Choice Hotels International Privacy Policy

Last Updated February 16, 2023

IMPORTANT NOTE: The North and South American operations of Radisson (“Radisson Hotels Americas”) were purchased by Choice Hotels International, Inc. (“Choice”), as of August 11, 2022. During this transitional period, you may see outdated references to Radisson corporate organizations on our website, mobile apps, and in our hotels and printed materials. This updated Privacy Policy only applies to this website and other operations of Radisson Hotels Americas that were purchased by Choice. Choice has a separate Privacy Policy on its website, the Choice Hotels Privacy and Security Policy, that applies to consumers who are on Choice’s website, www.choicehotels.com, or booking on Choice’s mobile apps or other (non-Radisson Hotels Americas) operations. For our UK site on choicehotels.com, please visit https://www.choicehotels.com/en-uk; for our EU sites on choicehotels.com, please visit one of the following: https://www.choicehotels.com/en-fr, https://www.choicehotels.com/fr-fr; https://www.choicehotels.com/en-de, https://www.choicehotels.com/de-de; https://www.choicehotels.com/en-it, https://www.choicehotels.com/it-it; https://www.choicehotels.com/en-ie.

Scope of this policy
Definitions
Hotel booking process
Hotel guests
Loyalty programs
Marketing
Mobile applications
Website forms
Meetings and events
Analytics
Social media and online reviews
Your rights
Security measures
What rules apply to children?
How is your Personal Data shared with Third Parties?
International data transfers
How long will we keep your Personal Data?
Delete my data
Does this Privacy Policy apply to Third Party websites?
What happens if we make modifications to this policy?
How to contact us

This Privacy Policy describes how Choice and its subsidiaries (“we” or “us”) collects, uses, consults or otherwise processes an individual’s Personal Data. 

In some of the situations described in this Privacy Policy, the hotel where you made a booking and/or stay will also process your data as an independent Controller. The hotel will be solely responsible for the processing activities for which it is the Controller.

Choice is a company incorporated under US laws, having its offices at 1 Choice Hotels Circle, Rockville, MD 20850.

We are committed to protecting the privacy of our users and customers.

This Privacy Policy is intended to inform you how we gather, define, and use Personal Data that you provide to us when using our websites and mobile applications or when relying on our hospitality services. Please take a moment to read this Privacy Policy carefully. Please note that if you plan to submit someone else’s Personal Data to us, for instance when making a booking on their behalf, you may only provide us with that person’s details with their consent and after they have been given access to information about how we will use their details, including the purposes set out in this Privacy Policy.

THIS POLICY INCLUDES A DESCRIPTION OF YOUR DATA PROTECTION RIGHTS, INCLUDING A RIGHT TO OBJECT TO SOME OF THE PROCESSING ACTIVITIES WE CARRY OUT. PLEASE NOTE THAT YOUR RIGHTS AS A DATA SUBJECT MAY VARY DEPENDING UPON WHERE YOU LIVE.

Local provisions

While this Privacy Policy applies globally, we understand no policy can be completely exhaustive. Choice endeavors to comply with all applicable local laws in the jurisdictions in which we operate. Accordingly, we may make variations to this Privacy Policy and our privacy practices in order to comply with specific legal provisions in particular jurisdictions. Provisions which apply in respect of particular jurisdictions are set out below.

If you have questions about an individual hotel’s practices or the information provided by it, please contact the hotel directly.

Choice: Choice administrative entities, including but not limited to Choice Hotels International Inc., and its subsidiaries, but also to the hotels operating under the Choice and Radisson Hotels Americas brands (including but not limited to Radisson Collection, Radisson Blu, Radisson, Radisson RED, Radisson Individuals, Radisson Inn & Suites, Park Plaza, Park Inn and Country Inn & Suites by Radisson) and their affiliated entities.

Controller: The natural or legal person which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

Processor: A natural or legal person which processes Personal Data on behalf of the Controller.

Recipient: A natural or legal person to which the Personal Data are disclosed, whether a Third Party or not.

Third Party: A natural or legal person other than the data subject, Controller, Processor and persons who, under the direct authority of the Controller or Processor, are authorized to process Personal Data.

Supervisory Authority: The regulator or authority with responsibility for data protection or data privacy issues in a particular jurisdiction.

Personal Data: Any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Radisson: Radisson Hotels Americas and hotels operating under the Radisson Hotels Americas brands, (including but not limited to Radisson Collection, Radisson Blu, Radisson, Radisson RED, Radisson Individuals, Radisson Inn & Suites, Park Plaza, Park Inn and Country Inn & Suites by Radisson).

Standard Contractual Clauses: Sets of standard contractual clauses for the international transfer of Personal Data as adopted or authorized by a Supervisory Authority or other relevant public authority. 

Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

1. Hotel booking process 

In the context of the hotel booking process – whether this takes place online on our  website, through an online booking channel, via mobile app, via a travel agent, through our call center or directly at the hotel – we process your Personal Data for the purpose of (i) enabling you to reserve a room in the hotel of your choice; (ii) verifying the availability of the hotel and to administer the booking; (iii) sending you a booking confirmation; and (iv) sending you pre-arrival emails. You may unsubscribe from pre-arrival emails at any time by clicking on the unsubscribe link in the emails sent to you. 

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories 
Address, Booking details (including reservation number), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, Payment card number and expiration date, Radisson Rewards Americas membership number, Telephone number, Title 

Source of data
Depending on the booking mechanism used:

- Directly from you through the online booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Radisson Hotels Americas hotel you made a direct booking with

Ground for processing
Processing is necessary to take steps to enter into and perform a contract.

Recipients of data
- The Radisson Hotel Americas hotel of your choice
- Other Choice entities involved
- IT service providers involved in the (online) booking process
- IT service providers
- Email communications service provider
- RHI business analytics platforms

2. Interrupted or incomplete online booking process (abandoned cart)

When you are booking online but for some reason are not able to finalize the booking process, we process your Personal Data for the purpose of enabling you to easily continue the online booking process by sending you an email with a link to the online booking form, which is pre-filled on the basis of the data you had already provided in the form.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Address, Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, Payment card number and expiration date, Radisson Rewards Americas membership number, Telephone number, Title

Source of data
Directly from you through the online booking form

Ground for processing
It is in Choice’s legitimate interest as a business to re-market an interrupted or incomplete booking process. In this context, Choice’s business interests prevail over yours.

Recipients of data
- Email communications service provider

- Provider of targeted advertisements

3. Guest satisfaction surveys

We may send you guest satisfaction surveys by email during or after your stay to enable us to measure the performance of our hotels. You may unsubscribe from our guest satisfaction survey emails at any time by clicking on the unsubscribe link in the emails sent to you.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Country of residence, Date of arrival and departure, Email address, First name / Last name, Nationality, Radisson Rewards Americas membership number, Stay details

Source of data
Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Radisson Hotels Americas hotel you made a direct booking with

Ground for processing
Processing is necessary to ensure and follow up on the good performance of the contract you have with us.

Recipients of data
- Other Choice entities involved
- Guest satisfaction survey provider

4. Service emails Analytics

In the context of service emails, which includes guest satisfaction survey emails and any pre-arrival emails concerning your booking, we may process and collect your Personal Data, and notably whether you have opened and actioned a service email, for analytical purposes in order to measure the click-through rate and improve the content of our service emails. You may unsubscribe from our service emails at any time by clicking on the unsubscribe link in the service emails sent to you.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Email address, Email clicking behavior, Email opening behavior, First name / Last name, Radisson Rewards Americas membership number

Source of data
From our email deployment and analytics service provider

Ground for processing
It is in Choice's legitimate interest as a business to understand the email clicking behavior of its guests in order to determine whether improvements are needed. In this context, Choice's business interests prevail over yours.

