Privacy Policy

The personal information that we may collect about you broadly falls into the following categories:

1. Information that you provide voluntarily

   The information we collect from you through our Websites, in connection with virtual and in person events and through correspondence with you, includes:

   • your name, email address, phone number, job title, company name and location;
   • information you include within any enquiry or request you make to us;
   • information about yourself which you provide in correspondence with us; and
   • comments and information about yourself which you submit to public areas of our Websites.

   We use this information to respond to enquiries and requests as well as to send marketing communications and personalized content about products and services we think may be of interest to you.

   In addition, in relation to our customers or prospective customers, service providers and partners, we use your personal information to:

   • provide you with information, products or services that you request from us;
   • manage services we provide to you/your company or products/services you/your company provide to us;
   • carry out our obligations under any contracts entered into between you/your company and us; and
   • manage our relationship with you/your company.

   If we ask you to provide any other personal information not described above, then the personal information we will ask you to provide, and the reasons why we ask you to provide it, will be made clear to you at the point we collect your personal information.

2. Information that we collect automatically

   When you visit our Websites, we may collect certain information automatically from your device. In some countries, including the United Kingdom and countries in the European Economic Area, this information may be considered “personal data” or “personal information” under applicable data protection laws.

   Specifically, the information we collect automatically may include information like your IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other technical information. We may also collect information about how your device has interacted with our Websites, including the pages accessed and links clicked. This includes the date and time, products you viewed or searched for, page response times, download errors, length of visits, and page interactions.

   We collect this information to:

   • Administer our Websites and for our internal operations, including troubleshooting, data analytics, testing, research, statistical and survey purposes;
   • Improve our Websites to ensure the content is presented in the most effective manner for you and for your device;
   • Allow you to participate in interactive features of our service, if you choose to do so;
   • Assist in our efforts to keep our Websites safe and secure;
   • Measure or understand the effectiveness of advertising we serve and deliver relevant advertising to you;
   • Make suggestions and recommendations to you about goods or services which may be of interest to you.

   Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.

3. Information that we obtain from third party sources

   From time to time, we may receive personal information about you from third party sources (including our business partners, technical, payment and delivery service contractors, advertising networks, analytics providers, search information providers and credit reference agencies), but only where these third parties have confirmed to us that they either have your consent or are otherwise legally permitted or required to disclose your personal information to us. We use this information to maintain and improve the accuracy of the records we hold about you and to send you personalized content.

   We will combine this personal information with personal information we already hold about you and use this combined information for the purposes set out above.

   Where we do not need your personal information to identify you, we may aggregate your personal information into an anonymised form. We may do this in order to use information for statistical purposes and to understand website interaction more generally.

We may disclose your personal information to the following categories of recipients:

• to our group companies, who may process personal information for the purposes that are described in this Privacy Notice. A list of our current group companies is available here.
• to our third party services providers and partners (including those through SiteMinder Exchange), who provide data processing services to us (for example, businesses providing information processing, managing and enhancing customer data, to provide customer service, to conduct customer research and satisfaction surveys, to support the delivery of, provide functionality on, or help to enhance the security of our Websites), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information. A list of our current service providers and partners is available here https://downloads.siteminder.com/gdpr/sub-processors-list.pdf;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, including to enforce our terms of use or any other agreements or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
• to any other person with your consent to the disclosure.

We use various technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

Specific measures we use include (amongst others):

• physical security and access to all SiteMinder premises
• all access to computer hardware is password protected, with encryption and default security firewalls in place;
• transfers of data between your device and our servers are encrypted using SSL and TLS encryption protocols;
• staff access controls to personal information;
• security standards consistent with Payment Card Industry Standard (PCI DSS) for which we are globally certified and undertake annual audits;
• staff data protection training.

As with any content that published on the Internet, any content, including personal information, that you contribute to be shared, published or transmitted to other users of our Websites, is visible to other users and can be read, collected, or used by them. We urge you to be careful about giving out information in public areas of our Websites. Please note that, even after removal, copies of your content, including personal information, that you contribute to be shared, published or displayed on our Websites, or transmitted to other users of our Websites, may still remain viewable in cached and archived pages, and may have been saved by other users.

Where you are located in the UK or EEA, you have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

If you are a California resident, the following information also applies to you and supplements the information contained in this Privacy Notice.

1. Information We Collect and Sources of Information

   Our Privacy Notice already describes the information we collect and the sources of information – see the above section “What personal information does SiteMinder collect and why?”. This section organizes that information around the personal information categories set out in the California Consumer Privacy Act (CCPA).

