WYNDHAM HOTEL GROUP, LLC PRIVACY NOTICE
Your Acceptance of Our Privacy Notice: By using the Services (defined below), you consent to the terms of this Privacy Notice and the ways we collect, use and share your personal information, including the transfer of your personal information to and within the United States. If you do not consent to the terms of this Privacy Notice, please do not continue to use the Services.
Wyndham Hotel Group, LLC ("WHG") and its subsidiaries are concerned about privacy issues and want you to be familiar with how we collect, use and disclose information. In this Privacy Notice, WHG and its subsidiaries may be referred to collectively, as "Wyndham," "we," "us" or "our." Wyndham Rewards®, and any successor or additional guest loyalty programs may collectively be referred to as "Loyalty Programs." This Privacy Notice applies for our Wyndham Rewards® Loyalty Program and each of the following of our other brands: Wyndham Grand®, Wyndham Hotels and Resorts®, Wyndham Garden®, Dolce Hotels & Resorts®, TRYP by Wyndham®, Dazzler Hotels®, Esplendor Boutique Hotels®, Wingate by Wyndham®, Hawthorn Suites by Wyndham®, Microtel Inn and Suites by Wyndham®, Ramada®, Baymont Inn & Suites®, Days Inn®, Super 8®, Howard Johnson®, Travelodge®, and Knights Inn®.
This Privacy Notice describes our practices in connection with information that we collect, whether through websites operated by us from which you are accessing this Privacy Notice (the "Websites"), through the software applications made available by us for use on or through computers and mobile devices (the "Apps"), through our social media pages that we control from which you are accessing this Privacy Notice (collectively, our "Social Media Pages"), through other offline services and collection mechanisms (such as when you call our call center or book a reservation directly with a Hotel and the Hotel shares that information with us), or otherwise (collectively, including the Websites, the Apps, our Social Media Pages, and other offline services and mechanisms, the "Services"). The information you provide helps us to operate effectively and continually provide you with the best hospitality products, services and experiences.
This Privacy Notice does not apply for hotels operated by franchisees (independently owned and operated hotels) of WHG and/or its subsidiaries or that are managed but not owned by WHG and/or its subsidiaries ("Hotels"). For example, Hotels may use e-mail and other methods of marketing communications to contact their guests and they are solely responsible for these campaigns. Please read each Hotel's privacy notice to understand how it will treat your personal information.
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Please read this Privacy Notice to learn more about our privacy practices.
What Information Is Collected and How Is It Collected?
1. We may collect personal information (which is information that identifies you or relates to you as an identifiable person) about you, such as your:
- Postal address (including billing and shipping addresses)
- Telephone number
- Email address
- Credit and debit card number
- Financial information
- Profile picture
- Social media account ID
- Stay information
- Communication preferences
We may collect information from you when you interact with us such as when you:
- Register for a product or service
- Contact us with a question or request
- Use our Services
- Make a payment for a product or service
- Stay at, or make a reservation for, a Hotel
- Provide a testimonial or story
- Participate in a competition or sweepstake
- Participate in our loyalty program
2. Other Information We Collect about you:
- One of the purposes of cookies is to simplify the use of the Website. A cookie may save a user's login details, for example, so that the user does not need to login every time. Cookies, by themselves, do not provide us with your personal information.
- Cookies may be either "persistent" or "temporary" (or "session") cookies. A persistent cookie retains user preferences for a particular Website, allowing those preferences to be used in future browsing sessions and remains valid until its set expiration date (unless deleted by the user before the expiration date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies are also used for statistical or marketing purposes, to determine how the Website is used. These cookies are provided by us as well as by third parties (e.g., advertising partners). While we do not control or have access to advertiser cookies, we do permit those cookies to be used on this Website to facilitate tailored advertising and to monitor patterns of buying specific goods or interest in, for example, holidays or hobbies. These cookies run advertisements tailored to the user based on the user's online buying habits.
- Google Analytics: We use Google Analytics to help us get a better understanding of how visitors use this Website. The information generated by the Google Analytics cookie about your use of this Website is transmitted to and stored by Google. If you do not want your activity on this Website to be tracked by Google Analytics, you may opt out by using this link: http://tools.google.com/dlpage/gaoptout?hl=en
- Other Non-Personal Information: In addition to any personally identifiable information or other information that you choose to provide to us on the Websites, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain web site usage information whenever you visit or interact with the Websites. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information. We may use this usage information for a variety of purposes, including to enhance or otherwise improve the Websites. In addition, we may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively, referred to herein as a “Device Identifier”). A Device Identifier is a number that is automatically assigned to your Computer, and we may identify your device by its Device Identifier. When analyzed, usage information helps us determine how our Websites are used, such as what types of visitors arrive at the Websites, what type of content is most popular, what type of content you may find most relevant and what type of visitors are interested in particular kinds of content and advertising. We may associate your Device Identifier or web site usage information with the personally identifiable information you provide, but we will treat the combined information as personally identifiable information.