Recipients of data
- Other Choice entities involved
- IT service providers
- Email service provider

1. Hotel check-in and check-out

When staying at the hotel of your choice, we will collect and process your Personal Data for the purposes of (i) registering your arrival and departure at the hotel; (ii) assigning you a key card to your room or allowing you to use your mobile device as a room key; (iii) obtaining a credit card guarantee or hotel deposit to ensure payment of your stay; (iv) managing (and archiving) your hotel registration card; (v) creating or updating your profile in our hotel management system; (vi) assessing your eligibility for a room upgrade and managing this if applicable; (vii) managing payment of your stay; (viii) establishing, printing or sending an invoice for your stay; and (ix) paying a commission to your travel agent (if applicable).

In the event you have booked a room in one of our hotels but do not show up – without cancelling – on the date of arrival communicated, we will process your Personal Data for the purposes of (i) cancelling your stay and any other reservation you may have made; and (ii) managing, processing and settling any outstanding payment that may be due.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Address, Bookings (hotel, restaurant, event, theater, etc.), Date of arrival and departure, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, Payment card number and expiration date, Radisson Rewards Americas membership number, Telephone number, Title

Source of data
Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Radisson Hotels Americas hotel you made a direct booking with
- Directly from you through the hotel registration card

Ground for processing
Processing is necessary to perform the contract you have with us.

Recipients of data
- Other Choice entities involved
- IT service providers
- Your travel agent (if applicable)

2. Credit limit reports

To ensure payment for all guests staying in a hotel room, each hotel guest is asked for a credit card or deposit upon arrival. In order to ensure that you do not exceed your credit limit during your stay, we produce a credit limit report multiple times a day for the purposes of verifying whether your credit limit has been exceeded. These credit limit reports may contain your Personal Data. Please note that in limited circumstances these credit limit reports may be subject to one of our internal financial audits, and may therefore be accessed by members of our internal audit department, in order to ensure that our hotels follow Choice's internal guidelines and policies.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Date of arrival and departure, First name / Last name, Payment card type, Payment card number and expiration date

Source of data
Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Radisson Hotels Americas hotel you made a direct booking with
- Directly from you through the hotel registration card

Ground for processing
Processing is necessary to ensure the performance of the contract you have with us.

Recipients of data
- Other Choice entities involved
- IT service providers

3. Hotel stay

When you stay in one of our hotels, we endeavor to make your stay as pleasant as possible. This requires processing your Personal Data for the purposes of providing specific services during your hotel stay. These services include (i) housekeeping and maintenance; (ii) returning lost or forgotten items to you; and/or (iii) managing your and your co-guests’ preferences, such as dietary requirements and pillow preferences, in order to provide you with a better service during your stay with us.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Address, Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Other preferences, Payment details (for the purpose of returning lost or forgotten items), Telephone number

Source of data
Depending on the booking mechanism used:

- Directly from you through the booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From the Radisson Hotels Americas hotel you made a direct booking with
- Directly from you during your stay at the hotel

Ground for processing
It is in Choice's legitimate interest as a business to organize its day-to-day hotel maintenance activities, to personalize the services it provides, and/or to be able to identify the owner of a lost or forgotten item. Taking into account the limited Personal Data processed and shared for such purpose(s), Choice's business interests prevail over yours.

Recipients of data
- Hotel personnel, including housekeeping, maintenance, front desk, and/or other hotel personnel concerned
- Other Choice entities involved
- IT service providers
- Delivery or courier service providers (for the purpose of returning lost or forgotten items)

4. Hotel guest additional services and facilities

In many of our hotels you can benefit from additional services and facilities, such as breakfast, room service, minibar, pool, restaurants and bars, spa treatments, laundry services, parking, taxi requests, free Wi-Fi, etc. In the event you make use of additional services or facilities at one of our hotels, your Personal Data may be processed to (i) manage the booking and use of such additional hotel services and/or facilities; (ii) administer any advance bookings of additional services and/or facilities to your file; (iii) personalize returning guests’ arrival to the hotel and the choice of room amenities and room features; and (iv) manage the expenses incurred for such additional services and/or facilities.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
Consumption habits, Date of arrival and departure, Dietary requirements, Email address, First name / Last name, First name / Last name of adult co-guest(s), Payment card type, Payment card number and expiration date, Radisson Rewards Americas membership number, Title

Source of data
- Directly from you through the online booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- Directly from you through the hotel registration card
- Directly from you when making your additional service/facility request with the hotel front desk or the concierge
- Through the online booking platform for additional services and facilities

Ground for processing
Processing is necessary to take steps with a view to entering into a contract and/or to perform the contract.

