Evason Ana Mandara
Six Senses Spa Punta Cana
Six Senses Bhutan
Six Senses Krabey Island
Six Senses Fiji
Six Senses Uluwatu, Bali
Six Senses Laamu
Six Senses Samui
Six Senses Yao Noi
Six Senses Con Dao
Six Senses Ninh Van Bay
Evason Ana Mandara
Six Senses Spa Punta Cana
The privacy and security of your information is very important to us. Whether you are visiting our website, using our app, booking a room, or are a member of one of our loyalty programs, we want you to trust the way that we manage your information and to keep you informed about how we use that information.
We have prepared this Privacy Statement to explain more about who we are, how we collect and manage your information (whether through our website, mobile apps, our social media pages, or offline) and the choices you have about how we use your information. Specific additional rights may apply if required by applicable law. For example, please view our additional disclosures directed to residents of California and the European Economic Area (EEA) in this Privacy Statement.
This Privacy Statement is issued by the InterContinental Hotels Group of Companies (collectively referred to as "IHG”, "we”, "us” or "our” in this Privacy Statement), which includes the direct and indirect subsidiaries of InterContinental Hotels Group PLC and covers information that we collect and use in the course of our business. When we mention "IHG", "we", "us", or "our", we are referring to the relevant company in the InterContinental Hotels Group that processes your personal information.
Your information may also be collected and used by IHG-branded hotels. In most cases, these hotels are independently owned, and their use of your information is covered by their own privacy notices, not this one.
If you would like to learn more about IHG and our relationship with our IHG-branded hotels, click below.
We are a global hospitality company operating in more than 100 countries. We predominantly franchise our brands to, and manage hotels on behalf of, independent owners. We also operate a number of programs that are related to our hotel business such as IHG® Rewards Club, which is our core loyalty program.
We franchise our brands to, and manage hotels on behalf of, independent owners (“IHG-branded hotels”). Most hotels operating under IHG’s brands are independently owned and operated by parties that have entered into a franchise agreement with IHG that allows them to use an IHG brand for the purposes of operating a hotel. If you make a reservation through us to stay at an IHG-branded hotel, we will share your information with that hotel. However, as IHG-branded hotels are not owned or controlled by IHG, their use of your information will generally be governed by their own privacy practices.
We collect personal information directly from you, about you from other persons/entities/online channels, and automatically as you use our website, mobile application, and through certain offerings or services available at IHG-branded properties (such as IHG Connect WI-FI). In particular, we collect and use information about you if you (or someone on your behalf) makes a reservation to stay at an IHG-branded hotel or property offered through IHG reservations, participate in one of our loyalty programs such as IHG® Rewards Club, or interact with us through our corporate site or mobile app. You do not have to provide us with your personal information in order to use our website or mobile app; in some cases, however, we may not be able to provide services to you without your personal information (for example, we would not be able to complete a requested booking or enroll you in our rewards program). To learn more about how we collect, use and share your information, please click the relevant section below.
Information we collect:
Directly From You: We collect information from you when you make a booking through our reservation system or stay at an IHG-branded hotel. Information collected during the course of the reservation and during your stay may include:
If you provide personal information to us about other persons when making a booking or during your stay, for example, family members or colleagues, we ask you to make sure they are happy for their personal information to be shared with us and to direct them to read this Privacy Statement if they want to find out more about how we use their information.
From Other Sources: We also collect reservation information about you from other persons/entities, including, travel agents, websites not owned and operated by IHG, persons booking on your behalf (e.g., a family member, company representative), your employer, or other entity. If you make a reservation directly with one of our IHG-branded properties, we typically receive a copy of that reservation. We also may collect information about you (indirectly) from airlines and other travel providers connected with your reservation; for example, we may learn your arrival time from a travel partner and use this information to contact you about early check-in options. We may obtain information about you from social media pages; for example, if you make a comment on IHG’s social media page or if you comment about IHG on a public social media feed. We use this information to improve our services to you and to other customers.
