personalization on their
platforms
* Hilton Partner Accommodations
Yes
* Telephone
* Directly from consumers themselves
* From third parties such as travel booking platforms and credit card providers
* From demographics companies
* Fulfill guest reservations
* Send guests communications relating to their reservations
* Provide customer service and support
* Verify identity
* Send marketing communications via SMS
* Process transactions with partners
* Authenticate mobile account
* Sending service-related SMS communications
* Detect and prevent fraud
* Engage in sales activity for group bookings, meetings and events
* Service providers who perform tasks on behalf of Hilton, which may include
those who send marketing communications on our behalf
* Hilton Grand Vacations
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* The third-party travel booking platform or travel agent through which a guest
made a reservation
* Third-party advertisers, for optimization and personalization on their
platforms
* Hilton Partner Accommodations
Yes
* Email address
* Directly from consumers themselves
* From third parties such as travel booking platforms and credit card providers
* From demographics companies
* Fulfill guest reservations
* Send guests communications relating to their reservations
* Administer membership and activity in the Hilton Honors loyalty program
* Provide customer service and support
* Verify identity
* Send marketing communications via email
* Process transactions with partners
* Administer contests and sweepstakes
* Share that data with Hilton Grand Vacations, Hilton's third-party partner
* Authenticate mobile account
* Detect and prevent fraud
* Engage in sales activity for group bookings, meetings, and events
* Service providers who perform tasks on behalf of Hilton, which may include
those who send marketing communications on our behalf
* Hilton Grand Vacations
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* The third-party travel booking platform or travel agent through which a guest
made a reservation
* Third-party advertisers, for optimization and personalization on their
platforms
* Hilton Partner Accommodations
Yes
* Home address
* Directly from consumers themselves
* From third parties such as travel booking platforms and credit card providers
* From demographics companies
* Fulfill guest reservations
* Administer membership and activity in the Hilton Honor loyalty program
* Provide customer service and support
* Verify identity
* Send marketing communications via direct mail
* Perform analytics to provide guests with personalized offers and content
* Perform analytics to improve business operations
* Process payments, including conducting SCA when required by law
* Process transactions with partners
* Administer contests and sweepstakes
* Detect and prevent fraud
* Engage in sales activity for group bookings, meetings, and events
* Service providers who perform tasks on behalf of Hilton
* Hilton Grand Vacations
* Payment card issuers and payment processors
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* The third-party travel booking platform or travel agent through which a guest
made a reservation
* Third-party advertisers, for optimization and personalization on their
platforms
* Hilton Partner Accommodations
Yes
* Nationality
* Directly from consumers themselves
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Government agencies pursuant to legal requirements in some countries
No
* Date of birth
* Directly from consumers themselves
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Government agencies pursuant to legal requirements in some countries
No
* Gender
* Directly from consumers themselves
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Government agencies pursuant to legal requirements in some countries
No
* Payment card information
* Directly from consumers themselves
* The third-party travel booking platform or travel agent through which a
consumer made a reservation
* Process payments, including conducting SCA when required by law
* Detect and prevent fraud
* Payment card issuers and payment processors
* Hilton Partner Accommodations
No
* Hilton Honors number
* Directly from Hilton Honors members themselves
* Fulfill guest reservations
* Send guests communications relating to their reservations
* Administer membership and activity in the Hilton Honors loyalty program
* Provide customer service and support
* Verify account
* Send marketing communications via email, direct mail, and social media
* Perform analytics in order to provide guests with personalized offers and
content
* Perform analytics to improve business operations
* Determine guests' eligibility for special or promotional rates
* Process payments
* Process transactions with partners
* Administer contests and sweepstakes
* Detect and prevent fraud
* Service providers who perform tasks on behalf of Hilton, which may include
those who send marketing communications on our behalf
* Hilton Grand Vacations
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* Third-party advertisers, for optimization and personalization on their
platforms
* Hilton Partner Accommodations
Yes
* WeChat ID
* Directly from consumers themselves
* Enable guests to log into Hilton Honors account
We do not share customers' WeChat ID with third parties
No
* Passport information
* Directly from consumers themselves
* Pursuant to laws that require the collection of such data
* Government agencies pursuant to legal requirements in some countries
No
* Preferred language
* Directly from consumers themselves, including from browser and computer
settings
* Better serve our guests
* Provide you with a superior guest experience
* Send you communications relating to Hilton Honors
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Hilton Grand Vacations
* Hilton Partner Accommodations
No
* Room preference
* Directly from consumers themselves
* Better serve our guests
* Fulfill your reservations
* Personalize your experience
* Perform analytics to provide you with personalized offers and content
* Perform analytics to improve business operations
* Hilton Partner Accommodations
No
* Room selection and assignment
* Guests can select their rooms on the Hilton Honors app and Hilton assigns
rooms
* Better serve our guests
* Fulfill reservations
* Hilton Partner Accommodations
No
* Arrival time
* Directly from consumers themselves
* Better serve our guests
* Fulfill reservations
* Personalize guest experience
* Provide customer service and support
* Hilton Partner Accommodations
No
* Departure date
* Directly from consumers themselves
* Better serve our guests
* Fulfill reservations
* Personalize guest experience
* Hilton Partner Accommodations
No
* Additional guest names
* Directly from consumers themselves
* Fulfill reservations
* Hilton Grand Vacations
* Hilton Partner Accommodations
Yes
* Corporate travel planner contact information (name, title, company, business
phone, email and address)
* Directly from the corporate contacts themselves
* Fulfill and manage corporate travel reservations
* Provide customer service and support
* Send marketing communications via email, direct mail, and social media
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
No
* Business contact data for members of the media and social media influencers
* From a third-party communications service provider
* Contact members of the media and social media influencers in their business
capacity
We do not share business contact data for members of the media and social media
influencers with third parties
No
* Corporate number and name
* Directly from consumers themselves
* Fulfill reservations
* Determine guests' eligibility for special or promotional rates
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* Hilton Grand Vacations
Yes
* Travel agent number and name
* Directly from consumers themselves
* From travel agents
* Properly attribute reservations to travel agents
* Fulfill your reservation
* Determine your eligibility for special or promotional rates
* Hilton Grand Vacations
Yes
* Airline partner number and name
* Directly from consumers themselves
* Properly attribute points to consumers who participate in airline loyalty
programs
* The respective airlines
* Hilton Grand Vacations
Yes
* Vehicle information
* Directly from consumers themselves
* From license plate recognition technology
* From video capabilities
* Enable guests to park at our properties
* Ensure safety and security
We do not share vehicle information with any third parties.
No
* Images or footage captured by closed circuit television (CCTV)
* Directly from cameras located on and around the property
* Protect guests, employees and visitors to properties
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Government agencies pursuant to legal requirements in some countries
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* Entities that have arranged a special rate plan with Hilton and/or organized
an event and/or room block with Hilton, as permitted by law
No
* Promotional images or footage captured by on-property photographers
* Directly from cameras utilized on the property
* Internal and external promotions and communications
We share promotional images with third parties that facilitate promotions.
No
* Internet or other electronic network activity information, including
information regarding a customer's interaction with Hilton websites,
applications, or advertisements
* Directly from consumers themselves via Cookies, server logs, web beacons,
tags, pixels, and other similar technologies
* Perform analytics in order to provide guests with personalized offers and
content
* Perform analytics to improve business operations
* Marketing
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* Optimize our websites and mobile apps
* Advertising networks
* Analytics providers for our websites and mobile applications
Yes
Note: If in the Hilton Honors iOS App you ask the App not to track you across
other companies' apps and websites, Hilton will honor that request. Please note
that you may still receive emails about properties you searched for either
directly within the Hilton Honors App, or on Hilton.com. You may also receive
emails related to Hilton-American Express Co-Branded Credit Cards; those emails
are not sent based oniOS tracking.
* IP addresses
* Directly from consumers as a result of their browsing activity on the
internet
* Perform analytics in order to provide guests with personalized offers and
content
* Perform analytics to improve business operations
* Share that data with advertising networks who serve personalized
advertisements
* Conduct SCA as part of the payment process, when required by law
* Optimize our websites and mobile apps
* Troubleshoot and resolve website issues
* Detect and prevent fraud
* Advertising networks
* Analytics providers for our websites and mobile applications
* Service providers who perform tasks on behalf of Hilton, which may include
those who send marketing communications on our behalf
* Payment card issuers and payment processors (only when conducting SCA)
No
* Session IDs
* Directly from consumers as a result of their browsing activity on the
internet
* Perform analytics in order to provide guests with personalized offers and
content
* Marketing
* Perform analytics to improve business operations
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* Advertising networks
* Analytics providers for our websites and mobile applications
Yes
* Booking engine
* Directly from consumers as a result of their browsing activity on the
internet
* Show you targeted advertisements on media
* Support marketing efforts
* Provide customer service
* Perform analytics to improve business operations
* Advertising networks
* Analytics providers for our websites and mobile applications
Yes
* Streaming service usage (including service used, hours of use, launch method,
and log-out method)
* Directly from consumer as a result of their logging into a streaming service
through Connected Room functionality
* Evaluate the usage of different streaming services
We do not share streaming service usage with third parties
No
* Whether you have a Hilton and American Express Co-Branded Credit Card
* From American Express
* Provide you with benefits associated with your co-branded card
* Show you targeted advertisements on media
* Support marketing efforts
* Provide customer service
* Perform analytics to improve business operations
* Advertising networks
* Analytics providers for our websites and mobile applications
* Hilton Honors affiliated partners
* Hilton Partner Accommodations
No
* Whether your Hilton and Amazon accounts are linked
* From Amazon
* Facilitate use of Honors points as part of Amazon's Shop with Points program
* Show you targeted advertisements on media
* Support marketing efforts
* Provide customer service
* Perform analytics to improve business operations
* Advertising networks
* Analytics providers for our websites and mobile applications
No
* Whether your Hilton and Lyft accounts are linked
* From Lyft
* Show you targeted advertisements on media
* Support marketing efforts
* Provide customer service
* Perform analytics to improve business operations
* Advertising networks
* Analytics providers for our websites and mobile applications
* Hilton Honors affiliated partners
No
* Geolocation information
* Directly from consumers as a result of their browsing activity on the
internet and use of the Hilton Honors app
* Enable guest access to guest room and hotel facilities
* Fulfill Digital Key sharing requests
* Perform analytics in order to provide guests with personalized offers and
content
* Marketing
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* Advertising networks
* Analytics providers for our websites and mobile applications
No
* Device information (including MAC address)
* Directly from consumers as a result of their browsing activity on the
internet, scanning of QR codes on property, and use of the Hilton Honors app
* Perform analytics to provide guests with personalized offers and content
* Marketing
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* Advertising networks
* Analytics providers for our websites and mobile applications
Yes
* Social media information; publicly available online information (including
through social media platforms)
* Directly from consumers themselves
* Indirectly from consumers by reviewing publicly available information on
their social media channels
* From publicly available online sources
* Perform analytics in order to provide guests with personalized offers and
content
* Respond to service concerns in order to better serve our guests
* Provide a more personalized welcome and stay experience
We do not share social media information with any third parties.
