CARLSON REZIDOR HOTEL GROUP PRIVACY POLICY - YOUR PRIVACY RIGHTS

Effective Date: April 1, 2015
Last updated: August 23, 2017

This Privacy Policy applies to the sites and apps where it appears.

This Privacy Policy describes how Carlson Hotels, Inc., and other entities within the Carlson Rezidor Hotel Group treat personal information collected through the websites and applications where it appears (sometimes referred to collectively as our “website”) and how Carlson Hotels, Inc. treats personal information transferred pursuant to the E.U.-U.S. and Swiss-U.S. Privacy Shields.

Carlson Rezidor Hotel Group is a system of hotels operating under various brands owned by Carlson Hotels, Inc. The hotels may be owned, managed, or licensed by Carlson Hotels, Inc. or by a master licensee (such licensed properties being independently owned and operated). In this Privacy Policy, the term “Carlson Rezidor Hotel Group” refers to Carlson Hotels, Inc., its affiliates, its master licensees, and all hotels operating under the Carlson Rezidor brands. We may also refer collectively to these entities as "the Group", "we" or "us".

This Privacy Policy applies only (1) to personal information collected through the websites and applications where it appears, including the sites and apps for our hotel brands and our loyalty programs, as well as information collected at our call centers or through reservations transferred to us by hotels or travel intermediaries, and (2) personal information transferred to Carlson Hotels, Inc. pursuant to the E.U.-U.S. and Swiss-U.S. Privacy Shields. This Privacy Policy does not apply to information collected through other channels.

Your consent

Please review this Policy before using this website or mobile app. By using this website, you are consenting to the collection, use and disclosure of your information as set forth in this Policy. If you do not agree to be bound by this Policy, you may not access or use this service.

We collect information from and about you.

We collect contact information. For example, we might collect your name and email address. We may also collect your phone number or mailing address.

We collect travel agent information. If you are a travel agent and you enroll in our travel agency loyalty program, we will collect your travel agency ID number. For U.S. travel agents who accrue certain point levels, we may also collect your social security number if required by law to do so.

We collect demographic information. We may collect information such as your gender, age and language preferences.

We collect guest stay and loyalty program information. For example, we collect information on the hotels where you have stayed, your dates of arrival and departure, goods and services purchased, special requests and service preferences. We collect information on your use of our loyalty programs, including how you earn and redeem points.

We collect payment information. For example, we may collect your credit card number if you make a reservation online.

We collect business information. For example, we collect contact and other relevant information about your business if your business enrolls in one of our loyalty programs, or if your employees or agents use a corporate account to do business with us.

We collect information you submit or post. For example, we collect feedback about our hotels and services that you submit to us. We also collect information if you apply for a job.

We collect other information. If you use our website, we may collect information about the browser you’re using. We might look at what site you came from, or what site you visit when you leave us. We may collect your precise, real-time location using GPS, cell phone towers, Wi-Fi signals, and/or beacon technology (including Apple’s iBeacon), and/or future technologies. We might look at how often you use an app and where you downloaded it. We collect this information using the tracking tools described below and in compliance with applicable local law. To control those tools, please read the choices section below.

We collect information in different ways.

We collect information that you give to us. For example, if you make a reservation online, or enroll in one of our loyalty programs. We also collect information if you contact us or participate in a promotion.

We collect information about you automatically. Where permitted by law we use tracking tools such as browser cookies and web beacons to collect information from you. We collect information about users over time when you use this website.

We may have third parties collect personal information this way. Learn more about these tools and how you can control them at www.parkplaza.com/section/privacy.cookies/privacy.sidemenus. We also collect information from our mobile apps.

We get information about you from third parties. Where permitted by law, we may share information among entities within the Group or we may get from other third parties with whom we do business. We may get information from persons acting on your behalf, for example if someone makes a reservation for you. We may also get information from social media platforms and advertising and analytics providers.

We combine information. For example, we may combine information that we have collected offline with information we collect online, to the extent covered by the transactional purpose or your consent. Or we may combine information we get from a third party with information we already have.

We use information as disclosed and described here, subject to any consent required by applicable law.

