Privacy Policy - Pre-September 2022

Preferred Hotel Group, Inc. (“PHG,” “we,” “us,” or “our”) has created this privacy policy (“Privacy Policy”) to inform you of how we collect, use, share, and secure your personal information online, on the websites https://preferredhotels.com, https://iprefer.com, https://www.preferredgolf.com, https://staybeyondgreen.com, and https://www.phgconsulting.com (the “Websites”), which we own and operate as the data controller, as well as through our offline interactions.

This Privacy Policy covers the following:

I. Information We Collect

II. How We Collect Information

III. Our Legal Basis for Processing Your Information

IV. How We Use Your Information

V. How We Share Your Information

VI. Minors

VII. Do Not Track

VIII. Transfers and Storage of Information

IX. Your Rights Regarding Your Information

X. Your California Privacy Rights

XI. What Other Choices Do You Have?

XII. Data Retention

XIII. Third Party Websites, Content, and Resources

XIV. Security

XV. Privacy Policy Updates

XVI. Contact Us

I. Information We Collect

Preferred Hotel Group, Inc. and our service providers operating on our behalf, may collect, receive or develop different types of personal information about you depending on the nature of your interactions with us. “Personal information” is information that identifies, relates to, describes, is capable of being associated with, or could be linked to you or your household, either on its own or when combined. We also collect and generate other information that is not personal information (“non-personal information”), for instance information that does not identify or relate to you, or information that has been de-identified or aggregated:

  • Contact Information. For example, your name, email address, postal address, and phone number.
  • Purchase and Preference Information. For example, information about your purchase history and your preferences when using our products and services.
  • Payment Information. Billing information, such as your credit card number, expiration date, card verification number, and billing address if you make a purchase on our websites.
  • Internet and Network Activity Information. If you use our website, we may collect information about the browser you are using or your IP address. We might also collect device identifiers. We might look at what site you came from, or what site you visit when you leave us. We may collect page interaction information (such as what areas of the websites you visit and for how long, what search terms you enter, and what products or content you view and click on), and methods used to browse away from the page.
  • Demographic Information. Demographic information, such as your age or gender.
  • Location Information. Information about your general location, using your zip code or postcode and IP address.
  • Employment-Related Information. When you apply for a job, we collect information you submit as part of your application and resume. This might include your work experience and previous employment, your education, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa to work in a particular territory, and/or salary expectations.
  • Inferences: Using the other pieces of personal information collected about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.

 

II. How We Collect Information

We collect the above-referenced categories of personal information from the following categories of sources:

Information You Provide to Us. When you use our Websites, such as when you reserve a room with one of our Preferred properties, or take advantage of special offers through our I Prefer loyalty program, we, or our service providers (acting on our behalf), collect personal information that you provide to us , such as your first and last name, email address, telephone number(s), postal address, and (when you purchase travel or make a reservation online) payment card information. We also collect more specific information that you provide, like travel behavior and lifestyle. Some of this more specific information is collected on our Websites, and some is collected from sources like business reply cards that are bound into various trade publications, and marketing partner data forms that are distributed at the front desk at all Preferred properties.

Information Collected Automatically from Your Device. When you use the Websites, we or our service providers, will also collect information about your use of the Websites and the device you use to access the Websites (e.g., your computer, tablet, phone, etc.) such as your IP address and country location, browser information (including browser type, capabilities, and language), operating system, the date and time you accessed the Websites, and Websites usage information, including the paths taken as you move from one webpage to another webpage (i.e., your “click stream” activity). We collect this information using cookies and other technologies.

  • Cookies. A cookie is a small piece of information sent by a website that is saved on your hard disk by your computer’s browser. It holds information a website may need to personalize your experience, including by determining whether you are logged in to your account. We use cookie technology as part of the Websites’ statistical reporting and for other purposes related to making the Websites available to you.
  • Web Beacon. A web beacon is an electronic image, also called a single-pixel or clear GIF, placed in the code of a webpage or in emails. The Websites use web beacons and similar technologies to track traffic patterns of users as they navigate from one page to another. This information may help us improve our users’ browsing experience. We also use web beacons through a third party website analytics provider, as well as standard web server log files, to help us count visitors and evaluate the technical capacity of the Websites. This information tells us how many people visit the Websites and helps us decide how to arrange pages in the most user-friendly way.