No
* Demographics data
* From third-party companies that provide demographics data.
* Perform analytics in order to provide guests with personalized offers and
content
* Link with customer information that Hilton already has on file
We do not share demographics data with any third parties.
No
* Your MyWay preferences
* Directly from consumers themselves
* Better serve our guests
* Send you the communications you would like to receive
* Hilton Partner Accommodations
No
* Your email and consent preferences (such as opt-out or opt-in, as applicable)
* Directly from consumers themselves
* Better serve our guests
* Send you the communications you would like to receive
* Advertising networks
No
* Description of an incident that occurs at a Hilton property or involves a
Hilton employee, including incidents related to safety, security, violation
of law, violation of applicable policy, or violation of contractual
obligation
* Directly from consumers themselves
* Directly from Hilton employees
* Directly from law enforcement
* Respond to safety & security concerns
* Better serve our guests
* Comply with legal or contractual obligations
* Law enforcement
* Employers pursuant to corporate agreements, employee consent, and as
permitted by law
* Entities that have arranged a special rate plan with Hilton and/or organized
an event and/or room block with Hilton
* The management and/or owners of a franchise property if the incident relates
to that property
* Others as required by law
No
* Description of a complaint that you make to us, including your free form
textual feedback if you are a Hilton Honors member
* Directly from consumers themselves
* Respond to safety and security concerns
* Better serve our guests
* Comply with legal or contractual obligations
* The management and/or owners of a franchise property if your complaint
relates to that property.
No
* Customer ratings and survey responses
* Directly from consumers themselves
* Troubleshoot and resolve website issues
* Improve customer experience
We do not share identifiable customer ratings and survey responses with any
third parties.
No
* Free form textual feedback
* Directly from consumers themselves
* Troubleshoot and resolve website issues
* Improve customer experience
We do not share your feedback with any third parties.
No
* Spa and wellness service or treatment details (such as date, time, and type
of service)
* Directly from consumers themselves
* Respond to safety and security concerns
* Better serve our guests
* Comply with legal or contractual obligations
We do not share your spa and wellness service or treatment details with any
third parties.
No
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COLLECTION OF PERSONAL INFORMATION – NOTICE AT POINT OF COLLECTION
BROWSING HILTON WEBSITES
When you browse a Hilton website, we collect the following categories of
personal information about you, which are used for the following purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Internet or other electronic network activity information, including
information regarding your interaction with Hilton websites, applications, or
advertisements
* Show you targeted advertisements on marketing efforts including media, email,
and chat (e.g., if you searched for Hilton properties in New York City, then
when you visit a non-Hilton website, we may show you an ad for a Hilton
property in New York City)
* Optimize our websites and mobile apps
* Perform analytics to improve business operations
* Perform analytics in order to provide guests with personalized offers and
content
* Marketing
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* IP address
* Perform analytics in order to provide guests with personalized offers and
content
* Show you targeted advertisements on media
* Optimize our websites and mobile apps
* Perform analytics to improve business operations
* Share that data with advertising networks who serve personalized
advertisements
* Conduct SCA as part of the payment process, when required by law
* Troubleshoot and resolve website issues
* Detect and prevent fraud
* Session ID
* Perform analytics in order to provide guests with personalized offers and
content
* Marketing
* Show you targeted advertisements on media
* Optimize our websites and mobile apps
* Perform analytics to improve business operations
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* Booking engine
* Show you targeted advertisements on media
* Support marketing efforts
* Provide customer service
* Perform analytics to improve business operations
* Whether your Hilton and Lyft accounts are linked
* Show you targeted advertisements on media
* Support marketing efforts
* Provide customer service
* Perform analytics to improve business operations
If you are a Hilton Honors member and you log into your account during your
browsing session, then we collect the following information about you, which are
used for the following purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Internet or other electronic network activity information, including
information regarding your interaction with Hilton websites, applications, or
advertisements
* Show you targeted advertisements on marketing efforts including media, email,
and chat (e.g., if you searched for Hilton properties in New York City, then
when you visit a non-Hilton website, we may show you an ad for a Hilton
property in New York City)
* Optimize our websites and mobile apps
* Perform analytics to improve business operations
* Perform analytics in order to provide guests with personalized offers and
content
* Marketing
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* IP address
* Perform analytics in order to provide guests with personalized offers and
content
* Share that data with advertising networks who serve personalized
advertisements
* Conduct SCA as part of the payment process, when required by law
* Show you targeted advertisements on media
* Optimize our websites and mobile apps
* Troubleshoot and resolve website issues
* Perform analytics to improve business operations
* Detect and prevent fraud
* Session ID
* Perform analytics in order to provide guests with personalized offers and
content
* Show you targeted advertisements on media
* Optimize our websites and mobile apps
* Perform analytics to improve business operations
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
* Customer ratings and survey responses
* Troubleshoot and resolve website issues
* Improve customer experience
* Free form textual feedback
* Troubleshoot and resolve website issues
* Improve customer experience
* Hilton Honors number
* Look up and verify your Hilton Honors account and reservation
* Fulfill guest reservations
* Send guests communications relating to their reservations
* Administer membership and activity in the Hilton Honors loyalty program
* Support marketing efforts
* Provide customer service and support
* Troubleshoot and resolve website issues
* Send marketing communications via email, direct mail, and social media
* Perform analytics in order to provide guests with personalized offers and
content
* Perform analytics to improve business operations
* Determine guests’ eligibility for special or promotional rates
* Process payments
* Process transactions with partners
* Share this information with Hilton Partner Accommodations
* Administer contests and sweepstakes
* Detect and prevent fraud
* Hilton Honors tier
* Support marketing efforts
* Provide customer service
* Share this information with Hilton Partner Accommodations
* Troubleshoot and resolve website issues
MAKING A RESERVATION
When you make a reservation at a Hilton property, we collect the following
categories of personal information about you, which are used for the following
purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Name
* Look up and verify your reservation
* Fulfill your reservation
* Send you communications relating to your reservation
* Administer membership and activity in the Hilton Honors loyalty program
* Provide customer service and support
* Send you marketing communications via email and direct mail
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Determine your eligibility for special or promotional rates
* Process payments
* Process transactions with partners
* Share this information with Hilton Grand Vacations, Hilton's third-party
partner and Hilton Partner Accommodations
* Administer contests and sweepstakes
* Optimize our websites and mobile apps
* Detect and prevent fraud
* Additional names
* Fulfill your reservation
* Share this information with Hilton Partner Accommodations
* Hilton Honors number
* Look up and verify your Hilton Honors account and reservation
* Administer your membership in Hilton Honors
* Fulfill guest reservations
* Send guests communications relating to their reservations
* Provide customer service and support
* Send marketing communications via email, direct mail, and social media
* Perform analytics in order to provide guests with personalized offers and
content
* Perform analytics to improve business operations
* Determine guests’ eligibility for special or promotional rates
* Process payments
* Process transactions with partners
* Share this information with Hilton Partner Accommodations
* Administer contests and sweepstakes
* Detect and prevent fraud
* Phone number
* Verify identity
* Fulfill your reservation
* Send you text messages relating to any services you may need during your stay
* Send marketing communications via SMS
* Provide customer service and support
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Process transactions with partners
* Share this information with Hilton Grand Vacations, Hilton's third-party
partner and Hilton Partner Accommodations
* Detect and prevent fraud
* Engage in sales activity for group bookings, meetings, and events
* Address
* Fulfill your reservation
* Send you communications relating to your reservation
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Process payments
* Process transactions with partners
* Share this information with Hilton Grand Vacations, Hilton's third-party
partner and Hilton Partner Accommodations
* Detect and prevent fraud
* Address type (home/work)
* Perform analytics in order to provide you with personalized offers and
content
* Share this information with Hilton Partner Accommodations
* Email address
* Look up and verify your Hilton Honors account and reservation
* Associate your reservation with your Hilton Honors account
* Send you communications relating to your reservation
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Determine your eligibility for special or promotional rates
* Process transactions with partners
* Share this information with Hilton Grand Vacations and Hilton Partner
Accommodations
* Detect and prevent fraud
* Authenticate mobile account
* Engage in sales activity for group bookings, meetings, and events
* Preferred language
* Provide you with a superior guest experience
* Send you communications relating to your reservation
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Share this information with Hilton Grand Vacations and Hilton Partner
Accommodations
* Payment card information
* Process payments
* Share this information with Hilton Partner Accommodations
* Detect and prevent fraud
* Room preference
* Fulfill your reservation
* Personalize your experience
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Share this information with Hilton Partner Accommodations
* Corporate name and number
* Fulfill your reservation
* Determine your eligibility for special or promotional rates
* Travel agent name and number
* Fulfill your reservation
* Determine your eligibility for special or promotional rates
* Properly attribute reservations to travel agents
* Airline partner name and number
* Credit points to you if you participate in an airline loyalty program
ENROLLING IN HILTON HONORS
When you enroll in Hilton Honors, we collect the following categories of
personal information about you, which are used for the following purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Name
* Administer your membership in the Hilton Honors loyalty program
* Verify your Hilton Honors account
* Send you communications relating to Hilton Honors
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Determine your eligibility for special or promotional rates
* Process payments
* Process transactions with Hilton Honors affiliated partners (such as
Points.com and Lyft)
* Share this information with Hilton Grand Vacations, Hilton's third-party
