This Policy applies to all Personal Information, as defined below, regarding guests and the other individuals with whom we do business or who visit us and to the use of that personal information in any form – whether oral, electronic or written.
This Policy gives effect to our commitment to protect your personal information and has been adopted by all of the separate and distinct legal entities that manage, operate, franchise, license, own and/or provide services to the various Locale properties around the world. References to “Locale”, “we” and “our”throughout this Policy, depending upon the context, collectively refer to those separate and distinct legal entities.
While this Policy is intended to describe the broadest range of our personal information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that personal information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of the applicable law.
There are three general categories of information Locale collects. The term “personal information” in this Policy refers to information that does or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) may or may not include:
your name, gender, personal and work contact details, business title, date and place of birth, image, nationality, and passport and visa information;
your financial information (like your bank account or credit card information) when you use the payment services to process payments.
guest stay information, including the hotels where you have stayed, dates of arrival and departure, goods and services utilized, special requests made, observations about your service preferences (including room and vacation preferences), telephone numbers dialed and faxes, texts and telephone messages received;
any information necessary to fulfill special requests (e.g., health conditions that require specific accommodation or services)
information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites or apps and those of third parties;
information collected while at a Locale property through the use of closed circuit television systems, internet systems (including wireless networks that collect data about your computer, smart or mobile device, or your location), card key and other security and technology systems;
contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents or meeting and event planners); and
in limited cases, information relating to the credit of customers
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries. Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life or judicial data (including information concerning the commission or alleged commission of a criminal offense). In some very rare instances, financial records may form part of Sensitive Personal Information where you are located. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.
When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to Locale that is considered to be Sensitive Personal Information or financial information. Except to the extent required by law, you are not obliged to provide Locale with any of your Sensitive Personal Information, and should you chose not to, this will not prevent you from purchasing any products or services from Locale.
How We Use Personal Information
Subject to applicable laws, we may collect, use and disclose relevant portions of your personal information in order to:
provide and charge for accommodation and other goods and services;
provide you with a better or more personalized level of service, including information and services from a third party (such as additional guest services at Locale properties, local attractions and transportation options);
respond to requests for information and services, including services from a third party (such as restaurants or transportation providers);
administer a frequent guest program;
fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers or your employer) and vendors (e.g., credit card companies, airline operators and third party loyalty programs);
conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions;
provide for the safety and security of staff, guests and other visitors;
administer general record keeping;
meet legal and regulatory requirements; and
test and evaluate new products and services.
Locale uses and retains your personal information for as long as is necessary to fulfill the Purpose.
Disclosure of your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries.
WHEN YOU AGREE TO THIS POLICY, YOU ARE, TO THE EXTENT REQUIRED AND PERMITTED UNDER YOUR LOCAL LAW, GRANTING YOUR CONSENT TO THE TRANSFER OF YOUR PERSONAL INFORMATION TO SUCH OTHER COUNTRIES FOR THE PURPOSE AND TO THE EXTENT STATED IN THIS SECTION AND AS DESCRIBED IN THE “HOW WE USE PERSONAL INFORMATION” SECTION ABOVE.
Circumstances where we might make such disclosure (in addition to those described in “How We Use Your Personal Information” above) include:
Our Agents, Service Providers and Suppliers
Like many other international accommodation providers, we may outsource the processing of certain functions and/or information to third parties. We may also engage market research firms to assist us in contacting guests for the purpose of market research and quality assurance. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.
To the extent we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under the “Contacting Us/Questions or Requests for Access to Personal Information” section below.
Legal Requirements; Compliance with Laws and Law Enforcement
Locale cooperates with government, law enforcement officials, and private parties to enforce and comply with the law. We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity. We may also disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to comply with the law, to protect the property and rights of Locale or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.
With your consent, we may post your testimonial on an Locale website along with your name. If you want your testimonial removed, please contact us at firstname.lastname@example.org
Aggregate Information and Non-Identifying Information
We may share aggregated information that does not include personal information and we may otherwise disclose non-identifying information and log data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your personal information.
Information We May Collect When You Visit Us Online
If you access any Locale website, you may wish to know the following:
You Can Browse Without Revealing Who You Are
You can always visit our websites without logging in or otherwise revealing who you are.
When you visit our websites, we collect information about how you use those websites. Examples of such information include the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of Internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website.
Our websites may also contain plug-ins and other features that integrate third party social media platforms into our websites. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
Links to Other Websites
From time to time, Locale may partner with third parties to offer services to and with our guests; Locale may also partner with third parties for non-guest-related services to expand the range of services we can offer our guests. If you visit an Locale website and decide, for example, to purchase a gift certificate, make an airline reservation, rent a car, submit award request forms or apply for a job online, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website.
To enhance your experience, Locale may provide a tablet, smart device, or other internet-enabled device for use while at an Locale property. Locale may not limit the content that accessible via these devices, and the website content you consume while using such a provided device may be subject to other privacy policies that are beyond the scope of this Policy.
This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.
Locale is very concerned with safeguarding your information. Because the security of your personal information is important to us, we use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to us online will be encrypted. When you enter sensitive information (such as a credit card number) on payment page, we encrypt that information using secure socket layer technology (SSL). (You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission.) We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on the Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system so that you can take the appropriate actions for the due protection of your rights.
Our websites do not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our websites with the involvement of a parent or guardian.
Re-marketing and Targeted Advertising
As you browse the Locale site, advertising cookies will be placed on your computer so that we can understand which type of content you are interested in. Our display advertising partners, AdRoll and Google, then enable us to present you with retargeting advertising on other sites based on your previous interaction with our site. The techniques our partners employ do not collect personal information such as your name, email address, postal address or telephone number.
Where permitted by law, we may work with other companies to show you advertisements we think you may find relevant and useful. This may include advertisements displayed on our own websites or apps, or advertisements from us displayed on other companies' websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our websites or third-party websites.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
If you provide us with your contact details (e.g., postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. We may also share your personal information with carefully-selected third parties, who may communicate directly with you. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described below or following the “unsubscribe” instructions contained in the communications.
In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g., where communications are required in order to fulfill your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g., where the information collected is regarded to be Sensitive Personal Information under local regulations).
We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be suppressed rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
Updating or Accessing Your Personal Information
With some limited exceptions, you have rights to access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by sending us a written request by letter or email to the addresses set out in the “Contacting Us” section below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information we may require to make that determination.
We reserve the right to charge you a fee, if permitted under applicable law, which is usually around US$20 for processing any such request. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.
You may request that we correct, cancel, and/or stop processing or using personal information that we hold about you. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal information to be incorrect in the relevant file(s).
Contacting Us/Questions or Requests for Access to Personal Information
If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request at:
by sending an email to: email@example.com
by calling us at: +1 512 580 7606
Address: 2400 E Cesar Chavez Ste 208, Austin, TX 78702
All requests for access to your personal information must be submitted in writing by letter or email and must include a copy of a document evidencing your identity (such as an ID card or passport). We may respond to your request by letter, email, telephone or any other suitable method.
Changes to this Policy
Effective Date: May 8, 2018
In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail.