Last updated: July 24, 2020
- For more information about our European Union privacy practices, click here
- For more information about our California privacy practices, click here
We collect data and information about our guests and other visitors in order to better provide our Services. The data collected is provided by you, either directly or via your use of the Services.
Personal data applies to any data that can identify you as an individual or relate to an identifiable individual. At various points during your stay and experience with the Independent Collection we collect certain Personal Data such as:
- Contact information: First and last name, Email address, Phone number, Address, State, Province, ZIP/Postal code, City, etc.
- Demographic information: Age, gender, date of birth, anniversary, primary language, etc.
- Reservation/Visit: Date of arrival and departure, special requests, goods, and services purchased and consumed, etc.
- Interests and Preferences: Regarding past, current and future stays at the Independent Collection properties, such as your interests, activities, hobbies, food, and beverage choices, etc.
In more limited circumstances, we also may collect:
Data about family members and companions, such as ages of children. Images and video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel.
PAYMENT PROCESSING INFORMATION
When you make a payment in connection with purchasing any of the Services, the Independent Collection may obtain credit card or other payment information.
Usage Data is collected automatically when you use the Service.
Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type (for example: Chrome, Firefox, Internet Explorer or Safari), browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, we may likewise collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique ID or IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you access the Service by or through a mobile device.
Usage data is collected via tracking technologies, including:
Cookies can be “Persistent” or “Session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while Session cookies are deleted as soon as you close your web browser.
We use both Session and Persistent cookies for the purposes set out below:
- Necessary / Essential Cookies
Type: Session Cookies; Administered by: Us
Purpose: These cookies are essential to provide you with the Services. They help to authenticate users and prevent fraudulent use of user accounts. We only use these cookies to provide the Services.
- Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies; Administered by: Us
- Functionality Cookies
Type: Persistent Cookies; Administered by: Us
Purpose: These cookies allow us to remember choices you make when you use our website(s), such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid your having to re-enter your preferences every time you use the website(s).
- Tracking and Performance Cookies
Type: Persistent Cookies; Administered by: Third-Parties
Purpose: These cookies are used to track information about traffic to the website and how it is used. The information gathered may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the website. We may also use these cookies to test new advertisements, pages, features, or new functionality of the website to see how our users react to them.
- Targeting and Advertising Cookies
Type: Persistent Cookies; Administered by: Third-Parties
Purpose: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. They use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.
Log files are deleted after 120 days. Session cookies expire and are deleted at the end of your browser session. Persistent cookies may be set to expire from 30 days to 1 year depending on the function of the cookie. After expiry of those periods, information will be deleted or made anonymous.
You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Most modern internet browsers allow individuals to change the settings in the ‘options’ or ‘preferences’ menu to avoid or limit cookie storage. In addition, third party cookies generated by certain advertisers may be turned off by making a request with the Network Advertising Initiative. Please visit http://optout.networkadvertising.org for more information.
In addition to cookies, we also use Web Beacons and Embedded Script.
Web Beacons help us better manage content on our Services by informing us of what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. This information is used to help improve the overall quality and experience of the Services.
Embedded Script is a programming code that collects information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Service.
Using and Disclosing Data
The data and other information that we collect is used and disclosed in the following manner(s) and for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage your account: to manage your registration as a user of the Service. The information you provide can give you access to different functionalities of the Service that are available only to a registered user.
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Service.
- To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
- To manage your requests: To attend and manage your requests to us.
- To tailor content, recommendations and offers we display to you on the Services and elsewhere online.
- Improve the Services and our products, including asking you to participate in surveys, and for other internal business purposes.
Our goal is to provide you with the highest level of hospitality and to assist us with doing so, we share personal, and other, data with the following parties:
- Strategic Business Partners: We disclose data, including personal data, and other information with select strategic business partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you. By sharing data with these parties, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables spa, restaurant, concierge, and other outlets at our properties to provide you with services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars, and vacation packages.
- Corporate Reorganization/Business Transfers: We may disclose or transfer your personal data and other information to a third party in the event of any reorganization, merger, sale of our assets, financing, joint venture, assignment, transfer or other disposition of all or any portion of the Independent Collection business, assets or stock. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business to another company. In any such case, the successor organization’s use and disclosure of your personal data will continue to be subject to this policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your personal data will be subject to the successor organization’s own policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use the website). If you submit personal data after such a transfer, that information may be subject to the successor entity’s policy.
- Sweepstakes, Contests and Promotions: We may work with third parties that sponsor or offer sweepstakes, contests, and other promotions. By participating in a promotion, you are agreeing to the terms, conditions or official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing us and the sponsor(s) of the promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing. If you choose to enter a promotion, personal information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.
