www.ihg.com Open in urlscan Pro
2.23.209.174  Public Scan

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English
Country/Region United KingdomUnited
States----------------------------AfghanistanAland IslandsAlbaniaAlgeriaAmerican
SamoaAndorraAngolaAnguillaAntarcticaAntigua and
BarbudaArgentinaArmeniaArubaAustraliaAustriaAzerbaijanBahamasBahrainBangladeshBarbadosBelarusBelgiumBelizeBeninBermudaBhutanBolivia,
Plurinational State ofBonaire Saint Eustatius and SabaBosnia and
HerzegovinaBotswanaBouvet IslandBrazilBritish Indian Ocean TerritoryBrunei
DarussalamBulgariaBurkina FasoBurundiCambodiaCameroonCanadaCape VerdeCayman
IslandsCentral African RepublicChadChileMainland ChinaChristmas IslandCocos
(Keeling) IslandsColombiaComorosCongoCongo, Democratic Republic of theCook
IslandsCosta RicaCroatiaCubaCuraçaoCyprusCzech RepublicIvory
CoastDenmarkDjiboutiDominicaDominican RepublicEcuadorEgyptEl SalvadorEquatorial
GuineaEritreaEstoniaEthiopiaFalkland IslandsFaroe IslandsFijiFinlandFranceFrench
GuianaFrench PolynesiaFrench Southern
TerritoriesGabonGambiaGeorgiaGermanyGhanaGibraltarGreeceGreenlandGrenadaGuadeloupeGuamGuatemalaGuernseyGuineaGuinea
BissauGuyanaHaitiHeard Island and McDonald IslandsHondurasHong
KongHungaryIcelandIndiaIndonesiaIran, Islamic Republic ofIraqIrelandIsle of
ManIsraelItalyJamaicaJapanJerseyJordanKazakhstanKenyaKiribati, Republic ofKorea,
Democratic People's Republic ofKorea, Republic ofKuwaitKyrgystanLaos, People's
Democratic Republic
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IslandsNorwayOmanPakistanPalauPalestinian National AuthorityPanamaPapua New
GuineaParaguayPeruPhilippinesPitcairnPolandPortugalPuerto
RicoQatarReunionRomaniaRussian FederationRwandaSaint BarthelemySaint HelenaSaint
Kitts and NevisSaint LuciaSaint Martin (French)Saint Pierre and MiquelonSaint
Vincent and the GrenadinesSamoa, Independent State ofSan MarinoSaint Thomas and
Prince IslandsSaudi ArabiaSenegalSerbiaSeychellesSierra LeoneSingaporeSint
Maarten (Dutch)SlovakiaSloveniaSolomon IslandsSomaliaSouth AfricaSouth Georgia
and the South Sandwich IslandsSouth SudanSpainSri LankaSudanSurinameSvalbard and
Jan MayenSwazilandSwedenSwitzerlandSyrian Arab RepublicTaiwanTajikistanTanzania,
United Republic ofThailandTimor-Leste, Democratic Republic
ofTogoTokelauTongaTrinidad and TobagoTunisiaTurkeyTurkmenistanTurks and Caicos
IslandsTuvaluUgandaUkraineUnited Arab EmiratesUnited States Minor Outlying
IslandsUruguayUzbekistanVanuatuVatican City StateVenezuela, Bolivarian Republic
ofVietnamVirgin Islands, BritishVirgin Islands, U.S.Wallis and FutunaWestern
SaharaYemenZambiaZimbabwe
language English
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PRIVACY STATEMENT



Book With Us Advantage


Worldwide Reservation Offices

 

--------------------------------------------------------------------------------

Who we are


Information we collect and how we use and share it

The legal basis for processing your personal data

Data transfer

Using our websites, mobile applications and other technology

Cookies and other tracking technologies

Use of WI-FI services (IHG Connect)

Using Personal Information to create profiles

How we secure your information

Managing your preferences and information

Links to other sites

Children

Retaining your information in our systems

How to contact us

Additional Information for UK/EU/EEA, Turkey, U.S, People’s Republic of China,
and Brazil

Additional Information for U.S. Consumers

CALIFORNIA CONSUMER RIGHTS

California Notice of Financial Incentive

Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, and Virginia
Consumer Rights

Loyalty Programme Disclosures for Colorado Consumers

Additional Information for The People’s Republic Of China (excluding for the
purposes of this statement Hong Kong SAR, Macau SAR And Taiwan) (“PRC”)

BRAZIL DATA SUBJECTS' RIGHTS UNDER BRAZIL DATA PROTECTION LAW

Changes to this Privacy Statement

 

The privacy and security of your information is very important to us. Whether
you are visiting our website, using our app, booking a room, or are a member of
one of our loyalty programmes, we want you to trust the way that we manage your
information and to keep you informed about how we use that information.

We have prepared this Privacy Statement to explain more about who we are, how we
collect and manage your information (whether through our website, mobile apps
and other IHG® Hotels & Resorts-branded digital channels (e.g., our branded IHG
Connect WiFi), our social media pages or offline) and the choices you have about
how we use your information. Specific additional rights may apply if required by
applicable law. For example, please view our additional disclosures directed to
residents of particular states within the United States, the UK, European
Economic Area (EEA) and Turkey, Brazil, and the People’s Republic of China
(Excluding for the purposes of this statement Hong Kong Sar, Macau Sar and
Taiwan) (“PRC”), in this Privacy Statement.

--------------------------------------------------------------------------------

WHO WE ARE

This Privacy Statement is issued by the InterContinental Hotels Group of
Companies (collectively referred to as "IHG”, “IHG® Hotels & Resorts”, "we”,
"us” or "our” in this Privacy Statement), which includes the direct and indirect
subsidiaries of InterContinental Hotels Group PLC and covers information that we
collect and use in the course of our business. When we mention “IHG”, “IHG®
Hotels & Resorts”, “we”, “us”, or “our”, we are referring to the relevant
company in the InterContinental Hotels Group that processes your personal
information. Your information may also be collected and used by IHG® Hotels &
Resorts-branded hotels. In most cases, these hotels are independently owned and
their use of your information is covered by their own privacy notices, not this
one. If you would like to learn more about IHG and our relationship with our
IHG® Hotels & Resorts-branded hotels, click below.



ABOUT IHG

We are a global hospitality company operating in more than 100 countries. We
predominantly franchise our brands to, and manage hotels on behalf of,
independent owners. We also operate programmes that are related to our hotel
business such as IHG® One Rewards, which is our core loyalty programme.


ABOUT OUR IHG-BRANDED HOTELS

We franchise our brands to and manage hotels on behalf of independent owners
(“IHG® Hotels & Resorts-branded hotels” or “IHG-branded hotels”). Most hotels
operating under IHG’s brands are independently owned and operated by parties
that have entered into a franchise agreement with IHG that allows them to use an
IHG brand for the purposes of operating a hotel. References to IHG-branded
hotels also include Iberostar Beachfront Resorts which can be booked via IHG’s
reservation system and which are part of IHG® One Rewards. If you make a
reservation through us to stay at an IHG-branded hotel, we will disclose certain
information with that hotel in order to enable your stay at the hotel. However,
as IHG-branded hotels are not owned or controlled by IHG, their use of your
information will be governed by their own privacy practices.

--------------------------------------------------------------------------------

INFORMATION WE COLLECT AND HOW WE USE AND DISCLOSE IT

We collect personal information directly from you, about you from other
persons/entities/online channels, and automatically as you use our website,
mobile application or other IHG-branded digital channels, and through services
available at IHG-branded properties (such as IHG Connect Wi-Fi). We provide more
detail in the sections below. In particular, we collect and use information
about you if you (or someone on your behalf) make a reservation to stay at an
IHG-branded hotel or property offered through IHG reservations, participate in
one of our loyalty programmes such as IHG® One Rewards, or interact with us
through our corporate site, mobile app or other IHG-branded digital channels.
You do not have to provide us with your personal information in order to use our
website or mobile app; however, in some cases we may not be able to provide
services to you without your personal information (for example, we would not be
able to complete a requested booking or enroll you in our rewards programme). To
learn more about how we collect, use and share your information and how you can
opt out, please click on the relevant section below.


IF YOU MAKE A RESERVATION OR STAY AT AN IHG-BRANDED HOTEL

Information we collect:


Directly From You: We collect information from you when you make a booking
through our reservation system, stay at an IHG-branded hotel, or respond to a
survey. Information collected during the reservation and your stay may include:

 * Your name, email address, home and business address, phone number,
   nationality and payment card information; for some reservations we may also
   collect national ID/passport information on behalf of the IHG-branded hotel
   where this is required by the hotel to comply with applicable local laws or
   by the hotel’s local policies.
 * Information relating to your membership in one of our services or programmes
   or those of our programme partners such as your IHG® One Rewards number or
   airline frequent flier number; and
 * Information such as stay and room preferences made during your reservation
   such as your preferred room type and specific requests to the hotel.

If you provide personal information to us about other persons when making a
booking or during your stay, for example, family members or colleagues, we ask
you to make sure they are happy for their personal information to be shared with
us and to direct them to read this Privacy Statement if they want to find out
more about how we use their information.

From IHG-branded properties: We receive information about your bookings and
stays from IHG branded hotels including those you booked directly with the
property. The information we receive includes names of those included on the
booking, dates of your stay, number of adults and children staying, rate detail,
room type, board type/meal plans and purchases made during your stay.

From Other Sources: We also collect reservation information about you from other
persons/entities, including, travel agents, websites not owned and operated by
IHG, persons booking on your behalf (e.g., a family member, company
representative), your employer, or other entity. We may obtain information about
you from social media pages; for example, if you make a comment on IHG’s social
media page or if you comment about IHG on a public social media feed. We use
this information to improve our services to you and to other customers.

