1. Collection and use of Personal Information
Personal information is information that can be used to directly or indirectly identify you. Personal information also includes anonymous information that is linked to information that can be used to directly or indirectly identify you. Personal information does not include information that has been irreversibly anonymized or aggregated so that it can no longer enable us, whether in combination with other information or otherwise, to identify you.
What Personal Information We Collect
We may collect different kinds of personal information from or about you:
Information you Provide: We collect the personal information you provide—such as your name and contact information; date of birth; preferred communication methods; business name, title and business address; date of arrival and departure; room and vacation preferences; travel history; and details on hotel, airline and rental car packages you book. We may also record details on joint travelers, including their names and the age of the driver of the rental car and any other information you may choose to provide us.
We may also collect other personal information when you interact with our websites in various ways. For example, if you Contact Us on our websites, or choose to create an online profile for meeting and event planning (e.g., weddings), we record meeting and event specifications, the date of the event, number of guests, details of the guest rooms, and, for corporate events, information on your organization (name, annual budget, number of sponsored events per year). We may also collect personal information if you apply for employment, interact with us at in-person events, or otherwise interact with us.
Information about Payments: We collect personal information in connection with your transactions with us. This information includes payment information, such as your credit card details, including the three-digit code that appears on the back of your credit card, or debit card number and other card information; other account and authentication information; and billing and contact details.
Information about Use of our Products and Services: When you visit our websites we may collect information about the type of device you use, your device’s unique identifier, the IP address of your device, your operating system, the type of Internet browser that you use, usage information, diagnostic information, browsing information, and (with your consent) location information from or about the computers, phones, or other devices from which you access our products or services. We may gather some of this information automatically.
Information from third parties: We may collect information from third parties, including business partners and marketing agencies, or publicly accessible sources. This may include your contact information from marketing partners when we engage in joint marketing or co-branding activities, as well as your IP address or location information from service providers to offer certain products and services relevant to your location.
How We Use Your Personal Information
We may use personal information to provide, improve, and develop our products and services, to communicate with you, to offer you targeted advertisements and services, and to protect us and our customers. We collect, process, and determine how to process your personal information as data controller for the following purposes:
Communicating with you: We may communicate with you about your transactions and employment requests, or to inform you about our policies and terms. Such processing is based on our legitimate interest in offering you products and services and for business continuity. Subject to your prior express consent, we may use personal information to send you marketing communications in relation to our own products and services. Also subject to your prior express consent, we may share your personal information with third-party partners who may send you marketing communications in relation to their products and services. If you no longer wish to receive email communications for marketing purposes, please Contact Us to opt out. We may use your information to process and respond to your requests when you contact us.
Providing, improving, and developing our products and services: We use personal information to help us provide, improve, and develop our products, services, and advertising. This includes using personal information for purposes such as data analysis, research, and audits. Such processing is based on our legitimate interest in offering you products and services and for business continuity.
Offering and measuring targeted advertisements and services: Subject to your prior express consent, we may use personal information to personalize your experience with our products and services, on third-party websites and applications, and to determine the effectiveness of our promotional campaigns.
For any of the uses of your data described above that require your prior express consent, note that you may withdraw your consent at any time by Contacting Us.
Promoting safety and security: We use personal information to help verify accounts and user activity, as well as to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies. Such processing is based on our legitimate interest in helping ensure the safety of our products and services.
2. With Whom We Share Personal Information
We make certain personal information available to partners that work with us to provide our products and services or help us market to customers. Personal information will only be shared by us with these companies in order to provide or improve our products, services, and advertising; it will not be shared with third parties for their own marketing purposes without your prior express consent. We may also share personal information with corporate affiliates and in case of corporate business transfers, and for purposes of legal compliance and security.
Electronic Credit Transactions: If you reserve rooms or make some other purchase on our sites, billing information will be shared with the credit card provider and, if you use a corporate credit card, possibly, your employer.
Group Events or Meetings: If you visit ETC as part of a group event or meeting, information collected from that meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
Service Providers: We may share personal information with service providers that provide certain products and services on our behalf, such as payment processing; reservations services; and those providing services in connection with our sites, including website hosting; email services; communicating news and delivering promotional and transactional materials via email and direct mail; processing credit card transactions; data hygiene and enhancement services; auditing; fulfilling customer orders; data analytics; providing customer support; conducting customer research and satisfaction surveys; and other services that assist in selling our products and services . These companies are obligated to protect your information and may be located wherever we operate.
Business Transactions: As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In the event of a merger, consolidation, sale, liquidation or transfer of assets, ETC may provide personal information to one or more affiliated or unaffiliated third parties.
Legal Requirements and Emergencies: ETC may disclose personal information, with or without prior notice to you, within or outside your country of residence, in order to: (i) comply with applicable laws; (ii) respond to governmental inquiries or requests from public authorities; (iii) comply with valid legal process; (iv) protect the rights, privacy, safety or property of ETC, site visitors, guests, employees or the public; and (v) respond to an emergency.
We do not knowingly disclose personal information to third parties for their direct marketing purposes.