Recipients of data
- Hotel personnel, including front desk, room service, and/or other hotel personnel concerned
- Other Choice entities involved
- IT service providers

1. Radisson Rewards Americas

Radisson Rewards Americas is a hotel rewards program applicable throughout the hotels of Radisson that were purchased by Choice that is available to guests staying in our hotels, and to professional partners irrespective of whether the professional partners stay as guests or book on behalf of others. The Radisson Rewards Americas program is managed by Choice. The Radisson Rewards Americas program provides you with a number of benefits during your stay at our hotel, and enables you to collect Radisson Rewards Americas points during your stay in our hotels and when purchasing from our selected partners. In such context, we may process your Personal Data in order to be able to (i) create your online Radisson Rewards Americas profile, including sending you an activation link by email; (ii) provide you with information on your Radisson Rewards Americas points; (iii) register your bookings and award points to your membership card; (iv) inform you about your rewards once you reach a certain points level; and (v) inform you about any changes to the Radisson Rewards Americas program.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
First name / Last name, Hotel stay details, Membership number of loyalty program of relevant partner company, email address, country

Source of data
- Directly from you when claiming or redeeming miles or points
- Directly from you when registering for the Loyalty program

Ground for processing
Processing is necessary to take steps at your request with a view to perform the contract you have with us as well as to perform the contract you have with our recognized partner(s).

Recipients of data
- Other Choice entities involved
- IT service providers
- Relevant partner company

2. Other loyalty program

Apart from Radisson Rewards Americas, we also offer our guests the possibility to earn miles or points in loyalty programs of our partners, such as frequent flyer programs, car rental programs and railway programs. In such context, we may process your Personal Data in order to be able to (i) award miles or points to your membership account with one of our recognized partners following your stay at our hotel; and (ii) assess and fulfil your request to redeem your miles or points of our recognized partners’ loyalty programs at our hotel.

Processed data categories
First name / Last name, Hotel stay details, Membership number of loyalty program of relevant partner company

Source of data
Directly from you when claiming or redeeming miles or points

Ground for processing
Processing is necessary to take steps at your request with a view to perform the contract you have with us as well as to perform the contract you have with our recognized partner(s).

Recipients of data
- Other Choice entities involved
- IT service providers
- Relevant partner company

3. Redemption

We provide you with the opportunity to redeem your loyalty points for items such as gift cards, partner offers or charities. When you make a redemption, we process your and, if applicable, the gift card recipient’s Personal Data for the purpose of managing and successfully completing your redemption. In cases where you purchase a gift card for another person, we will process additional Personal Data for the purpose of delivering the gift card to the recipient by email or by post.

Processed data categories
First name / Last name, Payment card type, number and expiration date, your Address, Telephone number, Connection logs, email address, and IP address. If you purchase a gift card for someone else and depending on the mode of delivery, we will also process the Address of the recipient, email address of the recipient, First name / Last name of the recipient, Telephone number of the recipient

Source of data
Directly from you when redeeming your points at the hotel or online

Ground for processing
Processing is necessary for the performance of the contract you have with us.

Recipients of data
- Other Choice entities involved
- IT service providers
- Gift card platform provider
- Payment service provider
- IT service providers involved in the (online) booking process

1. Marketing communications

If you have explicitly consented to receive our marketing communications, including in relation to Choice, we may, from time to time, contact you with information about our services and latest offers and process your Personal Data for this purpose.

