LAST UPDATED: June 2021
Use and Processing of the Information We Collect
The following chart provides examples of the type of information that we collect from you and how we use that information:
|Context||Types of Information||Primary Purpose for Collection|
and Use of Information
|Room Reservations||We collect your contact information, payment information, reservation information, and accommodation preferences. That information is collected directly from you when you make a room reservation. In a small number of cases, we collect information about a guest’s health where it has been volunteered. For example, a guest may voluntarily choose to provide information about a disability as part of a request for an accommodation preference.||We use your information in order to perform our contractual obligations, fulfil your requests for a reservation, and to take steps in anticipation of those obligations. In some jurisdictions we also need your information to comply with legal obligations to collect and maintain information about guests. We also have a legitimate interest in analysing trends and patterns among guests. In the rare circumstances in which we collect information about a guest’s health, that information is collected only for the purpose of accommodating a guest’s needs and is used for no other purpose.|
|Product / Service Orders||We collect your contact information, payment information and order information. That information is collected directly from you when you make an order for a product or service.||We use your information in order to perform our contractual obligations, fulfil your requests for a product or service, and to take steps in anticipation of those obligations. In some jurisdictions we also need your information to comply with legal obligations to collect and maintain information about guests. We also have a legitimate interest in analysing trends and patterns among guests.|
|Best Western Rewards® (“BWR”)||BWR is Best Western’s customer loyalty programme. We collect your contact information, communication preferences, reservation history, redemption details, and partner loyalty programme elections. Information is collected when you register for BWR, redeem reward points, make a hotel reservation, update your BWR account, or link your BWR account to a partner loyalty programme.||We use your information in order to perform our contractual obligations to you. For example, we use the information to allow you to earn and redeem rewards, points, or credits in connection with loyalty programmes. We also have a legitimate interest in marketing to you and analysing trends and patterns among our rewards members. For complete BWR programme terms see www.bestwesternrewards.com.|
|Best Western Travel Card®||We collect your contact information and payment information when you purchase a Best Western Travel Card®.||We use your information in order to perform our contractual obligations to you. We also have a legitimate interest in marketing to you and analysing trends and patterns among our Best Western Travel Card holders.|
For complete Best Western Travel Card terms and conditions see https://www.bestwestern.com/en_US/offers/travel-card.html.
|Cookies and Third Party Tracking||We participate in behaviour-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our Website so that it can provide advertising about products and services tailored to your interests on our Website or on other websites.||We have a legitimate interest in engaging in behaviour-based advertising.|
|Email Interconnectivity||If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, or make reservations.||We have a legitimate interest in understanding how you interact with our communications to you.|
|Customer Care||If you contact us with an issue, we will collect your name and e-mail address, as well as any other content that you send to us in order to reply.||We have a legitimate interest in receiving and acting upon the information that you provide to us concerning issues that you raise.|
|Communications List||When you opt-in or sign up to receive communications, we collect your email address, postal address, or phone number for text messaging.||We share information about our products and services or the products and services of other companies, if you consent to receive that information. We also have a legitimate interest in sharing information with you about our services and those of our partners.|
|Mobile Devices||We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our Websites or applications.||We have a legitimate interest in identifying unique visitors and in understanding how users interact with us on their mobile devices.|
|Partner Promotion||We collect information that you provide as part of co-branded promotions with other companies. For example, we collect information if you apply for a Best Western co-branded credit card.||We have a legitimate interest in fulfilling our promotions. That interest includes sharing your information with our partners to, among other things, determine your eligibility for a promotion.|
|Surveys||When you participate in a survey, we collect information that you provide through the survey.||We have a legitimate interest in understanding your opinions and collecting information relevant to our organisation to improve our services.|
|Services||When making a reservation or purchasing a product, we collect information about you that allows us or a Licensed Hotel, via Third Party Partners, to offer goods or services that may enhance your purchase. For example, enhancement of products purchased at Licensed Hotels.||We have a legitimate interest in maximising your experience of our products and services. That interest includes sharing your information with our partners that, among other things, facilitates the provision of those services.|
