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This policy was last updated January 1 , 2023. Previous version of this policy can be viewed here.
When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
I. Information We Collect and Purposes for Which We Use It
- Contact Information. For example, we may collect your name, mailing address, telephone number and email address when you make certain requests for information or when you make a reservation. We may also collect your mobile phone number.
- Payment Information. For example, we may collect your credit card number and billing address.
- Reservation History. For example, we collect personal information about the properties you viewed and made reservations with. We may also information about dining, recreation, and leisure activities you purchased or viewed while on our site.
- Employment Information. If you apply for a job with us, we collect the personal information you include in your application. For example, this may include the name and address of your employer and your employment history.
- Information You Submit. We collect personal information when you make a booking, log in, contact us, or use similar features on our website. This may include travel related details such as arrival or departure transportation and times. Individual hotels may collect additional information, including asking to see government identification to verify identity. .
- Voice Recordings. We may collect voice recordings if you call our reservations line or contact us for customer service.
- Device Information. We may collect the type of device you use to access our website. For example, we may also collect your device identifier, mobile carrier, operating system, screen dimensions, IP address or mobile operating system.
- Location Information. We may collect general location information from your device based on your IP address.
- Log and Analytics Data. We collect information about any online identifiers used for you or your household or any information about the type of device you are using and the browser you use to access the Site. We may look at what site you came from, what you click on when you are visiting our site, or what site you visit when you leave us. This may include information obtained through tracking technologies.
We may use or process your personal information in the following ways:
- To Provide Features and Functionality. This could include fulfilling your requests or customer services operations for reservations or services. It could also include processing purchases or other transactions.
- To Improve Our Products and Services. We may use your personal information to make our Site, products and services better. We may also use your personal information to customize your experience with us.
- To Understand Your Interests. For example, we may use your personal information to create inferences to better understand what products may interest you.
- To Respond to Your Requests or Questions. This may include responding to your product questions, feedback or notifying you if you win a promotion.
- To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Site’s terms and conditions.
- To Determine Your Eligibility. We may use your personal information to verify your identity or determine your eligibility for some of our products, services and promotions. For example, this may include verifying your age, date of birth and state of residence. If you apply for a job through our Platform, we may use the personal information you provide to evaluate your application.
- For Marketing Purposes. We may provide you with information about new products and special offers. We might use your personal information to serve you ads about products 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 have consented to this. We may also use your personal information to send you electronic communications, including through email or text message.
- For Interest-Based Advertising. We and our third party partners may engage in interest-based advertising using personal information gathered across multiple websites, devices, or other platforms to serve you relevant advertising on our Site or on other sites, services and mobile applications or on other devices you may use. For more information about your choices related to these communications, see the “Other Choices about your Personal Information” section below.
- For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Site.
- As Otherwise Permitted By Law or As We May Notify You.
II. How We Collect Information
We collect your personal information in the following ways:
-Directly From You (Either Offline or On the Site). For example, when you:
- Make reservations through our Site
- Sign up to receive promotional communications
- Submit a request to or contact our customer service team
- Apply for a job through our Site
-Automatically. For example, when you;
- Visit and navigate our Site on any device
- Enable location-based features on our Site.
- Click on sponsored links or third-party advertisements.
We may also collect personal information about you over time and across different websites, apps and devices when you use our Site, using tracking technologies such as cookies, pixels, Flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform.
-From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:
- Our business partners, including affiliated hotels and partner websites. For more information about our partners, you can click here,
- Social media sites, including Facebook. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.
- Third party sites, including those of affiliated hotels, online advertising networks, and analytics vendors.
- Companies that provide personal information to supplement what we already know about you, including data aggregators and trade publications. Certain third parties might link your name or email address to other information they have collected. That might include past purchases or reservations made offline or online. It might also include online usage information.
-By Combining Personal Information. For example, we may:
- Combine personal information that we collect offline with personal information we collect through our Site, allowing us to draw inferences about you.
- Combine personal information we collect about you from the different devices you use to access our Site.
- Combine personal information we get from third parties with personal information we already have about you.
III. Our Legal Basis for Processing Your Information
If you are accessing the Site in the European Economic Area (“EEA”), then applicable law requires us to ensure that we only process your personal information when we have a valid legal basis to do so. We will only process your personal information:
-If it is in our legitimate interests or the legitimate interests of others (such as our affiliates) to use your personal information. For example, it is in our legitimate interests to use your personal information to maintain and improve the Site.
- 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 at the end of this policy.
-If we need to use your personal information to perform our obligations under a contract we have with you (including, for example, processing your reservations or fulfilling your travel-related orders).
-If we have your consent. 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 at the end of this policy.
IV. How We Share Your Information
We may share or disclose your personal information for business purposes with the following categories of third parties:
- Partner Hotels: When you make a reservation, we may share your personal information, including your contact information with partner hotels.
- A Business That Acquires Us or Our Assets, in a Business Transfer: 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 Site, will be transferred to that 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 that can be sold or transferred to third parties.
- Marketing Partners. With your consent, we share personal information with related businesses that may offer products and services of interest to you.