If you no longer want to receive our marketing communications, please let us know by sending us an email at privacyinquiry@choicehotels.com. You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails sent to you. For Radisson Rewards Americas, you may also unsubscribe by updating your profile.

The information below describes the types of data we process for this purpose, where we get your data from, the legal grounds we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Address, Date of birth, Email address, First name / Last name, Gender, Hobbies and interests, Telephone number, Hotel stay history, Country of residence

Source of data
- Directly from you when subscribing to our marketing emails or later when completing your account

Ground for processing
- Ad hoc consent obtained during the subscription to our marketing emails

Recipients of data
- Other Choice entities involved
- IT service providers
- Email communications service provider
- Advertising platforms

2. Marketing communications analytics

In the context of our marketing communications, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our marketing communications.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Email address, Email clicking behavior, Email opening behavior, First name / Last name, Radisson Rewards Americas membership number

Source of data
- From our email analytics service provider

Grounds for processing
- It is in Choice's legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Choice's business interests prevail over yours.

Recipients of data
- Other Choice entities involved
- IT service providers
- Email analytics service provider
- Advertising platforms

In order to assist our guests in booking, planning and enjoying their stay, we offer a mobile application. This mobile app can be downloaded through online app stores, including the Apple App Store or the Google Play store.

Depending on how you use our mobile application, your Personal Data may be processed for the purposes of (i) enabling you to reserve a room in the hotel of your choice (see also Hotel Booking Process); (ii) processing your online check-in; (iii) managing your room service order; (iv) booking reservations at your request at a local restaurant; (v) performing special services at your request such as wake up calls, late check-out, or turn down service; (vi) enabling you to book meetings and events in our hotels; (vii) processing your online check-out and your feedback on your stay; (viii) addressing the requests you have made through the mobile app, including through the chat; and (ix) view how many loyalty points you have collected.

To avoid having us receive or use your real-time location, do not opt into location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the application. Equally, if you would like to no longer receive push notifications via our mobile application, you can revoke push notification permission for the mobile application in your device’s operating system settings.

The information below describes the types of data we process in the context of our mobile application, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Email address, First name / Last name, Location data, Stay details, Telephone number

Source of data
- Directly from you when downloading our application(s) or when interacting with the application(s)

Ground for processing
- Ad hoc consent obtained during the installation of the application or in the context of your use of the application

Recipients of data
- The Radisson Hotels Americas hotel of your choice
- Other Choice entities involved
- Mobile applications provider
- Cloud and hosting service providers<
- iOS and Android app stores

iBeacon
iBeacons are electronic devices that broadcast signals that can be received by mobile devices on which our mobile application is installed. If you have voluntarily installed our app on your device, and if you have granted permission for the app to track your location, then iBeacons installed in our hotels may send a signal to the app on your device about the precise, real-time location of the device. The app may use this information to deliver special offers and promotions to you, at a time and place when the information is most relevant. For example, if you are in one of our hotels late in the afternoon, your mobile device may receive a signal from an iBeacon that causes the app to notify you about drink or dinner specials. As a convenience to you, receipt of the iBeacons signal and delivery of the special offer or promotion may occur even if you are not currently using the app. To make our mobile app and services operate better, we may also collect other information based on iBeacon signals, for example, the strength of the signal between the iBeacon and your device, the duration your device is near the iBeacon, or the battery level of the iBeacon itself. To avoid having us receive or use your precise, real-time location, do not opt into location services. If you did opt in and have changed your mind, you may opt out of location services through your device settings or by deleting the app.

Should you have a particular query or feedback, including the exercise of one of your rights under applicable law, you may contact us through the contact forms available on our website(s). In such context, we may process your Personal Data for the purposes of handling and providing an answer to your query or request or to follow up on your feedback. We also provide other forms on our websites which may assist you in requesting a particular service from us, such as the best online rate guarantee form.

The information below describes the types of data we process for these purposes, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Address, Email address, First name / Last name, Radisson Rewards Americas membership number, Stay details, Telephone number, and any other data you may decide to share with us in open comment boxes.

