Privacy

StayNTouch Privacy Policy

This Privacy Policy was last updated on January 8th,  2018

Welcome to the StayNTouch, Inc.’s (“Company”) web site (the “Site”). This Site is operated by us and was created to provide general information about StayNTouch, including our proprietary mobile applications that, among other things, enable hotel guests to check-in, view upgrade offers, receive e-mail communications and manage lobby or kiosk key pick-up (collectively, including the Site, the “Company Services”). This Privacy Policy explains what data we collect when you use the Company Services, why we collect it and how that data is used. It applies to personal data collected by us from or about: (i) visitors to our Site, (ii) prospective and current customers, (iii) suppliers, (iv) job applicants; (v) and hotel guests who use our Site or the Company Services.

By using the Company Services, and providing us with your personal data, you consent to the processing of your personal data in the manner set out in this Privacy Policy.

Information We Collect:

When you interact with the Company Services, we will collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), as described below:

Personal Data That You Provide Through the Company Services: We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to Company Services or use certain Company Services. This data includes your first and last name, title, company name, e-mail address, mailing address, phone number, fax number, payment and billing information, country location.

When you apply for employment through the Site, our provider of recruiting services will collect your resume and any additional information that you elect to provide to us, including but not limited to employment history and education.

Our Use of Your Personal Data:

To provide the Company Services and respond to requests. We use account-related data provided by you in connection with the purchase, sign-up, use or support of your account (such as usernames, e-mail address and billing information), to provide you with access to the Company Services, contact you regarding your use of the Company Services or to notify you of important changes to the Company Services. Such use is necessary for the performance of the contract between you and us.

When you ask for information about the Company Services (for example, when you ask us to send you offers or price information), we will use your contact information to respond to your requests. Such use is necessary to respond to or implement your request prior to entering into a contract with us.

For marketing purposes. We will use your Personal Data to send you information by e-mail on our new products or services or other promotions. Where required by the applicable law (for example, if you are an EU data subject), we will send you such information only with your consent, which was given at the time you provided us with the Personal Data. In such case, if you do not provide us with your consent to the processing of your Personal Data for this purpose, we will not send you this information.

You have the right to withdraw your consent at any time, including by following the instructions contained in each promotional communication we send you permitting you to “opt-out” of receiving future promotional information. If at any time you wish not to receive any future communications or have your name deleted from our mailing lists, please contact us at: privacy@stayntouch.com. Please note that we will continue to contact you via e-mail to respond to your requests and regarding providing the Company Services.

To process applications for a job. When you apply for employment through the Company Services, your contact details and data about your employment history and education will be collected by our provider of recruiting services. We will use such data to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment. This data is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process your application.

To analyze, administer, support, improve use of the Company Services. We will also use data relating to your use of Company Services to help us improve the content and functionality of the Company Services and to better understand our users. We will also compile, anonymize and/or aggregate your Personal Data and other data and use this data for our business purposes, including sharing such data with affiliates and business partners.  This use of your Personal Data is necessary for our legitimate interests in understanding how you use the Company Services and to improve your experience. This aggregate information does not identify you. You have the right to object to processing that is based on our legitimate interests, as further described below.

Our Disclosure of Your Personal Data:

We share your Personal Data with certain third parties as set forth below:

Agents, Consultants and Other Service Providers: Like many businesses, we sometimes hire other companies or individuals to perform certain business-related functions. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. Examples of such functions include mailing information, hosting and maintaining databases and processing payments. When we employ third parties to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Hotel Owners: The Company Services facilitate interaction between you and hotels at which you have been a guest or may be a guest in the future (each, a “Hotel”). If you enter information in any Company Service, or in response to any e-mail sent by any Company Service, such information will be disclosed to the applicable Hotel for which such information was provided. Our use of information on behalf of Hotels is governed by our contract with that Hotel and the Hotel’s own privacy policies.  We are not responsible for Hotels’ privacy policies or privacy practices. Please consult the privacy notices that Hotels provided to you to understand Hotels’ data processing practices.

Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect and defend the rights or property of Company, (c) act in urgent circumstances to protect the personal safety of users of the Company Services or the public, or (d) protect against legal liability.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Your Choices:

You can use the Site without providing any Personal Data. However, if you choose not to provide any Personal Data, you may not be able to use certain Company Services.

EU Data Subjects:

This section applies solely if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland).

StayNTouch is the data controller for processing personal data provided to us through the Company Services. Our registered office is Bethesda, Maryland, USA.

Subject to applicable law, you have the following rights in relation to your Personal Data:

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or “block” the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
  • Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
    • If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
    • If we are processing your Personal Data for direct marketing.
  • Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
  • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Access to Information; Contacting Company” section below.

We will notify you of changes to the data processing activities described in this Privacy Policy by email or by posting a prominent notice on the Company Services.

Do Not Track Signals:

The Company does not currently respond to “Do Not Track” signals sent by your browser or mobile application. If we change our practices in the future and begin to respond to “Do Not Track” signals, we will update this Privacy Policy accordingly.

Exclusions:

This Privacy Policy only applies to Personal Data collected through the Company Services. This Privacy Policy shall not apply to any unsolicited information you provide to Company through the Company Services or through any other means. This includes, but is not limited to, customer service comments, ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Company shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children:

We do not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Company Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Company Services. If you have reason to believe that a child under the age of 13 has provided Personal Data to Company, please contact us, and we will endeavor to delete that information.

Third Party Sites and Services:

This Privacy Policy applies only to the Company Services. The Company Services may contain links to other web sites not operated or controlled by Company, including, without limitation, links to the Hotel web sites (the “Third Party Sites”). The policies and procedures we describe here do not apply to the Third Party Sites or services, or to any Hotel’s collection, storage or use of your Personal Data. The links from the Company Services do not imply that Company endorses or has reviewed the Third Party Sites. We suggest contacting those sites, services, entities or persons directly for information on their privacy practices and policies.

Data Retention:

We will keep your Personal Data for as long as is reasonably necessary for the purposes described in this Privacy Policy, or as required by law, whichever is the longer.

Security:

Company takes reasonable steps to protect the Personal Data provided via the Company Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Company Services may not be secure. We cannot guarantee the security of any information you disclose via e-mail or otherwise online.

Changes to the Privacy Policy:

The Company Services and our business may change from time to time. As a result, at times it may be necessary for Company to make changes to this Privacy Policy. Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Company Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information; Contacting Company:

To keep your Personal Data accurate, current, and complete, please contact us as specified below (for EU data subjects’ rights, please refer to the EU Data Subjects section above). We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Company Services. Please also feel free to contact us if you have any questions about this Privacy Policy or the information practices of the Company Services. You may contact us as follows: privacy@stayntouch.com.

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