Privacy Policy for Focus Hospitality Management
Focus Hospitality Management developed this Privacy Policy to explain how we collect, use, share, and protect Personal Information (defined below), and your choices about the collection and use of Personal Information.
This Privacy Policy applies to Personal Information collected or processed through our website that link to this Privacy Policy or our official social media pages (collectively, the “Site”).
1. What is Personal Information?
“Personal Information” is information that, either alone or in combination with other information, identifies you. Examples of Personal Information include, among others, name, email address, phone number, and mailing address. When we combine Personal Information with other information, we treat the combined information as Personal Information.
2. How We Use Personal Information
We use Personal Information for limited purposes, depending on the context in which we collect it. For example, when you book a room, we collect certain guest details (name, email address, billing address) in order to process your booking. In other words, we process Personal Information with your consent, as necessary to provide the Site, or for our legitimate interests, such as:
• Enabling secure use of the Site;
• Providing, analyzing, administering, and improving the Site and our services;
• Seeking your feedback on our services and your hotel experience through surveys;
• Sending information at your request;
• Responding to enquiries;
• Protecting our rights or our property;
• Meeting legal obligations; and
• For other purposes related to the reasons for which you provide Personal Information.
3. Types of Personal Information We Collect and Use
A. Information that You Provide Us
In various places on the Site, we request information, including Personal Information, from you via forms. The exact information we need to collect will depend on the purpose of the form. For example, when you book a hotel room, we ask for your full name, billing address, email address, phone number, and credit card information (which is processed securely through a third-party payment processor). We will indicate on the form whether a particular field of information is mandatory or optional. If you choose not to provide certain information, we may not be able to provide requested services.
B. Information We Receive from Your Use of the Site
We collect the following types of information automatically through your use of the Site:
• Cookies, Device Identifiers, and Similar technologies
When you use or access the Site, we, our service providers, and our advertisers use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Site. We process the information collected through such technologies, which may include Personal Information, to help operate certain features of the Site, to enhance your experience through personalization (including providing you with advertisements relevant to your travel interests), and to help us better understand the features of the Site that you and other users are most interested in. Should you visit our website using your mobile device, an advertising service may also collect your device’s unique identifier, or location, and attempt to synchronize your mobile website visit with other website visits.
Some of our service providers may use cookies or other methods to gather information regarding your use of the Site, and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
When a relevant advertisement is served to you on another website that uses data collected from this Site, it is referred to as an “Interest-Based” Ad and the advertisement should include a blue “Adchoices” icon in the upper-right hand corner. If you click on the Adchoices icon, you can learn more about the facilitating advertising service, and your opportunity to opt-out of Interest-Based ads from that service. We do not have access to, nor control over, these advertising services use of cookies when Interest-Based ads are served to you. However, you may choose to opt-out of the use of this information by clicking here: http://www.aboutads.info/choices/.
Please note that by opting out, you will continue to see ads, but they may not be as relevant based on your travel interests.
• Log File Information
When you use our Site, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), number of clicks, and how you interact with links on the Site, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Information collected from our implementation of the Site to further our legitimate interests in securing the Site by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our Site to improve the Site’s function and content.
4. DISCLOSURE OF PERSONAL INFORMATION
We will not disclose Personal Information except as set forth in this Privacy Policy or with your consent. In particular, we do not sell, lease, or exchange Personal Information.
This section describes to whom we disclose Personal Information, and for what purposes:
• Our Service Providers. We employ service providers to perform tasks on our behalf and to assist us in providing the Site. For example, we engage third parties such as SiteMinder to develop and host portions of the Site, including our online booking features (see SiteMinder’s Privacy Policy); Google Analytics to assist in analyzing website traffic through cookies and similar technologies (see “How Google uses data when you use our partners’ Services or apps”); and Sojern for marketing and advertising (see Sojern’s Privacy Center). We take commercially reasonable steps to help ensure our service providers provide at least the same level of protection for Personal Information as we do.
• Companies Involved in Mergers and Acquisitions Transactions. If we sell or otherwise transfer part or the whole of our business or assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, or liquidation), any information collected through the Site, including Personal Information, may be among the items sold or transferred.
• Law Enforcement, Government Agencies, and Courts: We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our rights or to defend against a legal claim or as otherwise required or allowed by law, or to protect the rights, property, or safety of any other person. We may also disclose Personal Information to investigate or prevent a violation by you of any contractual or other relationship with us or your illegal or harmful activity.
5. PERSONAL INFORMATION TRANSFERRED FROM OUTSIDE THE U.S.
If you are using the Site from outside the United States, please be aware that Personal Information may be transferred to, stored, and processed in the United States. Although we take steps to provide adequate safeguards, the data protection laws of the United States might not be as comprehensive as those in your country. By using the Site, you consent to your information being transferred to the United States for the purposes described in this Privacy Policy.
6. HOW WE PROTECT THE CONFIDENTIALITY OF PERSONAL INFORMATION
We to protect the confidentiality and security of information we obtain in the course of business. We use commercially reasonable safeguards, such as industry-standard encryption technology, to help keep the information collected through the Site (including credit card information) secure.
Despite these efforts to store Personal Information in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.
7. CHILDREN’S PRIVACY
We do not knowingly collect or solicit any Personal Information from children. In the event that we learn that we have collected Personal Information from a child without parental consent, we will promptly take steps to delete that information.
8. YOUR DATA SUBJECT RIGHTS
If you would like to access, amend, erase, export, or object to or restrict the processing of, Personal Information about you, you may submit a request to info@focushospitalitymanagement.net. We will promptly review all such requests in accordance with applicable laws. When we process Personal Information about you on behalf of a client, we must act on our client’s instructions—including with regard to how to respond to your request.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at info@focushospitalitymanagement.net, so we have an opportunity to address your concerns directly before you do so.
9. OPTING OUT OF RECEIVING E-MAIL COMMUNICATIONS
With your permission, we may send notifications, promotions, or other information via email (“Communications”). You may choose to stop receiving Communications by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in any email you receive. You may also send a global unsubscribe request to info@focushospitalitymanagement.net. Please note that certain Site-related Communications are necessary for the proper functioning and use of the Site (e.g., to provide you with confirmation of your booking) and you may not have the ability to opt out of those Communications.
10. RETENTION OF PERSONAL INFORMATION
We will retain your Personal Information for the period necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Privacy Policy unless a longer retention period is required by law.
11. OTHER WEBSITES AND SERVICES, INCLUDING SOCIAL MEDIA
We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. A link to a third party’s website should not be construed as an endorsement. We encourage you to investigate and ask questions before disclosing Personal Information to third parties.
12. CHANGES TO OUR PRIVACY POLICY
We may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SERVICE.
13. HOW TO CONTACT US
If you have any questions about this Privacy Policy or the Site, please email us at info@focushospitalitymanagement.net.