Source of data
- Directly from you through the form

Ground for processing
- Ad hoc consent obtained through the contact form

Recipients of data
- Other Choice entities involved
- IT service providers

1. Meetings and events organization and feedback

If you wish to organize a meeting or event in one of our hotels or if you would like more information on this possibility, you can reach out to us by filling in the Request a Proposal form or dedicated contact form on our website(s), by interacting with the online meetings and events chatbot, by directly contacting the hotel of your choice or by contacting us by other means. The Personal Data collected will be processed for the purposes of fulfilling your request to organize a meeting or event.

We may also send you meeting satisfaction surveys after your meeting or event to enable us to measure the performance of our hotels as meeting venues.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Address, Date of meeting or event, Email address, First name / Last name, Profession and employment, Radisson Rewards Americas membership number, Telephone number

Source of data
Directly from you through:

- the online Request a Proposal form
- the online contact form
- the meetings and events chatbot
- a request communicated by other means

Ground for processing
Depending on whether you contract directly with us or on behalf of your company:

- Processing is necessary to take steps at your request with a view to entering into and to perform a contract
- It is in Choice's legitimate interest as a business to have a lead contact person at the company organizing a meeting or event and providing feedback on that meeting or event. In this context, Choice's business interests prevail over yours.

Recipients of data
- The hotel of your choice
- Other Choice entities involved
- IT service providers
- Online chatbot service provider
- Meeting satisfaction survey provider

2. Meetings and events marketing communications

If you have opted in to receive commercial communications in the context of the organization of a meeting or event, we will also process your data to contact you with information about our services and latest offers.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Address, Email address, First name / Last name, Profession and employment, Telephone number

Source of data
Directly from you through:

- the online Request a Proposal form
- the online contact form
- the meetings and events chatbot
- a request communicated by other means

Ground for processing
Ad hoc consent obtained through:

- the Request a Proposal form online
- the contact form
- the meetings and events chatbot

Recipients of data
- Other Choice entities involved
- IT service providers
- Online chatbot service provider
- Email communications service provider
- The hotel at which the event/meeting is taking place

3. Meetings and events marketing communications analytics

In the context of our marketing communications concerning meetings and events, we may also process and collect your Personal Data, and notably whether you have opened and interacted with one of our communications, for analytical purposes in order to measure the click-through rate and improve the content of our marketing communications.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Email address, Email clicking behavior, Email opening behavior, First name / Last name, Profession and employment, Radisson Rewards Americas membership number

Source of data
- From our email analytics service provider

Ground for processing
- It is in Choice's legitimate interest as a business to understand the click-through rate of its emails in order to determine whether improvements are needed. In this context, Choice's business interests prevail over yours.

Recipients of data
- Other Choice entities involved
- IT service providers
- Email analytics service provider

We may use any data you provide to us for analytical purposes to optimize your experience, enhance our marketing, business and operational efficiency, create segments of our customers based on their Personal Data and tailor our offers and promotions to your preferences and consumption habits. In the context of such analytics, we analyze and may combine different data we hold about our guests, including (i) responses to guest satisfaction surveys; (ii) communications guests have with us; (iii) click-through rates for our marketing communications; (iv) our guests’ behavior on our websites; (v) bookings; and (vi) any information we receive via our Radisson Rewards Americas program. Please see also our dedicated sections on Meeting and Events Marketing Communications Analytics and Marketing Communications Analytics.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Hotel stay details, Address, Bookings (hotel, restaurant, event, theatre, etc.), Date of arrival and departure, Title, First name / Last name, First name / Last name of adult co-guest(s), Email address, Telephone number, Payment card type, number and expiration date, Radisson Rewards Americas membership number, redemption history

Source of data
- Directly from you when signing up to Radisson Rewards Americas or claiming or redeeming Radisson Rewards Americas points
- Directly from you through the online booking form
- Through the online booking channel you used to make the booking
- From your travel agent
- From our call center
- From our email analytics provider
- Directly from you when making your additional service/facility request with the hotel front desk or the concierge

Ground for processing
- It is in Choice's legitimate interest as a business to understand its guests’ preferences and consumption habits. In this context, Choice's business interests prevail over yours.

