Last Updated: March 4, 2022
I. INTRODUCTION
This Privacy Notice describes the information ESA Management, LLC and ESH Hospitality Strategies, LLC and its subsidiaries (collectively, “ESH”) collect about you, how it is shared, your rights and choices with regard to your personal information, and how we secure your information. This Privacy Notice applies to personal information collected by or on behalf of ESH (“we,” “us”), including information collected at our hotels, our websites at www.extendedstayamerica.com and other websites offered by us including mobile versions of those sites that link to this Privacy Notice (collectively, the “Site”), our social media pages, our mobile application and other software applications that we offer for use on or through computers and mobile devices that reference or link to this Privacy Notice (each an “App”), by email, by phone or other offline method, or anywhere else we display this Privacy Notice (collectively, the “Services”, and the users of our Services, the “Users”). This Privacy Notice also applies to the personal information about you that we receive from a third party, including Franchised Hotels (defined below), unless specifically covered by such third party’s privacy notice.
By staying at one of our properties or by accessing or using the Services, you are acknowledging that you have read and understand this Privacy Notice and agree to the terms in effect at the time of your use. If you do not agree with or consent to the terms of this Privacy Notice, please refrain from using or engaging with the Services, or if you are already using the Services, please immediately discontinue your use of the Services.
Certain hotels are franchised under the Extended Stay America® family of brands (“Franchised Hotels”). We do not own or operate these hotels, and we do not control the collection, use, or access of your information by Franchised Hotels and their staff. Franchised Hotels collect and process credit card information and receive payment for your stay, and the rules of their credit card processors will govern the security of your payment information.
For purposes of this Privacy Notice, “personal information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that has been aggregated, de-identified, anonymized, or made publicly available in accordance with applicable law.
II. HOW WE COLLECT, USE AND SHARE PERSONAL INFORMATION
We may collect personal information from hotel guests or visitors (“Hotel Guests”) and Users in different ways and for different purposes. For example, if you are a Hotel Guest, we may collect personal information from you to process a reservation in our network of hotels or if you elect to participate in our hotel rewards program. If you are a User, we may collect personal information from you if you visit our Site, create an account with us through the Services, or send us a message through the Services.
We collect personal information in the following ways: 1) information you provide to us when you use the Services or visit our hotels, and 2) information collected automatically when you interact with the Site, App or certain features of our hotels. The tables below describe the categories of personal information we may collect about you or may have collected about you in the last twelve months, the sources from which we collect that personal information, the purposes for which we may use that information, and the third parties with whom we may share that information. It is important to note that the types of personal information we collect will depend on your interaction with the Services, including whether you are a Hotel Guest or a User and the types of Services that you use.
A. Personal Information Collected from Our Hotel Guests
Categories of Personal Information Collected |
In addition to those listed above, we may also collect the following categories of information from Users:
|
Sources of Information |
|
Uses of Information |
We may use information collected about Hotel Guests and Users for our business and commercial purposes, including to:
|
Sharing Information |
Except as described in the Privacy Notice, we do not share your information outside our corporate family of companies without your consent. We may share your information with:
There may also be times when we share aggregate information (that does not individually identify any particular person) with advertisers, business partners, subsidiary companies, affiliated companies, parent corporations, sponsors, joint venture partners and other third parties in an effort to customize or enhance the content and advertising of the Site for future users or to improve our marketing and promotional efforts.
|
B. Additional Information Regarding the Categories of Personal Information Collected
The following provides more details regarding some of the categories of personal information described in the tables above:
For more information about interest-based advertising and cross-device linking, please visit the Adobe Target website. You may opt out of interest-based advertising and cross-device linking in web browsers and mobile apps on your current browser or device by following the instructions below.
To opt out in web browsers using Adobe's opt-out tool, please visit: https://hvmllc.tt.omtrdc.net/optout
To opt out of advertising on your browser by third parties that participate in self-regulatory programs, visit the Network Advertising Initiative at https://www.networkadvertising.org/understanding-online-advertising/what-are-my-options, and/or the Digital Advertising Alliance’s consumer choice tool at https://optout.aboutads.info/?c=2&lang=EN
Please note that Adobe Target is the primary site personalization tool for the Site and disabling Adobe Target could mean you will be unable to access certain content on the Site or use all features. Please further note that each of the opt-out options described above will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile advertising identifiers, change browsers (including upgrading certain browsers), or use a different device, any opt-out cookie or tool may no longer work, and you will need to opt out again.
Some browsers have a Do-Not-Track (“DNT”) feature that lets you tell websites that you do not want to have your online activities tracked. When you choose to turn on the DNT setting in your browser, your browser sends a signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity via cookies or other tracking technologies. Please note that the Site does not currently respond to browser-based DNT signals. For information regarding DNT and how to enable this setting, if available on your devices, click here.
C. Additional Information Regarding Information Collected from Franchisees
Franchised Hotels are independently owned and operated. Your personal information collected or maintained directly by Franchised Hotels is not subject to this Privacy Notice, unless such information has been shared with us, in which case this Privacy Notice only covers our collection, use, and maintenance of your personal information. If you book a reservation directly with a hotel and that hotel utilizes our property management system, your personal information related to that reservation will be transmitted to and processed by us.
We may disclose your personal information and other information we collect to the owners, managers and operators of Franchised Hotels and owners of hotels that we manage (but do not own) that require access to your personal information for our business purposes and required to provide you with requested Services.
III. LINKS TO OTHER SITES
The Site and App may contain links to websites or platforms owned or controlled by other companies, such as Facebook, Instagram, LinkedIn, Twitter and YouTube. We are only responsible for our Site and App or Services that link to this Privacy Notice. We have no control over and are not responsible for the data collection and use practices and privacy policies on third-party websites that you may access from our Site or App. We do not guarantee the quality, content or availability of any third-party website to which a link may be provided. Any links are made available to you as a convenience, and you agree to use the links at your own risk. We encourage our users to be aware when they leave our Services and to read the privacy statements of any other site that collects personal information.
IV. CHILDREN’S PERSONAL INFORMATION
WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 18 TO PARTICIPATE IN OUR SERVICES WITHOUT A PARENT OR GUARDIAN PRESENT. YOU MUST BE AT LEAST 18 YEARS OLD OR THE APPLICABLE AGE OF MAJORITY TO USE OUR SERVICE. PLEASE REVIEW THIS PRIVACY NOTICE WITH YOUR PARENT OR GUARDIAN IF YOU ARE UNDER 18. Please understand that we cannot necessarily tell if a user is providing us with his or her true age. If we become aware that we have unknowingly collected personal information from a child under the age of 18, we will make reasonable efforts to delete such information from our records right away. If a child has directly provided us with personal information, a parent or guardian of that child may contact us to have the information deleted from our records. To do so, contact us through the information provided below in the “Contact Us” section.
V. USERS OUTSIDE THE U.S.
We are headquartered in the United States and the Services are intended for Users in the United States. If you are located outside the United States, be advised that any information you provide to us will be transferred to and stored in the United States and to our service providers who may be located in other jurisdictions around the world, and that, by submitting information to us, you explicitly authorize its transfer and storage within the United States and other jurisdictions where the privacy laws may not be the same as the country in which you are located. We will protect the privacy and security of personal information according to this Privacy Notice regardless of where it is processed or stored. Do not provide us with personal information if you do not want your personal information to be transferred to the United States or to other jurisdictions, or if the laws in your country restrict these types of transfers.
VI. SECURITY
We use security safeguards and controls designed to protect your information from unauthorized access or use. Unfortunately, the transmission of information over the Internet is not completely secure. Therefore, we cannot guarantee the security of your personal information transmitted to the Services and any transmission is at your own risk. Once we have received your personal information, we will use reasonable efforts to implement procedures and security features to help prevent unauthorized access. However, due to the nature of evolving technologies, we cannot provide, and expressly disclaim, any assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
VII. YOUR RIGHTS AND CHOICES
You have certain rights and choices with regard to personal information we collect, including the right to:
Update Your Contact Information:
Enable / Disable App Location Tracking:
Promotional Emails:
VIII. NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with certain rights with regard to their personal information. This section explains those rights.
