BEST WESTERN INTERNATIONAL, INC. PRIVACY POLICY
Best Western International, Inc. ("BWI") is
committed to taking measures to respect and protect your privacy. This privacy policy sets
forth the measures we take with regard to how we use, protect and allow others to view
your personal information.
In particular, BWI is committed to complying with the
European Community Directive on Data Protection, commonly referred to as the "EU
Privacy Directive." BWI has chosen to comply with the EU Privacy Directive by joining
the US Department of Commerce's "Safe Harbor" program. In order to join the Safe
Harbor Program, we have submitted certain certifications to the US Department of Commerce
and details of such certifications may be found at the following website:
http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.
Our privacy policy addresses seven privacy principles
dictated by the Safe Harbor Program: Notice, Choice, Onward Transfer, Security, Data
Integrity, Access and Enforcement. Further information about how we address these privacy
principles is provided below.
1. Notice
The purpose of this section is to notify you about the manner in and the purposes for
which BWI may collect and transfer certain personal information. This privacy policy
should be read in its entirety because anyone who submits personal information to BWI has
certain rights regarding the use, collection and transfer of such personal information.
BWI maintains centralized reservations systems, a worldwide
accessible website, call centers and database computers in the United States as well as in
other locations around the world which are intended to help BWI conduct business and to
facilitate the operation and maintenance of a central reservations system and its
frequency marketing program known as "Gold Crown Club International"
("GCCI"). The central reservations system and GCCI are maintained for the
benefit of its member hotels and properties ("BWI Properties") as well as for
BWI "Affiliates" which are entities which operate groups of various BWI
Properties outside of the United States. BWI Properties and Affiliates are independent
entities not owned or controlled by BWI and may or may not be located in European Union
member countries or countries whose privacy protection laws have been deemed
"adequate" pursuant to the EU Privacy Directive.
BWI may collect certain personal information from and about
individuals which can be identified with such specific individual, including without
limitation, contact and payment information ("Personal Information") about
customers who wish to stay or make reservations at BWI member properties
("Travelers"). Personal Information about Travelers may be collected through our
websites, by our call centers or may be passed on to us by BWI Properties, Affiliates or
other third parties. Personal Information about Travelers is collected so that Travelers
can make reservations at BWI Properties and so that BWI Properties can receive and have
updated reservation information about Travelers who wish to stay at such BWI Properties.
Some of a Traveler's Personal Information (such as a credit card number) may be stored to
facilitate the making of future reservations by such Traveler. Only that Personal
Information which is reasonably required to facilitate travel reservations is collected
and shared between BWI, BWI Properties and Affiliates as outlined above. Personal
Information for Travelers will be transferred from BWI to BWI Properties and Affiliates.
BWI may collect Personal Information from Travelers who are
also members of the GCCI program ("GCCI Customers") so that BWI can perform
certain administrative tasks necessary for the administration and operation of the GCCI
program such as the following: (1) allow GCCI Customers to earn rewards, points or credit
("GCCI Points") for staying at various BWI Properties; (2) allow other BWI
Properties and Affiliates to be aware of the GCCI Points earned by GCCI Customers so that
such BWI Properties or Affiliates can redeem GCCI Points; (3) allow BWI Properties and
Affiliates to receive and share Personal Information for GCCI Customers as necessary in
order for such BWI Properties and/or Affiliates to satisfy contractual obligations among
and between various BWI Properties and/or Affiliates. GCCI Customers' Personal Information
may be collected through our various websites, by our call centers or may be passed on to
us by BWI Properties, Affiliates or other third parties. BWI may transfer Personal
Information to BWI Properties and Affiliates as a part of BWI administering the GCCI
program as outlined above.
BWI distributes Personal Information about GCCI Customers
to third parties for the purpose of having such third parties compile information about
the type and frequency of use of the GCCI program by such GCCI Customers as well as to
allow such third parties to conduct data processing for BWI and to engage in
communications on behalf of BWI with GCCI Customers. BWI may also distribute Personal
Information to airline companies upon request of the GCCI Customer, in order to allow a
GCCI Customer to earn frequent customer points with such airline companies. Examples of
these types of third parties include Direct Options and Cendyn.
BWI may send marketing information about BWI, BWI
Properties or the GCCI program as well as marketing information about offers or
information about third party products and services to GCCI Customers and Travelers based
upon the Personal Information BWI has collected for such GCCI Customers and Travelers.
BWI performs certain of its administrative tasks through
the use of several wholly owned subsidiaries ("BWI Subsidiaries") which
geneRally operate within the same facilities as BWI, employ personnel who are also BWI
employees and use the same equipment to store and process Personal Information as BWI. BWI
Subsidiaries employ data protection practices which are no less protective than those
employed by BWI. BWI may share or transfer Personal Information with BWI Subsidiaries
while performing the tasks described in this privacy policy.