|Sweepstakes or Contests||When you participate in a sweepstake or contest, we collect information about you that includes contact information to notify you if you are selected.||We have a legitimate interest in operating sweepstakes. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.|
|Website Interactions||We use website recording technology to monitor how you interact with our Website. This may include the links you click on, mouse movements or information that you type into our online forms.||We have a legitimate interest in understanding how you interact with our Website to better improve it and to understand your preferences and interests in order to select offerings that you might find most useful.|
|Web Logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our Website. Among other things, it helps us understand which of our services is the most popular.|
|WiFi Access||Although we do not provide WiFi networks at Licensed Hotels, we do provide access to WiFi at BWGB offices (e.g., our headquarters). We collect information about individuals that access those WiFi networks.||We have a legitimate interest in providing WiFi networks and in collecting information for fraud and security purposes.|
|CCTV Images||We maintain the use of closed-circuit television cameras (CCTV) at BWGB offices (e.g., our headquarters). We collect recorded images of individuals that visit our premises.||We have a legitimate interest in collecting information for security purposes.|
|Employment Candidates||If you apply to work for us, we collect information necessary to evaluate your application.||We use information about prospective employees in connection with our legal obligations and our legitimate interest in evaluating candidates.|
|Employees||If you are or were an employee of BWGB, we collect information necessary to your employment.||We use information about current employees in connection with our employment obligations. In some contexts, we are also required by law to collect information about our employees and we have a legitimate interest in complying with those laws. We also have a legitimate interest in using employment information to have efficient staffing and work force operations.|
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including BWI, Affiliates, business partners, or publicly available sources. For example, if you make a reservation at one of our Licensed Hotels, that hotel transmits information to us as part of our legitimate interest in, among other things, maintaining a global reservation system and providing for customer service and support.
In addition to the purposes and uses described above, we use information in the following ways:
• For internal administrative purposes as well as to manage our relationships.
• To conduct analytics.
• To identify you when you visit our Websites or Licensed Hotels.
• To provide services to you and to improve our services and product offerings.
• To respond to inquiries related to support, employment opportunities, or other requests.
• To send marketing and promotional materials, including information relating to our products, services, sales, or promotions.
• To streamline the reservation or checkout process.
• For the safety and security of guests, staff, and other visitors.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you make a room reservation we collect your information so that we, or so that a Licensed Hotel, can perform a contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your stay. As a result, our collection and processing of your information may be based upon our need to perform a contract, our obligations under law, our legitimate interest in conducting our business, and/or your consent.
Sharing of Information
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
2. BWR Partners. We share information with independent companies that we have partnered with, or that are participants in our BWR programme, to allow you to earn and redeem rewards, points, or credits in connection with your BWR membership and in accordance with your chosen earning and spending preferences. For example, you may decide to select a particular airline partner through which you can earn BWR points. We also share information with independent companies if you have selected that you would like to receive promotions and marketing material from Best Western’s third-party business partners.
4. Travel Agents and Online Travel Websites. We share your information with travel agents, and/or online travel websites that you use in order to process your reservation request and to comply with any requirements or needs of those entities.
5. Service Providers. We share your information with service providers. Among other things, service providers help us to administer our databases, Websites, marketing, communications, and surveys; service providers provide us with technical and logistical support; service providers process payments on our behalf; and service providers assist in the fulfilment of reservations and orders. If a service provider receives information from us about an EU data subject or a Swiss data subject and takes an action that is contrary to the principles of the EU-US Privacy Shield or the Swiss-US Privacy Shield, we shall be liable for those actions unless we prove that we are not responsible for causing them.
6. Public. Some of our Websites may provide the opportunity to post comments or reviews in a public forum. If you decide to submit information on these pages, that information may be publicly available.