Automatically: We collect information about you automatically as you use our
website, mobile app, our social media sites, interact with our other digital
channels, and, in some instances, when we correspond with you through email. In
these instances, information such as your country information, internet protocol
(“IP”) address, device ID, medial access control address, your interactions with
these channels, and other characteristics about your system or device may be
automatically collected. This information is collected for functional purposes
and to improve your experience when using these services. This information may
also be used for fraud prevention, aggregated trend and statistical analysis,
and for showing you more relevant advertisements and messages. More information
on these practices can be found in the Using our websites, mobile applications,
and other technologies section below. We do not typically associate an IP
address with your IHG® One Rewards profile.

Special Hotel Programmes/Biometrics: At IHG, we are always seeking more ways to
enhance your experience with us. A limited number of properties now offer a
biometrics check-in process to eliminate your need to stand in line. Some
properties also may allow room access through the collection of biometric
information. These programmes are opt-in only, and any information that we
collect through your participation will be used solely for the programme as
described in the notice provided to you at the time of the opt-in.

How we use this information:

We use your information primarily to fulfil your hotel reservations and to
provide and manage our IHG® One Rewards programme. This may include
communicating with you (e.g., sending a confirmation email) in advance of your
stay. Following your stay, we may also send you post-stay communications and
satisfaction surveys to get feedback on your experience.

Where we have your consent or as permitted under applicable law, we may send you
marketing communications (which may include text messages or calls placed using
autodialer technology) for products and services that we believe would be
relevant for you. We also may use information related to you and your stays to
display targeted advertisements on our websites, mobile apps, our other digital
channels or on non-affiliated websites or mobile apps, or to send you more
relevant messaging. Additionally, we aggregate your information with other guest
information to complete trend and statistical analysis, which we use to evaluate
and improve our products and services, plan new hotel locations and services,
and for other market research.

We will indicate whether the requested information is mandatory; the failure to
provide such information may impact our ability to and/or prevent us from
providing certain services to you.

Who we disclose your information with:

We disclose your reservation information as follows:

 * IHG-Branded Properties: We disclose your reservation information with the
   property you are staying at to fulfil your reservation and for properties to
   communicate with you regarding your stay. This includes information such as
   name, email address, dates of your stay, passport/national ID information
   where this is required by the hotel, and IHG® One Rewards information such as
   your member tier, and length of membership.
 * Service Providers: We will disclose your information with service providers
   to provide services related to our business and to help us improve our
   products and services. For example, we might use a service provider or a
   service provider’s product for the purposes of market research and data
   analytics, to communicate with you and serve advertisements through their
   platforms or on other websites or platforms. In certain instances, subject to
   local consent requirements, our service providers may also assist us with
   various marketing campaigns. These companies are authorised to use your
   personal information only as necessary to provide these services to us.
 * Partners: Where permitted by applicable law, or where we have your consent,
   we may also disclose your information with other parties, including our IHG®
   One Rewards partners and others, to extend special offers about their own
   products and services to you. You have options about whether you wish to
   receive these communications and offers; please log into the IHG® One Rewards
   preference centre at any time to view and exercise your communications
   choices. In addition, certain U.S. state residents may have the option of
   clicking on the “Do Not Sell or Share My Personal Information” link, which
   would eliminate the sharing that might constitute a sale under applicable
   law. Other requests may be directed to one of our global customer care
   offices or the Privacy Office.

We also share your stay information with other entities, which may include law
enforcement, professional advisors, and other persons, in circumstances such as:

 * when we believe in good faith that the disclosure is required by law or to
   protect the safety of hotel guests, employees, the public or IHG property;
 * when disclosure is required to comply with a judicial proceeding, court
   order, subpoena, warrant or legal process; or
 * in the event of a merger, asset sale, or other related transaction.


IF YOU JOIN ONE OF OUR LOYALTY PROGRAMMES

Information we collect:

We collect information from you during your membership in any of our loyalty
programs and services, including our core loyalty programme, IHG® One Rewards.
Information collected during your enrolment and participation in these programs
may include:


 * Your name, email address, home and business address, phone number,
   nationality, birthday and payment card information;
 * Your membership number and password as well as details of your memberships
   with any of our programme partners such as our airline or car rental
   partners;
 * Information that you choose to provide in your loyalty profile, such as your
   personal stay and destination preferences; and
 * Marketing and communications preferences, including how you prefer to be
   contacted by IHG as well as what types of information you are interested in
   hearing about.
 * Your stays at IHG-branded properties, including the property name, dates of
   stay, and, in some circumstances, the total GBP amount of your stay,
   food/beverage and other purchases (and, in some circumstances, an itemised
   breakdown of your spend at the property).

We may collect this information from you, other sources, and automatically.

From You/Other Person acting on Your Behalf: We collect your information through
our global reservation and Customer Care offices, through our websites, through
our mobile applications or through our other digital channels.

IHG-Branded Properties: We receive information about your stay from IHG-branded
hotels and other properties within the IHG network so that we can honour the
programme.

Service Providers: We may also collect information about you from other sources,
including entities that assist us in confirming the accuracy of your mailing
address; in some circumstances, we do not receive the updated address
verification from the vendor; rather, the vendor may simply update our mailing
with the address that it believes is aligned with the postal service
requirements. We may also obtain Personal Information from data enrichment
providers where permitted under applicable law.

Other Sources: We may obtain information about you from social media pages; for
example, if you make a comment on IHG’s social media page or if you comment
about IHG on a public social media feed. We use this information to improve our
services to you and to other customers. We do not typically append this
information to your rewards profile. We also obtain demographic information from
entities, which typically is in aggregated form. We may use this information in
combination with information in your profile to identify relevant opportunities
about which to notify you.

Your Friends:  We may obtain information about you from friends if they refer
you to us, where necessary with consent or another appropriate legal basis.

Automatically: We collect information about you automatically through our
website, mobile app, our emails, and social media sites. In these instances,
information such as your country information, internet protocol (“IP”) address,
device ID, medial access control address, and other characteristics about your
system or device may be automatically collected in accordance with an
appropriate legal basis. This information is collected for functional purposes
and to improve your experience using these services. This information may also
be used for fraud prevention, aggregated trend and statistical analysis, and for
showing you more relevant advertisements and messages. More information on these
practices can be found in the Using our websites, mobile applications, and other
technologies section below, and in our Cookies and other tracking technologies
section. We do not typically associate an IP address with your IHG® One Rewards
profile.

How we use this information: We use your information to operate and provide
services in connection with our loyalty programmes. We also use your information
to improve our products and services. Where permitted by applicable law or where
we have your consent, we also may share your information with other parties,
including our loyalty partners and others, to share special offers about their
own products and services with you.

This may include:

 * Enrolment in the loyalty programme;
 * The order and delivery of merchandise that you have redeemed online,
   including merchandise and services offered by our IHG® One Rewards partners;
 * Sending you updates, account statements and other information relating to
   your participation in one of our programmes or services;
 * Sending you marketing communications (which may include text messages or
   calls placed using autodialer technology), with your consent where required
   by applicable law, in relation to the products and services offered by IHG or
   our IHG® One Rewards partners or other partners or affiliates;
 * Providing you with personalized advertisements or communications for IHG
   and/or other products or services that we believe may be relevant for you;
   and
 * Analytics, statistical analysis and other research.

Although provision of much of the information requested is voluntary, the
failure to provide certain information may impact and/or prevent our ability to
offer you certain services.

We occasionally run promotions where we ask IHG® One Rewards Members to refer a
friend to the IHG® One Rewards with consent or other appropriate legal basis. In
these cases, we always ask members to make sure anyone they refer has consented
to sharing their personal information with us, and to direct friends to read
this Privacy Statement if they want to find out more about how we use their
information.

How you can manage your marketing preferences: You can manage your preferences
and decide what marketing communications you would like to receive from us in
our online preference centre. You can visit our Preference centre or find out
more information in the Managing your Preferences and information section.

In addition, you can opt out of collection of your personal information for use
in targeted advertising. Please see Managing cookies and opting out for more
information on how to do this.

We also recommend you routinely review the privacy notices and preference
settings that are available to you on any social media platforms as well as your
preferences within your IHG® One Rewards account. In addition, certain U.S.
state residents may have the option of clicking on the Do Not Sell or Share My
Personal information link, which would eliminate the sharing that might
constitute a sale under applicable law.

Who we disclose your information with: As part of our loyalty programs, we
disclose your information as follows:

 * Loyalty partners: to provide you with the products and services that you have
   requested and, where permitted by law, for the partner to offer its own
   products and services to you. We also may choose to partner with another
   company to offer a product, such as a co-branded credit card. You have
   options about how we disclose your information; please log into the
   preference centre at any time to view and exercise your choices. In addition,
   certain U.S. state residents may have the option of clicking on the Do Not
   Sell or Share My Personal information link, which would eliminate the sharing
   that might constitute a sale under applicable law.
 * Service providers: for the purposes of operating the programme and to provide
   you with the products and services that you have requested. We also use
   service providers to assist us with managing, carrying out and improving our
   advertising. These companies are authorised to use your personal information
   only as necessary to provide these services to us.

We also will share your information in the following circumstances:

 * When we believe in good faith that the disclosure is required by law or to
   protect the safety of hotel guests, employees, the public, or IHG property;
 * When disclosure is required to comply with a judicial proceeding, court
   order, subpoena, warrant, or legal process in any jurisdiction; or
 * In the event of a merger, asset sale, or other corporate transaction.