We use information to respond to your requests or questions. For example, we will use your information to provide the services you request, such as to fulfill a request for a hotel reservation, and to send you a pre-arrival email, a post-departure email, or to ask you to participate in a customer survey. Where legally permitted, we may use your personal data to personalize your experience with us. We might use your information to respond to a question about your loyalty account or to fulfill a redemption request. We use social security numbers and tax ID numbers to process tax documents.

We use information to improve our websites and services. We may use your information to make our hotels, services and loyalty programs better. We might use your information to customize your experience with us. Where legally permitted, we may combine information we get from you with information about you we get from third parties.

We use information to administer our site and for internal operations. For example, we may aggregate or anonymize your information for analytics, research or other business purposes.

We use information for security purposes. Where legally permitted, we may use your information to protect our company, our customers, and our websites.

We use information for marketing purposes. For example, we might send you information about new services and special offers. We might also use your information to serve you ads about our hotels, loyalty programs and offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. If you register with us, we’ll send you our promotional emails. We obtain consents as required by law before marketing to you. To manage this, read the choices section below. We may also use push notifications on our mobile apps.

We use information to communicate with you about your account or our relationship. We may contact you about your account or for feedback. We might also contact you about this Privacy Policy or our Site Usage Terms and Conditions.

We use information as otherwise disclosed or permitted by law.

We may share information with third parties.

We will share information within the Group unless legally prohibited. For example, we will share your information to facilitate reservations or to customize offers to your preference.

We will share your information with data processors that perform services on our behalf. For example, we share information with vendors who send emails and other communications for us. We also share information with companies that help us operate our sites or run promotions and advertisers and advertising networks that assist us in marketing and advertising our products and services. Some vendors may be located in a country other than where you live. We may also share information with analytics and search engine providers who act on our behalf.

We may share information with our business partners unless legally prohibited. For example, we might share information with third parties who co-sponsor a promotion. Some of these partners may send you information about product or services by mail or email where legally permitted or based on your prior consent.

We will share information if we think we have to in order to comply with the law or to protect ourselves, our customers or others. For example, we will share information to respond to a court order or subpoena, or in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Or, when required by law, we may share your information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list. We may share information in order to enforce our Site Usage Terms and Conditions or other agreements, and to protect the rights of others. We might share if we are investigating potential fraud. This might include fraud we think has happened during a promotion.

We may share information with a successor to all or part of our business. For example, if part of our business or assets are sold, we may disclose user information as part of that transaction. You have certain choices about sharing and marketing practices.

You can opt out of receiving our marketing emails. To stop receiving our promotional emails, you can visit your account settings on the site or follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will send you transactional messages. These include responses to your questions.

You can control participation in our iBeacon program. iBeacons are electronic devices that broadcast signals that can be received by mobile devices on which one of our mobile apps is installed. If you have voluntarily installed one of our apps on your device, and if you have granted permission for the app to track your location, then iBeacons installed in our hotels may send a signal to the app on your device about the precise, real-time location of the device. The app may use this information to deliver special offers and promotions to you, at a time and place when the information is most relevant. For example, if you are in one of our hotels late in the afternoon, your mobile device may receive a signal from an iBeacon that causes the app to notify you about drink or dinner specials. As a convenience to you, receipt of the iBeacons signal and delivery of the special offer or promotion may occur even if you are not currently using the app. To make our mobile apps and services operate better, we may also collect other information based on iBeacon signals, for example, the strength of the signal between the iBeacon and your device, the duration your device is near the iBeacon, or the battery level of the iBeacon itself. To avoid having us receive or use your precise, real-time location, do not opt-in to location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the app.

You can control cookies and tracking tools. To learn how to manage how we – and our vendors – use cookies and other tracking tools, please visit www.parkplaza.com/section/privacy.cookies/privacy.sidemenus.

You can control tools on your mobile devices. For example, you can turn off the location services or push notifications on your phone. Choices you make are device specific.

EU and Switzerland Residents.
Information about European Union and Switzerland residents may be sent to the U.S., where it is processed in accordance with this Privacy Policy and our Ad and Cookie Policy, the U E.U.-U.S. and Swiss-U.S. Privacy Shields. Carlson Hotels, Inc. complies with the E.U.-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland (please note that the Privacy Shields principles do not necessarily apply to the collection, use and retention of personal information from other countries). Carlson Hotels, Inc. has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. The Federal Trade Commission shall have enforcement jurisdiction over Carlson Hotels, Inc.’s compliance with the Privacy Shield. Carlson Hotels, Inc. may have potential liability in cases of onward transfer to third parties. To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov/.

