Last Updated: January 20, 2023
Effective Date: January 20, 2023
This Privacy Notice describes the information ESA Management, LLC and ESH Hospitality Strategies, LLC and its subsidiaries (collectively, “ESH,” “we,” “us,” or “our”) collect about you, how it is used and shared, and your rights and choices with regard to personal information. This Privacy Notice applies to personal information collected by or on behalf of ESH, including information collected at our hotels, our websites at www.extendedstayamerica.com and other websites offered by us (collectively, the “Site”), our social media pages, our mobile application and other software applications that we offer (each an “App”), by email, by phone or other offline method, or anywhere else we link to this Privacy Notice (collectively, 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 your personal information collected or maintained directly by Franchised Hotels is not subject to this Privacy Notice.
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
A. Information Collection
When accessing our Services, we may collect information about you, including your name, contact information, access credentials, stay preferences, Driver’s license or government ID, health information, and any other information you choose to provide. For example, we may collect this information from you when you make a reservation in our network of hotels, participate in our hotel rewards program, create an account with us, leave a review, contact us, or interact with us for any other purpose. We may also collect your payment information, such as billing address or credit card information, when you make a reservation or otherwise place an order with us.
B. Source of Information
We collect personal information from a number of sources, including the following:
C. Information Use
We may use information collected about you for our business and commercial purposes, including to:
D. Information Sharing
We may share information we collect with third parties, including the following:
We may share aggregate or deidentify information without limitation.
Please note California law gives consumers the right to opt out of “sales” or “sharing” of Personal Information, as those terms are defined by California law. This right applies even though ESH does not currently “sell” or “share” Personal Information. You are welcome to submit a request to ESH to opt-out of future “sales” or “sharing”. If we ever start “selling” or “sharing” Personal Information, we will honor your request and exclude your information.
E. Information Retention
We retain personal information that we collect for as long as we need to use it in connection with our business and in accordance with our standard practices or in compliance with applicable laws. When we no longer need the personal information, we will deidentify, aggregate, or delete this information where required by law.
III. DIGITAL ANALYTICS & ADVERTISING
We also partner with third parties who provide advertising services that are based on your online activities across websites, mobile apps, and devices over time (commonly referred to as “interest-based advertising”). Our advertising partners may collect information about your activities on our Services on your current device and combine it with information about your activities on other websites, mobile apps, and devices.
For more information about interest-based advertising and how to opt out of interest-based advertising on websites 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 at youradchoices.com. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. You may opt out of interest-based advertising through Adobe Target by visiting https://hvmllc.tt.omtrdc.net/optout.
Please note that electing to opt out will not stop advertising from appearing in your browsers or applications. It may make the ads you see less relevant to your interests.
IV. 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 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 encourage our users to be aware when they leave our Services and to read the privacy statements of any other sites that collect personal information.
V. EEA AND UK RESIDENTS
This section applies to residents of the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”).
A. Lawful Basis for Processing
We may collect and process personal information about you where the laws of your jurisdiction permit it. We may rely on the following legal bases to process personal information about you:
B. Transfers outside of the EEA or UK
Personal information may be transferred to the United States and to service providers in countries outside the EEA or UK and may be stored and processed manually and electronically through global systems and tools for the purposes outlined above.
When transferring personal information to countries outside the EEA or the UK, we are required to ensure personal information about you is adequately protected in the country where it is transferred. We transfer personal information to these countries only when it is subject to safeguards that assure the protection of personal information, such as entering contracts with transferee companies called the “standard contractual clauses” and the “UK addendum,” which require companies outside the EEA or UK to protect your personal information to the same extent as if it had remained in the EEA or UK.
C. Your Rights
See Section VII (“Your Rights and Choices”) of this Privacy Notice below for more information regarding rights that may be available to you.
VI. STATE PRIVACY NOTICE
California, Colorado, Connecticut, Utah, and Virginia residents have certain rights with regard to their personal information. If you are a resident of one of these states, this section of the Privacy Notice contains disclosures required by law. See Section VII (“Your Rights and Choices”) below for more information about the rights that may be available to you.
A. Collection, Use, and Disclosure of Personal Information
In the preceding 12 months, we collected and disclosed the following categories of personal information.
|Categories of personal information||Disclosed to the following categories of third parties for business purposes:||Shared for targeted advertising purposes with the following categories of third parties:|
|Personal and online identifiers (like first and last name, email address, or unique online identifiers)||Our affiliates and joint venture partners; Our business partners; Our service providers; and Advertising companies.||Advertising companies.|
|Customer record information (like bank account number, credit card number, debit card number, or driver’s license number)||Our affiliates and joint venture partners; Our business partners; and Our service providers.||N/A|
|Characteristics of legally protected classifications (like disability status)||Our affiliates and joint venture partners; Our business partners; Our service providers; and Advertising companies.||N/A|
|Commercial or transactions information (like records of personal property or products or services purchased, obtained, or considered)||Our affiliates and joint venture partners; Our business partners; Our service providers; and Advertising companies.||Advertising companies.|
|Internet or other electronic network activity information (like browsing history, search history, interactions with a website, email, application, or advertisement)||Advertising companies.|
|Geolocation information (including precise geolocation)||Our affiliates and joint venture partners; Our business partners; and Our service providers.||N/A|
|Sensory information (like videos and photos)||Our affiliates and joint venture partners; Our business partners; and Our service providers.||N/A|
|Professional or employment-related information||Our affiliates and joint venture partners; Our business partners; and Our service providers.||N/A|
|Sensitive personal information||Our service providers||N/A|
|Inferences drawn from the above information about your predicted characteristics and preferences||Advertising companies.|
|Other information about you that is linked to the personal information above||Advertising companies.|
We collect personal information from all categories of sources described in Section II.B (“Sources of Information”) of this Privacy Notice.