partner and Hilton Partner Accommodations
* Administer contests and sweepstakes
* Optimize our websites and mobile apps
* Detect and prevent fraud
* Phone number
* Administer your membership in the Hilton Honors loyalty program
* Verify your Hilton Honors account
* Send you text messages relating to any services you may need during your
stays at Hilton properties
* Authenticate mobile account
* Send service-related SMS communications
* Provide customer service and support
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Process transactions with partners
* Share this information with Hilton Grand Vacations and Hilton Partner
Accommodations
* Detect and prevent fraud
* Engage in sales activity for group bookings, meetings, and events
* Address
* Administer your membership in the Hilton Honors loyalty program
* Verify your Hilton Honors account
* Send you communications relating to Hilton Honors
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Determine your eligibility for special or promotional rates
* Process payments
* Process transactions with partners
* Share this information with Hilton Partner Accommodations
* Detect and prevent fraud
* Engage in sales activity for group bookings, meetings, and events
* Email address
* Administer your membership in the Hilton Honors loyalty program
* Verify your Hilton Honors account and reservation
* Associate your reservation with your Hilton Honors account
* Send you communications relating to Hilton Honors
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Determine your eligibility for special or promotional rates
* Process transactions with partners
* Share this information with Hilton Grand Vacations and Hilton Partner
Accommodations
* Detect and prevent fraud
* Authenticate mobile account
* Engage in sales activity for group bookings, meetings, and events
* Preferred language
* Provide you with a superior guest experience
* Send you communications relating to Hilton Honors
* Send you marketing communications
* Perform analytics in order to provide you with personalized offers and
content
* Share this information with Hilton Grand Vacations and Hilton Partner
Accommodations
* Payment card information
* Process payments
* Detect and prevent fraud
* Share this information with Hilton Partner Accommodations
* Room preference
* Fulfill your reservations
* Personalize your experience
* Perform analytics in order to provide you with personalized offers and
content
* Perform analytics to improve business operations
* Share this information with Hilton Partner Accommodations
* Corporate name and number
* Fulfill your reservation
* Determine your eligibility for special or promotional rates
* Travel agent name and number
* Fulfill your reservation
* Determine your eligibility for special or promotional rates
* Properly attribute reservations to travel agents
* Airline partner name and number
* Credit points to you if you participate in an airline loyalty program
* My Way preferences
* Provide you with a superior guest experience
* Share this information with Hilton Partner Accommodations
* Email subscription preferences
* Send you the communications you would like to receive
* Opt-out preferences
* Send you the communications you would like to receive
* Better serve our guests
CHECKING IN AT A HILTON PROPERTY
When you check in at a Hilton property, we may collect the following categories
of personal information about you, which are used for the following purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Name
* Look up and verify your reservation
* Fulfill your reservation
* Provide customer service and support
* Detect and prevent fraud
* Payment card information
* Receive payment for your reservation
* Detect and prevent fraud
* Additional guest names
* Fulfill your reservation
* Passport information
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Address
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Verify your Hilton Honors account
* Fulfill your reservation
* Send you communications relating to your reservation
* Send you marketing communications
* Perform analytics to provide you with personalized offers and content
* Perform analytics to improve business operations
* Process payments
* Process transactions with partners
* Share this information with Hilton Grand Vacations, Hilton’s third-party
partner
* Detect and prevent fraud
* Nationality
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Date of birth
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Gender
* Comply with applicable laws that require us to collect this information in
some jurisdictions
* Hilton Honors number
* Look up and verify your Hilton Honors account and reservation
* Administer your membership in Hilton Honors
* Support marketing efforts
* Provide customer service and support
* Fulfill guest reservations
* Send guests communications relating to their reservations
* Provide customer service and support
* Send marketing communications via email, direct mail, and social media
* Perform analytics in order to provide guests with personalized offers and
content
* Perform analytics to improve business operations
* Determine guests’ eligibility for special or promotional rates
* Process payments
* Process transactions with partners
* Administer contests and sweepstakes
* Detect and prevent fraud
* Frequent flyer number
* To facilitate the award of loyalty points
* Email address
* Send folios after the completion of a stay
* Associate your reservation with your Hilton Honors account
* Send you marketing communications
* Perform analytics to provide you with personalized offers and content
* Perform analytics to improve business operations
* Determine your eligibility for special or promotional rates
* Process transactions with partners
* Share this information with Hilton Grand Vacations
* Detect and prevent fraud
* Authenticate mobile account
* Engage in sales activity for group bookings, meetings, and events
E-CHECK IN
When you check in using e-check in, we collect the following categories of
personal information about you, which are used for the following purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Payment card information
* Receive payment for your reservation
* Detect and prevent fraud
* Room selection and assignment
* Fulfill your reservation
* Better serve our guests
* Arrival time
* Better serve our guests
* Fulfill your reservation
* Personalize your experience
* Provide customer service and support
* Departure date
* Better serve our guests
* Fulfill reservations
* Personalize guest experience
* Provide customer service and support
DIGITAL KEY
When you use Digital Key, we collect the following categories of personal
information about you, which are used for the following purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Payment card information
* Receive payment for your reservation
* Detect and prevent fraud
* Room selection and assignment
* Fulfill your reservation
* Better serve our guests
* Arrival time
* Better serve our guests
* Fulfill your reservation
* Personalize your experience
* Provide customer service and support
* Departure date
* Better serve our guests
* Fulfill reservations
* Personalize your experience
* Provide customer service and support
* Precise geo-location information
* Enable you to access your guest room and hotel facilities
* Fulfill Digital Key sharing requests
* Perform analytics in order to provide guests with personalized offers and
content
* Marketing
* Share that data with advertising networks who serve personalized
advertisements
* Detect and prevent fraud
GUEST ASSISTANCE
When you contact Guest Assistance, we collect the following categories of
personal information about you, which are used for the following purposes:
We collect the following categories of personal information…
We collect this information in order to…
* Description of complaint or inquiry
* Respond to your complaint or inquiry
* Perform analytics to improve business operations
* Provide customer service and support
* Share this information with Hilton Partner Accommodations
* Name
* Look up and verify your identity
* Search our records for information about your past stays and membership in
the Hilton Honors loyalty program
* Provide customer service recovery and support
* Detect and prevent fraud
* Share this information with Hilton Partner Accommodations
* Address
* Verify your identity
* Provide customer service and support
* Detect and prevent fraud
* Share this information with Hilton Partner Accommodations
* Email address
* Verify your identity
* Provide follow-up communications regarding your inquiry
* Perform analytics to improve business operations
* Detect and prevent fraud
* Provide customer service and support
* Authenticate mobile account
* Share this information with Hilton Partner Accommodations
* Phone number
* Verify your identity
* Provide follow-up communications regarding your inquiry
* Authenticate mobile account
* Send service-related SMS communications
* Provide customer service and support
* Detect and prevent fraud
* Share this information with Hilton Partner Accommodations
MINORS
Hilton does not knowingly collect, disclose, or sell personal information of
individuals under the age of majority in their respective jurisdiction without
permission from a minor’s parent or guardian. When searching for hotel
reservations on a Hilton website or on the Hilton Honors app, you may be asked
to provide the ages of any minor guests staying in the room. Hilton collects
this information for the purpose of determining room rates where applicable,
such as at an “all-inclusive” property.
CLOSED CIRCUIT TELEVISION (CCTV)
We use closed circuit television and other security measures at our properties
that may capture or record images of guests and visitors in public areas, as
well as information related to your location while on our properties (via
keycards and other technologies) for the protection of our staff, guests and
visitors to our properties, in accordance with applicable laws that require us
to collect information that is used to protect guests, employees, and visitors
of the property. We retain CCTV in accordance with our data retention policies,
as necessary to fulfill the purpose for which that information was collected, or
as required or permitted by law. You may be able to request access to CCTV
images within the time specified by applicable law and as required by law.
Franchised hotels are operated by entities that are separate from Hilton. To
request access to CCTV images from a franchised hotel, please contact that
hotel. In addition to Hilton Domestic Operating Company Inc., those entities
also are independent data controllers of CCTV images. When permitted by law, we
may charge an appropriate fee to cover the costs of responding to the request.
Such requests may be submitted by accessing the Data Subject Rights Requests
Portal at datarights.hilton.com or in writing to DataProtectionOffice@hilton.com
or Hilton Data Protection Officer, 7930 Jones Branch Drive, McLean, VA 22102,
USA.
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RESERVATIONS WITH HILTON PARTNER ACCOMMODATIONS
When making a reservation with AutoCamp or Small Luxury Hotels of the World
(SLH) through a Hilton channel, Hilton will provide AutoCamp or SLH with certain
guest information for the exclusive purpose of fulfilling the reservation, as
identified in this Statement. Hilton channels include Hilton’s website, Hilton
Honors application, or Mini Programs. The guest information will be processed
and retained in accordance with AutoCamp’s or SLH’s privacy policies and as
permitted by applicable law. You can access AutoCamp’s privacy policy here. You
can access SLH’s privacy policy here.
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COOKIES AND OTHER TECHNOLOGIES
Like many other websites, our site may use "Cookies" or "Other Technologies"
(such as "pixel tags," "web beacons," "clear GIFs," links in emails, JavaScript,
device IDs assigned by Google or Apple, or similar technologies). Cookies and
Other Technologies allow us and third parties to obtain information about your
visits to the site, including to analyze your visiting patterns. We use this
information to process your reservations or requests and to deliver online and
mobile advertisements, messages and content for us and others that are specific
to your interests. Depending on your jurisdiction, prior consent for the use of
non-essential Cookies may be required. If it is the case, we will obtain your
consent before using Cookies on your device.
