PRIVACY POLICY
1. Scope
This Privacy Policy applies to Personal Information Processed by Trestle Choo Choo Hotel Manager LLC
in the
course of operating our business, including on our websites (each a “Site”), mobile applications,
check-in
kiosks, messaging services, forums, blogs, and other online or offline offerings (collectively, the
“Services”). The terms “TCCHM”, “we”, and
“us”
include Trestle Choo Choo Hotel Manager LLC and our affiliates and subsidiaries.
This Policy applies to all TCCHM‘s operating divisions, subsidiaries, affiliates, and
branches,
and
any additional subsidiary, affiliate, or branch of TCCHM that we may subsequently form.
All
individuals whose responsibilities include Processing Personal Information for us are expected to
protect it
by
following this Privacy Policy.
2. Transparency/Notice
2.1. Personal Information We Collect and How We Use It
The types of Personal Information we collect, and our privacy practices depend on whether you are a
customer,
user, visitor (together, “Individuals”) and the requirements of applicable law.
- Choo Choo Hotel Information. When you register for or use the
Services, or
make a purchase online or in-person, we will collect information from you. This may include
Registration
Data, your name, email address, phone number, address, travel itinerary, date of birth, a copy
of your
government ID, credit card information, and other related information. We may also issue you a
personal
invite and/or promotional code. - Information about your Stay. When you stay at one of our hotels, we may collect
information
about your experience, including amenities purchased, preferences, feedback, and other related
information. - Communications with Us. We may collect Personal Information and the contents of
your
communication when you request information about our Services, register for our newsletter or
loyalty
program, request customer or technical support, or otherwise communicate with us. If you call
our
customer
support line, you agree we may record your conversation for quality assurance, fraud prevention
and
training
purposes. - Surveys. We may contact you to participate in surveys. If you decide to
participate,
you
may be asked to provide certain information which may include Personal Information. - Interactive Areas. We may offer forums, blogs, social media pages, messaging
services,
and
other Interactive Areas. TCCHM may collect the information you share in these
channels,
including the content of any messages. Any content you provide on public or community areas of
these
channels, including User - Biometric Information. As part of the check-in process, we may ask you to
provide a
government ID and also to take a “selfie”. We (and our service providers) may collect biometric
information
contained in both images and compare it for fraud and verification purposes. We do not use this
biometric
information for any other purpose. - Registration for Sweepstakes or Contests. We may run sweepstakes and contests.
Contact
information you provide may be used to reach you about the sweepstakes or contest and for other
promotional,
marketing and business purposes, if permitted by law. In some jurisdictions, we are required to
publicly
share information of winners. - Automatic Data Collection. We may collect certain information automatically
when you
use
the Services. This information may include your Internet protocol (IP) address, user settings,
IMEI, MAC
address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers,
details
about
your browser, operating system or device, location information, information about when you lock
or
unlock a
hotel room door with the mobile application, Internet service provider, pages that you visit
before,
during
and after using the Services, information about the links you click, and other information about
how you
use
the Services. Information we collect may be associated with accounts and other devices. - Information from Other Sources. We may obtain information about you from other
sources,
including through third party services and organizations (such as credit agencies) to supplement
information
provided by you. For example, if you access our Services through a third-party application, such
as an
App
Store, a third-party login service, or a Social Networking Site (e.g., Google, Facebook, etc.),
we may
collect information about you from that third-party application that you have made public via
your
privacy
settings. Information we collect through these services may include your name, your user
identification
number, your username, location, gender, birth date, email, profile picture, and your contacts
stored in
that service. This supplemental information allows us to verify information that you have
provided to us
and
to enhance our ability to provide you with information about our business, products, and
Services.
2.2. How We Use Your Information
We Process Personal Information about Individuals for a variety of business purposes, including:
- To Provide Products, Services, or Information Requested including to:
- Process and complete any transactions in connection with the Services (e.g., to sell you a
hotel
room); - Manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of our Services;
- Answer requests for customer or technical support;
- Allow you to register for events.
- For Administrative Purposes including to:
- Measure interest and engagement in our Site and Services;
- Conduct research and development;
- Improve our products and Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate with you about your account, activities on our Site and Services and policy
changes; - Process your financial information and other payment methods for products or Services
purchased; - Prevent potentially prohibited or illegal activities;
- Enforce our Terms;
- To Market Our Products and Services. We may use Personal Information to provide
you
with
materials about offers, products, and Services that may be of interest, including new content or
Services.
