2.1. Personal Information We Collect and How We Use It
The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user, visitor (together, “Individuals”) and the requirements of applicable law.
- TRC Information. When you register for or use the Services, or make a purchase online or in-person, we will collect information from you. This may include Registration Data, your name, email address, phone number, address, travel itinerary, date of birth, a copy of your government ID, credit card information, and other related information. We may also issue you a personal invite and/or promotional code.
- Information about your Stay. When you stay at one of our hotels, we may collect information about your experience, including amenities purchased, preferences, feedback, and other related information.
- Roommate Matching Technology. When you agree or ask to be paired with a roommate, we may collect information about your preferences such as languages you speak and your interests.
- Communications with Us. We may collect Personal Information and the contents of your communication when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us. If you call our customer support line, you agree we may record your conversation for quality assurance, fraud prevention and training purposes.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
- Interactive Areas. We may offer forums, blogs, social media pages, messaging services, and other Interactive Areas. TRC may collect the information you share in these channels, including the content of any messages. Any content you provide on public or community areas of these channels, including User
- Biometric Information. As part of the check-in process, we may ask you to provide a government ID and also to take a “selfie”. We (and our service providers) may collect biometric information contained in both images and compare it for fraud and verification purposes. We do not use this biometric information for any other purpose.
- Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
- Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, information about when you lock or unlock a hotel room door with the mobile application, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
- Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations (such as credit agencies) to supplement information provided by you. For example, if you access our Services through a third party application, such as an App Store, a third party login service, or a Social Networking Site (e.g., Google, Facebook, etc.), we may collect information about you from that third party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
2.2. How We Use Your Information
We Process Personal Information about Individuals for a variety of business purposes, including:
2.3. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use Google Analytics, Mixpanel, and other service providers to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
- Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
- Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising or Targeting Related. We may use first party or third party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on Third Party sites.
2.4. Third Party Websites, Social Media Platforms and Software Development Kits
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other Third-Party Content, websites or applications. Visiting these other websites or applications is at your own risk.
TRC’s Services may include publicly accessible blogs, forums, social media pages, Interactive Areas, and private messaging features. By using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
3. Onward Transfer—How We May Disclose Your Information
3.1. Information We Share
- Hotels to Book your Stay. When you purchase a hotel room operated by TRC, we will provide your information to that property in order to facilitate the transaction you requested. If all hotels in the TRC network are booked up, we may provide your information to other hotels we work with.
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Site and Services.
- Business Partners. We may provide Personal Information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
- Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, TRC may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Site and Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may follow the instructions below.
- Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
- Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
3.2. International Data Transfers
You agree that all information Processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the European Union, the United States or other countries in order to provide the Services. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request.
4. Your Choices: Right to Object to Processing
You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below.
4.2. Email and Telephone Communications
4.3. Mobile Devices
We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. TRCmay also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
4.4. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
4.5. Cookies and Interest-Based Advertising
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/ and http://www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
5. Rights of Access, Rectification, Erasure, and Restriction
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by TRC, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, TRC will take steps to verify your identity before fulfilling your request.
6. Data Retention
7. Security of Your Information
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
8. Children’s Information
The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
9. California Privacy Rights
10. Supervisory Authority
If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.
12. Terms of Service
13. Contact Us
LH 29 CENTRE MANAGER, LLC
222 Broadway Avenue Floor 18
New York, NY 10038
- “Personal Information” is any information relating to an identified or identifiable natural person. Personal Information does not included aggregated or de-identified data.
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.