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:
- For internal administrative purposes as well as to manage our relationships.
- To conduct analytics.
- To identify you when you visit our websites.
- To provide service to you and to improve our services and product offerings.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
- To streamline the reservation or checkout process.
- For the safety and security of guests, staff, and other visitors.
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:
- Independent Hotels. We share your information with the Independent Hotels that will be fulfilling a reservation. Depending upon the context, Independent Hotels use your information for a variety of purposes including preparing for your stay, providing you with accommodations, or marketing.
- WHR Partners. We may share information with independent companies that we partner with as part of WHR in order to allow you to earn and redeem rewards, points, or credits in connection with your loyalty program membership and in accordance with your chosen earning and spending preferences. For example, we may provide you with the choice to select a particular airline partner through which you can earn loyalty points. We also share information with independent companies if you have selected that you would like to receive promotions and marketing material from our third party-business partners.
- Travel Agents and Online Travel Websites. We share your information with travel agents, that you use in order to process your reservation request and to comply with any requirements or needs of those entities.
- Service Providers. We share your information with service providers. Among other things, service providers help us to administer our databases, websites, marketing, communications, and surveys; service providers provide us with technical and logistical support; service providers process payments on our behalf; and service providers assist in the fulfillment of reservations and orders.
- Public. Some of our websites may provide the opportunity to post comments or reviews in a public forum. If you decide to submit information on these pages, that information may be publically available.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws or for national security requirements within the jurisdictions in which we operate. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary. We also may share information with our corporate affiliates (e.g., subsidiaries, joint ventures, or other companies under common ownership or control). In addition, if another company acquires or plans to acquire our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
You can make the following choices regarding your personal information:
- Promotional Emails. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
- Access to Your Personal Information. You can request access to your personal information by completing and submitting a Request Form. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
- Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our website does not permit you to update or correct certain information you can request that your information be changed by completing and submitting a Request Form. Although we will attempt in good faith to respond to your request, we may not be able to change your information in all circumstances. For example we may not be able to change your information if doing so would impose an undue burden or expense, or if it would require us to change information relating to another person.
- Deletion of Your Personal Information. You can request information about how long we keep a specific type of information by contacting us at the address described below. You can request that your information be deleted by completing and submitting a Request Form. If required by law we will delete your personal information after such a request is made. You should note that there are some situations in which we may decline to delete your information. For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
- Revoking Consent or Objecting to Processing. You can revoke consent to processing (where such processing is based upon consent) or object to our processing by completing and submitting a Request Form. If you revoke consent or object to further processing we may no longer be able to provide you services. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
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 firstname.lastname@example.org. 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:
- Transmission of Information from the European Union to the United States. WorldHotels uses, or may use, certain service providers that are based within the United States including, among others, Best Western International. If WorldHotels transmits your information to a processor outside of the EEA, WorldHotels will take steps to ensure that the processor complies with the substantive principles of the GDPR. If you would like more information concerning the protections applied for a particular onward transfer, you can contact us using the information below. If you feel that WorldHotels has mishandled your personal information, please contact WorldHotels using the contact information below with a written description of your complaint. After receiving such written description, a representative from WorldHotels will contact you to set up a time and manner to discuss your complaint. WorldHotels is dedicated to addressing all legitimate complaints about its treatment of your personal information and will make a good faith effort to engage in communications to address such complaints.
- Transmission of Information from the European Union to Other Countries. In addition to having your information transferred to the United States, if you are making a reservation at an Independent Hotel in a foreign country your information will be sent to that hotel in that country. In addition, we may use service providers that are located outside of the United States. When we do so we generally utilize the Standard Contractual Clauses for the transfer of information from a Controller to a Processor.
The following additional information relates to our privacy practices:
- Third Party Applications, Websites, and Social Media. We have no control over the privacy practices of websites or applications that we do not own. Our websites or our communications may also contain plug-ins and other features that integrate third party social media platforms. If you interact with these, the third parties who operate these platforms may be able to identify you, determine how you use our website, and link and store this information with your social media profile.
- Accessibility. If you are visually impaired, you may access this notice through your browser’s audio readers.
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