Cookies are small text files that are stored on your computer or mobile device
("device") when you visit a website. Cookies alone cannot be used to disclose
your individual identity to us, though in some cases we may tie Hilton or
third-party Cookies to personal information you have provided to us or that we
have otherwise obtained about you. Cookies may be used on the site in order to
improve your experience. For example, we will use Cookies to:
* Remember your user name and password for future visits so that log-in is
easier and faster;
* Remember your language and other preferences;
* Ensure you obtain all requested information;
* Provide a safe and secure service for online transactions;
* Track your response to advertisements and website or app content for analysis
and the number of times we send you the same advertisement; Measure how many
people use the site, and how they use it, so that we may keep it running
quickly and efficiently; and
* Help us and others deliver communications and content to you that are
relevant and responsive to your interests and location.
Below we explain the different types of Cookies that may be used on the site.
* Essential Cookies – Essential Cookies are necessary for the site to work, and
enable you to move around it and use its services and features. Disabling
these Cookies may make the services and features unavailable.
* Functional Cookies – We use Functional Cookies to save your settings on the
site—settings such as your language preference, or booking information you
have previously used when booking a hotel with us. We also use Functional
Cookies to store such things as the last hotel you searched for, so that you
can easily find it the next time you visit. Some Functional Cookies are
essential to viewing maps or videos on our site.
* Session Cookies – These types of Cookies are stored only temporarily during a
browsing session, and are deleted from your device when you close the
browser. We use Session Cookies to support the functionality of the site and
to understand your use of the site—that is, which pages you visit, which
links you use and how long you stay on each page.
* Persistent Cookies – These types of Cookies are not deleted when you close
your browser, but are saved on your device for a fixed period of time or
until you delete them. Each time you visit the site, the server that set the
Cookie will recognize the persistent Cookie saved on your device. We and
others use persistent Cookies to store your preferences, so that they are
available for your next visit, to keep a more accurate account of how often
you visit the site, how often you return, how your use of the site may vary
over time and the effectiveness of advertising efforts.
* Advertising Cookies – Allow us and other advertisers to show you the most
relevant products, offers, and advertisements on the site and third-party
sites, or through emails or other message platforms. For example, some
Advertising Cookies help our service providers and other advertisers select
advertisements that are based on your interests, including those expressed or
inferred by visits to our websites or apps or across other websites, online
services, and apps over time. Others help prevent the same advertisement from
continuously reappearing for you. These types of Cookies also help us provide
you with content on the site that is tailored to your interests and needs. As
noted below, some Analytics Cookies and Other Technologies are used in part
to facilitate advertising.
* Social Plug-In Cookies – Advertising Cookies also include Social Plug-In
Cookies. Social Plug-In Cookies are used to share content from the site with
members and non-members of social media networks such as Facebook, Twitter,
YouTube and Pinterest. These Cookies are usually set by the social networking
provider, enabling such sharing to be smooth and seamless.
* Analytics Cookies – Collect information about your use of the site, and
enable us to improve the way it works. These Cookies give us aggregated
information that we use to monitor site performance, count page visits, spot
technical errors, see how users reach the site, and measure the effectiveness
of advertising (including emails we send to you).
* Other technologies may be used for the same purposes as our Cookies, to allow
us and third parties to know when you visit the site, and to understand how
you interact with emails or advertisements. Through Other Technologies,
non-personal information (e.g., your operating system, your browser version,
and the URL you came from) or aggregate information may be obtained and used
to enhance your experience and understand traffic patterns.
MANAGING COOKIES AND OTHER TECHNOLOGIES
If you want to remove or block Cookies from your device at any time, you can
update your browser settings (consult your browser's "help" menu to learn how to
remove or block Cookies). Hilton is not responsible for your browser settings.
You can find good and simple instructions on how to manage Cookies on the
different types of web browsers at www.allaboutcookies.org.
Please be aware that rejecting Cookies may affect your ability to perform
certain transactions on the Site, and our ability to recognize your browser from
one visit to the next.
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ANALYTICS AND INTEREST-BASED ADVERTISEMENTS
We partner with certain third-party service providers to collect information to
engage in analytics, auditing, research, and reporting. These third parties may
use server logs, web beacons, tags, pixels, and similar technologies, and they
may set and access Cookies on your computer or other device.
In particular, we use Adobe Analytics to help us understand how our customers
use our websites. We also use Adobe Audience Manager to create audiences for
personalizing content and advertising experiences. Read more about how Adobe
uses your Personal Information in web browsers by Adobe Analytics.
We also partner with Amazon Chat which supports our chat platform. We may use
Amazon Chat for sharing dynamic content for authenticated users.
We also partner with third parties to provide advertising services that are
targeted based on your online activities across websites, mobile apps, and
devices over time (commonly referred to as “interest-based advertising”). Our
advertising partners may collect information about your activities on our
Services on your current device and combine it with information about your
activities on other websites, mobile apps, and devices. They may collect such
information using server logs, Cookies, web beacons, tags, pixels, mobile
advertising IDs (such as Facebook Cookies or Google's Advertising ID),
cross-device linking, and similar technologies. For example, our advertising
partners may use the fact that you visited our website to target advertising to
you on other websites and mobile apps on your current device or on other devices
you use. They may match your browsers or devices if you log into the same online
service on multiple devices or if your devices share similar attributes that
support an inference that they are used by the same person or household. This
means that information about your activity on websites or apps on your current
browser or device may be combined and used with information collected from your
other browsers or devices. You can opt out of interest-based advertising in web
browsers and mobile apps on your current browser or device by following the
instructions below.
For more information about interest-based advertising and cross-device linking,
please visit the Network Advertising Initiative (“NAI”) website and the Digital
Advertising Alliance (“DAA”) website. We adhere to the DAA's interest-based
advertising principles by providing you enhanced notice, transparency, and
control of our digital marketing practices as stated at
http://www.aboutads.info/principles/. You may opt out of interest-based
advertising and cross-device linking in web browsers and mobile apps on your
current browser or device by following the instructions below.
* Web Browser Opt-Out. To opt out in web browsers, please visit
http://optout.aboutads.info/ and http://optout.networkadvertising.org. To
help preserve the choices that you make in the DAA's WebChoices page, you can
install the DAA's “Protect My Choices” extension that is available at
http://www.aboutads.info/PMC.
* Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the
advertising preferences on your mobile device (for example, in iOS, visit
Settings > Privacy & Security > Tracking, and in Android, visit Settings >
Google > Ads > Opt out of interest-based ads). You can also opt out for
companies that participate in the Digital Advertising Alliance's AppChoices
tool by downloading the app and following the instructions. For more
information about opting out on mobile devices, please see here.
Please note that the opt-outs described above will apply only to the specific
browser or device from which you opt out, and therefore you will need to opt out
separately on all of your browsers and devices. If you delete or reset your
cookies or mobile advertising identifiers, change browsers (including upgrading
certain browsers), or use a different device, any opt-out cookie or tool may no
longer work, and you will need to opt out again. We do not respond to Do Not
Track signals at this time.
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CHANGING AND ACCESSING YOUR PERSONAL INFORMATION
If you are a Hilton Honors member, you may review and update the information you
provided to us at the time of enrollment at any time by signing in to your
Hilton Honors account. You may also make changes to your information by
contacting Hilton Reservations and Customer Care by completing a support form.
If you are located in the United States or Canada, you can call customer care
toll free by dialing + 1-888-4HONORS (888-446-6677). Customers located outside
of the United States and Canada can review a list of customer care phone numbers
here.
You may be able to request that we inform you about the personal information we
maintain about you and, where appropriate, withdraw your consent for certain
data processing activity and/or request that we update, correct, delete, and/or
stop processing your personal information. We will make all required updates and
changes within the time specified by applicable law and as required by law. When
permitted by law, we may charge an appropriate fee to cover the costs of
responding to the request. Such requests may be submitted by accessing the Data
Subject Rights Requests Portal at datarights.hilton.com or in writing to
DataProtectionOffice@hilton.com or Hilton Data Protection Officer, 7930 Jones
Branch Drive, McLean, VA 22102, USA.
In addition, in some circumstances you may request that we cease sharing
personal information about you with our business partners or that Hilton cease
using personal information about you by contacting us using the email or mailing
address above.
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HOW WE PROTECT PERSONAL INFORMATION
We take reasonable measures to: (i) protect personal information from
unauthorized access, disclosure, alteration, or destruction, and (ii) keep
personal information accurate and up-to-date as appropriate.
Hilton employs a robust team of dedicated information security professionals who
are responsible for managing Hilton's security program. This team is responsible
for, among many other things, monitoring our systems for potential intrusions,
responding to potential incidents, supporting property-level information
security, regularly reviewing and updating the security controls Hilton uses to
protect data, and providing training on Hilton's information security program.
Hilton maintains a payment card industry (“PCI”) compliance program and an
Information Technology compliance program. This compliance program generates
audit reports concerning the adequacy and effectiveness of Hilton's Technology
internal controls, including a PCI Attestation of Compliance signed by an
external PCI Qualified Security Assessor and a SSAE16/SOC1 report addressing the
Technology general controls over systems that support certain accounting and
financial reporting.
We require third parties with whom we share personal information to exercise
reasonable efforts to maintain the confidentiality of personal information.
We will never ask you to send us confidential personal information or payment
card information via email or text message.
In the event of a security incident, Hilton will notify regulators and/or
consumers as required by applicable laws and regulations.
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DISCLOSURE PURSUANT TO LEGAL OBLIGATIONS OR TO PROTECT THE SAFETY AND SECURITY
OF PEOPLE AND PROPERTY
Hilton will disclose personal information as required by law. Examples of such
disclosures include when countries require Hilton to collect personal data about
visitors to properties in that country, when a law enforcement agency serves a
valid subpoena on Hilton, and when a civil litigant serves a lawful discovery
request on Hilton. Hilton may elect to share personal information with law
enforcement, employers, those who host events with Hilton, or others as
necessary to protect the safety and security of people and property, to pursue
available remedies or limit the damages that we may sustain, and to respond to
an emergency.
