LAST UPDATED: February 2021
You can select among various topics by clicking on the following options below:
Use and Processing of the Information We Collect
Sharing of Information
How We Protect Personal Information
How Long We Retain Information
Countries Used for Processing
Other Important Information
The following chart provides examples of the type of information that we collect from you and how we use that information.
|Context||Types of Information||Primary Purpose for Collection and Use of Information|
|Room Reservations||When you book a room reservation at our website or call WorldHotels, we collect your contact information, payment information, reservation information, and accommodation preferences. In a small number of cases we collect information about a guest’s health. For example, a guest may voluntarily choose to provide information about a disability as part of a request for an accommodation preference. Note that if you book a room reservation at a different website (e.g., an online travel agency or the website of one of our Independent Hotels), or if you call one of our Independent Hotels directly your information is not being collected by WorldHotels.||We use your information in order to fulfill your requests for a reservation and to take steps in anticipation of a stay at an Independent Hotel. In some jurisdictions we also need your information to comply with legal obligations to collect and maintain information about guests. We also have a legitimate interest in analyzing trends and patterns among guests. In the rare circumstances in which we collect information about a guest’s health, that information is collected only for the purpose of accommodating a guest’s needs and is used for no other purpose.|
|WorldHotels RewardsSM (“WHR”)||WorldHotels offers a loyalty program that entitles members to certain benefits or discounts. We collect your contact information, communication preferences, reservation history, redemption details, and partner loyalty program elections (if any). Information is collected when you register for WHR, redeem reward points, make a hotel reservation as part of WHR, update your WHR account, or link your WHR account to a partner loyalty program.||We use your information in order to perform our contractual obligations to you. For example, we would use the information to allow you to earn and redeem rewards, points or credits in connection with WHR. We also have a legitimate interest in marketing to you and analyzing trends and patterns among our rewards members. Per your express election and consent, we may also store payment-related information for future reservations.|
|Cookies and Third Party Tracking||We participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that it can provide advertising about products and services tailored to your interests on our website or on other websites;||We have a legitimate interest in engaging in behavior-based advertising.;|
|Email Interconnectivity||If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, or make reservations.||We have a legitimate interest in understanding how you interact with our communications to you.|
|Customer Care||If you contact us with an issue we will collect your name and e-mail address as well as any other content that you send to us in order to reply.||We have a legitimate interest in receiving and acting upon the information that you provide to us concerning issues that you raise.|
|Communications List||When you opt-in or sign up for one of our mailing lists we collect your email address.||We share information about our products and services or the products and services of other companies if you consent to receive that information. We also have a legitimate interest in sharing information with you about our services and those of our partners.|
|Mobile Devices||We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our websites or applications.||We have a legitimate interest in identifying unique visitors and in understanding how users interact with us on their mobile devices.|
|Surveys||When you participate in a survey we collect information that you provide through the survey.||We have a legitimate interest in understanding your opinions and collecting information relevant to our organization to improve our services.|
|Website Interactions||We use technology to monitor how you interact with our website. This may include the links you click on or information that you type into our online forms.||We have a legitimate interest in understanding how you interact with our website to better improve it and to understand your preferences and interests in order to select offerings that you might find most useful.|
|Web Logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.|
|WiFi Access||Although we do not provide the WiFi networks offered at Independent Hotels, we do provide access to WiFi at WorldHotels offices (e.g., our headquarters). We collect information about individuals that access those WiFi networks at headquarters.||We have a legitimate interest in providing WiFi networks and in collecting information for fraud and security purposes.|
|Employment Candidates||If you apply to work for us we collect information necessary to evaluate your application.||We use information about prospective employees in connection with our legal obligations and our legitimate interest in evaluating candidates.|
|Employees||If you are or were an employee of WorldHotels we collect information necessary to your employment.||We use information about current employees in connection with our employment obligations. In some contexts, we are also required by law to collect information about our employees and we have a legitimate interest in complying with those laws. We also have a legitimate interest in using employment information to have efficient staffing and work force operations.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including business partners, WHR Partners, Independent Hotels, Travel Agents, Online Travel Websites, or publicly available sources. For example, if you ask an Independent Hotel to transmit information to us, we will use that information as part of our legitimate interest to, among other things, respond to your query or provide customer service and support.
In addition to the purposes and uses described above, we use information in the following ways:
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you make a room reservation we collect your information so that we, or so that an Independent Hotel, can perform a contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your stay. As a result, our collection and processing of your information may be based upon our need to perform a contract, our obligations under law, our legitimate interest in conducting our business, and/or your consent.
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
You can make the following choices regarding your personal information:
If you do not want to submit a request through our online web portal request form, please address written requests and questions about your rights to email@example.com. An authorized agent submitting a request on behalf of an individual must submit a request through our Request Form.
Note that if you submit a request, we will, as required by law, require you to prove your identity. We will verify your identity by comparing the information you provide when submitting your request with the information in our database. Depending on your request, we may ask for additional information such as the email address you used to create your WHR account, the phone number you used to book your room reservation, and your past stay history. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. In order to confirm that you have indeed authorized an agent to make the request on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf, including a copy of the signed permission you have given to the authorized agent and verification of your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must submit a request through our Request Form and affirm that you are an authorized representative of a California resident as defined by Section 17014 of Title 18 of the California Code of Regulations. After receiving your request, we will contact you by e-mail with respect to the documentation and verification we require for submitting a request on behalf of someone else.
No method of transmission over the Internet or of electronic storage is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any breach to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
We retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. For example, we retain WHR information for as long as an individual remains a WHR member because WHR points do not expire and the information is needed in order to allow the individual to redeem their rewards. We retain information in our reservation system, in full or in summary form, for three years following a guest’s departure in order to process your reservation, provide post-reservation customer support, and provide invoicing and recordkeeping. We typically retain information in our customer care complaint system for three years after receipt, unless the information is needed for an ongoing purpose such as to address an open issue.
WorldHotels operates directly, or through service providers, in various countries including in the United States. Individuals that provide information to WorldHotels or visit WorldHotels website should be aware that the laws of the United States may differ from those of your country of residence. For example, there may be situations in which we are required to share your information with United States law enforcement personnel. The following provides additional information for data that WorldHotels transmits between jurisdictions:
The following additional information relates to our privacy practices:
We will attempt to respond to any questions, comments, or complaints concerning our privacy practices. Please feel free to contact us using the following information:
Main Airport Center
60549 Frankfurt am Main, Germany
Data Protection Officer
Attention: WorldHotels Privacy
First Privacy GmbH
28217 Bremen, Germany
Phone: +49 421 6966 32 822
Please note that e-mail communications will not necessarily be secure; accordingly you should not include payment information or sensitive information in e-mail correspondence to us.
If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.
LAST UPDATED: February 2021
EFFECTIVE: February 2021