Recipients of data
- Other Choice entities involved
- IT service providers
- Analytics service provider
- Providers of targeted advertisements

We may process your Personal Data obtained through social media platforms (including Facebook, Instagram, LinkedIn, Weibo and Twitter) or online reviews (including on TripAdvisor) concerning our Radisson Hotels Americas brands for the purposes of (i) addressing your questions or complaints; (ii) monitoring our online reputation; and (iii) improving our services and identifying opportunities on which we can focus.

Some of our social media pages allow users to submit their own content. Please remember that any content submitted to one of our social media pages can be viewed by the public, and you should be cautious about providing certain personal information (e.g., financial information or address details) via these platforms. We are not responsible for any actions taken by other individuals if you post personal information on one of our social media platforms (e.g., Facebook or Instagram). Please also refer to the respective privacy and cookie policies of the social media platforms you are using.

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- Any Personal Data you may decide to share with us or published on social media or in other online reviews about us

Source of data
- Directly from you through publicly accessible social media pages, online booking channels or other (review) websites
- From our online reputation monitoring service provider

Ground for processing
- It is in Choice's legitimate interest as a business to process the Personal Data you have chosen to address to us or make publicly available on social media platforms, online booking channels or other (review) websites in order to improve our services and identify business opportunities. In this context, Choice's business interests prevail over yours.

Recipients of data
- Other Choice entities involved
- Online reputation monitoring service provider

Social media contests

From time to time, we may organize a contest on one of our social media pages. If you choose to participate in such contest, we will process your Personal Data for the purpose of organizing and managing the social media contest and picking the winner(s).

The information below describes the types of data we process for this purpose, where we get your data from, the ground we rely on to carry out the processing, and who we may share your data with.

Processed data categories
- This depends on the data fields in the contest concerned, but typically includes the following categories of data:

Address, Email address, First name / Last name, Telephone number

Source of data
- Directly from you through our social media pages

Ground for processing
- Processing is necessary to take steps to enter into and perform a contract as you accept the terms and conditions of the contest.

Recipients of data
- Other Choice entities involved
- IT service provider

Depending on where you are located you will have different rights in respect of your Personal Data and we will comply with the relevant requirements of applicable laws and this Privacy Policy.

You may exercise the rights summarized below in respect of this Privacy Policy where such rights apply in your particular jurisdiction. These rights can in principle be exercised free of charge, except that we may charge you a reasonable fee where your request is excessive, repetitive, unfounded or vexatious. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request via email at privacyinquiry@choicehotels.com.

Should you have unresolved concerns, you have the right to lodge a complaint with a Supervisory Authority where you live or where you believe a breach may have occurred. We encourage you to come to us in the first instance but, to the extent that this right applies to you, you are entitled to complain directly to the relevant Supervisory Authority.

1. Right to withdraw consent

Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging in to your account on our website (if you have one) or by contacting us at privacyinquiry@choicehotels.com. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent. Please note that we may have other legal grounds for processing your data for other purposes, such as those set out in this Privacy Policy.

2. Right to access and rectify your data

You have the right to access, review, and rectify your Personal Data. You may be entitled to ask us for a copy of your information, to review or correct it if you wish to rectify any information like your name, email address, passwords and/or any other preferences, you can easily do so by logging in to your account on our website (if you have one) or by contacting us at privacyinquiry@choicehotels.com. You may also request a copy of the Personal Data processed as described in this Privacy Policy.

3. Right to erasure

You have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request via privacyinquiry@choicehotels.com.

4. Right to restriction of processing

You may ask us to restrict the processing of your Personal Data. This is the case when you contest the accuracy of your Personal Data or the lawfulness of our processing. In such event, we will restrict the processing until we can verify the accuracy of your data.