Automatically: We collect information about you automatically as you use our website, mobile app, and our social media sites. In these instances, information such as your country information, internet protocol (“IP”) address, medial access control address, and other characteristics about your system or device may be automatically collected. This information is collected for functional purposes as well as to improve your experience when using these services. This information may also be used for aggregated trend and statistical analysis, and for showing you more relevant advertisements and messages. More information on these practices can be found in the Using our websites, mobile applications, and other technologies section below. We do not typically associate an IP address with your IHG Rewards profile.
Special Hotel Programs/Biometrics: At IHG, we are always seeking more ways to enhance your experience with us. A limited number of properties now offer a biometrics check-in process to eliminate your need to stand in line. Some properties also may allow room access through the collection of biometric information. These programs are opt-in only, and any information that we collect through your participation will be used solely for the program as described in the notice provided to you at the time of the opt-in.
How we use this information: We use your information from you primarily to fulfill your hotel reservation and to provide and manage our IHG Rewards Club programme. This may include communicating with you (e.g., sending a confirmation email) in advance of your stay. Following your stay, we may also send you post-stay communications and satisfaction surveys to get feedback on your experience. When you stay at a hotel, we do not receive all of the information about your stay; for example, if you book a spa visit, that spa service may be provided either by the IHG-branded hotel (not IHG) or by a local entity.
In some instances, and where we have your consent or where permitted under applicable law, we may send you marketing communications (which may include text messages or calls placed using autodialer technology) for products and services that we believe would be relevant for you. We also may use information related to your stay to display targeted advertisements on our websites, mobile apps, or on non-affiliated websites or mobile apps, or to send you more relevant messaging.Additionally, we aggregate your information with other guest information to complete trend and statistical analysis, which we use to evaluate and improve our products and services, plan new hotel locations and services, and for other market research.
We will indicate whether the requested information is mandatory; the failure to provide such information may impact and/or prevent our ability from providing certain services to you.
Who we share your information with: We share your reservation information as follows:
We also share your stay information with other entities, which may include law enforcement, professional advisors, and other persons, in circumstances such as:
Information we collect: We collect information from you during the course of your membership in any of our loyalty programs and services, including our core loyalty program, IHG® Rewards Club. Information collected during the course of your enrollment and participation in these programs may include:
We may collect this information from you, other sources, and automatically.
From You/Other Person acting on Your Behalf: We collect your information through our global reservation and customer care offices, through our websites, or through our mobile applications.
Properties: We receive information about your stay from IHG-branded hotels and other properties within the IHG network so that we can honor the program.
Service Providers: We may also collect information about you from other sources, including entities that assist us in confirming the accuracy of your mailing address; in some circumstances, we do not receive the updated address verification from the vendor; rather, the vendor may simply update our mailing with the address that it believes is aligned with the postal service requirements.
Other Sources: We may obtain information about you from social media pages; for example, if you make a comment on IHG’s social media page or if you comment about IHG on a public social media feed. We use this information to improve our services to you and to other customers. We do not typically append this information to your rewards profile. We also obtain demographic information from entities, which typically is in aggregated form. We may use this information in combination with information in your profile to identify relevant opportunities about which to notify you.
Your Friends: We may obtain information about you from friends if they refer you to us.
Automatically: We collect information about you automatically as you use our website, mobile app, and social media sites. In these instances, information such as your country information, internet protocol (“IP”) address, medial access control address, and other characteristics about your system or device may be automatically collected. This information is collected for functional purposes as well as to improve your experience when using these services. This information may also be used for aggregated trend and statistical analysis, and for showing you more relevant advertisements and messages. More information on these practices can be found in the Using our websites, mobile applications, and other technologies section below, and in our Cookies and other tracking technologies section. We do not typically associate an IP address with your IHG Rewards profile.
How we use this information: We use your information to operate and provide services in connection with our loyalty programs. We also use your information to improve our products and services. Where permitted by applicable law, or where we have your consent, we also may share your information with other parties, including our IHG® Rewards Club partners and others, to extend special offers about their own products and services to you.