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MARKETING COMMUNICATIONS CHOICES
We want to make you aware of the fantastic products we offer! To do so, we may
send you communications via email, text message, push notifications, in-app
alerts, direct mail, and social media. In addition to traditional text messages,
we offer the opportunity to receive transactional and promotional messages via
text message by using a short code. A short code is a five-digit number that you
can message to opt-in to receive such text messages. We may also send you
marketing communications via WhatsApp. To enable us to send you such
communications, your information may be disclosed to service providers who use
such information solely to send out marketing communications on our behalf.
Furthermore, short code opt-in data and consent will not be shared with any
other third parties for their own marketing or advertising purposes. If,
depending on the circumstances, consent is required in your jurisdiction, we
will obtain your consent before sending you such communications.
If you are a Hilton Honors member, you may change the communications you receive
from us by logging on to your online account and managing your subscriptions; by
writing to us (and including your email address) at Hilton Data Protection
Officer, 7930 Jones Branch Drive, McLean, VA 22102, USA; or by emailing us at
DataProtectionOffice@hilton.com.
If you prefer not to receive email marketing materials from us, you may opt-out
at any time by using the unsubscribe function in any email you receive from us
or by clicking this link:
https://secure.hilton.com/en/hhonors/optout/unsubscribe.jhtml?listid=0, by
writing to us (and including your email address) at Hilton Data Protection
Officer, 7930 Jones Branch Drive, McLean, VA 22102, USA, or by emailing us at
DataProtectionOffice@hilton.com. Opt-out requests can take up to ten business
days to be effective.
To opt out of text or WhatsApp messages, reply “STOP” to the message you
received or to opt out of text messages from a specific hotel, tell the hotel
front desk that you do not want to receive text messages from the hotel .
You may control whether our mobile apps send you push notifications by changing
your notification settings on your mobile device. If we engage in sending you
in-app messages, we will allow control for those in our apps' settings.
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INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
As a global company, we endeavor to provide you with the same level of service
that you have come to expect at Hilton whether you are in San Francisco, London
or Tokyo. To provide this service, you acknowledge that we may share your
personal information among members of the Hilton Portfolio of Brands, our
service providers, and other third parties, which may be located in countries
outside of your own.
When you stay at a Hilton property outside the United States, the data
controller for that property transfers the personal information relating to your
reservation to Hilton in the United States pursuant to data transfer agreements
when required by applicable laws or regulations. The data controller may also
maintain a local copy of your personal information when so required by
applicable laws or regulations. Although the data protection laws of various
countries may differ from those in your own country, we will take appropriate
steps to ensure that your personal information is handled as described in this
Statement and in accordance with the law.
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DATA RETENTION PERIODS
We retain personal information about you necessary to fulfill the purpose for
which that information was collected or as required or permitted by law. When we
destroy your personal information, we do so in a way that prevents that
information from being restored or reconstructed.
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CHANGES TO THIS STATEMENT
We may modify this Statement from time to time. When we make material changes to
this Statement we will post a link to the revised Statement on the homepage of
our site. You can tell when this Statement was last updated by looking at the
date at the top of the Statement. Any changes to our Statement will become
effective upon posting of the revised Statement on the site. Use of the site,
any of our products and services, and/or providing consent to the updated
Statement following such changes constitutes your acceptance of the revised
Statement then in effect.
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CONTACT INFORMATION FOR QUESTIONS OR CONCERNS
If you have any questions or concerns, please contact us by sending an email to
DataProtectionOffice@hilton.com, by sending a letter to Hilton Data Protection
Officer, 7930 Jones Branch Drive, McLean, VA 22102, or by calling our toll-free
number: (800) 413-7470.
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ADDITONAL PROVISIONS APPLICABLE TO CALIFORNIA CONSUMERS
THE RIGHT TO KNOW, THE RIGHT TO DELETE, AND THE RIGHT TO OPT-OUT OF THE SALE OR
SHARING OF PERSONAL INFORMATION
The California Consumer Privacy Act (“CCPA”) affords California consumers (1)
the right to know what personal information we collect, use, disclose, and/or
sell; (2) the right to request that we delete their personal information; and
(3) the right to request that we no longer sell or share their personal
information.
If you would like information about the personal information that we collect,
disclose, sell and/or share about you, or if you would like to make a request
for us to delete or to stop selling your personal information, please visit our
website at datarights.hilton.com to submit your request. You also may call our
toll-free telephone number: (800) 413-7470, email the Data Protection Office
(“DPO”) at DataProtectionOffice@hilton.com, send a letter to the Data Protection
Office at 7930 Jones Branch Drive, McLean, Virginia, USA 22102, or complete a
paper form available from the front desk at any of our hotels. In addition to
these methods, California consumers may request that we no longer sell their
personal information by completing a personal data request form.
When the DPO receives your request, the DPO will first verify your identity. If
you are a Hilton Honors member, the DPO will verify your identity by asking you
to provide your name, Hilton Honors account number, and the email address and
phone number associated with your Hilton Honors account. If you are not a Hilton
Honors member, the DPO will verify your identity by asking you to provide your
name, the email address and/or phone number associated with a past stay, and
potentially a confirmation number from one of your stays at a Hilton property.
Once the DPO has verified your identity, the DPO will promptly fulfill your
request
If you would like, you may designate an authorized agent to make a request on
your behalf. To designate an authorized agent, please submit an order issued by
a court, a document submitted by a barred attorney, or a formal certified
document issued by an official governmental agency.
If you would like to opt out of the sale of your personal information, you may
do so by clicking on the banner that appears on any Hilton website when you
access that site from an IP address that relates to California or by visiting
our website at datarights.hilton.com or click the “Do Not Share or Sell My
Information” link at the bottom of any Hilton website to submit your request.
Please note that when you opt out of Cookies, tags, and pixels, that opt out
only pertains to the device and the browser that you are using when you opt out.
If you wish to opt out for other devices or browsers, you must opt out again
when you are using those devices or browsers.
SENSITIVE PERSONAL INFORMATION
We limit the use of your personal information to that use which is necessary to
perform reasonably expected services or as required by law.
DIRECT MARKETING DISCLOSURE
California consumers also may request information about our disclosures of
certain categories of personal information to third parties for their direct
marketing purposes. Such requests must be submitted to us at one of the
following addresses: CA_Privacy@hilton.com or DataProtectionOffice@hilton.com,
send a letter to the Data Protection Office at 7930 Jones Branch Drive, McLean,
Virginia, USA 22102. Within thirty days of receiving such a request, we will
provide a list of the categories of personal information disclosed to third
parties for third-party direct marketing purposes during the immediately
preceding calendar year, along with the names and addresses of these third
parties. This request may be made no more than once per calendar year. We
reserve our right not to respond to requests submitted to addresses other than
the addresses specified in this paragraph.
THE RIGHT TO NON-DISCRIMINATION
The CCPA prohibits a business from treating a consumer differently because the
consumer exercised a right conferred on him/her by the CCPA. We welcome you to
exercise your rights under the CCPA, and we will not discriminate against you
for doing so.
FINANCIAL INCENTIVE NOTICE
Hilton does not offer a financial incentive for the collection, sale, or
deletion of personal information. As detailed in this Statement, Hilton
primarily collects personal data from guests in order to fulfill guest
reservations and from Honors members in order to operate the Hilton Honors
loyalty program. Hilton also collects personal data for marketing and other
purposes as permitted by applicable law.
As set forth in the Hilton Honors Terms and Conditions, Hilton Honors members
have the ability to accumulate points and access discounted rates. The ability
to accumulate points and to access discounted rates is not directly related to
the value provided to the business of members' data.
REMOVAL OF CONTENT
If you are a California resident under the age of 18, and a registered user of
any site where this policy is posted, California Business and Professions Code
Section 22581 permits you to request and obtain removal of content or
information you have publicly posted. To make such a request, please send an
email with a detailed description of the specific content or information to
CA_Privacy@hilton.com. Please be aware that such a request does not ensure
complete or comprehensive removal of the content or information you have posted
and that there may be circumstances in which the law does not require or allow
removal even if requested.
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ADDITIONAL PROVISION APPLICABLE TO NEVADA CONSUMERS
THE RIGHT TO OPT-OUT OF THE SALE OF PERSONAL INFORMATION
If you are a Nevada resident, you may request that we stop selling certain
categories of personal information that we collect. To submit a request please
visit our website at datarights.hilton.com to submit your request. You also may
call our toll-free telephone number: (800) 413-7470, email the Data Protection
Office (“DPO”) at DataProtectionOffice@hilton.com, send a letter to the Data
Protection Office at 7930 Jones Branch Drive, McLean, Virginia, USA 22102, or
complete a paper form available from the front desk at any of our hotels. When
the DPO receives your request, the DPO will first verify your identity. If you
are a Hilton Honors member, the DPO will verify your identity by asking you to
provide your name, Hilton Honors account number, and the email address and phone
number associated with your Hilton Honors account. If you are not a Hilton
Honors member, the DPO will verify your identity by asking you to provide your
name, the confirmation number from one of your stays at a Hilton property, and
the email address associated with that stay. Once the DPO has verified your
identity, the DPO will promptly fulfill your request.
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ADDITIONAL PROVISION APPLICABLE TO FRENCH RESIDENTS
French residents: as disclosed in this Statement, we may collect your phone
number to fulfill guest reservations, send guests communications relating to
their reservations, provide customer service and support, verify identity, send
marketing communications via SMS, process transactions with partners, share data
with Hilton Grand Vacations, authenticate mobile accounts, send service-related
SMS communications, detect and prevent fraud, and engage in sales activities for
group bookings. We will not use your phone number for telemarketing.