 


IF YOU INTERACT WITH US THROUGH OUR CORPORATE SITES

Information we collect:

We collect information from you when you sign up to receive corporate news or
shareholder documents, participate in surveys, submit reviews, contact customer
service, or otherwise provide feedback to us or through social media or our
other digital channels.


Corporate News:

Information collected may include:

 * Information relating to your registration for corporate news such as your
   name, email address, profession, country/region and email service preferences
   for news; and
 * Information relating to the receipt of shareholder documents such as your
   initials, surname, postcode, shareholder account number, email address and
   password for shareholder communications.

We collect this information directly from you when you sign up for corporate
news or shareholder documents on our corporate site.

Competitions or sweepstakes:

We collect contact information from you when you sign up for a competition or
sweepstake; we do not necessarily include this information as part of your IHG®
One Rewards profile. In these instances, we will collect information from and
about you for running and administering the respective competition, sweepstakes
or service that you have elected to participate in. The information collected
may include personal details such as your name and address as well as certain
demographic information that you choose to provide. In each case, we will
collect, use and secure your information in a manner consistent with the general
principles set out in this Privacy Statement unless we tell you otherwise.

Other Collections:

We also collect information from you when you sign up to receive our newsletters
or other special offers and promotions, download one of our mobile applications,
or participate in one of our other services. The type of information that we
collect from you depends on your interaction with our site and services.

Automatically:

We also collect information about you when you browse our website, use our
mobile app, interact with our emails or use our social media sites. In these
instances, information such as your country information, internet protocol
(“IP”) address, media access control address and other characteristics about
your system or device may be automatically collected. This information is
collected for functional purposes and to improve your experience using these
services. This information may also be used for aggregated trend and statistical
analysis, and for showing you more relevant advertisements and messages. More
information on these practices can be found in the Using our websites, mobile
applications and other technology section below. We do not typically associate
an IP address with your IHG® One Rewards profile.

How we use this information:

We use your information to provide you with corporate news and shareholder
documents for which you have signed up. For corporate news, you may change your
communication preferences in accordance with the Managing your communication
preferences section below.

If you sign up for a promotion, we may associate that promotion with your
account (e.g., if related to an IHG® One Rewards programme.). If you sign up for
a contest or sweepstakes, we will use your information for the purpose of that
contest or sweepstakes. Please be advised that there may be additional rules for
the sweepstakes or contest, and those rules may provide additional information
about how we will use your information collected for any event that you choose
to enter.

For online collected data, please see Online Channels and our Cookies and other
tracking technologies for additional information.

Who we disclose your information with:

We may disclose your information with our service providers who provide services
on our behalf to help with our corporate site and our shareholder functions.
These services may include the provision of shareholder documents and services
related to management of our shareholder register. These companies are
authorised to use your personal information only as necessary to provide these
services to us.

We will also share your information in circumstances, such as:

 * when we believe in good faith that the disclosure is required by law or to
   protect the safety of hotel guests, employees, the public or IHG property;
 * when disclosure is required to comply with a judicial proceeding, court
   order, subpoena, warrant or legal process; or
 * in the event of a merger, asset sale, or other related transaction.

 

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THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We are committed to collecting and using your information in accordance with
applicable data protection laws.

We collect, use and share your information where we have an appropriate legal
basis to do this.

This may be because:

 * you have provided your consent to us using the personal information;
 * our use of your information is necessary to perform our contract with you,
   for example, making and managing your booking and operating and providing
   services in connection with our Loyalty Programme in accordance with the
   terms of our agreement with you;
 * our use of your information is necessary to meet responsibilities we have to
   our regulators, tax officials, law enforcement, or otherwise meet our legal
   responsibilities;
 * our use of your information is in our legitimate interest as a commercial
   organisation, for example to operate and improve our services and to keep
   people informed about our products and services (including for profiling and
   targetted advertising) - in these cases we will look after your information
   at all times in a way that is proportionate and respects your privacy rights
   and, depending on the applicable law, you have a right to object to
   processing as explained in To object to how we use your information.

If you would like to find out more about the legal basis for which we process
personal information please contact us (details found in the How to contact us
section). If you have provided your consent to our processing of your
information you can withdraw this consent at any time by contacting the IHG
Privacy Office (details found in the How to contact us section).

 

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DATA TRANSFER

As we operate via a global network of corporate offices, reservation and service
centres, data centres and hotels, it may be necessary to transfer your
information, for example, information collected in connection with a reservation
or stay at an IHG-branded hotel, joining one of our loyalty programs or
interacting with us through our corporate site, websites, emails or our other
digital channels to a country outside of the country where it was originally
collected or outside of your country of residence or nationality. The
information that you provide us during the course of a reservation or through
the provision of any other services may be transferred to any of our IHG-owned
or affiliated entities and hotels around the world for the purposes of carrying
out or facilitating these services. It will also be necessary to transfer this
information to other entities, including, without limitation, our IHG-branded
hotels, partners and our service providers.

Where we transfer information which originates in the European Union ("EU"),
United Kingdom ("UK"), Brazil, or Turkey to a country outside of the country of
origination, we will take steps to make sure such transfer is carefully managed
to protect your privacy rights:

 * transfers within the IHG Group will be covered by an agreement entered into
   by members of the IHG Group (an intra-group agreement) which contractually
   obliges each member to ensure that your information receives an adequate and
   consistent level of protection wherever it is transferred within the IHG
   Group;
 * where we transfer your data outside of the IHG Group including to other
   companies providing us with a service, we will obtain contractual commitments
   and assurances from them to protect your information. Some of these
   assurances are well-recognised certification schemes such as standard
   contractual clauses;
 * we will only transfer personal information to countries which are recognised
   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, or after having obtained explicit consent from you; and
 * any requests for information we receive from law enforcement or regulators
   will be validated before personal information is disclosed, where permitted
   by the applicable law.

When we otherwise transfer personal information between jurisdictions, we will
take such steps as required by local law in an effort to ensure that such
transfer is managed to protect your privacy rights.

 

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USING OUR WEBSITES, MOBILE APPLICATIONS AND OTHER TECHNOLOGY

We and our service providers use cookies, pixels, web beacons, tracking tools
and other similar technologies on our websites, mobile applications and in other
areas of our business to collect information and provide you with the services
that you have requested or participate in and to provide targeted advertising.
Subject to local consent requirements, we may use this and other information we
collect, such as a hashed email address, to help us and our service providers
identify other devices that you use (e.g., a mobile phone, tablet, other
computer, etc.). If you are using our mobile applications and have consented to
sharing your location information with us, this information might be collected
through GPS to enable us to provide certain personalised services to you such as
recommendations of hotels nearby, customised offers and promotions. Your
location preferences can be set or modified at the device level or through
modifying your settings with the relevant social media platform. This
information also includes personally identifiable information that you provide
when you join one of our loyalty programs to enable us to verify your
membership. We, and our service providers, also may use the cross-device
tracking and other information we learn about you to serve targeted advertising
on your devices. We also use the information that we collect to improve our
products and services as well as your experience when visiting our websites and
using our mobile applications. For more information on these subjects, please
click the relevant section below.

We may engage vendors to provide certain interactive features on our websites,
mobile applications and in other areas of our business. Your use of these
interactive features is voluntary, and we may retain the information that you
submit through these features. For example, we may offer an interactive chat
feature on the website to assist you for customer service purposes. When you
participate in the interactive chat, the contents of the chat may be captured
and kept as a transcript. By using these features, our vendors may process the
information obtained through the feature to provide the service on our behalf.

 

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COOKIES AND OTHER TRACKING TECHNOLOGIES

What is a cookie: A “cookie” is a small text file that is placed onto an
Internet user’s web browser or device and is used to remember as well as obtain
information about that party. You might be assigned a cookie when visiting our
websites or when using our mobile applications or other digital channels. In
some instances, where permitted under the applicable law, cookies may also be
used for the purposes of certain email campaigns.

What types of cookies we use and how we use them: We use different types of
cookies, which include:

 * Required Cookies –these cookies support the core functionality of our website
   and are necessary for a website to function and provide our products and
   services.
 * Functional and Session Replay Cookies – these cookies collect information
   needed to support the website and our applications and allow us to improve
   our website and identify any problems that you faced while visiting us. For
   example, performance cookies may provide us with information about how you
   came to our website and how you navigated around our website during your
   visit. We also use these cookies to provide us with certain statistical and
   analytics information.
 * Advertising Cookies – these cookies are used to collect information from you
   to help us to improve our products and services as well as serve you with
   targeted advertisements that we believe will be relevant for you. We use
   targeting cookies across our websites and applications for various marketing
   initiatives and campaigns. For more information, please see the Targeted
   advertising section below.

To learn more about cookies and how they are used, please visit:
http://www.allaboutcookies.org/.

Cookies: As described above, we use a number of service providers to help us
manage, carry out and improve our advertising. These parties set cookies at our
direction to help us collect information and provide you with advertisements
that we believe would be relevant for you. In some instances these parties may
also assist us by providing certain statistical and analytics information in
relation to our marketing practices. We also may share information collected
through cookies (and other tracking technologies) with third parties to use for
their own analytics and marketing purposes. These third parties may serve
targeted advertising to you about IHG and non-IHG branded hotels. The scope of
information shared may include information collected through cookies, such as
your IP address/device ID, and information about the search that you performed
on our website (e.g., you were looking for a hotel in New York City), but would
not include your name or IHG® One Rewards information. 