7. Other Disclosures Without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws or for national security requirements within the United Kingdom or the other jurisdictions in which we operate. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary. We also may share information with our corporate affiliates (e.g., subsidiaries, joint ventures, or other companies under common ownership or control). In addition, if another company acquires or plans to acquire our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
You can make the following choices regarding your personal information:
1. Promotional Emails. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
2. Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with "NO SNAIL MAIL" in the subject line along with your name, address and postal code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
3. Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
4. Access to Your Personal Information. You can request access to your personal information by completing and submitting a Request Form. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
5. Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our Websites allow you to modify or delete your account profile. Note that we may keep historical information in our backup files as permitted by law. If our Website does not permit you to update or correct certain information you can request that your information be changed by completing and submitting a Request Form. Although BWGB will attempt in good faith to respond to your request, we may not be able to change your information in all circumstances. For example, we may not be able to change your information if doing so would impose an undue burden or expense, or if it would require us to change information relating to another person.
6. Deletion of Your Personal Information. You can request information about how long we keep a specific type of information by contacting us at the address described below. You can request that your information be deleted by completing and submitting a Request Form. If required by law, we will delete your personal information after such a request is made. You should note that there are some situations in which we may decline to delete your information. For example, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
7. Revoking Consent or Objecting to Processing. You can revoke consent to processing (where such processing is based upon consent) or object to our processing by completing and submitting a Request Form. If you revoke consent or object to further processing, we may no longer be able to provide you services. In some cases, we may limit or deny your request if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
8. Online Tracking. Your web browser may let you choose your preference as to whether you want to allow websites to collect information over time about your online activities across different websites or online services. At this time, the Website does not respond to such “Do Not Track” or similar preferences you may have configured in your web browser, and the Website may continue to collect information in the manner described in this Policy. However, as stated in the “Cookies” paragraph located in the “Miscellaneous” section later in this Policy, we do allow you to exercise some choice in the information collected by adjusting your browser’s cookie settings.
How We Protect Personal Information
No method of transmission over the Internet or of electronic storage is fully secure. While we use reasonable efforts to protect your personal information from unauthorised access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any breach to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Some of our Websites permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorised by you. You should notify us of any unauthorised use of your password or account.
How Long We Retain Information
We retain your personal information for the period necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required or permitted by law. For example, we retain BWR information for as long as an individual remains a BWR member because BWR points do not expire and the information is needed in order to allow the individual to redeem their rewards. We retain information in our reservation system, in full or in summary form, for three years following a guest’s departure in order to process your reservation, provide post-reservation customer support, and provide invoicing and recordkeeping. We typically retain information in our customer care complaint system for three years after receipt, unless the information is needed for an ongoing purpose such as to address an open issue.
Countries Used for Processing
BWGB operates from the United Kingdom in accordance with the laws of the United Kingdom. As an Affiliate of BWI, data shared with BWGB is transferred to BWI, operating in the United States. Individuals that provide information to BWGB or visit BWGB’s Website should be aware that the laws of the United Kingdom and United States may differ from those of your country of residence. For example, there may be situations in which we are required to share your information with United Kingdom or United States law enforcement personnel. The following provides additional information for data received by BWGB from other countries or transmitted by BWGB to other countries:
• Transmission of Information from the UK. If BWGB transmits your information to a processor outside of the UK, BWGB will take steps to ensure that the processor complies with the substantive principles of the UK GDPR. If you would like more information
concerning the protections applied for a particular onward transfer you can contact us using the information below. If you feel that BWGB has mishandled your personal information, please contact BWGB using the contact information below with a written
description of your complaint. After receiving such written description, a representative from BWGB's Customer Care Department will contact you to set up a time and manner to discuss your complaint. BWGB is dedicated to addressing all legitimate complaints
about its treatment of your personal information and will make a good faith effort to engage in communications to address such complaints.
By booking a reservation, or providing your information to BWGB, you understand that you are transferring your information directly to BWI in the United States, which is a form of processing that you are choosing to undergo, and that the United States may not offer the same level of privacy protections as your home country.
• Transmission of Information to Other Countries. In addition to having your information transferred to the United States where BWI is located, if you are making a reservation at a Licensed Hotel in a foreign country your information will be sent to that hotel, as well as to any Affiliate associated with that hotel. In addition, we may send your information to a vendor or partner in a foreign country for purposes of administering our BWR programme and marketing efforts.