Nonetheless, if you would like to register on the list of opposition to
telephone canvassing, you may do so at www.bloctel.gouv.fr.
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ADDITIONAL PROVISION APPLICABLE TO HONG KONG CONSUMERS
If you are based in Hong Kong, we will obtain your consent on or before sending
you any marketing messages. You may opt out of receiving marketing messages from
us at any time by using the unsubscribe link found in our marketing messages.
If you would like to access or correct your personal information, please contact
the Data Protection Officer (“DPO”) at DataProtectionOffice@hilton.com, or
complete the paper form available from the front desk at any of our hotels. We
may require further information from you in order to verify your identity before
processing your request. In certain circumstances where permitted to do so under
applicable law, we may refuse to fulfil your request.
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ADDITIONAL PROVISION APPLICABLE TO KOREAN DATA SUBJECTS
LOCAL AGENT FOR INFORMATION AND COMMUNICATION SERVICES
Local Agent. You may contact our Local Agent below by phone, email or mail to
handle questions and complaints in connection with the processing of your
personal data if you are in Korea.
* Local Agent: Jung Byung-hyuk (Brad Jeong), Managing Director, Conrad Seoul
* Telephone: 02-6137-7600
* Email: Brad.jeong@conradhotels.com
* Address: 10 Gukjegeumyuong-ro Yeouido, Seoul, 07326, South Korea
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APPENDIX A
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
INFORMATION OF RESIDENTS OF CERTAIN COUNTRIES AND US STATES
This Appendix provides additional information for individuals residing in
countries and U.S. states that have enacted privacy laws giving certain
additional rights to residents of those jurisdictions. Once effective, the U.S.
states include, but are not limited to, California, Colorado, Connecticut,
Delaware, Florida, Indiana, Iowa, Montana, Nevada, Oregon, Tennessee, Texas,
Utah, and Virginia. These countries include, but are not limited to, those in
the European Economic Area (EEA), the United Kingdom and Switzerland, as well as
Australia, Brazil, China, Korea, Hong Kong, Monaco, Israel, Japan, Nigeria and
Türkiye. This Appendix outlines certain additional information that Hilton is
obligated to provide to you, as well as certain rights you have with respect to
the processing of your personal information, pursuant to applicable local laws.
This Appendix will control to the extent it conflicts with any provision in the
main body of this Statement.
Controller: Find more information on the Hilton entities that process your
personal information at Data Controllers.
Data Protection Officer: Hilton's Data Protection Officer may be contacted by
email at DataProtectionOffice@hilton.com, or at the following address:
Attn: Data Protection Officer 7930 Jones Branch Drive, McLean, VA 22102 USA
PURPOSES AND LEGAL BASIS FOR PROCESSING
Hilton processes your personal information for the purposes set forth in the
section titled Collection of Personal Information - Generally and the section
titled Collection of Personal Information - Notice at Point of Collection of the
main body of this Statement.
The legal bases for Hilton's processing activities include processing such
information as necessary to comply with our contractual obligations, compliance
with our legal obligations, protecting the safety of our employees, guests and
others, for our legitimate business interests, and pursuant to your consent.
The particular legal basis for the processing of your personal information is
based on the purpose for which such information was provided or collected:
Hilton Honors Participation: We process the personal information obtained in
connection with your participation in the Hilton Honors program on the basis of
our contractual relationship with you, consent if legally required, and for
pursuing our legitimate business interests, including to personalize your use of
our services and applications, to communicate news and promotional items, and to
deliver personalized advertising and content.
Surveys: Completion of surveys is voluntary – we process the information
obtained from surveys on the basis of your consent and in furtherance of our
business interests, including marketing, service improvements, and analytics.
On-property Collection: When you make a reservation and when you stay at one of
our hotel properties, we process your name, address, contact information, along
with the details of your stay (arrival and departure day and time, vehicle
information and information regarding others traveling or staying with you), on
the basis of our contractual relationship with you.
* We also process such data for pursuing our legitimate business interests,
with your consent if legally required, including for marketing, service
improvements, administration of our e-Folio program, and analytics and
service personalization, as described in the sections referenced above of our
Global Privacy Statement.
* We collect certain additional personal information during
registration/check-in at our properties (such as national ID or passport
information), as necessary to comply with our legal obligations.
* We use closed circuit television and other security measures at our
properties that may capture or record images of guests and visitors in public
areas, as well as information related to your location while on our
properties (via keycards and other technologies) for the protection of our
staff, guests and visitors to our properties.
* We process personal information in connection with on-property services (such
as concierge services, health clubs, spas, activities, child care services,
equipment rental, and our Digital Key functionality), in order to provide the
services to you and for our business interests including for marketing,
service improvements, administration of our e-Folio program, and analytics
and service personalization, as described in the sections referenced above of
our Global Privacy Statement.
Event Profiles: We process the personal information obtained in connection with
your event on the basis of our contractual relationship with you and for
pursuing our legitimate business interests, with your consent if legally
required, including for marketing, service improvements, and analytics and
service personalization, as described in the sections referenced above of our
Global Privacy Statement.
Social Media: Participation in Hilton–sponsored social media activities and
offerings is voluntary – we process information obtained from social media
participation on the basis of your consent if legally required and for pursuing
our legitimate business interests, including for marketing, service
improvements, and analytics and service personalization, as described in the
sections mentioned above of our Global Privacy Statement.
Promotions and Sweepstakes: Participation in sweepstakes, contests and other
promotional offerings is voluntary – we process the information obtained from
such participation based on your consent and as necessary to administer the
offering. We also use certain data for our business purposes, including for
marketing, service improvements, administration of our e–Folio program, and
analytics and service personalization, as described in the sections referenced
above of our Global Privacy Statement.
Direct Marketing: We use your personal information to send you marketing
messages on the basis of your consent. You may withdraw your consent for direct
marketing communications at any time by contacting us at
customer_privacy@Hilton.com or by following the unsubscribe instructions in the
marketing message, or by logging in to your Hilton Honors account and updating
your communication preferences.
Franchise and Ownership Opportunities: We process this information on the basis
of our contractual relationship with you and for our related legitimate business
interests, including maintaining and promoting the Hilton brand and facilitating
direct communication between properties within the Hilton Portfolio of Brands.
WMBE Suppliers: Participation in Hilton's Supplier Diversity Program is
voluntary – we process this information based on your consent and for our
related business legitimate interests, including maintaining and enhancing our
diversity program.
Retention: We retain personal information about you for the time necessary to
accomplish the purpose for which such information was collected, usually for the
duration of any contractual relationship and for any period thereafter as
legally required or permitted by applicable law. Our retention policies reflect
applicable statute of limitation periods and legal requirements.
DATA SUBJECT RIGHTS
Some regional, national, and state laws confer rights relating to personal data
as indicated in the Personal Data Requests Portal. Residents of certain
jurisdictions may have the following rights.
Access, Correction and Erasure Requests: You have the right to:
* ask us to confirm whether we are processing your personal information and
receive information on how your data is processed
* obtain a copy of your personal information
* request that we update or correct your personal information
* request that we delete personal information in certain circumstances
Right to Object to Processing: You have the right to request that Hilton cease
processing of your personal information: for marketing activities, including
profiling
* for statistical purposes
* where such processing is based on our legitimate business interests, unless
we are able to demonstrate a compelling legitimate basis for such processing
or we need to process your personal information for the establishment,
exercise or defense of a legal claim
Right to Restrict Processing: You have the right to request that Hilton limit
the processing of your personal information:
* while Hilton is evaluating or in the process of responding to a request by
you to update or correct your personal information where such processing is
unlawful and you do not want Hilton to delete your data
* where Hilton no longer requires such data, but you want us to retain the data
for the establishment, exercise or defense of a legal claim
* where you have submitted an objection to processing based on our legitimate
business interests, pending our response to such request
Where we limit the processing of your personal information pursuant to your
request, we will inform you prior to re-engaging in such processing.
Right to Object to Sale and Share: You have the right to request that Hilton not
sell or share your personal information. Please visit our website at
datarights.hilton.com to submit your request or click on the Do Not Share or
Sell My Information link at the bottom of any Hilton website. You also may call
our toll-free telephone number: (800) 413-7470, email the Data Protection Office
(“DPO”) at DataProtectionOffice@hilton.com, or send a letter to the Data
Protection Office at 7930 Jones Branch Drive, McLean, Virginia, USA 22102.
Data Portability Requests: You have the right to request that we provide you or
a third party that you designate with certain of your personal information in a
commonly used, machine readable format. Please note, however, that data
portability rights apply only to personal information that we have obtained
directly from you and only where our processing is based on consent or the
performance of a contract.
Submitting Requests: Your requests may be submitted by accessing the Data
Subject Rights Request Portal or in writing to DataProtectionOffice@hilton.com,
or the Hilton Data Protection Officer, 7930 Jones Branch Drive, McLean, VA
22102, USA. You may also update your personal information as provided in section
titled (Changing and Accessing Your Personal Information) of the main body of
this Global Privacy Statement.
We will respond to all such requests within the time period permitted by law.
Please note, however, that certain personal information may be exempt from such
rights pursuant to applicable data protection laws. In addition, we will not
respond to any request unless we are able to appropriately verify the
requester's identity. We may charge you a reasonable fee for subsequent copies
of data that you request.
If you want to present a complaint or have concerns about our data practices or
the exercise of your rights, you may either contact Hilton at
DataProtectionOffice@hilton.com or the supervisory authority in the Member State
of your residence. For the EEA, the supervisory authorities are available at the
European Data Protection Board’s website. For the UK, the supervisory authority
is available at ico.org.uk.
Right to Withdraw Consent: You have the right to withdraw your consent to any
processing that we conduct solely based on your consent (such as sending direct
marketing materials to your personal email account). You may withdraw your
consent to marketing activities by following the instructions on any marketing
emails, or contacting customer_privacy@hilton.com. For any other activities for
which you have previously consented, you may contact
DataProtectionOffice@hilton.com to withdraw such consent.
