Last Updated: July 1, 2018
Click on the links below to review the different sections of our Privacy Statement:
▼ How HOS Collects Information
· Directly from you;
· Through our websites and mobile apps;
· From social media or other public forums; and
· From third party vendors or business partners.
▼ Types of Personal Information that HOS Collects
The types of personal information HOS collects may include:
· Name, gender, contact information; business title, date and place of birth, nationality, passport and visa information.
· Information related to website searches, reservations, stays and visits to a property, including names of hotels, dates of arrival and departure, goods and services purchased, special requests made and information necessary to fulfill special requests, preferences that require special accommodations, observations regarding service preferences (including room, holidays, amenities requested, facilities or other services used), telephone numbers dialed, faxes sent or received, telephone messages received through hotel facilities.
· Information regarding participation in a membership or loyalty program, including online user account details, profile or password details and any frequent flyer or travel partner program affiliation and member number.
· Billing information such as credit card details, billing address, and purchase history.
· Personal characteristics, income, travel history.
· Information about vehicles brought onto HOS’ properties.
· Reviews and opinions about HOS or properties or other personal information in customer surveys.
· Hotel, airline, and rental car packages booked.
· Groups associated with stays at hotels, including contact and other relevant details concerning the employees of corporate accounts and vendors and others with which HOS does business (e.g., travel agents or meeting and event planners).
· Other types of information provided to HOS or obtained by HOS from third parties.
· Details on joint travelers, including their names and frequent flyer numbers, and the age of the driver of the rental car.
· Information and records related to conversations, including recording or monitoring of customer service calls.
· Additional contact information from third parties with which HOS does business (e.g., travel agents or similar providers), such as email addresses that may be provided by travel agents.
· Additional personal information collected during registration/check-in at HOS.
· Images, sound or video of guests and visitors in public areas and information related to visitor location while on property, closed circuit television and other technologies and security tools.
· Other recordings of sound or video using other technologies to protect staff.
· Personal information in connection with on-property services.
· Information about the guests that are a part of a group or event that may be provided by the group or meeting planner.
· Information provided by individuals, companies or groups to make a reservation on others’ behalf.
· Other information requested by or provided in the context of employment or supplier applications.
· Any information you enter via online.
· Geolocation data.
· Information obtained from other sources, such as public databases, social media platforms, and other third parties.
If you submit any personal information relating to other people to HOS, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Statement.
▼ Use of Personal Information
HOS may use personal information to:
· Provide requested services (such as facilitating reservations, sending confirmations, sending pre-arrival messages, and providing other information about the hotel and the area).
· Process and complete transactions, reservations, and bookings.
· Assist with and provide information about meeting, event or celebration.
· Operate, evaluate and improve our business, our Services, and other products and services we offer (including to develop new products and services).
· Administer surveys and other market research.
· Send offers and promotions that may be of interest to you.
· Offer promotions, sweepstakes, or other contests.
· Provide location information that is useful to you, including the use of Geolocation and Global Positioning System (GPS).
· Comply with legal requirements, judicial process, and our company policies
· Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile apps), and claims and other liabilities, including by enforcing the terms and conditions that govern the use of our websites and mobile apps.
We may use your information in furtherance of our legitimate interest to provide you with the Services offered by HOS. We may also use your information to manage our contractual relationship with you or to comply with our legal obligations.
To the extent we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
▼ How HOS Shares Personal Information
· Personal information provided in connection with a reservation is made available to the hotel in order to fulfill the reservation request. After the stay, the information, including stay details, room type, services, amenities used, etc. is retained. HOS may provide the hotel's owner and manager with limited information about past or future guests of that hotel.
· To provide users a single source for purchasing packages that include other travel-related services such as airline tickets or rental cars, HOS may enter into agreements with select reputable third-party companies that sell HOS-branded products. Any personal information provided to these third parties will be controlled by each of them and is subject to their respective privacy statements and practices.
· Information collected for meeting and event planning for stays or visits as part of a group event or meeting may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
· From time to time HOS may partner with other companies to provide products or services and may share information with HOS business partners to provide those products or services. For example, HOS may help to arrange tours, rental car or other services and share personal information in order to provide those services.
· HOS relies on service providers to provide certain products and services, such as to facilitate administrative functions and information technology operations, payment card or account billing, reservations services, market researchers, email service providers, providing services in connection with the website, including airline and rental car packages; communicating news and delivering promotional and transactional materials via email, direct mail, and online and mobile advertising; processing payment card or account transactions, data hygiene and enhancement services; professional services such as accounting, auditing and legal advice; investigating accident reports; processing insurance claims; and administering sweepstakes, prize draws, competitions, contests and customer surveys and will disclose personal information to service providers as appropriate.
· In the event of a reorganization, merger, consolidation, sale, liquidation or transfer of all or a part of any hotel or its business or assets, joint ventures, and related business transactions, including in relation to audit or reporting and other regulatory requirements, HOS may, in its sole and absolute discretion, transfer, sell or assign information collected, including, without limitation, other Information and personal information, to one or more affiliated or unaffiliated third parties.