This may include:
Although provision of much of the information requested is voluntary, the failure to provide certain information may impact and/or prevent our ability to offer you certain services.
We occasionally run promotions where we ask IHG Rewards Club Members to refer a friend to the IHG Rewards Club. In these cases, we always ask members to make sure anyone they refer is happy for their personal information to be passed to us, and to direct friends to read this Privacy Statement if they want to find out more about how we use their information.
How you can manage your marketing preferences: You can manage your preferences and decide what marketing communications you would like to receive from us in our online preference center. You can visit our Preference center or find out more information in the Managing your Preferences and information section.
In addition, you can opt out of collection of your personal information for use in targeted advertising. Please see Managing cookies and opting out for more information on how to do this.
We also recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your Rewards Club account. In addition, California residents have the option of clicking on the Do Not Sell link, which would eliminate the sharing that might constitute a sale under California’s law.
Who we share your information with: During the course of your participation in our loyalty programs, we share your information as follows:
We also will share your information in the following circumstances:
Information we collect: We collect information from you when you sign up to receive corporate news or shareholder documents, participate in surveys, submit reviews, contact customer service, or otherwise provide feedback to us or through social media.
Corporate News: Information collected may include:
We collect this information directly from you when you sign up for corporate news or shareholder documents on our corporate site.
Competitions or sweepstakes: we collect contact information from you when you sign up for a competition or sweepstake; we do not necessarily include this information as part of your IHG Rewards profile. In these instances, we will collect information from and about you for running and administering the respective competition, sweepstakes or service that you have elected to participate in. The information collected may include personal details such as your name and address as well as certain demographic information that you choose to provide. In each case, we will collect, use and secure your information in a manner consistent with the general principles set out in this Privacy Statement unless we tell you otherwise.
Other Collections: We also collect information from you when you sign up to receive our newsletters or other special offers and promotions, download one of our mobile applications, or participate in one of our other services. The type of information that we collect from you depends on your interaction with our site and services.
Automatically: We also collect information about you when you browse our website, use our mobile app, or use our social media sites. In these instances, information such as your country information, internet protocol (“IP”) address, media access control address and other characteristics about your system or device may be automatically collected. This information is collected for functional purposes as well as to improve your experience when using these services. This information may also be used for aggregated trend and statistical analysis, and for showing you more relevant advertisements and messages. More information on these practices can be found in the Using our websites, mobile applications and other technology section below. We do not typically associate an IP address with your IHG Rewards profile.
How we use this information: We use your information to provide you with corporate news and shareholder documents for which you have signed up. For corporate news, you may change your communication preferences in accordance with the Managing your communication preferences section below.
If you sign up for a promotion, we may associate that promotion with your account (e.g., if related to an IHG Rewards program.). If you sign up for a contest or sweepstakes, we will use your information for the purpose of that contest or sweepstakes. Please be advised that there may be additional rules for the sweepstakes or contest, and those rules may provide additional information about how we will use your information collected for any event that you choose to enter.
For online collected data, please see Online Channels and our Cookies and other tracking technologies for additional information.
Who we share your information with: We may share your information with our service providers who provide services on our behalf to help with our corporate site and our shareholder functions. These services may include the provision of shareholder documents and services related to management of our shareholder register. These companies are authorized to use your personal information only as necessary to provide these services to us.
We will also share your information in circumstances, such as:
We are committed to collecting and using your information in accordance with applicable data protection laws.
We collect, use and share your information where we have an appropriate legal basis to do this.
This may be because:
If you would like to find out more about the legal basis for which we process personal information please contact us (details found in the How to contact us section). If you have provided your consent to our processing of your information you can withdraw this consent at any time by contacting the IHG Privacy Office (details found in the How to contact us section).
As we operate via a global network of corporate offices, reservation and service centers, data centers and hotels, it may be necessary to transfer your information to a country outside of the country where it was originally collected or outside of your country of residence or nationality. The information that you provide us during the course of a reservation or through the provision of any other services may be transferred to any of our IHG-owned or affiliated entities and hotels around the world for the purposes of carrying out or facilitating these services. It will also be necessary to transfer this information to other entities, including, without limitation, our IHG-branded hotels, partners and our service providers.