Right to Object to Segmentation (also referred to as profiling) and Automated
Decision Making: You have the right to object to segmentation or profiling and
automated decision making. We use personal information to divide large groups of
consumers into sub-groups of consumers (known as segments) based on some type of
shared characteristics such as geography, behavior, or demographics.
With your consent, we make automated decisions, meaning without human
interference, using segmentation and/or your specific personal information to
offer you certain benefits based on your characteristics (such as discounted
room rates or other special offers based on your geography, behavior, or
demographics). For example, if you travel frequently during the week to hotels
in France, we may send you special offers for Hilton hotels in France.
International Data Transfers: We may transfer the personal information we
collect about you pursuant to the purposes described in this Statement to
countries that have not been found by the European Commission to provide
adequate protection. In particular, we transfer your personal information to the
United States.
We use appropriate safeguards for the transfer of personal information among our
affiliates in various jurisdictions, and where required, we have implemented
data transfer agreements, such as the European Commission standard contractual
clauses or other such safeguards for such purposes. To obtain a copy of theses
clauses or additional information on transfers, you may send your request to
privacy@hilton.com.
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APPENDIX B
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
INFORMATION OF DATA SUBJECTS IN TÜRKIYE
For data subjects in Türkiye, this Appendix outlines certain additional
information that Hilton is obligated to provide to you, as well as certain
rights you have with respect to the processing of your personal information,
pursuant to applicable local laws. This Appendix will control to the extent it
conflicts with any provision in the main body of this Statement, or Appendix A,
as applicable.
Data Controller. Hilton Domestic Operating Company Inc. is the Hilton entity for
all guest data and Hilton's marketing activities.
Your personal data may be processed by other Hilton entities in Türkiye who act
as a data controller based on the Hilton property you stay at. In such cases,
the relevant Hilton entity will act as the data controller for your personal
data, who will provide you with a separate privacy notice, where necessary.
Data Controller Representative. You may contact our data controller
representative in Türkiye by email or mail to handle questions and complaints in
connection with the processing of your personal data if you are in Türkiye.
* Esin Attorney Partnership
info@esin.av.tr
Akatlar Mah. Ebulula Mardin Cad. Gül Sok. No. 2
Legal bases for the processing your personal data. Hilton relies on the
following legal bases while processing your personal data for the purposes
indicated in the Global Privacy Statement in accordance with Article 5 of the
Law No. 6698 on Protection of Personal Data (“Data Protection Law”):
* processing of your personal data is necessary provided that it is directly
related to the conclusion or fulfilment of the contract between you and
Hilton;
* processing is mandatory for Hilton to be able to comply with our legal
obligations;
* processing is mandatory for Hilton’s legitimate interests, provided that it
does not violate your fundamental rights and freedoms; or
* your explicit consent. (Please note that we rely on your explicit consent
only when we require your consent for the processing and we do not rely on
this legal basis if and when we rely on one of the other legal grounds
above.)
Your rights. You have the rights under Article 11 of the Data Protection Law and
may exercise your rights by contacting us at: DataProtectionOffice@hilton.com or
Data Protection Officer, Hilton, 7930 Jones Branch Drive, McLean, VA 221102,
USA.
The requests found in your application will be resolved as soon as possible
according to the nature of your request and within thirty days at the latest
free of charge. However, if your request incurs additional cost to our company,
then you may be charged over the tariff fee determined by the Turkish Personal
Data Protection Board.
Amendments. The following sections of the Global Privacy Statement do not apply
to individuals in Türkiye: The following sentence at the second paragraph: By
using any of our products or services and/or by agreeing to this Statement, e.g.
in the context of registering for any of our products or services, you
understand and acknowledge that we will collect and use personal information as
described in this Statement.
The following sentence in the International Personal Data Transfers section: To
provide this service, you acknowledge that we may share your personal
information among members of the Hilton Portfolio of Brands, our service
providers, and other third parties, which may be located in countries outside of
your own.
Language. This Statement is available in English and Turkish. If there is any
inconsistency or different interpretation between the English and Turkish
versions, the Turkish text shall prevail.
International Data Transfers. Hilton is required to transfer your personal data
to its affiliates outside of Türkiye, which includes Hilton Domestic Operating
Company Inc., all resident in the United States, as well as their in-country
suppliers, in order to complete reservations, process Hilton Honors memberships
and conduct promotion activities through its website, whose servers are located
abroad. Without your consent, Hilton is unable to provide you with its services
through this website. Therefore, we ask for your consent when you access this
website for the cross-border transfer of your data.
This consent practice is only temporary, and Hilton is working on effecting an
undertaking letter, which is one of the alternative legal mechanisms for
cross-border data transfers. Accordingly, the consent practice will be
terminated once the undertaking letter is prepared and approved by the Personal
Data Protection Authority.
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APPENDIX C
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
INFORMATION OF CHINA RESIDENTS OR CITIZENS
1. INTRODUCTION
For individuals who reside in the People's Republic of China (for the purposes
of this Privacy Statement, excluding Hong Kong Special Administrative Region,
Macau Special Administrative Region and Taiwan) ("China") or citizens of the
People's Republic of China, we understand that privacy is important to you.
Therefore, in this Appendix, we provide you with an introduction to how Hilton
collects, uses, discloses, and otherwise processes your personal information
(including sensitive personal information, where applicable) that we receive or
collect from you. Please read this Statement carefully before using any of
Hilton's services or products.
This Appendix does not replace the main body of this Statement, but supplements
the main body of this Statement, and should be read together with the main body
and Appendix A, as applicable. In the event of any conflict or inconsistency
between this Appendix and the main body of this statement, this Appendix shall
prevail.
“Personal Information” shall have the same meaning as defined in the Personal
Information Protection Law of the People's Republic of China (as revised from
time to time). Such information can be recorded electronically or in other ways
and can identify the identity or reflect the activity of a specific natural
person alone or in combination with other information, including sensitive
personal information. "Personal Information" or "Information" used in the main
body of this Statement and in this Appendix also includes Sensitive Personal
Information (where applicable). “Sensitive Information” shall have the same
meaning as defined in the Personal Information Protection Law of the People'
Republic of China (as revised from time to time). The Sensitive Personal
Information involved in this Statement includes passport or ID card information,
payment card information, accommodation information (such as arrival time), web
browsing records, and precise positioning information. You agree that the
sensitive personal information will be processed in accordance with the purposes
and methods set forth in this Statement.
2. COLLECTION AND USE OF PERSONAL INFORMATION
Regarding the following issues, please refer to the section titled Collection of
Personal Information – Generally and Collection of Personal Information – Notice
at Point of Collection in the main body of this Statement.
* The types of personal information that we collect from you (including
sensitive personal information, which include the information that may
applicable as set out in the section titled Collection of Personal
Information – Notice at Point of Collection) in the main body of this
Statement.
* How we collect and use your personal information, the purposes for which we
use it, and how we share or disclose your personal information.
Hilton will not knowingly collect or disclose personal information from minors
under the age of 16. When we collect personal information from an individual
under the age of 16, we need to obtain consent from his/her parent or guardian
and we will process such information in accordance with the safeguards set out
in applicable laws and regulations.
We will use your personal information with your consent or as otherwise required
or permitted by applicable law. If we want to use your personal information for
other purposes, we will obtain your further consent. We will explain when it is
necessary for you to provide your personal information, and the result if you
provide.
3. DISCLOSURE AND SHARING OF PERSONAL INFORMATION
With your consent, we may share your personal information for the purposes
described in this Statement with members of the members of Hilton worldwide
brand portfolio, our service providers, and other third parties as follows:
* Hilton Worldwide Holdings Inc. and its subsidiaries, and members of the
Hilton brand portfolio, including franchised and managed hotels,
* Service providers providing services on Hilton's behalf,
* Payment card providers and processors,
* Employers specified in the company agreements,
* Advertising networks and analytics providers for Hilton's website and mobile
applications.
To provide and optimize our services, third-party software development kits
(SDKs) are embedded in our applications (including WeChat Mini Programs). The
following lists the names of the third-party SDKs we currently embed, the types
of personal information collected, and the purpose of collection and use. If you
have questions about the collection of your personal information by the third
parties through the SDKs, please refer to the privacy policies of such third
parties.
Name of the SDK
Provider of the SDK
Purposes of the SDK
Application where the SDK is embedded
Types of personal information collected by the SDK
Link to the privacy policy of the SDK
Alipay "App Payment" SDK
Alipay (China) Network Technology Co., Ltd.
Payment
iOS, Android
Common device information (IMEI/IMSI, SIM card serial number/MAC address,
android id (only for Android devices)), network information
https://opendocs.alipay.com/open/01g6qm
WeChat Pay
Tencent
Payment
iOS, Android, WeChat Mini-Program
WeChat User OpenId
https://weixin.qq.com/cgi-bin/readtemplate?t=weixin_business_pay
Adobe Analytics SDK for WeChat Mini-Program
Adobe
User clicks and usage records
WeChat Mini-Program
Location information, device information, version of operating system
https://github.com/NJRojas/aep-sdks-documentation/tree/master/resources/adobe-experience-platform-mini-programs-sdk
Adobe Analytics SDK
Adobe
User clicks and usage records
iOS, Android
Location information, device information, version of operating system
https://www.adobe.com/cn/privacy/policy.html
Baidu Maps SDK
Baidu
Displaying hotels nearby on the map
Android
Location information (domestic users)
https://lbsyun.baidu.com/index.php?title=open/law
Google Maps SDK
Google
Displaying hotels nearby on the map
Android
Location information (domestic users)
https://developers.google.cn/maps/faq?hl=zh-cn#tos_logging
Workspace one
Omnissa
Recording app crashes and error messages
iOS, Android
Device information, version of operating system
https://www.omnissa.com/omnissa-workspace-one-privacy-disclosure/
Despite the above situations, we may disclose personal information to third
parties to: comply with applicable laws or effective legal procedures; respond
to enquiries of the governments or requests of the public and/or the government
authorities; protect rights, privacy, security or property of Hilton, site
visitors, guests, employees or the public; pursue or exercise our rights; or
respond to emergencies.