Inquiries and Enforcement of Compliance

In compliance with the E.U.-U.S. and Swiss-U.S. Privacy Shield Principles, Carlson Hotels, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Switzerland residents with inquiries or complaints regarding this privacy policy should first contact Carlson Hotels, Inc. at the address provided below.

Carlson Hotels, Inc. has further committed to refer unresolved privacy complaints under the E.U.-U.S. and Swiss-U.S. Privacy Shields to the American Arbitration Association, http://go.adr.org/privacyshield.html. Finally, in certain limited circumstances and as a last resort, it may be possible for individuals to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Please note that if you are not a European Union or Switzerland resident, then Privacy Shield requirements regarding the handling of complaints may not apply to you and Privacy Shield enforcement mechanisms may not be available to you.

Russian Citizens.
In accordance with Russian Federal Law "On Personal Data" No. 152-FZ we collect, record, systematize, accumulate, store, update (renew and modify), and extract personal data about Russian citizens using databases located in the territory of the Russian Federation. If you indicate that you are a Russian citizen of the Russian Federation, we will process your personal data in compliance with this requirement and your profile will be maintained on databases in the Russian Federation. If you do not indicate that you are a citizen of the Russian Federation, we are not able to process and maintain your personal data under these requirements and will not be liable for that. You are solely responsible for indicating the country of your citizenship. Information containing personal data of Russian citizens may be transmitted from the Russian Federation to countries that ensure an adequate level of protection for personal data, including member states of the European Union and other countries which Russian law recognizes as ensuring adequate to protection, and also to other countries that may not ensure adequate level of protection for personal data. By submitting information to us on our sites and apps, submitting forms to us, or registering on our sites, programs and apps, or making reservations, you grant us consent to process your personal data.

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 at privacyquestion@carlsonrezidor.com 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.

Our sites and children.
Our sites and apps where this Privacy Policy is found are meant for adults. We do not knowingly collect personally identifiable information from children under 18 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 18 has given us information, you can contact us at privacyquestion@carlsonrezidor.com, or write to us at the address listed as the end of this Privacy Policy. Please mark your inquiries "COPPA Information Request." Parents in the United States, you can learn more about how to protect children's privacy on-line at www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.

We use standard security measures. The Internet is not 100% secure. We cannot promise that your use of our sites and apps will be completely safe. Any transmission of your data to our site is at your own risk. We encourage you to use caution when using the Internet. This includes not sharing your passwords.

We retain data. We keep personal information as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep information as otherwise required or permitted by law.

We store information both in and outside of the U.S.
Information we collect from you may be transferred to, or stored at, a destination in the United States or another destination outside of United States. It may be processed by staff operating in these locations who work for us or one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. U.S. laws may not afford the same level or protection as those in your country.

Your profile may be maintained on databases in Denmark if you have stayed at a Radisson Blu hotel (except for Radisson Blu Edwardian hotels) or are a member of Club Carlson residing in Europe, the Middle East and Africa. In such cases, you may access your profile and adjust your email preferences by contacting Rezidor Hotels ApS Danmark, Data Protection Office, Amager Strandvej 60 - 64. 3rd floor, DK Copenhagen S, Denmark.

We may link to other sites we don't control. If you click on a link to a third party site, you will be taken to a website we do not control. This Privacy Policy does not apply to the privacy practices of that website. Read the privacy policy of other websites carefully. We are not responsible for these third party sites or their policies.

Feel free to contact us if you have more questions.
If you have questions about an individual hotel's practices or the information it has, please contact that hotel directly. If you have any questions about this Privacy Policy, or if you want to correct, update, reasonably access or delete, your information with us, please email us at: privacyquestion@carlsonrezidor.com. For your safety and ours, we may need to authenticate your identity before fulfilling your request.

You can also write to us at:
Carlson Hotels, Inc.
Mail Stop 8256 Attn: Privacy
701 Carlson Parkway
Minnetonka, MN 55305

We may update this Privacy Policy.
From time to time we may change our privacy policies. We will notify you of any material changes to our Privacy Policy as required by law. We will also post an updated copy on our website. Please check our site periodically for updates.