Managing cookies and opting out: You can change your cookie preferences in our
Cookie preferences tool, which is also available from the Privacy and Cookies
Center. You can choose to visit our web sites without cookies, but in some cases
certain services, features and functionality may not be available. To visit
without cookies, you can configure your browser to reject all cookies or notify
you when a cookie is set. Each browser is different, so check the "Help" menu of
your browser to learn how to change your cookie preferences.

In relation to cookies placed by our service providers, we participate in the
Self-Regulatory Programme for Online Behavioural Advertising managed by the
Digital Advertising Alliance (“DAA”). As part of this commitment, IHG has agreed
to comply with the standards and guidelines promulgated by the DAA. For more
information regarding targeted advertisements and/or to opt out of automatic
collection for these purposes, please visit http://www.aboutads.info/choices/ or
http://www.networkadvertising.org/managing/opt_out.asp. Within the EU, UK and
Canada the local DAA organizations operate a similar “ad choices” scheme: see
http://www.youronlinechoices.com (UK/Europe) and http://youradchoices.ca/
(Canada). If you opt out of these targeted advertising cookies, your opt-out
will be specific to the web browser or mobile device from which you accessed the
opt-out. If you use multiple devices or browsers, you will need to opt out for
each browser or device that you use.

Other technologies: Other technologies such as pixels and web beacons may also
be used on our websites, mobile applications, in email messages and in other
areas of our business. These technologies are used to improve our products and
services as well as our marketing efforts. We use pixels in our emails to help
us determine the success of our advertising campaigns, such as to give us
insight into whether you opened, deleted or forwarded an email, or clicked on a
link contained in the email. 

Targeted advertising: We and our service providers may serve targeted
advertisements through the use of first-party or third-party cookies, pixels and
web beacons when you visit our website, use our mobile applications, or visit
websites owned by other entities. In some instances, these cookies may be
persistent cookies. As described in the Using our websites, mobile applications
and other technology section above, we and our service providers may also use
cookie and other information to try to identify other devices and web browsers
that you may use so we and our service providers may serve targeted
advertisements to those devices. We do this to provide you with advertising that
we believe may be relevant for you as well as improve our own products and
services, including the functionality and performance of our websites and mobile
applications. To learn more about opting out of certain types of targeted
advertising, please see the Managing cookies and opting out section above.

Do-Not-Track: Currently, our systems do not recognise browser “do-not-track”
signals except for certain locations as described below in the section US State
Consumer Rights. You may, however, disable certain tracking as discussed in this
section (e.g., by disabling cookies); you also may opt out of targeted
advertising by following the instructions at the DAA and the Network Advertising
Initiative websites.


LOCATION INFORMATION AND SERVICES

In some jurisdictions, and where permitted by applicable law or with your
consent, we may receive information about your location during the course of and
for the purpose of providing you the services described above through your use
of our websites and mobile applications. For example, if you are using our
mobile applications and have consented to sharing your location information with
us, this information might be collected through GPS or Bluetooth technologies to
enable us to provide certain services to you such as customised offers and
promotions. In addition to your use of our websites, mobile applications and
other digital channels, we may also receive location information from wireless
networks or telecommunications towers in proximity to your mobile device,
through your Internet protocol (“IP”) address or through your use of other
services we provide at our hotels. We may also have access to location
information that you provide to us through your use of social media, such as
when you “tweet” your location. We do not store this information as part of your
IHG® Rewards profile and we typically use this information at the point in time
at which you provide it to satisfy your request. Your location preferences can
be set or modified at the device level or through modifying your settings with
the relevant social media platform.


MOBILE APPLICATIONS

We receive information about you when you use our mobile applications. Some
information such as your device manufacturer, type and operating system version,
are collected automatically, while other information is only collected if you
choose to provide it and where permitted by applicable law, such as your precise
geolocation information. We do not typically associate the precise geolocation
information obtained through your use of our mobile apps with your IHG® Rewards
Account. It may sometimes be necessary to associate your geolocation information
with your account to support your participation in a particular programme or
feature that we may offer, but we do not otherwise retain your geolocation
information in a way that identifies you as an individual.

If you use our mobile app, we also send you push notifications from time-to-time
in order to update you about any events or promotions that we may be running. If
you no longer wish to receive these types of communications, you may turn them
off in your device settings. To ensure you receive proper notifications, we will
need to collect certain information about your device such as operating system
and user identification information.

We use mobile analytics software to allow us to better understand the
functionality of our mobile applications on your phone. This software may record
information such as how often you use the application, the events that occur
within the application, aggregated usage, performance data, and where the
application was downloaded from.


ONLINE CHANNELS AND OTHER INFORMATION SOURCES

We may use information from online sources, such as websites, social media and
information sharing platforms. This information may be used to help tailor and
improve our services and communicate with you effectively, as we know many of
our customers use a range of media channels to communicate and share
information.


We may use various social media features such as the Facebook “Like” button on
our websites and mobile applications. We collect certain information about you
through your use of these features in conjunction with our services and
programmes. Subject to your account and privacy settings, we may also be able to
see information that you post when using these social media platforms. In some
instances, depending on the circumstances, we may contact you on these social
media platforms. The information you post on social media sites as well as the
controls surrounding these disclosures are governed by the respective policies
of the social media site.

Where we use information from these sources, we will respect any permissions you
have set about how you would like your information to be used for each source.
We do not associate the information that we collect through these platforms with
your IHG® One Rewards account.

We recommend you routinely review the privacy notices and preference settings
that are available to you on any social media platforms. To learn more about
opting out of certain types of targeted advertising, please see the Managing
cookies and opting out section above.

 

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USE OF WI-FI SERVICES (IHG CONNECT)

When you use the IHG Connect WI-FI service (IHG Connect), we may collect and
process certain additional information.



THE INFORMATION WE COLLECT

 * Registration and User-Provided Information: When you register to use IHG
   Connect, we may collect personal information about you including your last
   name, IHG® One Rewards number, room number and, depending on your location
   and applicable law, other personal information (such as mobile phone number).
   You may also provide us with personal information about you in various ways
   when you use IHG Connect, for example, when you send us customer
   service-related requests.
 * Device Identifiers. We may automatically collect a device identifier (such as
   your IP address, MAC address, or device name or other unique identifier) for
   the computer, mobile device, technology or other device you use to access IHG
   Connect. A device identifier is a number automatically assigned to your
   device when you access IHG Connect, and we may identify it by its device
   identifier. When you use IHG Connect, we may view your device identifier and
   use this information to enhance our service. We may associate your device
   identifier with other information about you, such as your IHG® One Rewards
   number.
 * Other device information: We may also automatically record certain
   information from your device including, device type, the web pages, apps or
   sites that you visit, and the dates and times that you visit, access, or use
   IHG Connect (Internet activity information). While this information is
   generally pseudonymous and/or aggregated, this information may be associated
   with your IHG® Rewards number and/or other IHG service account information or
   persistent identifiers. This data helps us to manage our networks and
   provides us with information about the use of IHG Connect. We do not,
   however, collect and process the contents of email communications or other
   electronic communications you send or receive when using IHG Connect.
 * Location information: We may collect information about your location through
   your use of the WI-FI services we provide at our hotels to enable us to
   improve our service and provide certain services to you such as customised
   offers and promotions.
   



HOW WE USE THE INFORMATION WE COLLECT

We use personal information only for the purposes described in this Privacy
Statement, except if otherwise disclosed to you at the time the data is
collected or otherwise authorised by law or by you. We use the personal
information that we collect through IHG Connect:

 * to operate, maintain, enhance and provide all features of the service, to
   provide services and information that you request, to respond to comments and
   questions and to provide support to users.
 * to understand and analyse the usage trends and preferences of our users, to
   improve the IHG Connect service, and to develop new products, services,
   features, and functionality. If you provide your contact information or your
   IHG® One Rewards number, we may (with your consent or where permitted by
   applicable law) send you personalised offers based on your web usage and
   location. You can opt out of receiving these offers when signing in to use
   the IHG Connect service or at any time within your IHG® One Rewards account.
   Please see the 'Managing your preferences and information' section below.

 

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USING PERSONAL INFORMATION TO CREATE PROFILES

Our goal is to create a personalised and customised experience for you when you
stay at an IHG-branded property. In order to determine appropriate advertising
and to customise your experience, as described in the section above in relation
to cookies, we have relationships with companies such as Google and Facebook
which enable us to serve targeted advertising. In addition to the activities
described under the heading Targeted Advertising above, we also match Facebook
and Google users across sites and devices, which enables us to better understand
your interests. We use this information to enable us to tailor our marketing
communications to you so we can make sure we tell you about things which are
most likely to be of interest to you. You have options about how we share your
information; please log into the preference centre at any time to view and
exercise your choices. In addition, certain U.S. state residents may have the
option of clicking on the Do Not Sell or Share My Personal Information link,
which would eliminate the disclosure that might constitute a "sale"/"share"
under applicable law.

 

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HOW WE SECURE YOUR INFORMATION

We are committed to protecting the confidentiality and security of the
information that you provide to us. To do this, technical, physical and
organisational security measures are put in place to protect against any
unauthorised access, disclosure, damage or loss of your information. The
collection, transmission and storage of information can never be guaranteed to
be completely secure, however, we take steps to ensure that appropriate security
safeguards are in place to protect your information.

 

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MANAGING YOUR PREFERENCES AND INFORMATION

We want to ensure that you have the necessary tools at your disposal to control
the information that you provide to us, including how we communicate with you.
It is also important that you contact us to update your information if any of it
is inaccurate or changes. Please click the relevant section below to learn more
about how to control how we communicate with you and how to update, modify and
delete your information. EU, UK and Turkey Data Subjects, please see also the
Data Subject Rights under UK/EU/EEA and Turkey Data Protection Laws
specific-section. U.S residents, please see also the U.S.-specific section.
Californians, please see also the CA-specific section. Data Subjects located in
Brazil, please see also the Brazil-specific section. Data Subjects located in
PRC, please see also the PRC-specific section.