5. Right to object to processing

You may object to the processing of your Personal Data where our ground for processing is our legitimate interests. However, we may continue to process your Personal Data if either we demonstrate compelling legitimate grounds for the processing which override the your rights in the specific circumstances or where we need to process your Personal Data for the establishment, exercise or defense of legal claims. You have the absolute right to object to the processing of your Personal Data where this is for direct marketing purposes.

6. Right to data portability

Where you have provided your data directly to us and where the processing is carried out by automated means and based on your consent or the performance of a contract between you and us, you have the right to receive the Personal Data processed about you in a structured, commonly used and machine-readable format, and to transmit this data to another service provider.

California Privacy Rights

If you reside in California, you have the rights set forth in our California Privacy Policy.

Appropriate technical and organizational measures are implemented in order to ensure an appropriate level of security of your Personal Data, including but not limited to encryption techniques, physical and IT system access controls, obligations of confidentiality, etc.

In the event Personal Data is compromised as a result of a Personal Data Breach we will make the necessary notifications, as required under applicable laws.

We only share or disclose information as described herein, including with Third Parties.

Your Personal Data will also be shared: (i) with government authorities and/or law enforcement officials if we believe it to be necessary or appropriate to comply with applicable law; (ii) if mandated by law; (iii) if we believe it to be necessary or appropriate for the legal protection of the Controller(s) legitimate interests in compliance with applicable laws; (iv) to protect the rights, privacy, safety or property of Choice, you or others; (v) to enforce our terms and conditions; and (vi) to allow Choice to pursue available remedies or limit the damages that we may sustain in each case to the extent required under, or permitted by, applicable law. In addition, we may share your Personal Data and other information with a successor to all or part of our business, where this is in our legitimate interests in facilitating a business sale and in this context our business interests prevail over yours. For example, if parts of our business or assets are sold, we may disclose user information as part of that transaction, subject to applicable law.

We are based in the United States and so information is transferred to and accessed by our personnel in the United States. You consent to the processing, transfer and storage of your information in and to the United States and other countries, where you may not have the same rights as you do under your local law. We will process your Personal Data in accordance with applicable law and with this Privacy Policy regardless of where your personal information is stored or accessed.

If you reside in a jurisdiction which restricts the international transfer of your Personal Data, the data that we collect from you as described in this Privacy Policy may be transferred to and stored at a destination outside that jurisdiction, including for the purposes of processing that data by selected Processors, in order to facilitate Choice’s business. Countries outside your jurisdiction may not have laws which provide the same level of protection to your Personal Data as laws within your jurisdiction. Where this is the case we will put in place appropriate safeguards to ensure that such transfers comply with applicable law, for example by putting in place Standard Contractual Clauses or by ensuring that the transfer is to an organization certified to any compliance or certification mechanism recognized by your jurisdiction or to a territory which your jurisdiction deems provides an adequate level of protection of Personal Data.

In case you wish to obtain more details about our data transfer safeguards and the mechanisms in place, you may contact us at privacyinquiry@choicehotels.com.

We retain your Personal Data for as long as is required to fulfill the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law. For example, we may retain your Personal Data if it is reasonably necessary to comply with any legal obligations, meet any regulatory requirements, resolve any disputes or litigation, or as otherwise needed to enforce this Privacy Policy and prevent fraud and abuse.

To determine the appropriate retention period for the information we collect from you, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

Questions, comments, remarks, requests or complaints regarding this Privacy Policy or our privacy practices are welcome and should be addressed to privacyinquiry@choicehotels.com. If you have questions about an individual hotel’s practices or the information it has, please contact the hotel directly.

You can also write us at:

Choice Hotels
Attention: Privacy Officer
18615 Claret Drive
Scottsdale, AZ 8525

For individuals in Quebec, Canada, the title and contact information of the person responsible for protection of personal information is:

Privacy Officer

Choice Hotels International
Attention: Privacy Officer
18615 Claret Drive
Scottsdale, AZ 85255
Email: privacyinquiry@choicehotels.com