California Consumer Privacy Act Statement
Last Updated: January, 2020
Under the California Consumer Privacy Act (CCPA), Minor Hotel Group (MHG) is required to inform California residents about our collection, use, and disclosure of their personal information for the past 12 months:
PERSONAL INFORMATION WE COLLECT
We collect the following categories of Personal Information:
- Identifiers, such as name, nationality, passport, visa or other government-issued identification data, and online identifiers;
- Contact information, such as address, telephone number, e-mail, address.
- Characteristics, such as gender, age, primary language, national origin, citizenship, preferences, family circumstances and marital status;
- Commercial information, such as transaction information, purchase history, financial details, payment methods, and membership or loyalty program data;
- Health information, such as dietary requirements, and allergies (only collected with your consent)
- Technical information, such as IP address, geographic data, browser and computer system, application version, language settings and pages that have been shown to you, etc.; and
- Assumptions drawn from any of the Personal Information to create a profile or summary about, for example, an individual’s preferences and characteristics.
In this section of our Privacy Notice, and in accordance with the CCPA, “personal information” includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
SOURCES OF PERSONAL INFORMATION
Most of the time we collect the information directly from you, or other persons/entities making a reservation on your behalf (e.g., travel agent, a member of your travel party, someone making the booking on your behalf). In limited circumstances, we may receive this information from our trusted partners, such as airlines and travel agencies. With regard to internet or other electronic information, we collect that information automatically as you use this site and services.
USE OF PERSONAL INFORMATION
The primary purpose of our collection and use of this information is to fulfil your reservations and enhance and personalize your experience with us. In particular, we will use this information for the following purposes:
- Performing our customer service obligations: management of reservations and your stay in our properties, payment, catering to your requests, monitoring use of services (telephone, bar, pay TV etc.) in response to a contractual relationship between you and us, such as a hotel booking or service request.
- Improvement of our services: assessment of our services in hotels, restaurants, and other outlets, improvement in the operation of our business as part of the contracted relationship between you and us. Personalization of our services and communications: personalize content and tailor our digital customer experience and offerings, understand customers’ requirements to develop targeted marketing programs, newsletters, and promotions. We will always seek and record your permission to opt in and participate in any of our marketing campaigns. Use of your information for marketing is presented in more detail under the Marketing section below.
- Personalization of our website based on your preferences is covered in the Cookies section at the end of this Notice.
- Compliance with legal obligations: compliance with applicable laws, such as local privacy laws, prevention of fraud or money laundering, police investigations, and tourism regulations
DISCLOSURE OF PERSONAL INFORMATION
We disclose this information for business purposes, including at your direction, to MHG-branded properties (e.g., if you make a reservation through our website, then we share that information with the applicable property so that they can fulfil your request). Where needed we may share some of your information with our Service Providers, Business Affiliates and Strategic Business Partners) for our operational business purposes.
SALE OF PERSONAL INFORMATION
We use third party targeted advertising companies that aggregate data collected through cookies placed on this website and other websites/mobile apps. Under the CCPA, this type of sharing of information could be deemed a “sale”. We also disclose your information to our marketing partners through a central marketing/analytics company.
California consumers may opt-out at any time through our communications portal and by clicking on the Do Not Sell My Personal Information link on our website.
For purposes of this Privacy Statement, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
CALIFORNIA INDIVIDUAL PRIVACY RIGHTS
If you are a California resident, you may request that we:
(1) Disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
- The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information (if applicable); and
- The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
(2) Delete Personal Information we collected from you.
To exercise your opt-out rights, please complete the Do Not Sell My Personal Information form.
We do not knowingly collect personal information about consumers that are younger than 18 years nor do we sell personal information about consumers that we know are younger than 18 years old.
VERIFICATION OF CONSUMER REQUEST
When you submit your request, we will take steps to verify your identity. To safeguard the privacy and security of your personal information, we will only complete requests where we are certain about the identity of consumer.
The law allows consumers to designate an authorized agent to exercise their rights under CCPA. If you use an authorized agent to submit a request, we will ask your agent to provide information to verify his authority to submit such request.