We may provide you with these materials as permitted by applicable law. Such uses include: - To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our partners;
- Other purposes you consent to or are disclosed when you provide Personal Information.
You may contact us at any time to opt out of the use of your Personal Information for marketing
purposes as
described below.
- De-identified and Aggregated Information Use. We may use Personal Information
and other
information about you to create de-identified and aggregated information, such as de-identified
demographic
information, de-identified location information, information about the computer or device from
which you
access our Site and Services, or other analyses we create. De-identified or aggregated
information is
not
Personal Information, and we may use such information in a number of ways, including research,
internal
analysis, analytics, and any other legally permissible purposes. - Other Uses. TCCHM may use Personal Information to pursue
legitimate
interests,
such as direct marketing, research (including marketing research), network and information
security, and
fraud prevention, or any other purpose disclosed to you at the time you provide Personal
Information or
with
your consent.
2.3. Cookies, Pixel Tags/Web Beacons, Analytics Information, And Interest-Based
Advertising
We, as well as third parties that provide content, advertising, or other functionality on the
Services, may
use
cookies, pixel tags, local storage, and other technologies (“Technologies”) to
automatically
collect information through the Services. Technologies are essentially small data files placed on
your
computer,
tablet, mobile phone, or other devices that allow us to record certain pieces of information
whenever you
visit
or interact with our Site and Services.
- Cookies. Cookies are small text files placed in visitors’ computer browsers to
store
their
preferences. Most browsers allow you to block and delete cookies. However, if you do that, the
Services
may
not work properly. - Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of
code
embedded on the Site that collects information about users’ engagement on that web page. The use
of a
pixel
allows us to record, for example, that a user has visited a particular web page or clicked on a
particular
advertisement. - Analytics. We may also use Google Analytics, Mixpanel, and other service
providers to
collect information regarding visitor behavior and visitor demographics on our Site and
Services. For
more
information about Google Analytics, please visit
http://www.google.com/policies/privacy/partners/. You
can
opt out of Google’s collection and Processing of data generated by your use of the Services by
going to
http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to
our Site,
Services, applications, and tools that are required to identify irregular site behavior, prevent
fraudulent
activity and improve security or that allow you to make use of our functions such as
shopping-carts,
saved
search, or similar functions; - Performance Related. We may use Technologies to assess the performance of our
Services,
including as part of our analytic practices to help us understand how our visitors use the
Services; - Functionality Related. We may use Technologies that allow us to offer you
enhanced
functionality when accessing or using our Site and Services. This may include identifying you
when you
sign
into our Site or Services or keeping track of your specified preferences, interests, or past
items
viewed; - Advertising or Targeting Related. We may use first party or third-party
Technologies to
deliver content, including ads relevant to your interests, on our Site and Services or on Third
Party
sites.
2.4. Third Party Websites, Social Media Platforms And Software Development Kits
The Services may contain links to other websites and other websites may reference or link to our Site
or
other
Services. These other domains and websites are not controlled by us. We encourage our users to read
the
privacy
policies of each website and application with which they interact. We do not endorse, screen or
approve, and
are
not responsible for the privacy practices or content of such other Third-Party Content, websites or
applications. Visiting these other websites or applications is at your own risk.
TCCHM’s Services may include publicly accessible blogs, forums, social media pages, Interactive
Areas, and
private messaging features. By using such services, you assume the risk that the Personal
Information
provided
by you may be viewed and used by Third Parties for any number of purposes.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of
our
Services.
APIs and SDKs may allow third parties including advertising partners to collect your Personal
Information to
provide content that is more relevant to you. For more information about our use of APIs and SDKs,
please
contact us as set forth below.
