Under the California Consumer Privacy Act (“CCPA”), we are required to notify California consumers about our collection, use and disclosure of their personal information (whether collected through this website or offline). In this section of our Privacy Statement, and in accordance with the CCPA, “personal information” includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
This Privacy Statement does not apply to applicants for positions with IHG.
Categories of Personal Information that We Collect, Disclose, and Sell
Below we identify the categories of personal information that we collect about California consumers and households, the purposes for which we use each category, and whether we disclose or sell information within each category. Please note our data collection practices set forth below are not different than those described above; rather, the CCPA specifies particular categories of data that we must address, and, in this section, we aim to describe some of the information already provided above in accordance with the categories as outlined by the CCPA. This section should therefore be read in conjunction with the further information provided in the rest of this Privacy Statement.
Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation.
Identifiers and Similar Data:
Collection. We collect:
- Identifiers: Your real name, alias, postal address, unique identifier (e.g., your IHG® Rewards number if you choose to enrol in the program), IP address (if you access our websites, emails or other digital channels), email address or other similar identifiers.
- Signature, physical characteristics, telephone number, financial information (e.g., payment information for your reservation). We typically do not collect medical information from our guests absent an emergency situation or specific request (which typically would be information provided to us by IHG-branded hotels and not information that we collect directly from you).
- Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Sources: We collect the information directly from you, from other persons/entities making a reservation on your behalf (e.g., travel agent, a member of your travel party, someone making the booking on your behalf) from IHG-branded hotels (that are independently owned and operated). In limited circumstances, we may obtain this information from carefully selected travel partners, including airlines and rental car agencies. With regard to the internet or other electronic information, we collect that information automatically as you use our Site and services.
Purposes of Collection: The primary purpose of our collection and use of this information is to fulfil your reservations and enhance and personalise your experience with us. In particular, we use your information to fulfil your reservation, manage your IHG® Rewards account, send direct marketing to you (in connection with your preferences), send targeted and personalised advertising to you, and as otherwise required by applicable law.
Disclosure: We disclose this information for business purposes, including at your direction, to IHG-branded properties (e.g., if you make a reservation through our central reservation department, then we share that information with the applicable property so that they can fulfil your request). We also share certain of your information to our carefully selected partners, including airlines and rental car agencies, for the purpose of personalising your stay; for example, if we know that you are arriving early in the morning, we may seek to offer you an early check-in. If you use our WiFi services at IHG-branded properties, we share certain unique identifiers like your device’s MAC address with our internet service providers to provide WiFi to you.
Sale: We use third party targeted advertising companies that collect certain information about you through website cookies (and similar technologies designed for mobile applications). These third parties may collect information about you that they then aggregate with data collected about you through cookies placed on other websites/mobile apps. Under the CCPA, this type of sharing of information could be deemed a “sale”. We also disclose your information to carefully selected marketing partners, advertising technology vendors and social media platforms through a central marketing/analytics company. We direct which entities may have access to your information and the scope of information to which they may access. This type of disclosure only occurs in limited markets and California consumers may opt out at any time through our communications portal and by clicking on the Do Not Sell link on our website/in the mobile app.
Protected Classifications/Audio/Visual Data:
Collection: We do not request information about protected classifications under California law such as race, sex, age, religion, national origin, disability, citizenship information, or genetic information. Nonetheless, we may capture information related to these categories in the following circumstances, by way of example only: IHG corporate offices and certain IHG-branded hotels use closed-circuit television for security purposes and the recordings may capture such information by virtue of the recording. We do not obtain recordings from the IHG-branded properties absent a unique situation (e.g., concern for security at a particular property). You have the option of providing your age range when you sign up for IHG® Rewards, but we do not require you to disclose that information. You have the option of requesting an accessible room.
Sources: We collect the information directly from you, from other persons/entities making a reservation on your behalf (e.g., travel agent, a member of your travel party, someone making the booking on your behalf), from IHG-branded hotels (that are independently owned and operated). In limited circumstances, we may obtain this information from carefully selected travel partners, including airlines and rental car agencies.
Purposes of Collection: The primary purpose of our collection and use of this information is to enhance and personalise your stay with us, in particular, to provide you with the specific room type requested. We may use video surveillance for security purposes and to protect their rights and interests as well as the rights and interests of other guests.
Disclosure: We disclose any information about special requests for business purposes, including at your direction, to IHG-branded properties (e.g., if you make a reservation through our central reservation department, then we share that information with the applicable property so that they can fulfil your request). If we obtain CCTV footage, we do not disclose such data except as necessary to protect our rights and interests and the rights and interests of other persons.
Sale: We do not sell this information.
Biometric and Geolocation Information:
Information Collected: In an effort to enhance your stay with us and to provide for a faster and easier check-in process, we may offer certain services on property such as check-in and/or room entry through the use of biometric identifiers at a limited number of IHG-branded properties. Any interested guest must affirmatively opt-into the programme; Where IHG is providing these services we will provide information about the specific biometrics collected through the programme and the use and disclosure of those identifiers so that you can choose whether you would like to participate in any particular programme. With your consent, we collect your geolocation information through our mobile application and our website or from internet service providers through certain services we offer on property such as IHG Connect (WiFi). We use this information for analytics purposes (e.g., to determine the general area where our guests may access our services from), to personalise your experience (e.g., suggest hotels of interest), and, in certain limited markets, to provide special offers based on your location.
Sources: We collect biometric information and geolocation information directly from you and automatically as you use devices designed to collect biometric information or, in the case of geolocation information, your own device.
Purposes of Collection: The primary purpose of our collection and use of this information is to enhance and personalise your stay with us. In particular, we use your information to create a faster check-in and/or room entry experience. With regard to geolocation information, we also seek to offer you relevant offers based on your location, where permitted.
Disclosure: Where this service is offered, we may disclose your biometric information to service providers that assist us in validating your identity. We may make available your biometric identifier to the IHG-branded property where you are staying for the purposes of that particular stay.
Sale: We do not sell your biometric information.
We may draw (or use service providers to draw) inferences from any of the information identified above to create or enhance a profile about a consumer reflecting the consumer’s preferences and tendencies (e.g., what types of properties the consumer prefers, how frequently the consumer travels, etc.). We may purchase aggregated and deidentified data and append such data to your profile (e.g., based on your age range) to assist us in determining relevant marketing opportunities.
Sources: We draw inferences based on the data collection described in this Notice.
Purposes of Collection: We use inferences to enhance your overall experience with IHG. For example, we may use inferences to identify and offer relevant marketing opportunities. Disclosure: We may disclose your information to carefully selected marketing partners, advertising technology vendors and social media platforms to provide relevant offers to you.