MANAGING YOUR COMMUNICATION PREFERENCES

Through the provision of the services described above, we, and in some instances
our IHG-branded Hotels, IHG® One Rewards partners, and service providers may
communicate with you in relation to a reservation, as a member of any of our
loyalty programmes, through online digital services (e.g. online advertising,
social media communications), or to support any other services that we provide.

In some instances, especially if you are a member of IHG® One Rewards or an
InterContinental Ambassador, you can go to your account, sign in and click on
the “Communication Preferences” section to revise your communication
preferences. IHG® One Rewards members can also contact any of our IHG® One
Rewards Service Centres. Additionally, the option to unsubscribe from marketing
communications will be included within the communication itself. In all other
cases, or if you are having difficulties with unsubscribing from any particular
communication, please contact one of our global customer care offices or the IHG
Privacy Office (details found in the How to contact us section).

Please be aware that unsubscribing from one type of communication may not
unsubscribe you from another type. Likewise, unsubscribing from our
communications may not mean that you are unsubscribed from certain
communications carried out independently by our IHG-branded hotels.


MANAGING YOUR INFORMATION

In the event any information that you provide to us is inaccurate or changes,
you can let us know by contacting one of our global customer care offices. In
some instances, especially if you are an IHG® Rewards or InterContinental
Ambassador member, you can update certain aspects of your personal information
by going to your account, signing in and clicking on the “Personal Information”
section to update and amend your personal information. For all other cases,
please contact the IHG Privacy Office (details found in the How to contact us
section). We will respond to your request within a reasonable timeframe.

 

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LINKS TO OTHER SITES

Our websites and applications contain links to websites that are maintained
and/or controlled by non-affiliated parties. In some instances these websites
may be co-branded and display our logos or other trademarks. You can always tell
whether you are on one of our websites by checking the uniform record locator
("URL”) on the page that you are visiting. We encourage you to review the
privacy policies of these websites as their privacy practices may differ from
ours.

 

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CHILDREN

Our websites are not intended for children and we do not intentionally solicit
or collect personal information from individuals under the age of 18. If we are
notified or otherwise discover that a minor’s personal information has been
improperly collected, we will take all commercially reasonable steps to delete
that information.

 

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RETAINING YOUR INFORMATION IN OUR SYSTEMS

We generally only keep your information for as long as is reasonably required
for the purposes explained in this privacy policy. In some cases we keep
transactional records (which may include your information) for longer periods if
necessary to meet legal, regulatory, tax or accounting needs. We will also
retain information if we reasonably believe there is a prospect of litigation.
We maintain a data retention policy which we apply to the records we hold.

 

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HOW TO CONTACT US

For any questions or concerns regarding this Privacy Statement or our data
privacy practices, please contact us:

 * By email: privacyoffice@ihg.com
 * By post:
   InterContinental Hotels Group
   Attn: Privacy Office
   Three Ravinia Drive
   Atlanta, Georgia 30346
   
   InterContinental Hotels Group
   Attn: Privacy Office
   Windsor Dials 1
   Arthur Road
   Windsor
   Berkshire, SL4 1RS, United Kingdom
   
   GDPR main establishment in the EU:
   InterContinental Hotels Group
   Attn: Privacy Office
   Thurn-und-Taxis-Platz 6
   60313 Frankfurt am Main
   Germany
 * By phone: 1-770-604-8347
 * By fax: 1-770-604-5275

You may also contact our Data Protection Officer by
emailing privacyoffice@ihg.com.

To the extent permitted under the local law, you may also use the above contact
details to request access to, correct, or (in certain circumstances) delete, any
of your personal information that is held by IHG, or, where we have relied upon
your consent to process your personal information, to withdraw your consent to
such processing of your personal information. These requests will be reviewed
and processed in line with the local law.

You also may have a right under the local law to lodge a complaint with us or
with your local data protection supervisory authority at any time. However, we
ask that you please try to resolve any issues with us first before referring
your complaint to the supervisory authority.

In the EU, IHG’s GDPR lead supervisory authority is the Hessen supervisory
authority, which can be contacted at:
Der Hessische Beauftragte für Datenschutz und Informationsfreiheit (The
Commissioner for Data Protection and Freedom of Information of Hesse)
Gustav-Stresemann-Ring 1
65189 Wiesbaden
Germany

For Turkish data subjects, our Data Controller Representative in Turkey is
Özdağıstanli Ekici Avukatlık Ortaklığı for compliance with the Turkish data
protection regulations and can be contacted at info@iptech-legal.com.

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ADDITIONAL INFORMATION FOR UK/EU/EEA, TURKEY, U.S, PEOPLE’S REPUBLIC OF CHINA,
AND BRAZIL

DATA SUBJECTS RIGHTS UNDER UK/EU/EEA AND TURKEY DATA PROTECTION LAWS

UK, EU/EEA and Turkey data subjects have legal rights under their respective UK,
EU and Turkish Data Protection Laws in relation to your personal information.
Click on the links below to learn more about each right you may have subject to
applicable laws in your location. To exercise any of your rights please use the
forms available in our Privacy and Cookie Centre or contact our Data Protection
Officer by emailing privacyoffice@ihg.com.

 * To access personal information
   You can ask us to confirm whether or not we have, how we are using your
   personal information and, if applicable, for a copy of your information.
 * To correct/erase personal information
   You can ask us to correct any information about you which is incorrect. We
   will be happy to rectify such information but would need to verify the
   accuracy of the information first.
   You can ask us to erase your information if you think we no longer need to
   use it for the purpose we collected it from you. You can also ask us to erase
   your information if you have either withdrawn your consent to us using your
   information (if we originally asked for your consent to use your
   information), or exercised your right to object to further legitimate use of
   your information, or where we have used it unlawfully or where we are subject
   to a legal obligation to erase your personal information. Also, depending on
   your location you may have the right to request reporting of the erasure
   requests to third parties to whom your personal data has been transferred.
   We may not always be able to comply with your request, for example where we
   need to keep using your information to comply with our legal obligation or
   where we need to use your information to establish, exercise or defend legal
   claims.
 * To restrict how we use personal information
   You can ask us to restrict our use of your information in certain
   circumstances, for example:
   * where you think the information is inaccurate and we need to verify it;
   * where our use of your information is not lawful but you do not want us to
     erase it;
   * where the information is no longer required for the purposes for which it
     was collected but we need it to establish, exercise or defend legal claims;
     or
   * where you have objected to our use of your personal information but we
     still need to verify if we have overriding grounds to use it.
   We can continue to use your information following a request for restriction
   where we have your consent to use it; or we need to use it to establish,
   exercise or defend legal claims, or we need to use it to protect the rights
   of another individual or a company. 
 * To object to how we use your information
   You can object to any use of your information which we have justified on the
   basis of our legitimate interest, if you believe your fundamental rights and
   freedoms to data protection outweigh our legitimate interest in using the
   information. If you raise an objection, we may continue to use your
   information if we can demonstrate that we have compelling legitimate
   interests to use the information.
   Based on the available data protection rights, you can also require us to
   stop using your data for direct marketing purposes and, if applicable, object
   to decisions about you based on processing of your personal data, exclusively
   by automatic means.
 * To request information about data transfers to third parties
   Depending on your location, you may have the right to ask us for information
   about which  third parties  your personal data has been transferred to.
 * To ask us to transfer your information to another organisation
   You can ask us to provide your personal information to you in a structured,
   commonly used, machine-readable format, or you can ask to have it transferred
   directly to another data controller (e.g. another company).
   You may only exercise this right where we use your information in order to
   perform a contract with you, or where we asked for your consent to use your
   information. This right does not apply to any information which we hold or
   process that is not held in digital form.
 * Right to obtain a copy of personal information safeguards used for transfers
   outside your jurisdiction
   Depending on your location you may be able to ask to obtain a copy of, or
   reference to, the safeguards under which your personal information is
   transferred outside of the European Union or the UK.  We may redact data
   transfer agreements to protect commercial terms.

We may ask you for proof of identity when making a request to exercise any of
these rights. We do this to make sure that we only disclose information where we
know we are dealing with the right individual. We will not ask for a fee, unless
we think your request is unfounded, repetitive or excessive. Where a fee is
necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us
longer if the request is particularly complicated or you have made several
requests. We will let you know if we think a response will take longer than one
month. To help us respond more quickly, we may ask you to provide more detail
about what you want to receive or are concerned about.
We may not always be able to do what you have asked, for example if it would
impact the duty of confidentiality we owe to others, or if we are otherwise
legally entitled to deal with the request in a different way.

 

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U.S. STATE CONSUMER RIGHTS

This section supplements the other parts of our Privacy Statement and provides
additional information for residents of California, Colorado, Connecticut,
Montana, Nevada, Oregon, Texas, Utah, and Virginia. The rights under this
section will apply to you to the extent the law permits.

As used in this section, “Personal Information” means information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
consumer or household. Personal Information does not include information that is
publicly available, de-identified, or aggregated. Personal Information includes
“personal data” as defined by applicable state privacy laws.

Click on the links for each state to learn more about specific California and
Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah and Virginia
consumer rights.

Submitting Requests. You can exercise your rights by visiting our Privacy and
Cookie Center or by contacting us at 1 877 424 2449 (toll free). We will respond
to your requests within 45 days, unless additional time is needed, in which case
we will let you know.