3. Your Access and Control Over Information
Depending on where you live, you may have the rights described below. To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct, or suppress personal information about you that we maintain. You are also entitled to object, at any time, to the further processing of your personal information or restrict the purposes for which it is processed. You have the right to receive your personal information in a structured and standard format and you have the right to have the data transferred to a third party. You may lodge a complaint with the competent data protection authority regarding the processing of your personal information.
To protect the privacy and the security of your personal information, we may request information from you to enable us to confirm your identity and right to access such information, as well as to search for and provide you with the personal information we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.
We will make all required updates and changes within the time specified by the applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request.
In addition, in some circumstances, based on applicable law, you may request that we cease sharing personal information about you with our business partners or that ETC cease the use of personal information about you on the grounds that such personal information was acquired by unjust means or used in violation of law. We will seek to honor those requests consistently with applicable law.
Please remember that if you make requests of these types, we may not be able to provide you with the some quality and variety of services to which you are accustomed.
Such requests must be submitted in writing to ETC HOTELS, One Pico Blvd., Santa Monica, CA 90405.
4. California Privacy Rights
If you are a California resident, California law permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. You may Contact Us to exercise your rights.
If you are a California resident under the age of 18, and you are a registered user of our products or services, California law permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please Contact Us with specific information about where the content or information is posted and attesting that you posted it. We will then make reasonable, good faith efforts to remove the post from prospective public view, or anonymize it so you cannot be individually identified, to the extent required by applicable law. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
5. Cookie Technology
We use “cookie technology” on our websites to provide, evaluate, and improve the functionality of our websites, such as by personalizing content, offering and measuring advertisements, understanding user behavior, and providing a safer experience.
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our websites. Further information about cookies and how they work is available at alloboutcookies.org.
We do not knowingly collect, use, or disclose information from children under 16. If we learn that we have collected the personal information of a child under 16—or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States—we will take steps to delete the information as soon as possible. Please immediately Contact Us if you become aware that a child under 16 has provided us with personal information.
7. Third-Party Websites and Services
8. Information Security, Integrity, and Retention
We take reasonable technical, administrative, and physical security precautions to protect and prevent unauthorized access to your information.
It is important that you take precautions to protect against unauthorized access to your information and computers or other devices. If you feel that the security of your personal information has been compromised in connection with our products or services, please immediately Contact Us. Please be aware that, despite our efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.
9. Information Transfers, Storage, and Processing Globally
If applicable, when we share your personal information with our partners, affiliates, and service providers, your personal information may be transferred to and/or made accessible from countries out of the European Economic Area (“EEA”). In such circumstances, we will enter into model contractual clauses as adopted by the European Commission, or rely on alternative legal bases such as the Privacy Shield, where applicable, or binding corporate rules where our partners or service providers have adopted such internal policies approved by European data protection authorities. If you reside in the EEA and would like to obtain a copy of the safeguards used to transfer your data out of the EEA, you may Contact Us with your request.
11. Contact Us
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Definition of “Cookies”
Cookies are small pieces of text used to store information on web browsers. Cookies are widely used to store and receive identifiers and other information on computers, phones, and other devices. We also use other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, including web beacons and pixel tags, for similar purposes. In this Cookie Statement, we refer to all of these technologies as “cookies.”
Types of Cookies
• Essential cookies: These cookies are strictly necessary to provide you with our websites and services and to enable essential features, such as providing shopping cart or product application functionality. If you disable these cookies, we will not be able to fulfill your requests.
• Performance and functionality cookies: These cookies collect information about how you use our websites and services and allow us to remember the choices you make while browsing. The information these cookies collect allows us to optimize our websites and make them easier for you to use, and it does not personally identify you. If you disable or opt out of these cookies, you may not be able to use certain features of our websites, applications, and services, and it may reduce the support or information that we can provide you.
• Analytics and customization cookies: These cookies collect information we use in aggregate form to help us understand how our websites, applications and services are being used and how effective our marketing campaigns are, and to help us customize our websites. If you disable or opt out of these cookies, you may not be able to use certain features of our websites, applications and services, and it may reduce the support or information that we can provide you.
• Advertising cookies: These cookies collect information about your browsing or shopping history and are used to make advertising messages more relevant to you. They perform functions like preventing the same advertisement from continuously reappearing, ensuring that advertisements are properly displayed, and in some cases selecting advertisements that are based on your interests. We may share this information with third parties to help create and deliver advertising personalized to you and your interests. If you disable or opt out of these cookies, you may not be able to use certain features of our websites, applications and services, and it may reduce the support or information that we can provide you.
• Social networking cookies: These cookies are used to enable you to share pages and content on our websites and services through third-party social networking and other websites. These cookies may also be used for advertising purposes.
Cookies Placed by Third Parties
Controlling and Opting Out of Cookies
Your browser or device may offer settings that allow you to choose whether browser cookies are set and to delete them. For more information about these controls and to exercise your cookie preferences, visit your browser or device’s help material. If you choose to reject cookies, as noted above, you may not be able to use certain features of our websites and services.
Do Not Track
Some browsers include the ability to transmit “Do Not Track” signals. We do not process or respond to “Do Not Track” signals. Instead, we adhere to the standards described in our Privacy Statement and this Cookie Statement