   In the past 12 months, we have collected the following information for the following purposes:

   • Identifiers (such as your name, username, email address and cookies). We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our products and services.
   • Business records (such as payment information). We obtain this information directly from you or otherwise automatically in the course of your interactions with our products and services.
   • Demographic information / Classification characteristics under California or federal law (such as age, date of birth or disabilities). We obtain this information if you provide it to us.
   • Commercial information (such as products and services purchased). We obtain this information directly from you or otherwise automatically in the course of your interactions with our products and services.
   • Internet or other electronic network activity information (such as search history and browser information). We obtain this information automatically in the course of your interactions with our products and services.
   • Geolocation data (such as your country location based on your IP address). We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our products and services.
   • Audio, video and other electronic data (such as chat and any interaction that you may have with us, for example for customer service purposes). We obtain this information when you provide it to us or otherwise automatically in the course of your interactions with our products and services.
   • Professional or employment-related information (such as your job title). We obtain this information when you provide it to us.
   • Profiles and inferences (such as inferences drawn from any of the information identified above to create a profile). We obtain this information automatically in the course of your interactions with our Website.

   We do not share your personal information except as approved by you or as otherwise described in this Privacy Notice. In the preceding 12 months, we have disclosed the following categories of personal information described above for the business purposes described in this Privacy Notice:

   • Identifiers such as those set forth above;
   • Internet or other electronic network activity information;
   • Demographic information / Classification characteristics;
   • Commercial information;
   • Geo-location data;
   • Audio, video and other electronic data;
   • Professional or employment-related information; and
   • Profiles and inferences.

   Under the California Consumer Privacy Act (CCPA), a “sale” is defined very broadly and includes a wide array of data sharing. As the term is defined by the CCPA, we “sold” the following categories of personal information in the last 12 months: identifiers/contact information, Internet or other electronic network activity information, and inferences drawn from the above. We “sold” such information to advertising networks and data analytics providers. The business purposes of “selling” personal information is for third-party companies to perform services on our behalf, such as marketing, advertising, and audience measurement. We do not have any actual knowledge that we “sell” personal information of consumers under 16 years of age.

   Most modern web browsers give you the option to send a Do Not Track signal to the sites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a site should respond to this signal, and we do not take any action in response to this signal.

2. California Privacy Rights

   If you are a California resident, you have the following consumer privacy rights:

   • Right to Know: You have the right to request that we disclose to you the personal information we have collected, used, disclosed and sold over the past 12 months, and information about our data practices.
   • Right to request deletion: You can request that we delete personal information about you. Although you may request deletion, we are allowed, under California law, to keep certain personal information. You can submit a request to delete by submitting a form here.
   • Right to Opt-Out of “Sale” of Personal Information: You can opt out of the “sale” of your personal information to “third parties” by clicking on this link (as those terms are defined in the CCPA).
   • Right to be Notified of Financial Incentives: You have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without your prior informed opt-in consent. We do not offer any such incentives at this time.
   • Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

   California law also permits you to request certain information regarding the disclosure of your personal information by us and our related companies to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing purposes.

   In addition to the specific forms listed above, you can exercise any of these rights by contacting us at [email protected] and providing us with your name, email and address (including zip code). We may verify your identity and by providing us with your California zip code or other proof of California residency.

   You can also authorize an agent to submit a request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Authorized agents that are business entities must be registered with the California Secretary of State to conduct business in California. Where you use an agent, we will ask for verification of your authorization, namely a copy of your written authorization for the agent to submit the request on your behalf.

   We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We do not discriminate against any consumer for exercising their consumer rights.

If you have any questions or concerns about our use of your personal information, please contact us using the following details: [email protected]

You can also contact us at one of our following locations:

• SiteMinder Limited, a company registered in Australia (ABN 59 121 931 744) with our registered office at Bond Store 3, 30 Windmill Street, Millers Point NSW 2000, Australia;
• SiteMinder Distribution Limited, a company registered in England and Wales (Company Number: 07242801) with our registered office at Waterfront, Hammersmith Embankment, Manbre Road, London, W6 9RH;
• Online Ventures Hospitality Limited, a company registered in Ireland (Company Number: 581051) with our registered office at 5 Dock Road, Galway, Ireland; and
• SiteMinder Hospitality Corporation, a company registered in Delaware with our registered office The Colonnade, Tower 1, Suite 350, 15301 North Dallas Parkway, Addison, TX 75001, USA.

The data controller operating the Websites is SiteMinder Limited. Other entities within the Siteminder group may also be controllers of your personal information, depending on your location and the type of product or service provided.