When you submit your request, we will take steps to attempt to verify your
identity. We will attempt to match the information in your request to the
Personal Information we maintain about you. As part of our identity verification
process, we may ask you to submit additional information or to sign into your
account.

Non-Discrimination: If you choose to exercise any of the privacy rights
described below, you will not subjected to discriminatory treatment by us.

 

Personal Information We Collect and How We Use and Disclose it

Category of Personal Information Purposes for Collection, Use, and Disclosure
Categories of Recipients to Which Personal Information is Disclosed Identifiers,
including real name, alias, postal address, unique identifier (e.g., your IHG®
One Rewards number if you choose to enrol in the programme), IP address (if you
access our websites, emails, or other digital channels), email address or other
similar identifiers.
 * To communicate with you, including about your reservations.
 * To process transactions.
 * To fulfil your reservations.
 * To manage your IHG® One Rewards account.
 * To enhance and personalise your experience with us.
 * To advertise and market to you in connection with your preferences.
 * To perform analytics
 * To detect and prevent fraud

 * IHG-branded properties
 * Advertising partners
 * Analytics companies
 * Payment processors
 * Co-branded partners
 * Travel providers such as our partner airlines and rental car agencies
 * Data enrichment providers

Customer Records, including Personal Information such as name, signature,
address, telephone number, driver’s license number, and financial information
(e.g., payment information for your reservation).
 * To communicate with you, including about your reservations.
 * To process transactions.
 * To fulfil your reservations.
 * To manage your IHG® One Rewards account.
 * To enhance and personalise your experience with us.
 * To advertise and market to you in connection with your preferences.
 * To protect your rights and interests 

 * IHG-branded properties
 * Advertising partners
 * Analytics companies
 * Payment processors
 * Co-branded partners
 * Travel providers such as our partner airlines and rental car agencies

Characteristics of Protected Classifications, including age.
 * To enhance and personalise your experience with us.
 * To advertise and market to you in connection with your preferences.

 * IHG-branded properties 
 * Advertising partners
 * Analytics companies

Commercial Information, including records of products or services purchased,
obtained, or considered, or other purchasing or consuming histories or
tendencies.
 * To enhance and personalise your experience with us.
 * To advertise and market to you in connection with your preferences.

 * Advertising partners
 * Analytics companies
 * Co-branded partners
 * Travel providers such as our partner airlines and rental car agencies

Internet or other electronic network activity information, including browsing
history, search history, and information regarding a consumer’s interaction with
an Internet Web site, application, or advertisement.
 * To communicate with you, including about your reservation.
 * To enhance and personalise your experience with us.
 * To advertise and market to you in connection with your preferences.

 * IHG-branded properties
 * Advertising partners
 * Analytics companies
 * Payment processors
 * Co-branded partners
 * Travel providers such as our partner airlines and rental car agencies

Geolocation Data
 * To provide you with in-room or in-hotel Wi-Fi service.

 * IHG-branded properties
 * Internet service providers

Sensory Data, including closed-circuit television recordings from IHG-branded
properties (collected for security purposes), and audio recordings of customer
care calls.
 * To protect your rights and interests as well as the rights and interests of
   other guests.

 * If we obtain CCTV footage, we do not disclose such data except as necessary
   to protect our rights and interests and the rights and interests of other
   persons, including law enforcement.

Inferences used to create or enhance a profile about a consumer reflecting the
consumer’s preferences and tendencies (e.g., what types of properties the
consumer prefers, how frequently the consumer travels, etc.). 
 * To enhance your overall experience with IHG, for example, to identify and to
   offer relevant marketing opportunities and to show you hotel information and
   trip extras you may be interested in.

 * Advertising partners
 * Analytics companies
 * Co-branded partners

Personal Information that reveals a consumer’s precise geolocation.
 * To provide you with in-room and in-hotel Wi-Fi service.
 * To locate properties nearby.

 * IHG-branded properties

Personal Information collected and analysed concerning a consumer’s
accessibility needs.
 * To fulfil your reservations or request for an accessible room.
 * To enhance and personalise your experience with us.

 * IHG-branded properties

 

We may also disclose all categories of Personal Information described above to
our service providers and other vendors that are contractually restricted from
using your Personal Information for any purposes other than providing requested
services to us. In addition to the purposes for collection, use, and disclosure
of Personal Information described in the above table, we may collect, use, and
disclose Personal Information to meet responsibilities we have to regulators,
tax officials, law enforcement, or otherwise meet our legal responsibilities.

Sources of Personal Information 

We collect the Personal Information identified above directly from you, from
other persons/entities making a reservation on your behalf (e.g., travel agent,
a member of your travel party, someone making the booking on your behalf),
automatically via cookies and tracking technologies when you access our online
services, from travel partners, including airlines and rental car agencies, and
from IHG-branded hotels (that are generally independently owned and operated).
We may also obtain Personal Information from data enrichment providers.  

Targeted Advertising, Sales, and Sharing of Personal Information

We may sell or share with third parties for cross-context behavioral advertising
or targeted advertising the following categories of Personal Information:

 * Identifiers
 * Commercial Information
 * Internet or other electronic network activity information
 * Geolocation data based on your IP address

The third parties to whom this Personal Information is sold or shared are
advertisers, data enrichment providers, and analytics vendors. 

We may also sell the following categories of Personal Information: to airlines,
holiday ownership and co-branded credit card partners:

 * Identifiers
 * Customer Records
 * Commercial Information
 * Geolocation data based on hotel location
 * Inferences

You may opt out of the sale or sharing of your Personal Information as provided
below.

Retention of Personal Information

We keep the categories of Personal Information described above for as long as
necessary for the purposes described in this section or as otherwise authorised
by law. This generally means holding the Personal Information for as long as one
of the following apply: 

 * Your Personal Information is reasonably necessary to manage our operations,
   to manage your relationship with us, or to satisfy another purpose for which
   we collected the Personal Information;  
 * Your Personal Information is reasonably necessary to carry out a disclosed
   purpose that is reasonably compatible with the context in which the Personal
   Information was collected; 
 * The Personal Information is reasonably required to protect or defend our
   rights or property; or 
 * We are otherwise required or permitted to keep your Personal Information by
   applicable laws or regulations.

Where Personal Information is used for more than one purpose, we will retain it
until the purpose with the latest period expires. 


 

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CALIFORNIA CONSUMER RIGHTS

The California Consumer Privacy Act (“CCPA”) provides California residents the
right to submit certain requests relating to their Personal Information as
described below.

Right to Know. You have the right to know what Personal Information we have
collected about you, which includes:

(1) The categories of Personal Information we have collected about you,
including   

a. The categories of sources from which the Personal Information was collected

b. Our business or commercial purposes for collecting, selling, sharing, and
disclosing Personal Information

c. The categories of recipients to which we disclose Personal Information

d. The categories of Personal Information that we sold or shared, and for each
category identified, the categories of third parties to which we sold that
particular category of Personal Information

e. The categories of Personal Information that we disclosed for a business
purpose, and for each category identified, the categories of recipients to which
we disclosed that particular category of Personal Information

(2) The specific pieces of Personal Information we have collected about you

To submit a request to know, please fill out the form here.

Right to Delete: You have the right to request that we delete Personal
Information we collected from you, subject to certain exceptions. To submit a
request to delete, please fill out the form here.

Right to Correct Inaccurate Information. If you believe that Personal
Information we maintain about you is inaccurate, you have the right to request
that we correct that information. To submit a request to correct, please contact
us at PrivacyOffice@ihg.com.

Right to Opt Out of Sales and Sharing of Personal Information. You have the
right to opt out of the sale of your Personal Information, and to request that
we do not share your Personal Information for cross-context behavioural
advertising. To opt-out of cookie-based sales and sharing, please click “View
Cookie Preference Tool” under Cookie Settings here, toggle cookie settings to
“No” and click “Submit Preferences. To opt out of offline sales or Personal
Information, please fill out the form here. If you would like to use a universal
opt-out preference signal, please download and use a browser supporting the
Global Privacy Control (GPC) browser signal. If you choose to use the GPC
signal, you will need to turn it on for each supported browser or browser
extension you use. 

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not
process sensitive Personal Information for purposes to which the right to limit
use and disclosure of sensitive Personal Information applies, and therefore we
do not provide such a right. 

Appeals. If you would like to submit an appeal regarding our response to a
request, you may appeal by contacting us at PrivacyOffice@ihg.com.

Authorised Agents. The CCPA allows California consumers to designate an
authorised agent to exercise their rights under CCPA. If you use an authorised
agent to submit a request, we will ask your agent to provide information to
demonstrate the agent has your authorised consent to submit a request. Proof of
authorisation evidenced by your signed permission should be submitted to
PrivacyOffice@ihg.com. We may also ask you to provide information to verify your
identity directly with us.

If you are a California employee or job applicant, or if you interact with us in
a commercial context, please contact us at PrivacyOffice@ihg.com to submit a
request.

Metrics: Our annual metrics related to California Consumer Requests received and
other information, including the number of requests and the mean number of days
for our response, can be found here.

Shine the Light

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California
residents who provide us with certain Personal Information are entitled to
request and obtain from us, free of charge, information about the Personal
Information (if any) we have shared with third parties for their own direct
marketing use.  Such requests may be made once per calendar year for information
about any relevant third party sharing in the prior calendar year. If you are a
California resident and would like to make such a request, please submit your
request in writing to PrivacyOffice@IHG.com. In your request, please attest to
the fact that you are a California resident and provide a current California
address. 