- With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed. If you interact with other users or register through a third-party social media platform, your contacts on such social media platform may see your name, profile, pictures, and description of your activity. Similarly, other users may be able to view descriptions of your activity, communicate with you and view your profile.
In addition to the above scenarios, we may also disclose information about you to certain third parties if we have a good-faith belief that we are required to do so by law or legal process, to respond to legal claims, or to protect our rights, property, or safety, or the rights, property, or safety of others. We will only use your payment processing information with your explicit consent.
RETENTION OF DATA
We will also retain usage data for internal analysis purposes.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
CONSENT TO TRANSFER
The Independent Collection is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our website(s) or the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
The security of your data is important to us, and the Independent Collection takes commercially reasonable security and backup measures to protect the information submitted to us. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security. We encourage our customers and partners to retain copies of all uploaded information on their own systems.
The Services are general audience services and are not intended for individuals younger than the age of 13. We do not knowingly collect personal data from individuals younger than the age of 13 without parental consent. If we discover that a child under the age of 13 has provided us with personal data, or that we have otherwise inadvertently collected personal data from anyone younger than the age of 13, we will delete it in accordance with applicable law.
California residents have additional rights regarding our use of your personal data and are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year.
California residents under the age of 18 who are registered users of online sites, services or applications also have the right under California law to request and obtain removal of content or information they have publicly posted. If you are a California resident and wish to request removal of such data, you can contact us using the contact information provided below.
California residents are also entitled to exercise certain rights as expressly set forth by the California Consumer Privacy Act, including the right to give the instruction ‘Do Not Sell My Personal Information’ to third parties. For additional details on your California Privacy rights, see our California Privacy notice.
EUROPEAN UNION PRIVACY
We comply with the provisions of the European Union’s General Data Protection Regulation (“GDPR”) as to any information in its possession regarding EU-based persons (“data subjects”). Accordingly, we only process personal information on data subjects where we has a lawful basis to do so, which may include the consent of each person (especially in the case of website visitors who provide their information) or compliance with a legal obligation. For additional details on your European Union Privacy rights, please see our European Union Privacy notice.
Additional Information on the Processing of Personal Data
We may use third party service providers to show advertisements to you to help support and maintain our Service. Such third parties include, but are not limited to:
- Bing Ads: Bing Ads is an advertising service provided by Microsoft Inc. You can opt-out from Bing Ads by following the instructions on Bing Ads Opt-out page: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
We may use the email address that you provide to us in order to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email we send or by contacting us as set forth below.
- Google Ads (AdWords): Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
- Bing Ads Remarketing: Bing Ads remarketing service is provided by Microsoft Inc. You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads.
- Facebook/Instagram: Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation.
FACEBOOK FAN PAGE
- Facebook Insights: We use the Facebook Insights function in connection with the operation of the Facebook Fan Page in order to obtain anonymized statistical data about our users. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
USAGE, PERFORMANCE AND MISCELLANEOUS
We may use third-party service providers to improve our Service.
- Invisible reCAPTCHA
- By email: firstname.lastname@example.org
- By mail:
510 Walnut St 9th floor
Philadelphia, PA 19106
If you are a resident of the European Union (the “EU”) or reside in the European Economic Area (the “EEA”) and we collect personal data relating to you in the context of the offering the Services, your personal data will be subject to Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”).
LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR
We may process your personal data pursuant to one of the following conditions:
- Consent: You have given your consent for processing personal data for one or more specific purposes.
- Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
- Vital interests: Processing personal data is necessary in order to protect your vital interests or those of another natural person.
- Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests of the Independent Collection.
In any case, upon reasonable request we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
YOUR RIGHTS UNDER THE GDPR
The Independent Collection undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.
- Request access to your personal data. You can access, update or request deletion of your personal data, please contact us and we will attempt to assist you as possible. You also have a right upon request to receive a copy of the personal data we hold about you.
- Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
- Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation which makes you want to object to our processing. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request erasure of your personal data. You have the right to ask us to delete or remove personal data from further processing.
- Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.
EXERCISING YOUR GDPR DATA PROTECTION RIGHTS
You may exercise your rights of access, rectification, cancellation and opposition by contacting us via email at email@example.com or mail at Independent Collection, ATTN: Legal, 510 Walnut St 9th Floor, Philadelphia, PA 19106. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information please contact your local data protection authority in the EEA.
Your Rights as a Consumer
The CCPA grants you specific rights in and to your personal information. Specifically, you have the rights set forth below and may exercise them, as applicable, as further described below.
