Introduction

Hospitality Marketing Concepts, LLC. (“HMC” “we” “us” or “our”), based in the United States of America, values your privacy.

This Privacy Policy outlines how your personally identifiable information and other information about you (your “Personal Data”) will be collected, used, and shared in connection with your access to and/or use of this website and/or mobile application, available for iOS and Android mobile platforms, and any content, features, services, or other offerings that HMC may provide in connection therewith, including in relation to any email communications or newsletters that HMC may send in connection with your use of our website or mobile apps (collectively, the “Interactive Services”).

NOTICE FOR EU RESIDENTS: This Privacy Policy is intended to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of the European Union 27 April 2016 (the “General Data Protection Regulation” or “GDPR”) and provide appropriate protection and care with respect to the treatment of your user information in accordance with the GDPR.

Topics

What Data Do We Collect?

At a variety of times, we may collect information about you and/or the persons accompanying you, including the following:

  • Contact details (for example, last name, first name, telephone number, email)
  • Personal Data (for example, date of birth, nationality)
  • Information contained on a form of identification (such as National ID card, passport or driver license)
  • Your credit card number (for membership purchase transaction and hotel reservation purposes)
  • Your arrival and departure dates (for hotel bookings)
  • Your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests, food and beverages preferences, etc.)
  • Your questions/comments, during or following a stay in one of our partner hotels
  • Information relating to your children (for example, first name, date of birth, age)
  • Your membership number for the associated loyalty programs or other partner program (for example, an airline or partner hotel loyalty program) and information related to your activities within the context of the loyalty program
  • Technical and location data you generate as a result of using our websites and mobile applications
  • The technical and location data we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your apps, browsers, and devices with our services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request

How Do We Collect Your Data?

  • The information we learn from customers helps us personalize and continually improve your experience. Here’s how we gather your data.
    • Enrolling in a loyalty program:
    • When you create an account, enroll in a loyalty program, or purchase a membership
  • Hotel related activities:
    • Booking a room (if HMC facilitates the booking)
    • Eating/drinking at the hotel bar or restaurant during a stay or while visiting a hotel (transmitted automatically from the hotel to HMC)
    • Requests, complaints and/or disputes regarding hotel visits sent to us via email or interactive chat
    • Reviews of our partner hotels or our services
  • Participation in marketing programs:
    • Signing up for loyalty programs
    • Participation in surveys
    • Subscription to newsletters, in order to promotions via email
  • Transmission of information from third parties:
    • Hotel reservation systems, hotel property management systems, hotel point of sale system, and other similar partner systems
  • Internet activities:
    • Connection to HMC websites (IP address, cookies in accordance with our Policy about the use of cookies)
    • Online forms (including HMC-operate pages on social networks)
  • Mobile Apps:
    • When you download or use apps created by HMC, we receive and store information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as hotel promotions, search results, and other personalized content.
    • Online forms (including HMC-operate pages on social networks)
  • Other sources:
    • We may receive information about you from other sources (for instance, your hotel loyalty program membership number and profile)
  • How Will We Use Your Data?

    HMC collects your data so that we can:

    • Input, process and transact payments for loyalty program membership sales, renewals, and cancelations
    • Provide your Personal Data and payment data to third-party payment processors (such as WorldPay, Stripe, Alipay, WeChat, local banks and financial institutions) for the purpose of transacting loyalty membership payments
    • Provide your personal data and payment information to hotel partners to process, confirm, provide and charge for hotel arrangements and restaurant reservations and our goods and services
    • Fulfill contractual obligations to you, anyone involved in the process of planning related to your loyalty program membership (e.g. hotel partners) and vendors (e.g. credit card companies, gift card providers, airline operators and other loyalty programs)
    • Provide benefits and services to you, process applications for and administer membership programs, verify and validate your ability to access and use certain products, services and information
    • Managing claims, feedback, and complaints
    • Provide you with access to the content on our Interactive Services, and respond to your enquiries and requests for information and services
    • Administer, and disclose the winner of, contests and lucky draw competitions conducted by us or on our behalf
    • Implementing security and fraud prevention
    • To provide you with a better, more personalized level of service, and further develop our products and services, including linking or combining with information we get from others to do so
    • Conduct market analysis, market research, customer satisfaction and quality assurance surveys to improve our services
    • Monitor your use of our Interactive Services and your bookings, and conduct analysis of the use of our Interactive Services in order to operate, evaluate and improve our Interactive Services and business practices, understand your preferences, display customized content to you on our Interactive Services
    • Conforming to any applicable legislation (for example, storing of accounting documents), including managing requests to unsubscribe from newsletters, promotions, offers and satisfaction surveys, and managing your requests regarding your Personal Data
    • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company
    • With our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations
    • If you have consented, facilitate direct marketing, promotional and customer management purposes, including sending you promotional communications
    • For any other purposes for which we have your consent

    NOTICE FOR CALIFORNIA RESIDENTS: Although HMC does not share personal information with unrelated third parties for their own direct marketing purposes, partner hotels, which are separately owned and operated, are permitted to use the personal information they receive from HMC to market their hotels. If you are a customer who resides in the State of California, you may request from HMC information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. This request may be made no more than once per calendar year.

    How Do We Store Your Data?

    When you join a loyalty program operated by HMC, your Personal Data will be transferred to the United States, where our primary IT applications and databases are located, and possibly to other countries where our many of our international offices are located and where we or our service provider Microsoft Azure operates. HMC employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law and industry standards.

    HMC uses appropriate security measures to protect the security of our Members’ Personal Data both online and offline including data in backups or any replicated copies.

    These security measures include:

    • We use encryption to keep your data private while in transit
    • Personal Data is encrypted at rest everywhere, at all times
    • Personal Data is guarded and protected with firewalls, and can only be accessed thru VPNs
    • Anti-virus software is running on all servers and PCs which are in contact with Personal Data
    • We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems, including a quarterly Vulnerability Scan to our network and security code review for all our applications
    • We restrict access to Personal Data to HMC employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations

    In case of a data breach or un-authorized access to HMC’s data, HMC will notify the members affected and the relevant authorities within 72 hours.
    Subject to local laws and regulations, HMC will store your data if needed to provide our services and to operate our business, up to 7 years from the expiry date of your loyalty program membership(s) and/or contractual relationship with HMC. If HMC is asked to delete specific Personal Data from our Members Database prior to 7 years, we will honor this request, unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, conducting required audits, or causing non-compliance with local laws.

    Marketing

    HMC would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies (such as the hotels that we operate loyalty programs in conjunction with).

    If you have agreed to receive marketing from HMC, you may always opt out later. You have the right at any time to stop HMC from contacting you for marketing purposes or providing your data to our subsidiaries and third parties.

    If you no longer wish to be contacted for marketing purposes, please email us at privacy@clubhotel.com or via the Contact Us screen on this website or mobile application.

    What are Your Data Protection Rights?

    HMC wants to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

    1. The right to access – You have the right to request HMC for copies of your personal data. We may charge you a small fee for this service.
    2. The right to rectification – You have the right to request that HMC correct any information you believe is inaccurate. You also have the right to request HMC to complete information you believe is incomplete.
    3. The right to erasure – You have the right to request that HMC erase your personal data, under certain conditions.
    4. The right to restrict processing – You have the right to request that HMC restrict the processing of your personal data, under certain conditions.
    5. The right to object to processing – You have the right to object to HMC’s processing of your personal data, under certain conditions.
    6. The right to data portability – You have the right to request that HMC transfer the data that we have collected to another organization, or directly to you, under certain conditions.

    If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please email us at privacy@clubhotel.com or via the Contact Us screen on this website or mobile application.

    What are Cookies?

    Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

    For further information, visit allaboutcookies.org.

    How Do We Use Cookies?

    HMC uses cookies in a range of ways to improve your experience on our websites and mobile apps. A cookie file can contain and/or automatically collect user information, such as a user identification code or IP address, that a website will use to track the pages and number of times you have visited. The data read from these cookies may be linked to your user information, so our use of these cookies may allow us to better understand how you use our Interactive Services, or to serve you with personalized advertising.

    In particular, we and our partners use cookies and similar technologies on the Interactive Services to personalize and optimize your browsing experience and the Interactive Services by:

    • Providing you with personalized, relevant content (for example, access to your data and specific membership benefits)
    • Allow you to access your personal pages more quickly by storing the login details or information that you previously entered
    • Storing specific information that you enter on HMC Interactive Services in order to facilitate and customize your subsequent visits (including displaying the visitor’s first and last names if the visitor has a user account)
    • Tracking web and advertising analytics throughout the Interactive Services and its affiliate websites, specifically, the Interactive Services uses Google Analytics
    • Retargeting advertisements to you via third-party advertising networks, (e.g. Facebook Advertising Network)
    • Educating ourselves about how we can continue to improve the Interactive Services and its various elements
    • Safeguarding against spam and malware
    • Analyzing trends, traffic, and user behavior
    • Enabling social media features
    • our user base as a whole
    • Administering the Interactive Services
    • Gathering demographic information about
    • Remembering your preferences and voluntarily submitted information
    • Performing location-related functionalities and analytics
    • Participating in market research (e.g., Interactive Services ratings)

    What Types of Cookies Do We Use?

    There are several different types of cookies, however, our website uses:

    • Functionality – HMC uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
    • Advertising – HMC uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. HMC sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
    • Visitor Tracking – HMC uses cookies aimed at improving the experience of users by helping us understand your interactions with HMC Interactive Services (most visited pages, applications used, etc.); these cookies may collect statistics or test different ways of displaying information in order to improve the relevance and usability of our services.
    • Affiliate cookies identify the third-party website that redirected a visitor to HMC Interactive Services.
    • We may use web beacons (invisible images often referred to as pixel tags or clear GIFs) on our Interactive Services in order to recognize users, assess traffic patterns, identify preferred content and to measure site engagement. We may also include web beacons in our email communications, including newsletters, in order to measure engagement with our communications (e.g., to count how many, and when, email communications have been opened, or which links in such communications have been clicked on).
    • HMC and its partners (including advertising partners) may also use web beacons to collect various data provided by your browser while you are on our Interactive Services and elsewhere (i.e., outside of the Interactive Services) where we may be acting as a 3rd party. This data is collected in the aggregate but may include or be associated with other user information that users have voluntarily submitted.

    How to Manage Your Cookies?

    Although most browsers are set by default to accept cookies, you can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. For further information, visit allaboutcookies.org.

    Please be aware that if you do choose to disable the receipt of cookies from our Interactive Services, you may not be able to use or benefit from certain features of the Interactive Services, particularly the features that are designed to personalize your experience.

    Privacy Policies of Other Websites

    HMC Interactive Services contains links to other websites. Our privacy policy applies only to our Interactive Services, so if you click on a link to another website or use another mobile app, you should read the relevant company’s privacy policy.

    Changes to Our Privacy Policy

    HMC keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 30 August 2019. We may modify this charter from time to time. Therefore, we recommend that you consult it regularly.

    How to Contact Us?

    If you have any questions regarding this Privacy Policy or how to remove or modify your user information or related consents, please feel free to contact us at privacy@clubhotel.com or via the Contact Us screen on this website or mobile application.
    You can also send us a posted letter addressed to:

    Hospitality Marketing Concepts, LLC
    Attention: Privacy Team – Customer Service
    1201 Dove Street, Suite 370
    Newport Beach, CA 92660

    Translations of This Privacy Policy

    For your convenience, HMC may make translated versions of this Privacy Policy available on the Interactive Services. In the event that the terms of any such translated version conflict with the terms of the English version, the terms of the English version of this Privacy Policy will apply.