2. Choice
All Travelers, GCCI Customers and anyone else who submits Personal Information to BWI may
choose to not have any of their Personal Information submitted or transferred to third
parties in accordance with the terms of this privacy policy. Please see below for further
details.
If you do not wish for your Personal Information to be
disclosed to any third parties, besides BWI Affiliates, BWI Properties and BWI
Subsidiaries, please let us know through our Customer Relations Department. The contact
information for the BWI Customer Relations Department is located at the end of this
privacy policy. Within a reasonable time after receiving your request to not distribute
your Personal Information to such third parties, we will cease any distribution to such
third parties. Please be aware that if you choose to not have your Personal Information
distributed to such third parties, then we may not be able to provide all of the available
GCCI services to you or such services may not be delivered as quickly.
If you do not wish for your Personal Information to be
disclosed to BWI Affiliates, BWI Properties or BWI Subsidiaries, please let us know
through our Customer Relations Department. The contact information for the BWI Customer
Relations Department is located at the end of this privacy policy. Within a reasonable
time after receiving your request to not distribute your Personal Information to BWI
Affiliates, BWI Properties or BWI Subsidiaries, we will cease any distribution of your
Personal Information to any BWI Affiliates, BWI Properties or BWI Subsidiaries. Please
keep in mind that if BWI cannot disclose or share your Personal Information to our BWI
Affiliates, BWI Properties or BWI Subsidiaries, we may be unable to provide you with all
or certain reservation services, other services or GCCI related benefits.
Sensitive Information
BWI will only collect sensitive Personal Information related to your health if you submit
such type of Personal Information and such sensitive Personal Information will only be
used by BWI in order to allow us to help you obtain special accommodations or other health
related benefits at a BWI Property. This type of Personal Information will be submitted to
BWI Properties and Affiliates only if necessary for us to facilitate the reservation of a
room at one of the BWI Properties which will help meet your health needs. If you do not
want us to collect and use such type of Personal Information, please do not submit such
type of Personal Information to us.
3. Onward Transfer
Please note that our descriptions of our activities under the "Notice" and
"Choice" principles above describes certain transfers of Personal Information
that BWI will be making to third parties.
BWI wants all individuals who submit Personal Information
to BWI to understand that anyone who submits Personal Information, by submitting such
Personal Information and checking the appropriate box which indicates that such individual
is consenting to the use and transfer of Personal Information in accordance with this
privacy policy, authorizes certain data transfers of such Personal Information to BWI
Properties, BWI Subsidiaries and/or other third parties ("Transfer Recipients")
for use of such Personal Information by Transfer Recipients in accordance with the
description provided in the "Notice" section. Transfer Recipients may not
necessarily be in the European Union or countries which have been deemed by the European
Union to have "adequate" data protection laws (such as by example only, Canada)
and may be in territories like the United States where an equivalent level of data
protection is not granted.
4. Security
BWI has conducted an internal review of its data collection and processing practices and
the security measures it has implemented and believe that such security measures provide
reasonable precautions against the unauthorized access, disclosure, alteration or
destruction of Personal Information that BWI collects.
BWI's Systems Architecture group has also conducted an
internal review of its computer network and its data protection measures and believes that
it has implemented a reasonable level of technology and software to protect against the
loss of Personal Information. Such measures include without limitation, the following: the
use of several firewalls to separate user network traffic from server network traffic; the
use by BWI web applications of SSL encryption whenever sensitive information is being
accessed; the use of the Secure File Transfer Protocol (SFTP) when exchanging data with
third parties so that files, usernames and passwords are encrypted; the use of intrusion
detection software at eleven different points in the internal BWI network and the use of
virus protection software on BWI's e-mail servers and client computers.
BWI has also implemented certain physical security measures
to protect against the unauthorized access to Personal Information. All server rooms are
protected through a keycard system that checks user privileges against a central database
and these server rooms are locked at all times.
5. Data Integrity
BWI has conducted an internal review of its data collection and processing practices and
believe that only that Personal Information is collected and processed which is required
in order for BWI to provide services for or to fulfill its contractual obligations with
Travelers, GCCI Customers, BWI Properties and BWI Affiliates. BWI will be implementing a
periodic review of its data collection and processing practices to ensure that it only
collects or processes Personal Information which is required in order for BWI to provide
services for or to fulfill its contractual obligations with Travelers, GCCI Customers, BWI
Properties and BWI Affiliates.
6. Access
BWI will make a good faith attempt to allow all Travelers, GCCI Customers or others who
BWI collects Personal Information from, to have the opportunity to view the Personal
Information it has collected for such individuals, subject to the provisions in this
Section 6.
BWI may make certain Personal Information available through
an on-line program, website or procedure ("On-Line Procedure") for inspection by
the individual associated with such Personal Information. If Personal Information is
available through the On-Line Procedure devised by BWI, the Personal Information can only
be reviewed through such On-Line Procedure. The On-Line Procedure will also contain
information about how to request any corrections or deletions of any erroneous Personal
Information. Information about the availability of On-Line Procedures for viewing certain
types of Personal Information is geneRally available at the website or on the printed
materials where such type of Personal Information was first submitted.
If BWI has not set up an On-Line Procedure to allow the
viewing of Personal Information, then those Travelers, GCCI Customers or others who
submitted Personal Information to BWI for use by BWI can review the Personal Information
collected for them by contacting the BWI Customer Relations department through the contact
information provided below.
BWI will make all corrections and/or deletions of erroneous
Personal Information brought to its attention within a reasonable time period but BWI must
make all corrections and/or deletions of erroneous Personal Information in a manner which
does not impose undue burden or expense on BWI. Further, BWI may not necessarily allow
access to review Personal Information collected for an individual for any Personal
Information which BWI reasonably determines to either not be sensitive for the individuals
involved or is not used in a manner which will not significantly affect the individual
involved if providing such review privileges would cause undue burden or expense on BWI.
7. Enforcement
BWI engages in self-assessment on a periodic basis in order to determine its continued
compliance with the requirements of the Safe Harbor program and the terms of this privacy
policy. When engaging in a self-assessment review, BWI engages an outside law firm to help
coordinate its review of its then current data collection practices and at a minimum, at
least one representative from BWI's finance, information services, technology services and
marketing groups or divisions is involved in the self-assessment.
Dispute Resolution
All Travelers, GCCI Customers or others who submit Personal Information to BWI who feel
that BWI has mishandled their Personal Information in violation of the Safe Harbor
requirements ("Disputing Party") should contact BWI through its Customer
Relations department (with such contact information provided below) with a written
description of their complaint. After receiving such written description, a representative
from BWI's Customer Relations department will contact the Disputing Party to set up a time
and manner to discuss the Disputing Party's complaint. BWI is interested in addressing all
legitimate complaints about its adherence to the Safe Harbor and believes that a Disputing
Party and BWI should make a good faith effort to engage in communications to work out or
settle any of a Disputing Party's complaints. If these good faith efforts fail to resolve
the dispute, then the Disputing Party shall have the opportunity to make use of an
independent, dispute resolution procedure. Currently, BWI is a member of the BBBOnline
Dispute Resolution Program and has agreed to allow Disputing Parties to bring privacy
complaints against BWI pursuant to the rules and procedures of such program. Any Disputing
Parties who wish to lodge a complaint through the BBBOnline Dispute Resolution Program
will be provided with information from BWI about how to proceed with lodging a complaint.
BWI is currently investigating the use of other dispute
resolution mechanisms in an effort to find the dispute resolution mechanism that best fits
the needs of BWI, Travelers, GCCI Customers and others who submit Personal Information to
BWI. If BWI agrees to adopt the services of another independent, dispute resolution
procedure, it will do so only after revising its privacy policy to reflect such new
procedure and by informing all Disputing Party's of such change.
A Disputing Party and BWI may agree to use an independent
dispute resolution body or procedure to resolve disputes about BWI's compliance with the
Safe Harbor upon mutual written agreement of both parties.
Remedies
If it is determined by an independent dispute resolution body or procedure that BWI has
engaged in behavior not in compliance with the requirements of the Safe Harbor, BWI may be
ordered to engage in actions necessary to reverse or correct any actions taken by BWI
which were in violation of the Safe Harbor and which were harmful to the Disputing Party.
BWI may also be required to take all actions deemed necessary for BWI to be in compliance
with the Safe Harbor in the future. BWI's non-compliance with the Safe Harbor may be
reported to the appropriate governmental authorities if BWI has engaged in a pattern of
persistent failure to comply with the Safe Harbor.
CONTACTING BEST WESTERN INTERNATIONAL, INC. IF YOU
HAVE QUESTIONS OR COMMENTS
If you have any questions or comments about the manner in which we use or share your
Personal Information, please contact our customer relations department through the contact
information included below:
Best Western International, Inc.
Customer Relations Department
Telephone: 1-800-528-1238
Fax: 623-780-6199
Email: customerservice@bestwestern.com
Regular Mail: PO Box 10203
Phoenix, AZ 85064
Attn: Customer Service
|