Right of Access to Collected Information; Data Portability
You have the right to request that the Independent Collection disclose the categories and specific pieces of personal information that we have collected about you. Upon receipt of any request, we will send you a verification notice and, once your identity has been verified, we will disclose to you:
- The categories of your personal information that we have collected.
- The specific pieces of your personal information that we have collected.
- The categories of sources from which we have collected your personal information.
- The commercial reason for our collection or sale of your personal information.
- The categories of third parties, if any, with whom we have shared your personal information.
The Independent Collection will disclose this information to you either electronically or by mail. If provided electronically, the information will be in a portable and, to the extent feasible, readily useable format so as to allow you to transmit the information to another party without hindrance.
Right of Access to Information Sold or Disclosed for a Business Purpose
You have the right to request that the Independent Collection disclose the categories of personal information that we have sold or otherwise disclosed to a third party about you. Upon receipt of any request, we will send you a verification notice and, once your identity has been verified, we will disclose to you:
- The categories of your personal information that we have collected.
- The categories of your personal information that we have sold.
- The categories of your personal information that we have otherwise disclosed to a third party for a business purpose.
- The categories of third parties to whom we have sold your personal information.
Right to Request Deletion
You have the right to request that the Independent Collection delete any of your personal information that we have collected and retained about you, subject to certain exceptions. Upon receipt of any request, we will send you a verification notice and, once your identity has been verified, we will delete (and direct any third-party service providers to delete) your personal information.
The Independent Collection may deny your deletion request if retaining your personal information is necessary for us to: complete the transaction for which we originally collected your personal information; provide a service that you requested; take reasonably anticipated actions within the context of our ongoing business relationship; to comply with a legal obligation; or otherwise as set forth in the CCPA. If we deny your deletion request, we will provide you with the reason(s) for such denial.
Right to Opt-Out of the Sale of Your Personal Information
You have the right to request that the Independent Collection not sell your personal information. This right is also referred to as the right to “opt-out” of the sale of your personal information. The Independent Collection does not sell consumers’ personal information.
Right of Non-Discrimination
You have the right to exercise any or all of the rights identified above free of discrimination. The Independent Collectionwill not discriminate against you for exercising your CCPA rights.
Exercising Your California Privacy Rights
To exercise your rights to access about your personal information that is collected and/or sold by the Independent Collection, or to request the deletion of your personal information or an opt-out from the sale of your personal information, you can submit a verifiable request by:
- Email: firstname.lastname@example.org
510 Walnut St 9th floor
Philadelphia, PA 19106
Only you or an individual authorized to act on your behalf with the California Secretary of State’s office may make a valid request as relates to your personal information. If you are a parent or guardian of a minor child, you may make a request on their behalf.
The Independent Collection uses commercially reasonable efforts to respond to any verifiable consumer request within 45 days of our receipt of such request. If we require additional time, we will inform you of the same along with our reason(s) and any extension period in writing via the contact information that you provide to us upon request. Any information disclosure that we provide will cover the 12-month period immediately preceding our receipt of your request. You may make a request for disclosure at any time, but we will not provide any such disclosures more than two times in a 12-month period.
Information That We Collect
The Independent Collection has collected the following categories of personal information about consumers in the last 12 months.
Identifiers: Real name, postal address, online identifier, email address, Internet Protocol address, or other similar identifiers.
Categories of personal information listed in the California Customer Records statute: Name, address, telephone number, education, employment, employment history. Information included in this category is specifically set forth by California statutory law and may overlap with information in other categories.
Commercial information:Information or details of products or services purchased, obtained, or considered.
The Independent Collection collects your information in order to better provide hospitality services at our portfolio of hotels.
Information That We Sell
The Independent Collection collects consumer personal information directly from consumers and uses it solely for the purpose(s) for which it is collected. We do not sell consumer personal information.
Information That We Disclose for a Business Purpose
The Independent Collection discloses personal information to certain third party(s) for business purposes. When we do so, we enter into contracts that describe the business purpose and which require such third party(s) to keep the personal information confidential and to only use personal information as set forth in and explicitly allowed by the contract.
We have disclosed to a third party for a business purpose the following categories of personal information about consumers in the last 12 months.
- Personal information listed in the California Consumer Records statute
- Commercial information
The Independent Collection discloses personal information for a business purpose only to our third-party service provider(s).
Changes to this California Privacy Notice
We may update this Notice at any time and the changes will be effective upon posting. This Notice will be reviewed and updated as necessary at least once every 12 months.
If you have questions or comments about this Notice or our California privacy practices generally, please feel free to contact us via email at email@example.com or mail at the Independent Collection, ATTN: Legal, 510 Walnut St 9th Floor, Philadelphia, PA 19106.