Where we transfer information which originates in the European Union ("EU") to a country outside of the EU, we will take steps to make sure such transfer is carefully managed to protect your privacy rights:
When we otherwise transfer personal information between jurisdictions we will take such steps as required by local law in an effort to ensure that such transfer is managed to protect your privacy rights.
What is a cookie: A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and is used to remember as well as obtain information about that party. You might be assigned a cookie when visiting our websites or when using our mobile applications. In some instances, where permitted under the applicable law, cookies may also be used for the purposes of certain email campaigns.
What types of cookies we use and how we use them: We use three primary types of cookies, which include:
To learn more about cookies and how they are used, please visit: http://www.allaboutcookies.org/.
Cookies: As described above, we use a number of service providers to help us manage, carry out and improve our advertising. These parties set cookies at our direction to help us collect information and provide you with advertisements that we believe would be relevant for you. In some instances these parties may also assist us by providing certain statistical and analytics information in relation to our marketing practices. We also may share information collected through cookies (and other tracking technologies) with third parties to use for their own analytics and marketing purposes. These third parties may serve targeted advertising to you about IHG and non-IHG branded hotels. The scope of information shared may include information collected through cookies, such as your IP address/device ID, and information about the search that you performed on our website (e.g., you were looking for a hotel in New York City), but would not include your name or IHG Rewards information.
Managing cookies and opting out: You can change your cookie preferences in our Cookie preferences tool, which is also available from the Privacy and Cookies Center. You can choose to visit our web sites without cookies, but in some cases certain services, features and functionality may not be available. To visit without cookies, you can configure your browser to reject all cookies or notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. To manage Flash cookies, please see Flash Player Help.
In relation to cookies placed by our service providers, we participate in the Self-Regulatory Program for Online Behavioral Advertising managed by the Digital Advertising Alliance (“DAA”). As part of this commitment, IHG has agreed to comply with the standards and guidelines promulgated by the DAA. For more information regarding targeted advertisements and/or to opt out of automatic collection for these purposes, please visit http://www.aboutads.info/choices/ or http://www.networkadvertising.org/managing/opt_out.asp. Within the EU and Canada the local DAA organizations operate a similar "ad choices" scheme: see http://www.youronlinechoices.com (Europe) and http://youradchoices.ca/ (Canada). If you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out. If you use multiple devices or browsers, you will need to opt out each browser or device that you use.
Other technologies: Other technologies such as pixels and web beacons may also be used on our websites, mobile applications, in email messages and in other areas of our business. These technologies are used to improve our products and services as well as our marketing efforts.
Targeted advertising: We and our service providers may serve targeted advertisements through the use of first-party or third-party cookies, pixels and web beacons when you visit our website, use our mobile applications, or visit websites owned by other entities. In some instances, these cookies may be persistent cookies. As described in the Using our websites, mobile applications and other technology section above, we and our service providers may also use cookie and other information to try to identify other devices and web browsers that you may use so we and our service providers may serve targeted advertisements to those devices. We do this to provide you with advertising that we believe may be relevant for you as well as improve our own products and services, including the functionality and performance of our websites and mobile applications. To learn more about opting out of certain types of targeted advertising, please see the Managing cookies and opting out section above.
Do-Not-Track: Currently, our systems do not recognize browser “do-not-track” signals. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions at the DAA and the Network Advertising Initiative websites.
In some jurisdictions, and where permitted by applicable law or with your consent, we may receive information about your location during the course of and for the purpose of providing you the services described above through your use of our websites and mobile applications. For example, if you are using our mobile applications and have consented to sharing your location information with us, this information might be collected through GPS or Bluetooth technologies to enable us to provide certain services to you such as customized offers and promotions. In addition to your use of our websites and mobile applications, we may also receive location information from wireless networks or cellular towers in proximity to your mobile device, through your Internet protocol (“IP”) address or through your use of other services we provide at our hotels. We may also have access to location information that you provide to us through your use of social media, such as when you “tweet” your location. We do not maintain this information as part of your IHG Rewards profile, and we typically use this information at the point in time at which you provide it to satisfy your request. Your location preferences can be set or modified at the device level or through modifying your settings with the relevant social media platform.