4. MOBILE AND LOCATION SERVICES
We may collect your personal information if you download and use our mobile
applications or use other digital platforms such as our WeChat Mini-Programs. We
will obtain your consent and collect, use, disclose and otherwise process this
information in accordance with this Statement. If you allow us to access the
location information on your device to provide you with our application features
and services, such information may include geolocation information. We also
collect information device information, such as your phone brand, model,
operating system, operating system version, to direct you to the appropriate APP
store to download our mobile apps.
You can prevent or limit the collection of this information by changing the
settings in the Hilton Honors APP or by changing the settings in your device.
5. ANALYTICS AND INTEREST-BASED ADVERTISEMENTS
We also cooperate with third parties to serve targeted advertising based on your
online activities across different websites, mobile applications, and devices
over time. Our advertising partners may collect information about your
activities related to our services on your current device and combine it with
information about your activities on other websites, mobile applications, and
devices. They may collect this information using server logs, Cookies, web
beacons, tags, pixels, mobile advertising IDs, cross-device linking and similar
technologies. This may include your personal information.
You can opt out interest-based advertising and cross-device linking in the
current browser or the web browsers and mobile apps on your device. We do not
currently respond to "do not track" signals. For more information, please see
the section titled Analytics and Interest-Based Advertising as well as the
section titled Cookies and Other Technologies, in the main body of this
Statement.
6. CHANGING AND ACCESSING YOUR PERSONAL INFORMATION, AND DEREGISTRATION OF
ACCOUNTS
You have the right to access, correct and/or (in certain circumstances) delete
your personal information, withdraw consent to our processing of your personal
information, deregister your membership account (if any), object to the use of
your personal information in automated decision making and make complaints about
how we process your personal information. You may have other rights under other
applicable laws. Please see the contact information in Section 11 below, or the
section titled Changing and Accessing Your Personal Information in the main text
of this Statement, to learn how to contact us. We seek to handle these requests
within the legally required period in accordance with the applicable laws.
Particularly, we will respond to your request to deregister within 15 days of
our receipt of the request, unless there are extenuating circumstances, in which
we will inform you of the anticipated timeline if we expect our response to take
longer than 15 days. Please note that if you request to deregister your
membership account, you will no longer be able to enjoy any membership benefits
from the date of deregistration. After you deregistered your membership account,
your personal information will be deleted or anonymized unless the applicable
laws require us to retain this information.
7. HOW WE PROTECT PERSONAL INFORMATION
We take reasonable steps to: (i) protect personal information from unauthorized
access, disclosure, alteration, or destruction, and (ii) keep personal
information appropriately accurate and current by using appropriate technical
and organizational measures. For more information, please see the section titled
How We Protect Personal Information in the main body of this Statement.
We are not responsible for the collection, use, disclosure, or otherwise
processing of personal information by our third-party websites or applications.
Please read the privacy policies and terms of use of these websites and
applications. This applies to: (1) in-hotel internet services we may offer; (2)
third-party websites and applications to which the links in our websites and
mobile applications may direct; and (3) third-party digital messaging
applications or platforms which we use to communicate with you.
8. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
With your express consent, we may transfer your personal information (including
your sensitive personal information, if applicable) outside of China, including
United States, Europe, and other jurisdictions where we, our service providers
and other relevant third parties conduct business. We will take appropriate
steps to protect the integrity and confidentiality of your information and to
ensure that your personal information is processed in accordance with the main
body of this Statement and in accordance with the applicable laws.
9. DATA RETENTION PERIOD
We will retain personal information about you for as long as necessary to
complete the purpose for which it was collected, or as required or permitted by
the laws. We will destroy your personal information in accordance with our
retention and records management procedures. For more information, please see
the section titled Data Retention Period in the main body of this Statement.
10. CHANGES TO THIS STATEMENT
If we make material changes to this Statement, we will publish these changes.
For more information, please see the section titled Changes to Statement Content
in the main body of this Statement. If required by the local laws, we will
notify you and/or seek your consent.
11. CONTACT INFORMATION FOR QUESTIONS OR CONCERNS
You can contact us if you have any questions, requests, or complaints regarding
the protection of personal information. You can contact our Data Protection
Office at DataProtectionOffice@hilton.com, or, if you would like to get in touch
with the contact in China, please contact: China_Privacy@hilton.com.
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APPENDIX D
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
INFORMATION OF BRAZIL RESIDENTS OR CITIZENS
To the extent you are located within Brazil or is any form subject to the
Brazilian General Data Protection Law – Federal Law nº 13709/18 (“LGPD”), the
provisions indicated below should be read and applied to the processing or your
personal data accordingly. Unless stated otherwise in this Annex, the remainder
of the Policy, including Appendix A as applicable, shall not vary and shall
remain in full force and effect.
1. DATA SUBJECTS RIGHTS
Under certain circumstances, you have the following rights under the LGPD in
relation to your personal data:
* Right to Information: right to obtain clear, transparent and understandable
information on how we use your personal data;
* Right of confirmation and access: right to receive confirmation and access
your personal data held by us about you;
* Right of rectification: right to have your personal data corrected if they
are outdated, inaccurate or incorrect and/or to complete them;
* Right of anonymization, blocking or deletion: Anonymize, block or eliminate
any unnecessary or excessive data or data processed in noncompliance with the
applicable law;
* Right to withdraw consent at any time for consent-based data processing:
right to withdraw your consent to the processing of your personal data when
such processing is based on consent;
* Right to data portability: right to request copying, transferring your
personal data to another database in accordance with further regulation of
the local authority;
* Right to receive information about public and private entities: right to
receive information about public and private entities with which your
personal data is shared;
* Right to object: right to oppose any processing activity based on a legal
basis other than consent in case there is violation of the LGPD;
* Right to review automated decisions: right to review of decisions, whenever
they are based only on automated processing of personal data, by a natural
person, whenever it affects your interests;
* Right to file a complaint with your local Data Protection Authority or
consumer protection entities.
2. LEGAL BASES
Hilton usually relies on one of the following legal bases when processing your
personal data for the purposes indicated in the Global Privacy Statement in
accordance with Article 7 of the LGPD:
* Data subject’s consent (art. 7, I)
* For compliance of a legal or regulatory obligation (art. 7, II)
* Whenever necessary for the performance of a contract or preliminary
procedures relating to contracts in which the data subject is a party (art.
7, V)
* Whenever necessary for the legitimate interests of the controller or of third
parties, except in the prevalence of fundamental rights of the data subject
(art. 7, IX).
However, depending on the concrete situation, other legal bases set forth in the
LGPD may apply.
3. INTERNATIONAL TRANSFERS
Where we transfer information that originates in Brazil to a country outside of
Brazil, we will take steps to make sure such transfer is carefully managed to
protect your privacy rights:
* Transfers within the Hilton Group of Companies may be covered by an agreement
entered into by members of Hilton (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
Hilton in accordance with the LGPD;
* Where we transfer your data outside of the Hilton Group of Companies,
including to other companies providing us with a service, we will obtain
contractual commitments and assurances from them to protect your information,
such as standard contractual clauses or binding corporate rules. In the lack
of instructions from the local supervisory authority, we may follow the
standard models adopted under the European Union or by other competent
authorities until then;
* We are also able to 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
Please contact us if you want further information on the specific mechanism used
by us when transferring your personal data out of Brazil.
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APPENDIX E
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
DATA OF DATA SUBJECTS IN THE PRINCIPALITY OF MONACO
For data subjects in the Principality of Monaco, this Appendix outlines certain
additional information that Hilton is obligated to provide to you, as well as
certain rights you have with respect to the processing of your personal data,
pursuant to applicable local laws. This Appendix will control to the extent it
conflicts with any provision in the main body of this Statement or Appendix A,
as applicable.
1. LEGAL BASES FOR THE PROCESSING OF YOUR PERSONAL DATA
Hilton relies on legal bases while processing your personal data for the
purposes indicated in the main body of the Global Privacy Statement in
accordance with the Monegasque Law No. 1.165 of 23 December 1993 on Protection
of Personal Data, as amended (the “Data Protection Law”).
2. PERSONAL DATA ACCESS AND CUSTOMER RIGHTS
In accordance with the Data Protection Law, you have a right of access to and a
right to the rectification, erasure and portability of your personal data as
well as a right to object and restrict the processing of this personal data.
With proof of your identity, you may exercise your rights by contacting the Data
Protection Officer (“DPO”) by email at DataProtectionOffice@hilton.com. If,
after contacting the DPO, you do not feel that your rights have been observed,
you may make a claim with the French Data Protection Authority (CNIL –
Commission Nationale de l'Informatique et des Libertés) or the Monegasque
authority, the Commission for Control of Personally Identifiable Information
(CCIN.mc – Commission de Contrôle des Informations Nominatives).
3. PERSONAL DATA SECURITY
In case of breach of your personal data liable to pose a high risk to your
rights and freedoms, Hilton shall inform you as soon as possible and take all
necessary measures to limit the risks related to this breach. Whether your data
is processed by Hilton or by its subcontractors and partners, the same security
and privacy requirements apply to your personal data.
4. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Hilton is required to transfer your personal data to its affiliates outside of
the Principality of Monaco which includes Hilton Domestic Operating Company
Inc., all resident in the United States, as well as their in-country suppliers,
in order to complete reservations, process Hilton Honors memberships and conduct
promotion activities through its website, whose servers are located abroad.
When a subcontractor or partner is located in a country that has not been
recognized as having an adequate level of protection as the one offered by the
Data Protection Law (which is the case for the United States), Hilton must
fulfil a transfer authorization form in order to comply with the Data Protection
Law’s own requirements on the security and privacy of personal data and the
subcontractors should ensure a satisfactory protection of your personal data.
5. LANGUAGE
Statement is available in English and French. If there is any inconsistency or
different interpretation between the English and French versions, the English
text shall prevail.
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