· HOS may share guests’ telephone numbers among partners and service providers, for purposes of telemarketing.
· In addition, HOS may disclose personal information without the guest or user’s permission in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal processes, (iv) protect the rights, privacy, safety or property of HOS, website and apps visitors, guests, employees or the public, (v) permit HOS to pursue available remedies or limit the damages that HOS may sustain, (vi) enforce website and apps terms and conditions, and (vii) respond to an emergency.
▼ Other Non-Personal Information Collected by HOS
When guests or users are visiting and interacting with the Services, HOS and third parties may collect Other Information (for example, a catalog of the site pages visited, and the number of visits to HOS’ sites).
Because Other Information does not personally identify the user, such information may be disclosed for any purpose. In some instances, HOS may combine Other Information with personal information. If HOS does combine any Other Information with personal information, the combined information will be treated by HOS as personal information in accordance with this Statement.
We may aggregate and/or de-identify data about visitors to our Services and use it for any purpose, including product and service development and improvement activities.
▼ Cookies and IP Addresses
Users can set their computer to warn them each time a cookie is sent or turn off all cookies (except Flash cookies) through their browser. The browser's Help menu or users’ built-in mobile device settings can be checked to see how. Some mobile devices store cookies not only in areas connected to the browser, but also in areas that are app-specific, which cannot be controlled by the browser settings. App settings options on mobile devices can be checked to see how to manage or delete cookies that may be stored in these other areas. If users do not accept cookies, some features, Services or activities that are available on the website and apps may be adversely affected and users may be unable to perform certain transactions, use certain functionality, and access certain content.
· Session cookies which are automatically deleted once users close their browser.
· HTTP request header information in order to make the website function correctly and to personalize content presented to users, better understand how visitors use the Services and how HOS can better meet user needs.
· Throughout the online reservation process to remember dates used in hotel searches, check room availability and fulfill the reservation.
· Allow registered users to sign in without typing their email, and YouFirst number each time.
· Measure usage of various pages on the website and apps to help make HOS’ information more personalized and easily accessible.
· Provide functionality such as online reservations, YouFirst transactions, and other functionality that HOS believes would be of interest and value to users.
· Track customer response to HOS advertisements and website content.
· Determine the browser’s ability to receive HTML email messages to determine the appropriate format to receive and read email.
· Know how many users open an email and allow HOS’ service provider to compile aggregated statistics about an email campaign for us.
· Serve ads through third-party advertising technology when users visit the website and apps and sites upon which HOS advertises. In the course of serving HOS’ advertisements to users, unique third-party persistent cookies, clear gifs or beacon gifs may be placed on users’ computer or device, provided by HOS’ ad-serving providers, to help manage HOS’ online advertising and which recognize when a device visits the website, to learn which banner ads bring users to the website and to track whether a reservation is made. The information HOS’ ad-serving providers and HOS collect through this technology is not personally identifiable, but is used to create a profile which allows the ad-serving provider to serve adverts targeted towards users and users’ interests across the ad-serving network. To the extent third-party vendors are using Cookies or Other Technologies to perform these services for HOS or others, HOS does not control the use of this technology or the resulting information, and is not responsible for any actions or policies of such third parties. Ads, emails, and other messages may be delivered to users based on their online or mobile behavior (on the website and non-HOS sites), users’ search activity, users’ geographic location or other information. For example, if a user goes to the website to book a hotel room, they may later see an advertisement from HOS when they visit another website. These ads may appear on the website, third-party websites or on mobile platforms. Users may also see advertisements for third parties on the website and apps, other websites or properties, or mobile, based on their visits to, and activities on, the website and apps, other sites and mobile. Some of HOS’ vendors and HOS may use anonymous data, such as demographic data received from third parties, or intent information (such as travel intent information) to assist in the delivery of advertisements to users. In some instances HOS may combine Other Information with personal information.
HOS and its third-party service providers use web beacons and pixel tags to:
· Track customer response to the HOS advertisements and Website content;
· Determine users’ ability to receive HTML-based email messages and know how many users open an email and allow HOS service provider to compile aggregated statistics about an email campaign for HOS; and
· Allow HOS to better target interactive advertising, enhance customer support and site usability, and provide offers and promotions that HOS believes would be of interest to users.
▼ Do Not Track Signals
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.
From time to time, guests and site users may enroll to receive special offers by agreeing to the use of beacon technology. Beacon technology may allow HOS to collect information about users’ location within participating hotels through users’ mobile phone or device’s Bluetooth or similar capabilities in combination with technology implemented by HOS’ properties. HOS will only gather these kinds of location information if users agree to share them with HOS by opting-in to receive the special offers and by enabling these capabilities on users’ mobile device. Once users have opted-in to receive the HOS special offers and consented to HOS’ gathering of location information, HOS will continue to collect location information until users log off or disable users’ mobile device’s applicable geolocation, GPS, Bluetooth or similar capabilities.
▼ Personal Information from Children
HOS does not knowingly collect personal information from individuals under 18 years of age. Parents or legal guardians should not to allow children to submit personal information without permission. Parents or legal guardians may provide information regarding children accompanying them.
▼ Mobile and Location-Based Service
HOS may provide mobile apps that can be downloaded to smart phones or other devices. These apps provide services and may collect personal and Other Information that will be used in accordance with this Statement.
HOS’ mobile apps may use the device’s Global Positioning System (GPS) technology to locate a nearby hotel and/or to provide relevant location-based information. HOS may also share this information with third parties. The device’s settings are used when accessing any geo-location data. To the extent any geo-location data is combined with personal information, that information will be treated as personal information in accordance with this Statement.
HOS may make available from time to time a virtual concierge application, which may be pre-loaded on a HOS-owned device, or may be downloadable to a mobile device. Using these applications, guests may be able to order services from the hotel, such as room service or valet parking; access HOS’ sites; access third-party sites, including local attractions and social media; and book a reservation. To order services from the hotel, guests may need to enter name and room number, and may be able to receive order confirmations via text messaging. If text confirmation is requested, a phone number and carrier may be required. Booking reservations may require sign in to a HOS’ YouFirst account or entry of a HOS’ confirmation number and security codes.
You may stop sharing your location data by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.
▼ Links to Third Parties
The Services may contain links to third party sites, applications and services. Please note that HOS is not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties or the content of their sites, applications and services.
Other third-party sites, applications and services include the landing page of the high-speed Internet providers at HOS hotels, as well as social media and other sites (such as Facebook, Twitter, Instagram, TripAdvisor, etc.) on which HOS or HOS may have accounts where users may be able to post information and materials. Logging-in or connecting with such sites may also provide HOS with information via that third party in accordance with their policies and privacy selections on their sites (e.g., locations, postings, connections, etc.).
Information provided to or on third-party sites is subject to the privacy statement and terms of service on those sites. HOS encourages users to read the privacy policies of sites, applications and services before submitting personal information.
▼ Protection Personal Information
Because the security of personal information is important, HOS enables the use of Secured Socket Layer (“SSL”) browser transmission of personal information. If a user’s browser is SSL enabled, transmission of personal information to HOS online through the browser can be encrypted. Users can verify whether their personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of their browser window. Users can also verify that transmission of personal information is encrypted using SSL encryption by making certain that the prefix for the web address listed for that page has changed from “http” to “https”. If the appropriate symbol and the “https” prefix is not visible, a user should not assume that the personal information that they are being asked to provide will be encrypted prior to transmission. The personal information collected from users online through the Services is stored by HOS and/or HOS service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and HOS is not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. HOS will also seek to require HOS’ affiliates and service providers with which HOS shares personal information to exercise reasonable efforts to maintain the confidentiality of personal information shared by HOS For online transactions, HOS uses reasonable technology to protect personal information provided to HOS via the Services. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure. Use of the Services and related applications and transmission of data is at the user’s own risk. Use caution in using electronic communications and media. Do not share passwords.
For privacy protection, HOS encourages users not to include sensitive personal information in any emails sent to HOS Do not send payment card or account numbers or any sensitive personal information to HOS via email.
HOS will not contact users by mobile/text messaging or email to ask for confidential personal information or payment card or account details. HOS will only ask for confidential personal information or payment card or account details by telephone or website when users are booking a reservation or promotional package by telephone. HOS will not contact users to ask for YouFirst account log-in information. Do not respond to those kinds of requests.
▼ Your Privacy Choices
If you would like to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us, or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us at firstname.lastname@example.org.
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information removed from our database, or other limitations you would like to put on our use of your personal information. We may reject your request, as permitted by applicable law.
We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal information provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.
▼ Retaining Personal Information
HOS retains personal information for the period necessary to fulfill the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law.
▼ International Data Transfers
We may transfer your personal information to countries other than the country in which you initially provided the information for the purposes described in this Privacy Statement. For example, if you are located outside of the United States, we typically transfer your personal information to the United States, where HOS is headquartered. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information.
We may transfer personal information from the European Economic Area (“EEA”) to countries that the European Commission has deemed to adequately safeguard personal information, in which case no additional safeguards are required in order to transfer this information. If we transfer your personal information to other countries, we will either transfer it subject to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield, or Binding Corporate Rules, or with your consent to the transfer, unless we are permitted by law to transfer personal information without such formalities.
▼ Special Notification to California Residents
Individual users who reside in California and have provided their personal information to HOS may request information about HOS’ disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to HOS at email@example.com. Within thirty days of receiving such a request, HOS will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. HOS reserves HOS’ right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
▼ Updates to this Statement
HOS may modify this Statement from time to time. When HOS makes material changes to this Statement HOS will post a link to the revised Statement on the homepage of the Services. Users can tell when this Statement was last updated by looking at the link and at the date at the top of the Statement. Any changes to HOS’ Statement will become effective upon posting of the revised Statement on the site. Use of the Services following such changes constitutes acceptance of the revised Statement then in effect.
▼ How to Contact HOS
Questions about this Statement or how HOS processes personal information may be submitted to HOS by email at firstname.lastname@example.org.