We receive information about you when you use our mobile applications. Some information such as your device manufacturer, type and operating system version, are collected automatically, while other information is only collected if you choose to provide it and where permitted by applicable law, such as your precise geolocation information. We do not typically associate your precise geolocation information obtained through your use of our mobile apps with your IHG Rewards Account. It may sometimes be necessary to associate your geolocation information with your account to support your participation in a particular program or feature that we may offer, but we do not otherwise retain your geolocation information in a way that identifies you as an individual.
If you use our mobile app, we also send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
We use mobile analytics software to allow us to better understand the functionality of our mobile applications on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
We may use information from online sources, such as websites, social media and information sharing platforms. This information may be used to help tailor and improve our services and communicate with you effectively, as we know many of our customers use a range of media channels to communicate and share information.
We may use various social media features such as the Facebook “Like” button on our websites and mobile applications. We collect certain information about you through your use of these features in conjunction with our services and programs. Subject to your account and privacy settings, we may also be able to see information that you post when using these social media platforms whether or not you are using one of our services. In some instances, depending on the circumstances, we may contact you on these social media platforms. The information you post on social media sites as well as the controls surrounding these disclosures are governed by the respective policies of the social media site.
Where we use information from these sources, we will respect any permissions you have set about how you would like your information to be used for each source. We do not associate the information that we collect through these platforms with your IHG Rewards account.
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms To learn more about opting out of certain types of targeted advertising, please see the Managing cookies and opting out section above.
When you use the IHG Connect WI-FI service (IHG Connect), we may collect and process certain additional information.
We use personal information only for the purposes described in this Privacy Statement, except if otherwise disclosed to you at the time the data is collected or otherwise authorized by law or by you. We use the personal information that we collect through IHG Connect:
Our goal is to create a personalized and customized experience for you when you stay at an IHG-branded property. In order to determine appropriate advertising and to customize your experience, as described in the section above in relation to cookies, we have relationships with companies such as Google and Facebook which enable us to serve targeted advertising. In addition to the activities described under the heading Targeted Advertising above, we also match Facebook and Google users across sites and devices which enables us to better understand your interests. We use this information to enable us to tailor our marketing communications to you so we can make sure we tell you about things which are most likely to be of interest to you. You have options about how we share your information; please log into the preference center at any time to view and exercise your choices. In addition, California residents have the option of clicking on the Do Not Sell link, which would eliminate the sharing that might constitute a sale under California’s law.
We are committed to protecting the confidentiality and security of the information that you provide to us. To do this, technical, physical and organizational security measures are put in place to protect against any unauthorized access, disclosure, damage or loss of your information. The collection, transmission and storage of information can never be guaranteed to be completely secure, however, we take steps to ensure that appropriate security safeguards are in place to protect your information.
We want to ensure that you have the necessary tools at your disposal to control the information that you provide to us, including how we communicate with you. It is also important that you contact us to update your information if any of it is inaccurate or changes. Please click the relevant section below to learn more about how to control how we communicate with you and how to update, modify and delete your information. EU Data Subjects, please see also the EU-specific section Californians, please see also the CA-specific section.
Through the provision of the services described above, we, and in some instances our IHG-branded Hotels, IHG Rewards Club partners, and service providers may communicate with you in relation to a reservation, as a member of any of our loyalty programs, through online digital services (e.g. online advertising, social media communications), or to support any other services that we provide.
In some instances, especially if you are a member of IHG® Rewards Club or an InterContinental Ambassador, you can go to your account, sign in and click on the “Communication Preferences” section to revise your communication preferences. IHG® Rewards Club members can also contact any of our IHG Rewards Club Service Centres. Additionally, the option to unsubscribe from marketing communications will be included within the communication itself. In all other cases, or if you are having difficulties with unsubscribing from any particular communication, please contact one of our global customer care offices or the IHG Privacy Office (details found in the How to contact us section).