We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and to improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated companies and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.
- Adobe Marketing Cloud Device Co-op: WHG participates in the Adobe Marketing Cloud Device Co-op to better understand how you use our Websites across the various devices you use, and to deliver tailored promotions. Go to https://cross-device-privacy.adobe.com to learn more about how Adobe does this and to manage your choices relating to this linking of devices.
- From Other Sources: We may receive your personal information from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your Website account, certain personal information from your social media account will be shared with us, which may include personal information that is part of your profile or your friends’ profiles.
- Mobile Devices: When you use or access our Services from a mobile device, we may collect information such as your unique device ID and your location information. When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number, as well as any other personal information specified by the App in its terms or notices.
How Do We Use Your Information?
The information we collect from you helps us to identify ways that we can continue to serve you in the best way possible and provide you with personalized products and services that suit your lifestyle. We use personal information for the following purposes:
- To respond to your inquiries and fulfill your requests, such as to send you newsletters.
- To send administrative information to you, for example, information regarding the Services or an event that you are attending and changes to our terms, conditions, and policies.
- To complete and fulfill any purchases or requests for services, for example, to process your payments or a hotel stay or vacation rental, communicate with you regarding your purchase and provide you with related customer service.
- To send you marketing communications that we believe may be of interest to you via postal mail, email, telephone or SMS.
- To personalize your experience on the Services by presenting products and offers tailored to you.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. By entering any promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion. If you choose to enter a sweepstakes, contest or other promotion, personally identifiable information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion's official rules, such as on a winners list.
- To facilitate social sharing functionality.
- To allow you to send messages to a friend through the Services. By using this functionality, you are telling us that you are entitled to use and provide us with your friend's name and email address.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
- As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We may also aggregate and/or anonymize personal information for research, to improve our products and services, and for other business purposes.
How Do We Disclose Your Information?
Your information may be disclosed as follows:
- Affiliates: To other Wyndham businesses (our “Affiliates”), which may jointly or independently use the personal information for the purposes described in this Privacy Notice. A list of our primary Affiliates can be found in Wyndham Worldwide’s 10-K Annual Report. We may disclose your information to our Affiliates for the purpose of administering reservations, commission payments, promotions, sweepstakes or similar activities. In connection with our Loyalty Program, we may disclose your information to our Affiliates for the purpose of serving your Loyalty Program account, for example (without limitation) to participating loyalty program hotels, airlines, car rental services, retail stores and credit agencies and other program and marketing participants. You may be offered an opportunity to request additional information, materials or offers from the sponsor or our Affiliates; should you make such a request, we will provide your personal information to the Affiliate so that they can fulfill your request.
- Hotels and Vacation Rentals: We may share personal information with the owners and operators of Hotels and timeshare resorts in order to provide you with services.
- Business Partners, Loyalty Program Participants, and Other Third Parties: We may disclose your information to business partners, sponsors or other third parties in connection with administering reservations, commission payments, promotions, sweepstakes or similar activities. In connection with our Loyalty Program, we may disclose your information to third parties for the purpose of serving your Loyalty Program account, for example (without limitation) to participating loyalty program hotels, airlines, car rental services, retail stores and credit agencies and other program and marketing participants. You may be offered an opportunity to request additional information, materials or offers from the sponsor or other third party; should you make such a request, we will provide your personal information to the third party so that they can fulfill your request.
If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us. Opt-out requests can take up to ten business days to be effective. Please note that if you choose to opt-out, we may not have the ability to perform the requested Services or you may not be able to participate in one or more of our programs.
- Service Providers: We may disclose your information to service providers retained by us in connection with our business such as: travel services companies, financial services companies, property owners’ associations, vacation insurance companies, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, credit card processing, tax and financial advisers, legal advisers, accountants or auditing services.
Your information may also be disclosed as follows:
- Message Boards: We may make message boards, blogs, and other such user-generated content facilities available to users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to disclose your personal information. We are not responsible for the privacy practices of other users, including website operators to whom you provide information.
- Merger or Acquisition: To a third party who acquires any part of Wyndham Worldwide Corporation itself or any of its Affiliates, whether such acquisition is by way of merger, consolidation or purchase of all, or a substantial portion, of our assets.
- Disclosure Permitted by Law: To law enforcement authorities, government or public agencies, regulators, and/or to any other person having appropriate legal authority or justification for receipt of your information, if we believe that we are required or permitted to do so by law or legal process, to respond to claims, or to protect the rights, property or safety of Wyndham or others.
- Anonymized/Aggregated Information: Because aggregated or anonymized information does not personally identify you, we may use it for any purpose. If we combine anonymized or aggregated data with personal information, we will treat the combined information as personal information according to this Privacy Notice.
