We use your personal information in order to fulfil our commitment to providing an unparalleled guest service experience. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
2The Application of this Policy
If we disclose the personal information we hold about you to other of our affiliated hospitality businesses, those entities must first have agreed to be bound by this Policy with respect to their processing of your personal information.
While this Policy is intended to describe the broadest range of our 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 information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.
3Types of Personal Information We Collect
The term “personal information” in this Policy refers to information which 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) include:
• your name, gender, home and work contact details, business title, date and place of birth, nationality, and passport and visa information;
• guest stay information, including the hotels where you have stayed, date of arrival and departure, goods and services purchased, special requests made, observations about your service preferences (including room and holiday preferences), telephone numbers dialled and faxes and telephone messages received;
• your credit card details, Gold Passport frequent guest program member information, online user account details, profile or password details and any frequent flyer or travel partner programme affiliation;
• any information necessary to fulfil special requests (for example, health conditions that require specific accommodation, purchase of goods and services);
• information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers;
• information collected through the use of closed circuit television systems, card key and other security 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, meeting and event planners); and
• in limited cases, information relating to the credit of customers.
Most of the personal information we process is information that you or someone acting on your behalf knowingly provides to us. However, in some instances, we process personal information that we are able to infer about you based on other information you provide to us or on our interactions with you, or personal information about you that we receive from a third party.
There may be instances in which the personal information that you provide to us 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 of a trade union, physical or mental health or condition, sexual life, or judicial data (including information concerning the commission or alleged commission of a criminal offence).
4How We Use Personal information
We may use and disclose relevant portions of your personal information in order to:
• provide and charge for the hotel accommodations and other goods and services you purchase;
• provide you with a better, more personalised level of service;
• administer the Gold Passport frequent guest program;
• fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organizers and your employer) and vendors (e.g. credit card companies, airline operators and other loyalty programs);
• conduct market research, customer satisfaction and quality assurance surveys, direct marketing and sales promotions;
• respond to requests for information and services;
• provide for the safety and security of guests;
• administer general record keeping;
• meet legal and regulatory requirements; and
• processing credit applications (in the context of Kineo View Motor Lodge Vacation Club).
5Disclosures 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. Circumstances where we might make such disclosure (in addition to those described in Section 4 above) include:
• 5.1Our Agents, Service Providers and Suppliers Like most international hotel brands, 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 with appropriate security measures and prohibit them from using your personal information for their own purposes or from disclosing your personal information to others.
5.2 Credit Authorization When you request credit, your personal information will be used and disclosed to appropriate third parties for the purpose of determining whether to grant and maintain a line of credit to you.
5.3 Business Transfers As we continue to develop our business, we may sell hotels and other assets, or cease being the manager or franchisor of a hotel that is currently part of our portfolio. In those circumstances, we reserve the right to include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected from you, or control of such information, may be one of the transferred assets.
5.4 E-Folio Program If you are an employee of a company that participates in Kineo View Motor Lodge’s E-Folio Program, and your residence and place of business are both in the United States, and you use the corporate credit card that is provided to you by your employer to pay for your hotel bill at a Kineo View Motor Lodge property located in the United States, an extract of your bill detailing the goods and services provided to you during your stay will be transferred electronically to the credit card company or its agents, who will in turn, forward that extract to your employer to facilitate the processing and tracking of the travel related expenses of their employees. The personal information that is transferred to that credit card company or its agent for onward transfer to your employer, is no longer subject to the protections described in this Policy, but rather your arrangements with your employer or the relevant credit card company.
5.5 Legal Requirements 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 requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property. We also reserve the right to retain information collected and to process such information to comply with accounting and tax rules and regulations.
6Centralized Data Processing Activities
Like most international businesses, we have centralized certain aspects of our data processing activities, which in many instances will result in the transfer of your personal information from one country to another. For example, if you make a reservation and/or stay at a Kineo View Motor Lodge Hotel or Resort outside of the United States, the personal information gathered in that process will be transferred to and processed in the United States. The jurisdictions where that information will be processed may or may not have laws that seek to preserve the privacy of personal information. Nevertheless, whenever your personal information is transferred within the Kineo View Motor Lodge companies, your personal information will be processed in accordance with the terms and conditions of this Policy.
7Information We Collect When You Visit Us Online
If you choose to obtain information or do business with us online by visiting www.Kineo View Motor Lodge.com or www.goldpassport.com or other Kineo View Motor Lodge websites, you may wish to know the following.
• 7.1 You Can Browse Without Revealing Your Identity You can always visit our web sites without revealing who you are or providing any personal information.