Information from Third Parties. We also receive data from outside sources, and we combine this information with other information about you to facilitate more relevant, targeted communications as well as develop products and services that better suit our customers’ needs.

III. Our Legal Basis for Processing Your Information

If you are accessing our Websites in the European Economic Area (“EEA”), then applicable law requires us to ensure that we only process your personal information where we have a legal basis to do so. We will only process your personal information where at least one of the following applies:

  • If it is in our legitimate interests or the legitimate interests of others (such as our Preferred properties) to use your personal information. For example, it is in our legitimate interests to use your personal information to improve our Websites, and to share your personal information with third parties who provide services to us relating to our Websites. If you would like further information about how we decide when a particular use is in our legitimate interests, you may contact us using the contact details set out below.
  • We need to use your personal information to perform our responsibilities under a contract we have with you (including, for example, processing your reservations, fulfilling your travel-related orders, and administering our I Prefer loyalty program).
  • Sometimes we may ask for your consent to use certain types of personal information (e.g., by asking you to tick an online box). In these circumstances, your consent will be our legal basis for processing your personal information. If you have provided consent, you may withdraw it at any time. You may do this by “opting out” where we give you the opportunity to do so, or by contacting us using the contact details below.

IV. How We Use Your Information

We (and our service providers) will use your personal information for the following purposes:

  • To provide the features and functionality of the Websites to you.
  • To facilitate your hotel reservations and experience purchases.
  • To give you rewards through the I Prefer loyalty program, and to inform you about special promotions that run throughout the year.
  • To identify you as the sender of, and to process, your emails.
  • To respond to questions and comments.
  • To review your job applications and contact you about employment opportunities, if you have consented to this.
  • To improve, enhance, and tailor the Websites for you (for example by providing content or features that match your interests), and to improve and enhance the overall experience for all users of the Websites.
  • To send you emails or postal mail about special offers or promotions, if you have consented to this.
  • To introduce you to additional value-added services offered by our partners that we feel may be of interest to you, if you have consented to this.
  • To protect our website and our customers (for security purposes).

We may anonymize your information (for example by aggregating it with other individuals’ personal information so that it no longer identifies you) and use it for other purposes in anonymized form.

V. How We Share Your Information

We will share your personal information for the following purposes:

  • Our Affiliates: Other PHG businesses (our “Affiliates”) jointly use personal information for the purposes described in this Privacy Policy, where this is acceptable under applicable law.
  • Business transfers: If a third party acquires all or substantially all of our assets, your personal information, and any other information that we have collected in connection with the Websites, will be transferred to such third party as part of our business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information will be considered part of our assets and may be sold or transferred to third parties.
  • Legal purposes: We will share your personal information with third parties (including, potentially, government agencies) if required or requested to do so by law, or if we believe such action is necessary or advisable in order to: (1) conform to the requirements of the law or comply with legal process served upon us; (2) protect or defend our legal rights or property, the Websites, or our users; (3) investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use; and/or (4) any other reason in our sole discretion.
  • Service providers: We use third parties to perform services on our behalf, such as payment processing, email marketing, analytics, promotions, and customer service. These service providers will access your personal information as necessary for them to perform their duties. For example, we will share bank details and payment card information with payment processors when you provide a payment card in connection with a purchase.

VI. Minors

The Websites are intended for use only by persons who are at least 18 years of age. Accordingly, we do not and will not knowingly collect personal information from anyone whom we know to be under 18 years of age. If you are under the age of 18, you may not use the Websites unless your parent or guardian has provided us with their consent for your use of these Websites.

VII. Do Not Track

We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

VIII. Transfers and Storage of Information

If you reside in a country other than the United States of America, you should be aware that the data that we collect from you will be transferred to, and stored in the United States The laws of the United States may not protect the privacy of your information at the same level as provided by the laws of your country. In an effort to safeguard individual privacy, we will only transfer personal information from the EEA to the United States if one of the following applies: we have entered into an agreement using standard contract clauses (approved by the European Commission or a data protection authority) with our service provider or Affiliate regarding the transfer; the service provider that transfers the data is certified under the EU-US Privacy Shield Framework; or you give your express consent to the transfer.