Please be aware that unsubscribing from one type of communication may not unsubscribe you from another type. Likewise, unsubscribing from our communications may not mean that you are unsubscribed from certain communications carried out independently by our IHG-branded hotels.
In the event any information that you provide to us is inaccurate or changes, you can let us know by contacting one of our global customer care offices. In some instances, especially if you are an IHG® Rewards Club or InterContinental Ambassador member, you can update certain aspects of your personal information by going to your account, signing in and clicking on the “Personal Information” section to update and amend your personal information. For all other cases, please contact the IHG Privacy Office (details found in the How to contact us section). We will respond to your request within a reasonable timeframe.
Our websites and applications contain links to websites that are maintained and/or controlled by non-affiliated parties. In some instances these websites may be co-branded and display our logos or other trademarks. You can always tell whether you are on one of our websites by checking the uniform record locator ("URL”) on the page that you are visiting. We encourage you to review the privacy policies of these websites as their privacy practices may differ from ours.
Our websites are not intended for children and we do not intentionally solicit or collect personal information from individuals under the age of 18. If we are notified or otherwise discover that a minor’s personal information has been improperly collected, we will take all commercially reasonable steps to delete that information. In limited instances, we may have a campaign or program targeted toward children. In these instances, details on the information practices will be presented within the terms and conditions of the program or campaign.
We maintain a data retention policy which we apply to the records we hold.
For any questions or concerns regarding this Privacy Statement or our data privacy practices, please contact us:
InterContinental Hotels Group
Attn: Privacy Office
Three Ravinia Drive
Atlanta, Georgia 30346
InterContinental Hotels Group
Attn: Privacy Office
Denham, UB9 5HR, United Kingdom
You may also contact our Data Protection Officer by emailing [email protected].
To the extent permitted under the local law, you may also use the above contact details to request access to, correct, or (in certain circumstances) delete, any of your personal information that is held by IHG, or, where we have relied upon your consent to process your personal information, to withdraw your consent to such processing of your personal information. These requests will be reviewed and processed in line with the local law.
You also may have a right under the local law to lodge a complaint with us or with your local data protection supervisory authority at any time. However, we ask that you please try to resolve any issues with us first before referring your complaint to the supervisory authority.
EU data subjects have legal rights under EU data protection laws in relation to your personal information. Click on the links below to learn more about each right you may have. To exercise any of your rights please use the forms available in our Privacy and Cookie Center or contact our Data Protection Officer by emailing [email protected].
We may ask you for proof of identity when making a request to exercise any of these rights. We do this to make sure that we only disclose information where we know we are dealing with the right individual. We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will let you know if we think a response will take longer than one month. To help us respond more quickly, we may ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to do what you have asked, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.
Under the California Consumer Privacy Act (“CCPA”), we are required to notify California consumers about our collection, use, and disclosure of their personal information (whether collected through this website or offline). In this section of our Privacy Statement, 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.
This Privacy Statement does not apply to applicants for positions with IHG.
Categories of Personal Information that We Collect, Disclose, and Sell
Below we identify the categories of personal information that we collect about California consumers and households, the purposes for which we use each category, and whether we disclose or sell information within each category. Please note our data collection practices set forth below are not different than those described above; rather, the CCPA specifies particular categories of data that we must address, and, in this section, we aim to describe some of the information already provided above in accordance with the categories as outlined by the CCPA. This section should therefore be read in conjunction with the further information provided in the rest of this Privacy Statement.
Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation.
Collection. We collect:
Sources: We collect the information directly from you, from 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), from IHG-branded hotels (that are independently owned and operated). In limited circumstances, we may obtain this information from carefully selected travel partners, including airlines and rental car agencies. With regard to internet or other electronic information, we collect that information automatically as you use our Site and services.