- Service Providers: We use third parties to perform services on our behalf, such as payment processing, email marketing, website analytics, marketing and promotions, advertising technology services, cloud data storage, technology support, 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. When we share personal information with Service Providers our contracts prohibit them from using or sharing your personal data for any reason except to assist us in operating our business and providing services to you.
The Site is directed to general adult audiences, and is intended to be used only by persons who are at least 18 years of age. We do not and will not knowingly collect or process personal information from anyone we know to be under 18 years of age. If you are under the age of 18, you may not use the Site unless your parent or guardian has provided us with a legally sufficient form of consent.
VI. 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 or the United Kingdom (UK) 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 European data protection authority), or using the International Data Transfer Agreement (approved by the UK’s Information Commissioner’s Office) with our service provider, business partner, or Affiliate regarding the transfer 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 information provided at the end of this policy.
VII. Your Rights Under the General Data Protection Regulation (GDPR)
If you are in the EEA, the UK, or Switzerland and certain other countries with similar data protection laws, you have additional rights in relation to your personal information. 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.
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 in Europe is available here.
VIII. State-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you:
Collection, disclosure and sale of personal information
In the last 12 months, we have collected, disclosed for a business purpose and sold the following categories of personal information:
|Category of Personal Information||Collected||Disclosed for Business Purposes||Sold|
|Identifiers, such as name, email address and other information||X||X|
|California Customer Records (Cal. Civ. Code 1798.80(e), such as Payment Information||X||X|
|Commercial Information, such as Reservation History and other information relating to your hobbies, interests, and shopping behavior||X||X|
|Internet/Network Information, such as IP address, Device Information, and Log and Analytics Data||X||X|
|Geolocation Data, such as location information from your device or estimated based on your IP address||X||X|
|Sensory Information, such as recording of phone calls between you and us, where permitted by law||X||X|
|Other Personal Information, such as information you submit to us||X|
|Inferences, such as predictions about your interests and preferences.||X|
Your California Privacy Rights
If you are a California resident, you have specific privacy rights under the California Consumer Privacy Act (CCPA).
Right to Know. You have the right to ask us to disclose the personal information we have collected, shared, or sold about you in the past 12 months. If we are able to verify your identity, we will provide the categories of Personal Information we have collected about you, the categories of sources from which we collect it, our business or commercial purpose for collecting the personal information, and the specific pieces of personal information we collected.
If we have disclosed your personal information to any third party for any reason, we will also tell you the categories of personal information we disclosed, the categories of third parties with whom we shared it, and the purpose for which we shared it.
Right to Opt Out of Sale of Your Personal Information. California law defines “sell” very broadly. Sharing information such as your IP address or online identifier, or allowing another party to have access to your travel preferences may be considered a “sale” of personal information. You have the right to tell us “Do Not Sell or Share My Personal Information” to third parties.
Note that if you clear cookies on your browser, or use a different browser of device, you may have to opt-out again to make your “Do Not Sell” choice effective.
Right to Deletion. You have the right to request that we delete any personal information we have collected about you. We will only do this if we can confirm your identity, and in some cases, we are required or permitted by law to retain all or some of your information for specific purposes.
Authorized Agent. You have the right to appoint an authorized agent to exercise these rights for you.
You have the right not to be discriminated against, for example by receiving a different quality of services, if you exercise any of these rights.
To exercise your rights under the CCPA email us, or call +1 202 772 8000. In order to respond to your request, we may validate your email address if you have an account with us. If you use an authorized agent to exercise rights for you, we will confirm that the agent is authorized by you.
When you make a request to access or delete your information or opt out of sale, we will generally confirm receipt of your request within 10 days, and respond within 45 days, though in some cases we have the right to take additional time if needed.
“Shine the Light” Law. If you are a California resident, 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.
IX. Online Advertising and Third Party Tracking.
Cookies and Other Tracking Technologies:
- We use this information collected through tracking technologies to provide custom, personalized content and information, including targeted content and advertising, recognize you across multiple devices, monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and otherwise enhance our Site and your user experience.
- Your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
- If you block cookies, certain features on our Site may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.
Google Analytics and Advertising:
We use Google Analytics to better understand how our users interact with our Platform. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Site. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by visiting the online resources provided by the Network Advertising Initiative at http://www.networkadvertising.org/choices.
Our Do Not Track Policy:
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. We continue to review new technologies and standards as they develop.
X. Data Retention
XI. Third Party Websites, Content, and Resources
XII. How We Protect Your Information
We take reasonable steps, including technical and organizational measures, to protect the security and integrity of all personal information we receive and process, including using encrypted transmission for sensitive information such as credit card information. However, please note we cannot guarantee that any information transmitted through the Internet or stored on our system or otherwise in our care, will be completely safe from prohibited intrusion by others, or from access alteration or loss, as no data transmission or storage is perfectly secure. We want you to feel confident that we use reasonable security, but we cannot warrant the security of any information you provide or transmit to us.
XIV. How to Contact Us
If you have any questions or comments regarding our privacy practices, you may contact us using the following information:
Historic Hotels Worldwide
1420 New York Ave NW, Suite 200
Washington, DC 20005