If you have any questions about our transfer of personal information to the United States, or would like further information, please contact us using the details below.

IX. Your Rights Regarding Your Information

If you are in the EEA, you have certain additional rights in relation to your personal information. If you would like further information in relation to these or would like to exercise them, please contact us using the contact details below at any time. You have the right to request that we:

  • provide access to any personal information we hold about you;
  • update any of your personal information which is out of date or incorrect;
  • delete any personal information which we are holding about you;
  • restrict the way that we process your personal information;
  • prevent the processing of your personal information for direct-marketing purposes;
  • provide your personal information to a third party provider of services;
  • provide you with a copy of any personal information which we hold about you; or
  • consider any valid objections which you have to our use of your personal information.

We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

You may ask us to stop using your personal information for advertising or marketing purposes at any time. If you wish to do this, please follow the removal instructions in any communication you receive, or contact us using the information below.

X. Your California Privacy Rights

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

If you reside in California, you have the right to make the following requests with respect to your personal information:

  • Access – You have the right to request that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the categories of personal information sold or disclosed, the business or commercial purpose for collecting and selling the personal information, the categories of third parties with whom we share the personal information, and the specific pieces of personal information collected about you over the past 12 months.
  • Deletion – You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
  • Right to be free from discrimination – You have the right not to be discriminated against for exercising these rights.
  • Opt-out – For purposes of this privacy policy, “sell” means the sale, rental, release, disclosure, dissemination, availability, transfer, or other oral, written, or electronic communication of your personal information to an outside party for monetary or other valuable consideration. Based on our understanding of California law, we do not sell your personal information, so we do not offer the opt-out right.

We will not discriminate against you because you exercised any of these rights.

A California resident can exercise these rights by clicking here, by emailing us at privacy@preferredhotels.com or by calling us at 1-866-990-9491. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.

XI. What Other Choices Do You Have?

Opt-Out of Cookies & Other Technologies. If you prefer, you can configure your browser to reject all cookies, or to 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 and privacy preferences. For more information about HTTP cookies and how to disable them, or restrict the categories of cookies you wish to accept, you can consult the information at www.allaboutcookies.org/manage-cookies/. However, if you reject cookies, your use of the Websites may be impaired.

XII. Data Retention

We will generally store information associated with your account until it is no longer necessary to provide services to you, until you ask us to delete it, or until your account is deleted, whichever comes first; but there are some exceptions to this general rule. We will retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements, and take other actions permitted by law. For more information, contact us using the details below.

XIII. Third Party Websites, Content, and Resources

Please be aware that when you are using the Websites, you could be directed via links or other means to third-party websites, content, and resources that are not affiliated with the Websites or PHG. These third-party websites, content, and resources may send their own cookies to visitors, collect data, and/or solicit and use your personal information in ways different than those set forth in this Privacy Policy. The privacy policies of these third parties may be very different from this Privacy Policy. We are not responsible for the privacy practices of the third-party providers of these other websites, content, and resources and cannot provide you with information regarding the security of any personal information they collect.

XIV. Security

We will take reasonable steps to protect the security and integrity of all personal information provided to these Websites. However, please note that we cannot guarantee that any information transmitted through the Internet or stored on our system or otherwise in our care will be absolutely safe from prohibited intrusion by others. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after the transmission or storage of your personal information.

XV. Privacy Policy Updates

From time to time, we may revise this Privacy Policy to reflect initiatives in the hospitality industry, changes in the law or technology, or changes in our privacy practices. If we make any material changes we will provide you with a prominent notification prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

XVI. Contact Us

If you have any questions or comments regarding our privacy practices, you may contact us using the following details:

Email: Privacy@PreferredHotels.com

Post: Preferred Hotel Group, Inc.

Consumer Privacy Policy
311 South Wacker Drive
Suite 1900
Chicago, Illinois  60606 USA

In addition, if you are in the EEA and you have any complaints about how we use your Personal Information, you have the right to lodge a complaint with the data protection authority in your country or seek a remedy through local courts if you believe your rights have been breached. A list of data protection authorities is available here.

Effective Date: January 1, 2020