Purposes of Collection: 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 use your information to fulfil your reservation, manage your IHG Rewards account, direct marketing to you (in connection with your preferences), targeted and personalized advertising to you, and as otherwise required by applicable law.
Disclosure: We disclose this information for business purposes, including at your direction, to IHG-branded properties (e.g., if you make a reservation through our central reservation department, then we share that information with the applicable property so that they can fulfil your request). We also share certain of your information to our carefully selected partners, including airlines and rental car agencies, for the purpose of personalizing your stay; for example, if we know that you are arriving early in the morning, we may seek to offer you an early check-in. If you use our WiFi services at IHG-branded properties, we share certain unique identifiers like your device’s MAC address with our internet service providers to provide WiFi to you.
Sale: We use third party targeted advertising companies that collect certain information about you through website cookies (and similar technologies designed for mobile applications). These third parties may collect information about you that they then aggregate with data collected about you through cookies placed on other websites/mobile apps. Under the CCPA, this type of sharing of information could be deemed a “sale”. We also disclose your information to carefully selected marketing partners, advertising technology vendors and social media platforms through a central marketing/analytics company. We direct which entities may have access to your information and the scope of information to which they may access. This type of disclosure only occurs in limited markets and California consumers may opt-out at any time through our communications portal and by clicking on the Do Not Sell link on our website/in the mobile app.
Collection: We do not request information about protected classifications under California law such as race, sex, age, religion, national origin, disability, citizenship information, or genetic information. Nonetheless, we may capture information related to these categories in the following circumstances, by way of example only: IHG corporate offices and certain IHG-branded hotels use closed circuit television for security purposes, and, the recordings may capture such information by virtue of the recording. We do not obtain recordings from the IHG-branded properties absent a unique situation (e.g., concern for security at a particular property). You have the option of providing your age range when you sign up for IHG rewards, but we do not require you to disclose that information. You have the option of requesting an accessible room.
Sources: We collect the information directly from you, from 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), from IHG-branded hotels (that are independently owned and operated). In limited circumstances, we may obtain this information from carefully selected travel partners, including airlines and rental car agencies.
Purposes of Collection: The primary purpose of our collection and use of this information is to enhance and personalize your stay with us, in particular, to provide you with the specific room type requested. We may use video surveillance for security purposes and to protect their rights and interests as well as the rights and interests of other guests.
Disclosure: We disclose any information about special requests for business purposes, including at your direction, to IHG-branded properties (e.g., if you make a reservation through our central reservation department, then we share that information with the applicable property so that they can fulfil your request). If we obtain CCTV footage, we do not disclose such data except as necessary to protect our rights and interests and the rights and interests of other persons.
Sale: We do not sell this information.
Information Collected: In an effort to enhance your stay with us and to provide for a faster and easier check-in process, we may offer certain services on property such as check-in and/or room entry through the use of biometric identifiers at a limited number of IHG-branded properties. Any interested guest must affirmatively opt-into the program; Where IHG is providing these services we will provide information about the specific biometrics collected through the program and the use and disclosure of those identifiers so that you can choose whether you would like to participate in any particular program. With your consent, we collect your geolocation information through our mobile application and our website or from internet service providers through certain services we offer on property such as IHG Connect (WiFi). We use this information for analytics purposes (e.g., to determine the general area where our guests may access our services from), to personalize your experience (e.g., suggest hotels of interest), and, in certain limited markets, to provide special offers based on your location.
Sources: We collect biometric information and geolocation information directly from you and automatically as you use devices designed to collect biometric information or, in the case of geolocation information, your own device.
Purposes of Collection: The primary purpose of our collection and use of this information is to enhance and personalize your stay with us. In particular, we use your information to create a faster check-in and/or room entry experience. With regard to geolocation information, we also seek to offer you relevant offers based on your location, where permitted.
Disclosure: Where this service is offered, we may disclose your biometric information to service providers that assist us in validating your identity. We may make available your biometric identifier to the IHG-branded property where you are staying for the purposes of that particular stay.
Sale: We do not sell your biometric information.
We may draw (or use service providers to draw) inferences from any of the information identified above to create or enhance a profile about a consumer reflecting the consumer’s preferences and tendencies (e.g., what types of properties the consumer prefers, how frequently the consumer travels, etc.). We may purchase aggregated and deidentified data and append such data to your profile (e.g., based on your age range) to assist us in determining relevant marketing opportunities.
Sources: We draw inferences based on the data collection described in this Notice.
Purposes of Collection: We use inferences to enhance your overall experience with IHG. For example, we may use inferences to identify and to offer relevant marketing opportunities.
Disclosure: We may disclose your information to carefully selected marketing partners, advertising technology vendors and social media platforms to provide relevant offers to you.
California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.
Do-Not-Sell. California consumers have the right to opt-out of our sale of their personal information. We do not knowingly collect personal information about consumers that are younger than 18 years nor do we have actual knowledge that we sell personal information about consumers that we know are younger than 18 years old. To exercise your opt-out rights, please visit our Do-Not-Sell page. You may also submit a do-not-sell request by clicking on the link in the footer of this website, or by contacting the Privacy Office. If you use an authorized agent to submit a do-not-sell request, we will ask your agent to provide information to demonstrate the agent has your authorized consent to submit a request. Proof of authorization evidenced by your signed permission should be submitted to [email protected]. We may also ask you to provide information to verify your identity directly with us.
Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see Submitting Requests for instructions about how to exercise your rights:
Deletion: the right to request deletion of their personal information that we have collected about you, subject to certain exemptions.
Copy: the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months.
Right to Know (Collection): where we have collected their personal information, the right to request that we disclose certain information about how we have handled their personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling their personal information; and the categories of third parties/with whom we have disclosed or shared their personal information.
Right to Know (Disclosure and Sale): where we have sold or disclosed for a business purpose their personal information, the right to request that we disclose certain information about how we have handled their personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom the consumer’s personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories personal information that we have disclosed or shared with a third party for a business purpose.
Submitting Requests. You can exercise your rights by visiting our Privacy and Cookie Center, by contacting us at 1 877 424 2449 (toll free). We will respond to your Copy, Delete and Right to Know requests within 45 days, unless additional time is needed, in which case we will let you know.
When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you are an IHG® Rewards Club member, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request where we are satisfied that we have verified your identity to a reasonable degree of certainty.
Authorized Agents. The CCPA allows California 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 demonstrate the agent has your authorized consent to submit a request. Proof of authorization evidenced by your signed permission should be submitted to [email protected]. We may also ask you to provide information to verify your identity directly with us.
Incentives and Discrimination.The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information.
Discrimination: if consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data.
Disclosure of Incentives: if businesses offer any financial incentives for the collection, sale or deletion of their personal information, consumers have the rights to be notified of any financial incentives offers and their material terms, as well as to not be opted into such offers without prior informed opt-in consent and to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We currently do not offer incentives.
Metrics on California Consumer Rights Handling
Metrics, such as the number of requests we received, complied with, denied, and the median or mean number of days within which we substantively responded to requests, where required for the previous calendar year, will be published here.
Your California Privacy Rights under California’s Shine-the-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to [email protected] In your request, please attest to the fact that you are a California resident and provide a current California address.
If you have questions about our privacy practices, would like to make a complaint, or to request a printable version of this Privacy Statement, please contact us at [email protected]. This California privacy notice is effective from January 1, 2020 and was last updated on July 22, 2020.
In some instances, we may have to change, modify or amend this Privacy Statement in order to comply with the evolving regulatory environment or the needs of our business. Subject to any applicable legal requirements to provide additional notice, any changes to this Privacy Statement will be communicated through our websites and mobile applications. However, if there will be changes made to the use of your personal information in a manner different from that stated at the time of collection we will take appropriate steps to notify you, such as by posting a notice on our website for 30 days prior to the changes taking effect or by emailing you. We will obtain your consent to such changes where required to do so by applicable law.
Effective Date: July 22, 2020