Other Important Information
The following additional information relates to our privacy practices:
• Cookies. Cookies are small text files placed on your computer or mobile device by a website’s server and are commonly used on the internet. It contains anonymous information, for example a unique identifier and the name of the website, as well as some numbers and digits. We use them to:
• remember your preferences, and items you have placed in your shopping cart;
• collect information that will help us understand visitors' browsing habits on our Website;
• compile statistical reports on website activity, e.g. number of visitors and the pages they visit;
• temporarily store any information which you may enter in tools, such as calculators or demonstrations on our Website;
• in some cases, remember information about you when you visit our site. We may need to do this to provide some of our services;
• in some cases, information about your booking so you can return to it at a later stage.
We also collect Non-Personal Information when you voluntarily provide this information to us. Additionally, we may aggregate or anonymise Personal Data in a manner such that the end product does not personally identify you or any other individual (e.g., by using Personal Data to calculate the percentage of our Website users who are from a particular geographic location). We do not store any personal information in cookies that others could read and understand.
We use three types of cookie:
• Session cookies – these are temporary and are deleted as soon as you close your browser.
• Persistent cookies – these are stored on your computer until they expire, or you remove them. Persistent cookies store your personal preferences such as your language preferences on multi-lingual sites to make subsequent visits easier. They also, for example, remember questions we have asked you previously, such as a request to complete an online survey. A persistent cookie will prevent you from being asked to complete the same survey every time you visit the Website.
• Third Party cookies - In addition, we may engage third party tracking and advertising providers to act on BWGB’s behalf to track and analyse your usage of our Website through the use of such automatic data collection technologies. These third parties collect and share with us, as we may request, website usage information about visits to our Website, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our Website, help us target and track use of our Internet banner advertisements on our Website and on other websites, and track use of other links from our marketing partners' websites to our Website. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. Our Website may also use a website recording service which may record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. Data collected by this service is used to improve our Website usability. The information collected is stored and is used for aggregated and statistical reporting and is not shared with anybody else.
Our Website may also use software to improve your user journey by identifying areas you have visited before or areas you may be interested in. To do this we may drop persistent and session cookies onto your computer or device. The information collected is safely stored and is also used for aggregated and statistical reporting. We will not collect any Personal Data.
Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. The “Help” function within your browser should tell you how to do this.
If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Alternatively, the websites www.aboutcookies.org and www.allaboutcookies.org
have produced a series of web pages which explain how cookies work and how they can be managed.
• Website Interactions. Entry into website forms can be removed by visiting the web address https://sessioncam.com/choose-for-form-data-not-to-be-recorded/ and selecting ‘Enable Masking of All Data’, whilst tracking on the Website entirely can be removed by visiting the web address https://sessioncam.com/choose-not-to-be-recorded/ and selecting ‘Disable Tracking Completely’.
• Web Logs. Your IP address is a number that your Internet Service Provider automatically assigns to the computer that you are using to access the Website. This number is identified and logged automatically in our server log files whenever users visit the Website, along with the time of each visit and the page(s) that were visited. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites. We use IP addresses for purposes such as calculating website usage levels, helping diagnose server problems, validation of a legitimate user session via Google® captcha and administering the Website. Please note that we treat IP addresses, server log files, and related information as Non-Personal Information, except when we are required to do otherwise under applicable law.
We will attempt to respond to any questions, comments, or complaints concerning our privacy practices. Please feel free to contact us using the following information:
If you would like to update your information or modify your communication preferences, please contact us by e-mail at email@example.com, by phone on 01904 695482 or write to us at the following address:
Best Western GB,
Amy Johnson Way,
Should you have any questions about this privacy statement or your personal data, please contact our Data Protection Officer at firstname.lastname@example.org or by phoning 01904 695400.
Should you have any queries or concerns regarding BWI’s handling of your Personal Data, please e-mail email@example.com or write to the following address:
(BWI representative in the EU)
Best Western International, Inc.
Unit 7 Citylink Business Park
Old Nass Road
Please note that e-mail communications will not necessarily be secure; accordingly, you should not include payment information or sensitive information in e-mail correspondence to us.
If you are not satisfied with our response, and are in the UK or European Union, you may have a right to lodge a complaint with your local supervisory authority.
LAST UPDATED: June 2021
EFFECTIVE: June 2021