How Do We Safeguard Your Information?
Security of Your Information: We will take reasonable steps to protect the information you provide us from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure your information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of information that you provide to us via the Services.
Other Important Information
- Information Provided on Someone Else’s Behalf: If you provide us with information about someone else, please ensure you have the person’s permission to do so for the purposes detailed in this Privacy Notice.
- Links to Websites: The Services may have links to other websites that are not operated by us and, therefore, we have no control over how these websites may collect your information. You should read the privacy notices on those other websites before you submit your information through them.
- Social Media Sites: Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, or any personal information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
- Changes to Our Privacy Notice: From time to time we may revise this Notice and/or use personal information for new, unanticipated uses not previously disclosed in this Notice to meet changes in the regulatory or business environment, or to satisfy the needs of our customers and service providers. Updated and date stamped versions will be posted on the Services.
- Minors: We do not knowingly collect, maintain or use personal information from children under 18 years of age, and no part of our Services is directed to individuals under the age of 18.
- International Transfers: We are an international company and we may, subject to applicable law, transfer your information to our Affiliates or selected third parties where information protection standards may differ. For example, your information may be stored on servers located in other jurisdictions. We will take steps to help protect your information when it is transferred.
- Retention Period: We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Choices and Access
- Marketing: We may contact you by email, telephone, SMS or postal mail with information about products or services offered by Wyndham or a third party that may be of interest to you. You can opt-out at any time by doing the following:
- If you do not wish to receive further commercial emails from us, you can opt-out by using the unsubscribe function in the email you receive from us.
- If you do not wish to receive further direct marketing (including commercial emails) from us about Wyndham products or services, you can opt-out by sending an email to email@example.com.
- “Do Not Track” Browser Settings: At this time, we do not respond to browser ‘do not track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit our Website. You can learn about how to exercise choice regarding the collection of information about your online activities over time and across third-party websites or online services by visiting www.aboutads.info and www.networkadvertising.org.
- Access to Information We Hold about You: If you would like to access, obtain copies of, update, correct, or request that we suppress or delete any of the information we hold about you, or if you require further information from us about how we use your information, please contact us at firstname.lastname@example.org. In some jurisdictions, you may be charged a reasonable fee for access to your information.
Notice to California Residents
If you are a resident of California, California Civil Code, Section 1798.83, allows you to request information regarding the disclosure of your personal information by us to third parties for the third parties' direct marketing purposes. To make such a request, please contact us at email@example.com.
For Clients Booking a Property Located in Italy
1. Responsible Persons and Representatives: Contact us at firstname.lastname@example.org to obtain, free of charge, a complete and up to date list of "Responsible Persons" i.e., any person who we voluntarily appoint as such and who processes your personal information for and on our behalf, including vendors, service providers and/or our Affiliates (as applicable). You may contact our "Responsible Persons" to obtain copies of or access to your personal information. Currently, Wyndham Hotel Group's Privacy Lead is appointed as a "Responsible Person" to process your personal information for Hospitality Services. Separately, we may appoint a representative in your country for data privacy purposes. Contact us at email@example.com for details.
2. Additional information about your data privacy rights: You have a right to:
- Ask for confirmation as to whether or not your personal information is processed and receive communication of that in an intelligible form.
- Get information relating to:
- The collection source of your personal information;
- The Purposes and methods of processing your personal information;
- The identity of the Data Controller and its “responsible” persons or local representatives, if appointed; and/or
- The entities and individuals or relevant categories to whom or which your personal information may be communicated.
- Updates, rectification or integration to/of your personal information;
- Confirmation that your personal information is deleted, made anonymous or blocked if processed unlawfully, including the personal information whose retention is unnecessary for the purposes for which it has been collected or subsequently processed; and/or
- Confirmation that the aforesaid operations have been notified, as also related to their contents, to entities and individuals to whom or which your personal information was communicated or disseminated, unless it is impossible or it may involve manifestly disproportionate efforts compared with the right that is to be protected.
- Object, on the whole or partially:
- On legitimate grounds, to the processing of your personal information, even though relevant to the purpose of its collection; and/or
- To the processing of your personal information for the purpose of sending advertising materials or direct selling or for the performance of market surveys or marketing communications.
This Privacy Notice is available in multiple languages. The English version will control for all purposes, including any controversies, disputes or claims that will be resolved by arbitration or other legal proceeding.
If you have any questions or privacy concerns after reviewing this Privacy Notice, please send an email to firstname.lastname@example.org or send a letter to:
Wyndham Hotel Group
22 Sylvan Way
Parsippany, New Jersey 07054, USA
Attn: Legal Privacy
- Effective Date: September 15, 2016
- Last Updated Date: April 24, 2017