We collect, use, and disclose personal information for the business and commercial purposes described in Section II.C (“Information Use”) of this Privacy Notice.
We do not sell or share the personal information of minors we know are under 16 years old.
B. Notice of Financial Incentive
Our Extended Perks Discount Program (“Extended Perks”) collects personal information, including name, email address, and stay preferences, to facilitate its operations and provide you with discounts, offers and deals. Participating in Extended Perks is entirely optional and is subject to its terms and conditions. You can opt in by signing up for an Extended Perks account. The amount and nature of these benefits will be determined by the extend of your participation in Extended Perks. We may adjust the terms of participation from time to time.
You may terminate Extended Perks participation at any time by contacting us at email@example.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. We may continue to process information about you in connection with your transactions with ESH.
The price and service differences, such as discounts and credits, that are available to you through Extended Perks are based upon our reasonable determination of the value that we receive from collecting, retaining, and selling (as defined by applicable law) personal information about you in connection with operating our business. This estimated value takes into account a variety of factors as permitted by law, including (but not limited to) our expenses incurred in collecting and processing the information, our expenses incurred in providing rewards to you, and the estimated marginal revenue that we may derive from information related to a specific Extended Perks participant.
VII. YOUR RIGHTS AND CHOICES
A. Your Rights:
Residents of certain jurisdictions, including the EEA, U.K., California, Colorado, Connecticut, Virginia, and Utah, have rights with respect to the personal information collected by us. You may be able exercise the following rights, subject to certain exceptions and limitations.
If you are unhappy with our response to your request, we hope you will reach out to us first at firstname.lastname@example.org. For residents of the EEA and the UK, if you are still unhappy, you have the right to complain to your data protection authority.
Additionally, for Colorado, Connecticut, or Virginia residents, if you have submitted a request that you believe we have not reasonably fulfilled, you may contact us to appeal our decision by sending an email with the subject line “Appeal” to email@example.com.
To exercise any of the rights identified above, you may submit a request through Privily.io at https://portal.privily.io/dataSubject?cStartId=a80cf585c61490a1d0dce42d25198db4, calling 877.651.2124 to speak to an ESH representative, or write our Privacy Officer at 11525 North Community House Road, Ste. 100, Charlotte, NC 28277 or firstname.lastname@example.org.
You may exercise these rights yourself or have the option to designate an authorized agent to submit a request on your behalf. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, your name and email address.
If you would like an authorized agent to submit a request on your behalf, please contact us using the methods in 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.
B. Update Your Contact Information:
C. Enable / Disable App Location Tracking:
D. Promotional Emails:
E. Interest-Based Advertising:
We use Automated License Plate Recognition (“ALPR”) technology to collect information relating to vehicles present at various points of entry onto some physical properties in certain states. We use this information to detect, prevent, investigate, report and address activities that may violate our policies, be illegal, or otherwise impact the safety or security of our employees, vendors, and hotel guests, as well as for loss prevention purposes.
ESH restricts access to ALPR technology and ALPR Information to only those ESH personnel with a need-to-know such information for their job requirements. Access is granted to ESH District Managers only. These personnel receive training in data security and the sensitivity of ALPR Information. ESH’s use of ALPR technology is overseen by Vice President of Safety & Security.
ALPR Information is securely stored on ESH’s vendors’ servers subject to access control processes and procedures. ALPR Information is password protected, encrypted in transit and storage, and not used for purposes other than those disclosed in this Privacy Notice. ESH takes reasonable measures to ensure accuracy and integrity of the ALPR information its vendors collect, including maintaining access controls and access logs (which includes the date/time information is accessed, license plate number, username of the person who accessed the information, and the purpose for accessing this information). ESH also monitors access logs to prevent unauthorized access. When using this information in connection with the investigation of an incident, ESH considers all available information, including information from other systems.
ALPR Information is stored for approximately seven (7) days before it is permanently deleted, unless we need to retain the information for compliance with applicable law, investigation of specific incidents, upon request of law enforcement, or other valid legal processes.
When ALPR Information is necessary for one of the above purposes, ESH uses reasonable safeguards, including encryption, to secure the transfer of ALPR information. ESH does not sell ALPR Information to third parties.
IX. UPDATES TO THIS PRIVACY NOTICE
We may modify this Privacy Notice from time to time. When we make 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. We encourage you to visit this page periodically to learn of any updates.
X. CONTACT US
For questions or comments regarding this Privacy Notice, including to exercise your rights, please contact 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 email@example.com.