 

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CALIFORNIA NOTICE OF FINANCIAL INCENTIVE

The IHG® One Rewards programme (“Programme”), which includes InterContinental®
Ambassador and IHG® Business Rewards, is a loyalty programme offered by Six
Continents Hotels, Inc. and its subsidiaries and affiliates, all of which are
referred to herein as IHG.

IHG® One Rewards programme. IHG offers guests the opportunity to participate in
the Programme which may provide benefits, including free internet, as well as
the opportunity to earn points that can be redeemed for discounted or free stays
or other items, as described in the IHG® One Rewards member benefit chart to
those who choose to join. These benefits may be considered to be financial
incentives under the CCPA and are described along with other material terms and
conditions here. 

Information we collect. To join the Program, IHG collects at a minimum, your
first name, last name, address, email address, country/region, city, and zip
code.

IHG may also collect the following additional information from you during the
course of your membership in the Programme. 

 * Your name, email address, home and business address, phone number,
   nationality, birthday and payment card information;
 * Your membership number and password as well as details of your memberships
   with any of our Programme partners such as our airline or car rental
   partners;
 * Information that you choose to provide in your loyalty profile, such as your
   personal stay and destination preferences;
 * Marketing preferences, including how you prefer to be contacted by IHG as
   well as what types of information you are interested in hearing about; and
 * Your stays at IHG-branded properties, including the property name, dates of
   stay, and, in some circumstances, the total amount of your stay (and, in some
   circumstances, an itemised breakdown of your spend at the property).

How we use the information. We use your information to operate and provide
services in connection with our Programme in accordance with our IHG® One
Rewards Membership Terms and Conditions. We also use your information to improve
our products and services. Where permitted by applicable law or where we have
your consent, we also may share your information with other parties, including
our loyalty partners and others, to share special offers about their own
products and services with you.

This may include:

 * Enrolment in the loyalty programme;
 * The order and delivery of merchandise that you have redeemed points for
   online, including merchandise and services offered by our IHG® One Rewards
   partners;
 * Our co-branded credit card partners and Holiday Inn Club Vacations;
 * Sending you updates, account statements and other information relating to
   your participation in one of our programmes or services;
 * Sending you marketing communications (which may include text messages or
   calls placed using autodialer technology), with your consent where required
   by applicable law, in relation to the products and services offered by IHG or
   our IHG® One Rewards partners or other partners or affiliates;
 * Providing you with personalized advertisements or communications for IHG
   and/or other products or services that we believe may be relevant for you;
   and
 * Analytics, statistical analysis and other research.

Who we share your information with: During the course of your participation in
our loyalty programmes, we share your information as follows:

 * Loyalty partners: To provide you with the products and services that you have
   requested and, where permitted by law, for the partner to offer their own
   products and services to you. We also may choose to partner with another
   company to offer a product, such as a co-branded credit card.
 * Service providers: for the purposes of operating the programme and to provide
   you with the products and services that you have requested. We also use
   service providers to assist us with managing, carrying out and improving our
   advertising. These companies are authorised to use your personal information
   only as necessary to provide these services to us.

We may also disclose your information in other circumstances, as fully described
under “If you join one of our loyalty programmes” in our Privacy Statement.

Our members can opt-out of sharing their personal information with our partners
for offers and rewards through Communication Preferences in their accounts. Our
California members can also opt-out of the sale of their personal information by
using our Do Not Sell My Personal or Share Information link. If you opt-out, we
will no longer disclose your information with our loyalty partners where such
sharing could be construed as a “sale” under the CCPA.

Joining IHG® One Rewards. You may register for our Programme online, through the
IHG website or mobile app, or when you book a reservation. You may also be
offered to join the Programme at the time of check-in.

Value of Consumer’s Data. Pursuant to the valuation methods defined by certain
U.S. state laws, a good faith estimate of the value of our consumers’ (members’)
Personal Information to IHG is US $0.42 in 2023. This estimate is calculated by
dividing the annual value of the revenue generated from the commercial
relationships we have with our loyalty partners with respect to consumer data,
by the number of US members in our Programme. This estimate is not specific to
any individual consumer. The actual value to the consumer of becoming a member
of the Programme may vary significantly as this will depend on an individual
member’s engagement with the Programme.

Withdraw from the IHG® One Rewards programme. You have the right to withdraw
from the Programme at any time. You may do so by notifying IHG® One Rewards
Customer Care Centre.

Under certain U.S. State laws, members have the right to delete their Personal
Information. However, if you exercise your right to delete your account
information, you will no longer be enrolled in the Programme and accumulated
points will also be deleted.

Contact Us

If you have questions about our privacy practices, would like to make a
complaint, or to request a printable version of this Privacy Statement, please
contact us at PrivacyOffice@ihg.com. This California privacy notice is effective
from 1 January, 2020 and was last updated on 1 July, 2024.

 

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COLORADO, CONNECTICUT, MONTANA, NEVADA, OREGON, TEXAS, UTAH AND VIRGINIA
CONSUMER RIGHTS

If you are a resident of Colorado, Connecticut, Montana, Oregon, Texas, Utah, or
Virginia, you have the right to submit certain requests relating to your
Personal Information as described below.

Access and Data Portability: You have the right to confirm whether we are
processing your Personal Information, to access your Personal Information, and
to obtain a copy of your Personal Information in a portable format. To submit a
request to access, please fill out the form here.

Deletion: You have the right to request that we delete the Personal Information
that we have collected about you, subject to certain exemptions. To submit a
request to delete, please fill out the form here.

Right to Correct: If you are a resident of Colorado, Connecticut, Montana,
Oregon, Texas or Virginia, you have the right to request that we correct
inaccuracies in your Personal Information, taking into account the nature of the
Personal Information and our purposes for processing it. To submit a request to
correct, please contact us at PrivacyOffice@ihg.com.

Opt-out of the Sale of My Personal Information and Targeted Advertising. You
have the right to opt out of the sale of your Personal Information and the use
of your Personal Information for targeted advertising. To opt out of sales of
Personal Information and targeted advertising via cookies, please click “View
Cookie Preference Tool” under Cookie Settings here, toggle cookie settings to
“No” and click “Submit Preferences.” To opt out of offline sales of Personal
Information, please fill in the form here. If you are a resident of Colorado and
would like to use a universal opt-out preference signal, please download and use
a browser supporting the Global Privacy Control (GPC) browser signal. If you
choose to use the GPC signal, you will need to turn it on for each supported
browser or browser extension you use.

Authorised Agents. If you are a resident of Colorado, Connecticut, Montana,
Oregon or Texas, you may designate an authorised agent to exercise your right to
opt-out of the sale of your Personal Information. If you use an authorised
agent, we will ask your agent to provide information to demonstrate the agent
has your authorised consent to submit this request. Proof of authorisation
evidenced by your signed permission should be submitted to
PrivacyOffice@ihg.com. We may also ask you to provide information to verify your
identity directly with us.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not
process sensitive Personal Information for purposes to which the right to limit
use and disclosure of sensitive Personal Information applies, and therefore we
do not provide such a right.

Appeals. If you would like to submit an appeal regarding our response to a
request, you may appeal by contacting us at PrivacyOffice@ihg.com. 

 

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LOYALTY PROGRAMME DISCLOSURES FOR COLORADO CONSUMERS

The purpose of this section is to notify Colorado consumers of how we use
Personal Information in connection with your participation in the IHG® One
Rewards loyalty programme. You have the right to delete your Personal
Information associated with your IHG® One Rewards account; however, if you
delete your Personal Information, we will be unable to link your rewards to your
account, and therefore you will be unable to receive benefits from the
programme. The chart below identifies the categories of Personal Information
that we collect, sell, or process for targeted advertising, and the third
parties who receive each category in connection with IHG® One Rewards.

 

Category of Personal Information Third Parties Who Receive Each Category
Identifiers

Third-party advertisers

Data enrichment providers

Customer Records Commercial Information

 

Through the IHG® One Rewards programme, consumers can earn points with airline,
dining, rental car, vacation ownership, hotel alliance, loyalty platform and
financial loyalty programme partners for discounted or free IHG hotel stays and
loyalty partner services and products.

Consumers can also redeem or transfer their the IHG® One Rewards programme
points with gift card, charity, loyalty platform, vacation ownership and hotel
alliance loyalty programme partners for services or products provided by the
partners,

For more information about how we process your Personal Information, please see
the other sections of our Privacy Policy. 

NEVADA CONSUMER RIGHTS 

Nevada residents have the right to opt out of the of the sale of certain
Personal Information called “covered information” to third parties. IHG does not
sell “covered information” as defined by the law. If you are a Nevada resident
and you would like to be notified if we change our practices regarding the sale
of “covered information” to third parties, please contact us at
PrivacyOffice@ihg.com.

 

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ADDITIONAL INFORMATION FOR THE PEOPLE’S REPUBLIC OF CHINA (EXCLUDING FOR THE
PURPOSES OF THIS STATEMENT HONG KONG SAR, MACAU SAR AND TAIWAN) (“PRC”)

If there is any inconsistency between the below and the above Privacy Statement,
the following shall prevail in respect of the PRC.

Data controller

For the PRC, Intercontinental Hotel Groups (Shanghai) Co., Ltd., Registered
office: 22nd Floor, Citigroup Tower, No. 33 Huayuanshiqiao Road, China
(Shanghai) Pilot Free Trade Zone, is the data controller. For questions or
concerns related to your personal information or related to the Privacy
Statement, please contact privacyoffice@ihg.com.

Consent

We will obtain your consent (where applicable, separate consent) to collect,
use, share, transfer (including but not limited to overseas transfer), disclose
or otherwise process your personal information if and to the extent required by
the applicable laws.

Sensitive personal information

Certain types of personal information described in this Privacy Statement are
considered “sensitive” and, depending on your jurisdiction of work or residence
and applicable law, additional rules will apply in respect of this personal
information. References to personal information in this Privacy Statement shall
be deemed to include references to sensitive personal information (if any) where
applicable.

“Sensitive personal information” as defined under PRC laws and regulations that
we may collect and use for the purposes described in the above Privacy Statement
may include information relating to:

 * payment card information;
 * stay records;
 * biometric information;
 * password;
 * your precise geolocation;
 * web browsing history

Share and disclose your personal information with another controller

With your consent, we may share and disclose your personal information with
another data controller as explained in the section “Information we collect and
how we use and disclose it” in the Privacy Statement.

International data transfers

As IHG is a global hospitality group, for the purposes described in this Privacy
Statement and in order to provide you with privileged and quality service
worldwide, we may, with your separate consent (if required by applicable laws),
transfer your personal information to IHG affiliated entities outside of
mainland China, such as Six Continents Ltd (UK) (“IHG Foreign Affiliated
Entity”), who will process your personal information for the purposes and in the
manner as described in this Privacy Statement. IHG will take appropriate
measures to ensure that cross-border data transfer and the processing of your
personal information by IHG Foreign Affiliated Entities comply with the
requirements of applicable laws and that such mechanisms are aimed at ensuring
an adequate level of protection as regards your personal information under the
applicable laws. If you wish to exercise your rights with respect to your
personal information with any IHG Foreign Affiliated Entity, you can contact
such entity through the means described in “How to Contact Us” section.

How we store and protect your personal information

We will store your personal information for as long as necessary to achieve the
purposes described in this Privacy Statement and for as long as you use our
services, and as otherwise required by applicable law. We take reasonable
security measures to protect your personal information in accordance with
industry standards and are committed to using various technologies and
initiatives to protect your personal information from unauthorized access, use,
modification, disclosure and damage, such as the use of encryption technology to
protect your personal information. We will deal with personal information
security incidents in accordance with applicable laws and regulations, and
conduct training and dissemination of personal information protection to
relevant personnel to enhance their awareness of the importance of personal
information and responsibilities related to personal information protection.

SDKs and other similar software technologies made available by non-affiliated
entities

Under the PRC laws, IHG is required to disclose SDKs. As a practical matter, the
information described below is captured elsewhere in the privacy statement,
including, in particular, in our description of IHG’s use of cookies. If you
have any questions about which trackers listed in our cookie policies are SDKs,
please contact the Privacy Office.

We use software known as software development kits (SDKs) and other similar
technologies made available by non-affiliated entities on our mobile
applications and mini programmes to ensure their stable operation and to provide
the services as described in this Privacy Statement. Please see our SDK list for
more information about our integrated SDKs.

If you are using these features or any plug-ins provided by non-affiliated
entities, the privacy policies of these entities may also apply to you. Some of
these entities may collect data from you for their use and processing and may
obtain your consent prior to doing so. In any case, we recommend that you read
the privacy policies of these non-affiliated entities to understand how they
collect and process your data before using their features and plug-ins.

Personalised marketing

In order to provide you with personalised advertising, we may collect your
personal information.

You can turn off personalised advertising in our App in “Account”-“Personalized
recommendations”. Once you turn off it, you will not receive any personalised
advertising, including promotional offers and special offers.

Mobile device permissions

If you choose to use certain functions using our mobile app we will ask you for
related permissions to use features on your mobile device to enable this.

When you add a payment method to book a hotel, we will ask you for camera
permission if you choose to add payment information by scanning your payment
card using the camera.

If you choose to add the booking to your calendar after the booking is made, we
will ask you for calendar permission to help you add the booking to your
calendar (only applicable to IHG Android App).

If you choose to use the voice search function when booking a hotel, we will ask
you for microphone permission to allow dictation on your device to enable this.

If you choose to use the function to search for hotels near your location we
will ask you for permission to access your location to enable this.

If you choose to give app feedback and upload screenshots or attachments with
your feedback, we will ask you for storage permission.

Your rights

In addition to the rights mentioned in the Privacy Statement, you have the
following rights where permitted by the PRC data protection laws:

 * To access your personal information and obtain a copy
   You have the right to access or obtain a copy of the personal information we
   hold about you.
 * To transfer your personal information
   You have the right to request transferring your personal information to
   another data controller where permitted by the applicable laws.
 * To deregister your account
   You also have the right to ask us to deregister your loyalty programme
   account by contacting one of our global customer care offices
 * Rights to request deletion and rectification
   You can ask us (details found in the How to contact us section) to correct
   any information about you which is incorrect. We will be happy to rectify
   such information but would need to verify the accuracy of the information
   first.
   You can ask us to erase your information if you think we no longer need to
   use it for the purpose we collected it from you. You can also ask us to erase
   your information if you have either withdrawn your consent to us using your
   information (if we originally asked for your consent to use your
   information), or exercised your right to object to further legitimate use of
   your information, or where we have used it unlawfully or where we are subject
   to a legal obligation to erase your personal information.
   We may not always be able to comply with your request, for example where we
   need to keep using your information to comply with our legal obligation or
   where we need to use your information to establish, exercise or defend legal
   claims.
 * Rights to withdraw consent to use mobile device permissions
   You can withdraw your authorisation or withdraw your consent for mobile
   device permissions in your device settings.

To exercise any of your rights above, you may also contact us by emailing
privacyoffice@ihg.com as well.

We aim to respond to all valid requests to exercise the above rights within 15
working days upon verifying your identity. To help us respond more quickly, we
may ask you to provide more detail about your enquiry.

We may not always be able to do what you have asked, for example if it would
impact the duty of confidentiality we owe to others, or if we are otherwise
legally entitled to deal with the request in a different way.

Purchasing product vouchers through IHG WeChat Mini Programme

When you purchase a product voucher through our IHG WeChat Mini Programme, we
will collect your WeChat OpenID, UnionID, membership number and purchase,
redemption, and refund records. We process your information primarily to
attribute your purchases to you, to show you the status of product redemptions
or refunds status, and to notify you of necessary product information changes.
You can check purchase, redemption, and refund records at any time. We will
share your information with the hotel providing the product voucher to provide
you with the services described in the product voucher. If you decline to
provide such personal information, we will not be able to provide you with the
abovementioned services.

 

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BRAZIL DATA SUBJECTS' RIGHTS UNDER BRAZIL DATA PROTECTION LAW

Brazil data subjects have legal rights under Brazil’s Federal Law nº 13.709/2018
(LGPD), as well as any other applicable laws in relation to your personal
information. To exercise any of your rights please use the forms available in
our Privacy and Cookie Center or contact our Data Protection Officer by emailing
privacyoffice@ihg.com.

 * To access personal information
   You can ask us to confirm whether or not we have and are using your personal
   information and for a copy of your information.
 * To correct personal information
   You can ask us to correct any information about you which is incorrect,
   inaccurate or outdated. We will be happy to rectify such information but
   would need to verify the accuracy of the information first.
   
 * To erase / anonymise personal information
   You can ask us to erase, anonymise or block your information if you think we
   no longer need to use it for the purpose we collected it from you, or if such
   data are excessive or are processed in violation of applicable law. You can
   also ask us to erase your information if you have withdrawn your consent to
   us using your information (if we originally asked for your consent to use
   your information).We may not always be able to comply with your request, for
   example where we need to keep using your information to comply with our legal
   obligations or where we need to use your information to establish, exercise
   or defend legal claims.
 * To object to how we use your information
   You can object to any use of your information which we have justified on any
   legal bases other than consent only in case of infringement of the applicable
   law. If you raise an objection, we may continue to use your information if we
   can demonstrate that we have a legal basis to continue to use the
   information.
 * To ask us to transfer your information to another organisation
   You can ask us to provide your personal information to you or you can ask to
   have it transferred directly to another data controller (e.g. another
   company.
 * Other rights
   You may at any time revoke your consent to the processing of your personal
   data, whenever you have given it.
   You may file a claim before competent governmental authorities, such as the
   national data protection authority.You may ask us to provide information
   about any public and private entities with which we have shared your data.You
   may request a review of decisions taken solely on the basis of automated
   personal data processing that affects your interests, including decisions
   intended to define your personal, professional, consumer and or aspects of
   your personality.

We may ask you for proof of identity when making a request to exercise any of
these rights. We do this to make sure that we only disclose information where we
know we are dealing with the right individual.

We aim to respond to all valid requests within 15 (fifteen) days. It may however
take us longer if the request is particularly complicated or you have made
several requests. We will let you know if we think a response will take longer
than 15 (fifteen) days. To help us respond more quickly, we may ask you to
provide more detail about what you want to receive or are concerned about.

We may not always be able to do what you have asked, for example if it would
impact the duty of confidentiality we owe to others, or if we are otherwise
legally entitled to deal with the request in a different way.

If there is any inconsistency between the rights above and this Privacy
Statement, the above specific rights shall prevail in respect of Brazil.

 

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CHANGES TO THIS PRIVACY STATEMENT

In some instances, we may have to change, modify or amend this Privacy Statement
in order to comply with the evolving regulatory environment or the needs of our
business. Subject to any applicable legal requirements to provide additional
notice, any changes to this Privacy Statement will be communicated through our
websites and mobile applications. However, if there will be changes made to the
use of your personal information in a manner different from that stated at the
time of collection we will take appropriate steps to notify you, such as by
posting a notice on our website for 30 days prior to the changes taking effect
or by emailing you. We will obtain your consent to such changes where required
to do so by applicable law.

 

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Effective Date: July, 2024


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