A. Collection of Personal Information
For details on the personal information (as defined by the CCPA) we collected about California residents in the last 12 months, the sources of that information, our business or commercial purposes for collecting that information, and the third parties with whom we shared that information, please refer to Section II. of our Privacy Notice – INFORMATION WE COLLECT AND HOW WE COLLECT, USE AND SHARE PERSONAL INFORMATION.
B. Your Rights
If you are a California resident, you have certain rights with regard to your personal information, pursuant to the CCPA. Those rights may only apply in certain circumstances and may be subject to certain exemptions. Please see the information below for a summary of your rights and how to exercise them. Please note that we may require certain identifying information about you as necessary for us to verify the request in accordance with applicable law.
We will not discriminate against any California resident who exercises any of the rights described above. Specifically, except as permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates, including through granting discounts or other benefits, or imposing penalties; provide you with a different level of service or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
C. How to Submit a Request
If you are a California resident and would like to exercise any of the CCPA rights identified above, you may submit a request by either clicking the link below or calling 877.651.2124 to speak to an ESH representative.
Click here to submit a privacy request through Privily.io.
D. Submitting a Request through Your Authorized Agent
If you are a California resident, you may exercise these rights yourself or have the option to designate an authorized agent to submit a request on your behalf. If you would like an authorized agent to submit a request on your behalf, please contact us using the methods in subsection C above for instructions and details on proof and information required for use of an authorized agent. We may need to also contact you directly to verify the request.
E. Disclosure of Personal Information
F. Notice of Financial Incentive
Our Extended Perks Discount Program (“Extended Perks”) collects personal information to facilitate its operations and provide you with discounts, offers and deals, including Contact Information and Stay Preferences (as defined in Section II.A). You can opt-out of non-Extended Perks marketing emails, or delete your personal information from our active marketing lists and retain your Extended Perks account and benefits. Participating in Extended Perks is entirely optional, but is subject to its terms and conditions. You must opt-in by signing up for an Extended Perks account. California consumers may make a personal information deletion request under the CCPA, but will maintain their Extended Perks account because such deletion requests will not terminate participation in Extended Perks. You may, however, terminate Extended Perks participation at any time by contacting us at dataprivacy@extendedstay.com to delete your account. Upon a termination request, some Extended Perks data associated with the terminated account may be retained for record keeping and other legally permissible purposes. For CCPA purposes, we treat the value of any personal information collected as the equivalent of relevant expenses related to the collection and retention of consumers’ personal information as part of Extended Perks, the details of which we maintain as a trade secret. We pay these expenses and provide the Extended Perks benefits to foster a positive relationship with our members that is invaluable.
G. Third-Party Marketing Disclosure
Under California Civil Code § 1798.83, California residents with whom we have a business relationship can request information about the types of personal information, if any, we shared with third parties for the direct marketing purposes of the third parties and the identities of the third parties with whom we shared such information in the last 12 months. You may request more information by emailing us at dataprivacy@extendedstay.com or using the contact information at the bottom of this Privacy Notice.
IX. UPDATES TO THIS PRIVACY NOTICE
We may modify this Privacy Notice from time to time. When we make material changes to this Privacy Notice, we will post a link to the revised Privacy Notice on the homepage of our site. You can tell when this Privacy Notice was last updated by looking at the date at the top of the Privacy Notice. Any changes to our Privacy Notice will become effective upon posting of the revised Privacy Notice on the Services. Use of the Services, any of our products and services, and/or providing consent to the updated Privacy Notice following such changes constitutes your acceptance of the revised Privacy Notice then in effect.
X. CONTACT US
For questions or comments regarding this Privacy Notice, including to exercise your rights, please contact our guest services at 877.651.2124 or you may write our Privacy Officer at 11525 North Community House Road, Ste. 100, Charlotte, NC 28277 or dataprivacy@extendedstay.com.