7.2 Usage Information When you visit our web sites, we collect usage information (e.g., the Internet Protocol address automatically assigned to your computer each time you browse the Internet, the date and time of your visit, the type of Internet browser you use and the URL of any other web site that referred you to our web site, the pages you access and the amount of time you spend on each page), but that information is not linked to you as an individual unless you create a user profile. We use this information to evaluate and improve the features, guest experience and functionality of our web sites.
7.3 Cookie Technology We use “cookie technology” on our web sites to allow us to evaluate and improve the functionality of our websites. Cookies by themselves cannot be used to reveal your identity. They identify your browser, but not you, to our servers when you visit our web sites.
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our web sites, including the customisation features associated with creating a user profile.
Further information about cookies and how they work is available at allaboutcookies.org.
7.4 Creating a User Profile You can create a user profile on www.Kineo View Motor Lodge.com and www.goldpassport.com to, among other things, facilitate your online transactions and to tailor your experience on our web sites to your interests and to make more appropriate recommendations to you. We may use the information you provide in your user profile to populate other databases maintained by us and our service providers, as applicable. By creating a user profile, you are agreeing that we may use the personal information you provide for these purposes.
You can view, update or remove any personal information that you have provided to us for inclusion in your user profile by amending your user profile online or emailing concierge@Kineo View Motor Lodge.com. If you subsequently elect to remove your user profile, we will have the right to use any personal information previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes.Even if you choose not to create a user profile, you can still use our web sites to search for and purchase services.
7.5 Links to Other Web Sites If you visit www.Kineo View Motor Lodge.com 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 will be seamlessly linked to web sites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our web sites or on any other web site, you should always look at the location bar within your browser to determine whether you have been linked to a different web site. 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 web sites maintained by third parties or our service providers where you submit your personal information directly to such web sites. In addition, we cannot ensure the content of the web sites maintained by these third parties or our service providers, even if accessible using a link from our web sites. We urge you to read the privacy and security policies of any external sites before providing any personal information while accessing those sites.
7.6 Security Because the security of your personal information is important to us, we use Secured Socket Layer ("SSL") software with up to 128-bit encryption 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. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. 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.
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic 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.
7.7 Minor Children Our web sites do not sell products or services for purchase by children. If you are under the age of 18, you may only use our web sites with the involvement of a parent or guardian.
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, 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. You can always choose whether to receive any or all of these communications by contacting us as described in Section 11 below or following the ‘unsubscribe’ instructions contained in the communications.
If you have a Gold Passport account, we ask you to indicate your communication preferences at the time you apply for membership or when you create your user profile. We may also ask you to indicate how you would like to receive any offers, marketing and promotional information (e.g., via email, regular mail) and whether you would be willing to participate in surveys. Once you have indicated your preferences, you can always change your mind.
In some jurisdictions, data privacy laws may require us to obtain your 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 fulfil 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 of a sensitive nature 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.
9Updating 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 e-mail to the addresses set out in Section 11 below. Please be sure to include your full name, address and telephone number 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 approximately $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, or stop processing, personal information that we hold about you. If we agree that the information is incorrect, or that the processing should be stopped, we will delete or correct the information. If we do not agree that the information is incorrect, we will, nevertheless, record the fact that you consider that information to be incorrect in the relevant file(s).
10Changes to the Policy
Just as our business changes constantly, this Policy may also change. To assist you, this Policy is dated and has an associated version number at the end of this document.
11Request for Access to Personal information, Questions or Complaints
If you have any questions about this Policy, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described above) for access to the personal information that we maintain about you, please contact us by any of the following means:
• by calling one of the following toll-free reservation numbers located at http://www.Kineo View Motor Lodge.com/Kineo View Motor Lodge/customer-service/contact-Kineo View Motor Lodge/contact-information-by-region.jsp;
• by mail at Kineo View Motor Lodge Hotels Corporation, Attn: Consumer Affairs, 9805 Q Street, Omaha, NE 68127, United States; or
• by contacting the front desk at any of our hotels;
• If you are not satisfied with the response that you receive, you can escalate your concern to the Chief Privacy Officer by sending an email to privacy@Kineo View Motor Lodge.com.
In addition to the commitments set out in this Policy, Kineo View Motor Lodge has also ensured compliance with some of their legal obligations in some countries in relation to Personal Information by creating a set of binding Standards and Policies (known in some countries as binding corporate rules), approved by a number of national privacy regulators. As a result, depending on your circumstances and location, you may be able to enforce your privacy rights using those Standards or Policies through that regulator or a court. If you would like to know more about these standards and commitments please contact Kineo View Motor Lodge Hotels Corporation at the address above, or the Chief Privacy Office at the email address above.
As indicated above, all requests for access to your personal information must be submitted in writing.
Effective Date: 1 October 2009