Updated and Effective May 2023
This policy describes how World Hotels GmbH (“WorldHotels” “we” “us”) collects, uses, and shares personal information. Please note that hotels that are members of WorldHotels are independently owned and operated (“Independent Hotels”) and are not owned, managed, or controlled by WorldHotels. In addition, outside of the United States, companies that are not owned by WorldHotels are sometimes permitted to license the WorldHotels™ brands. Although these companies are referred to by WorldHotels as “Affiliates” they are not under our ownership or control. When you provide information to an Independent Hotel or to an Affiliate, those companies may have their own privacy practices and policies.
If you are visually impaired, you may access this notice through your web browser’s audio readers.
You can select among various topics by clicking on the following options below:
Use and Processing of the Information We Collect
Sharing of Information
Choices
How We Protect Personal Information
How Long We Retain Information
Countries Used for Processing
Third Party Applications, Websites, and Social Media
Changes to this Privacy Policy
Additional Information for California Residents
Contact Information
The following chart provides examples of the type of information that we collect from you in a variety of contexts and how we use that information.
| Context | Types of Information | Primary Purpose for Collection and Use of Information |
|---|---|---|
| Room Reservations | We collect your contact information, payment information, reservation information, and accommodation preferences. That information is collected directly from you when you make a room reservation. In a small number of cases we collect information about a guest’s health. For example, a guest may voluntarily choose to provide information about a disability as part of a request for an accommodation preference. You are required to provide this information in order to complete a reservation. If you choose not to provide this information, we may be unable to complete your request. | We use your information in order to perform our contractual obligations, fulfill your requests for a reservation, and to take steps in anticipation of those obligations. In some jurisdictions we also need your information to comply with legal obligations to collect and maintain information about guests. We also have a legitimate interest in analyzing trends and patterns among guests. In the rare circumstances in which we collect information about a guest’s health, that information is collected only for the purpose of accommodating a guest’s needs and is used for no other purpose. |
| WorldHotels RewardsSM (“WHR”) | WorldHotels offers a loyalty program that entitles members to certain benefits or discounts. We collect your contact information, communication preferences, reservation history, redemption details, and partner loyalty program elections. Information is collected when you register for WHR, redeem reward points, make a hotel reservation as part of WHR, update your WHR account, or link your WHR account to a partner loyalty program. You are required to provide this information in order to participate in WHR. If you choose not to provide this information, we may be unable to provide you with WHR functionality. | We use your information in order to perform our contractual obligations to you. For example, we use the information to allow you to earn and redeem rewards, points or credits in connection with loyalty programs. We also have a legitimate interest in marketing to you and analyzing trends and patterns among our rewards members. Per your express election and consent, store payment-related information for future reservations. WHR program terms and conditions |
| Cookies and First Party Tracking | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. In most cases, you are required to provide this information. If you choose to turn off first party cookies, the website may not function correctly. | We have a legitimate interest in making our website operate efficiently and analyzing trends and patterns among our website visitors. |
| Cookies and Third Party Tracking | We participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that it can provide advertising about products and services tailored to your interests on our website or on other websites. The provision of this information is voluntary. You may choose to opt out of third party tracking through our Cookie Preferences Center. | We base the use of third party tracking, including behavioral advertising, on consent where required by law. |
| Email Interconnectivity | If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, or make reservations. The provision of this information is voluntary. | We have a legitimate interest in understanding how you interact with reservation confirmations. We base other email tracking on consent where required by law. |
| Customer Care | If you contact us with an issue we will collect your name and e-mail address as well as any other content that you send to us in order to reply. If you choose not to provide this information, we may be unable to assist with your issue or question. | We have a legitimate interest in receiving and acting upon the information that you provide to us concerning issues that you raise. |
| Communications List | When you opt-in or sign up to receive communications, we collect your email address, postal address, or phone number for text messaging. If you choose not to provide this information, we may be unable to send you the requested communications. | We share information about our products and services or the products and services of other companies if you consent to receive that information. We also have a legitimate interest in sharing information with you about our services and those of our partners. |
| Mobile Devices | We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our websites or applications. In most cases, you are required to provide this information. If you choose not to provide this information the mobile website and app may not function correctly. | We have a legitimate interest in identifying unique visitors and in understanding how users interact with us on their mobile devices. |
| Partner Promotion | We collect information that you provide as part of co-branded promotions with other companies. The provision of this information is voluntary, but please note that we may be unable to provide you with certain products or services if you choose not to provide this information. | We have a legitimate interest in fulfilling our promotions. That interest includes sharing your information with our partners to, among other things, determine your eligibility for a promotion. |
| Surveys | When you participate in a survey we collect information that you provide through the survey. The provision of this information is voluntary. | We have a legitimate interest in understanding your opinions and collecting information relevant to our organization to improve our services. |
| Sweepstakes, Promotions or Contests | When you participate in a sweepstakes, promotions, or a contest we collect information about you that includes contact information to notify you if you are selected. The provision of this information is voluntary. | We have a legitimate interest in operating sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws. |
| Text Messages to Independent Hotels | Some Independent Hotels may provide guests with the ability to communicate by text message or through a text-message-based automated platform concerning a guest’s hotel stay. The provision of this information is voluntary. If you choose not to provide this information, the Independent Hotel may not be able to communicate through text message. | Independent Hotels that provide guests with the ability to communicate by text message or through a text-message-based automated platform concerning a guest’s hotel stay request consent from the guest before communicating with guests about their stays and responding to guest-initiated text communications. Guests can ask the Independent Hotel about its specific privacy practices. |
| Website Interactions | We use technology to monitor how you interact with our website. This may include the links you click on or information that you type into our online forms. The provision of this information is voluntary. You may choose to opt out of third party tracking through our Cookie Preferences Center. | We have a legitimate interest in understanding how you interact with our website to better improve it and to understand your preferences and interests in order to select offerings that you might find most useful. |
| Web Logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. In most cases, you are required to provide this information. If you choose not to provide this information the website may not function correctly. | We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. |
| WiFi Access | Although we do not provide WiFi networks at Independent Hotels, we do provide access to WiFi at WorldHotels offices (e.g., our headquarters). We collect information about individuals that access those WiFi networks. If you choose to access the WiFi networks, the provision of this information is required. | We have a legitimate interest in providing WiFi networks and in collecting information for fraud and security purposes. |
| Employment Candidates | If you apply to work for us, we collect information necessary to evaluate your application. If you choose not to provide us with the requested information, we may be unable to process your application for employment. | We use information about prospective employees in connection with our legal obligations and our legitimate interest in evaluating candidates. |
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including business partners, WHR Partners, Independent Hotels, Affiliates, Travel Agents, Online Travel Websites, or publicly available sources. For example, if you make a reservation at one of our Independent Hotels, that hotel transmits information to us as part of our legitimate interest in, among other things, maintaining a global reservation system and providing for customer service and support.
In addition to the purposes and uses described above, we use information in the following ways:
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you make a room reservation we collect your information so that we, or so that an Independent Hotel, can perform a contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your stay. As a result, our collection and processing of your information may be based upon our need to perform a contract, our obligations under law, our legitimate interest in conducting our business, and/or your consent.
To the extent we maintain and use personal information in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
You can make the following choices regarding your personal information:
Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.
Submitting Requests
If you do not want to submit a request through our online web portal Request Form, please address written requests and questions about your rights to privacy@worldhotelsrewards.com or call us at 1(800) 772-7081.. An authorized agent submitting a request on behalf of an individual must submit a request through our Request Form. If you are a former employee of WorldHotels please use the email address or telephone number listed above.
Note that if you submit a request, as required by law, we will require you to prove your identity. We will verify your identity by comparing the information you provide when submitting your request with the information in our database. Depending on your request, we may ask for additional information such as the email address you used to create your WHR account, the phone number you used to book your room reservation, and your past stay history. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. In order to confirm that you have indeed authorized an agent to make the request on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf, including a copy of the signed permission you have given to the authorized agent and verification of your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must submit a request through our Request Form and affirm that you are an authorized representative of the requesting party. After receiving your request, we will contact you by e-mail with respect to the documentation and verification we require for submitting a request on behalf of someone else.
If you disagree with how we handled a request, you may appeal our decision by emailing us with the subject line “Appeal.”
No method of transmission over the Internet or of electronic storage is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any breach to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
We retain your personal information for the period necessary to fulfill the purposes outlined in this policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. For example, we retain WHR information for as long as an individual remains a WHR member because WHR points do not expire and the information is needed in order to allow the individual to redeem their rewards. We retain information in our reservation system, in full or in summary form, for three years following a guest’s departure in order to process your reservation, provide post-reservation customer support, and provide invoicing and recordkeeping. We typically retain information in our customer care complaint system for three years after receipt, unless the information is needed for an ongoing purpose such as to address an open issue.
WorldHotels operates from the United States in accordance with the laws of the United States. Individuals that provide information to WorldHotels or visit WorldHotels website should be aware that the laws of the United States may differ from those of your country of residence. For example, there may be situations in which we are required to share your information with United States law enforcement personnel. The following provides additional information for data received by WorldHotels from other countries or transmitted by WorldHotels to other countries:
We generally attempt to utilize the Standard Contractual Clauses approved by the European Commission or the International Data Transfer Agreement approved by the Information Commissioner’s Office for the transfer of personal information from the EEA or UK, as applicable, to countries that have not adopted similar data privacy laws. If you are located in the EEA, you may request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.
For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. We have no control over the privacy practices of websites or applications that we do not own. Our websites or our communications may also contain plug-ins and other features that integrate third party social media platforms. If you interact with these, the third parties who operate these platforms may be able to identify you, determine how you use our website, and link and store this information with your social media profile. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.
We may change our privacy policy and practices over time. When we make changes to the policy, we will change the "Updated and Effective” date at the beginning of this policy, and we will provide any other form of notice as may be required by law. All changes shall be effective from the date we post the revised policy.
California law requires us to disclose additional information related to our privacy practices. If you are a California resident, please click here to learn more about how we use and process your personal information.
We will attempt to respond to any questions, comments, or complaints concerning our privacy practices. Please feel free to contact us using the following information:
World Hotels GmbH
Attn: Privacy
Main Airport Center
Unterschweinstiege 2-14
60549 Frankfurt am Main, Germany
e-mail:privacy@worldhotelsrewards.com
Data Protection Officer
Attention: WorldHotels Privacy
Peter Suhren
First Privacy GmbH
Konsul-Smidt-Str. 88
28217 Bremen, Germany
Phone: +49 421 6966 32 822
E-mail: psuhren@firstprivacy.com
Website: www.first-privacy.com
Please note that e-mail communications will not necessarily be secure; accordingly you should not include payment information or sensitive information in e-mail correspondence to us.
If you are not satisfied with our response, and are in the European Union or the United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.