3. Onward Transfer—How We May Disclose Your Information
3.1. Information We Share
We may share your information as described in this Privacy Policy:
- Hotels to Book your Stay. When you purchase a hotel room operated by TCCHM, we
will
provide
your information to that property in order to facilitate the transaction you requested. If all
hotels in
the
TCCHM network are booked up, we may provide your information to other hotels we work with. - We Use Vendors and Service Providers. We may share any information we receive
with
vendors
and service providers. The types of service providers (processors) to whom we entrust Personal
Information
include service providers for: (i) provision of IT and related services; (ii) provision of
information
and
services you have requested; (iii) payment processing; (iv) customer service activities; and (v)
the
provision of the Site and Services. - Business Partners. We may provide Personal Information to business partners
with whom
we
jointly offer products or services. In such cases, our business partner’s name will appear along
with
ours. - Marketing – Interest-Based Advertising and Third-Party Marketing. Through our
Services,
TCCHM may allow third-party advertising partners to set Technologies and other tracking tools to
collect
information regarding your activities and your device (e.g., your IP address, mobile
identifiers,
page(s)
visited, location, time of day). We may also combine and share such information and other
information
(such
as demographic information and past purchase history) with third party advertising partners.
These
advertising partners may use this information (and similar information collected from other
websites)
for
purposes of delivering targeted advertisements to you when you visit third-party websites within
their
networks. This practice is commonly referred to as “interest-based advertising” or “online
behavioral
advertising”. We may allow access to other data collected by the Site and Services to share
information
that
may be useful, relevant, valuable, or otherwise of interest to you. If you prefer not to share
your
Personal
Information with third-party advertising partners, you may follow the instructions below. - Disclosures to Protect Us or Others. We may access, preserve, and disclose your
Personal
Information, other account information, and content if we believe doing so is required or
appropriate
to:
(i) comply with law enforcement or national security requests and legal process, such as a court
order
or
subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or
safety;
(iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we
believe
disclosure is necessary or appropriate to prevent physical harm or financial loss or in
connection with
an
investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good
faith,
believe
that disclosure is otherwise necessary or advisable. - Merger, Sale, or Other Asset Transfers. If we are involved in a merger,
acquisition,
financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets,
or
transition
of service to another provider, then your information may be sold or transferred as part of such
a
transaction as permitted by law and/or contract.
3.2. International Data Transfers
You agree that all information Processed by us may be transferred, processed, and stored anywhere in
the
world,
including but not limited to, the European Union, the United States, or other countries in order to
provide
the
Services. Personal Information may be stored in the cloud, on our servers, on the servers of our
affiliates
or
the servers of our service providers. Your Personal Information may be accessible to law enforcement
or
other
authorities pursuant to a lawful request.
4. Your Choices: Right to Object to Processing
4.1. General
You have the right to object to or opt out of certain uses of your Personal Information. Where you
have
consented
to the Processing of your Personal Information, you may withdraw that consent at any time and
prevent
further
Processing by contacting us as described below.
4.2. Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the
email
to
opt out of receiving future emails. Note that you will continue to receive transaction-related
emails
regarding
products or Services you have requested. We may also send you certain non-promotional communications
regarding
us and our Services, and you will not be able to opt out of those communications (e.g.,
communications
regarding
the Services or updates to our Terms or this Privacy Policy).
4.3. Mobile Devices
We may send you push notifications through our mobile application. You may at any time opt-out from
receiving
these types of communications by changing the settings on your mobile device. TCCHM may
also
collect location-based information if you use our mobile applications. You may opt-out of this
collection by
changing the settings on your mobile device.
4.4. “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note
that we
do
not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
4.5. Cookies and Interest-Based Advertising
You may stop or restrict the placement of Technologies on your device or remove them by adjusting
your
preferences as your browser or device permits. The online advertising industry also provides
websites from
which
you may opt out of receiving targeted ads from data partners and other advertising partners that
participate
in
self-regulatory programs. You can access these, and also learn more about targeted advertising and
consumer
choice and privacy, at www.networkadvertising.org/managing/opt_out.asp,
http://www.youronlinechoices.eu/,
https://youradchoices.ca/choices/ and http://www.aboutads.info/choices/. To separately make choices
for
mobile
apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store.
Alternatively, for some devices you may use your device’s platform controls in your settings to
exercise
choice.
Please note you must separately opt out in each browser and on each device. Advertisements on third
party
websites that contain the AdChoices link may have been directed to you based on information
collected by
advertising partners over time and across websites. These advertisements provide a mechanism to opt
out of
the
advertising partners’ use of this information for interest-based advertising purposes.
5. Rights of Access, Rectification, Erasure, And Restriction
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we
are
processing your Personal Information; (ii) obtain access to or a copy of your Personal Information;
(iii)
receive an electronic copy of Personal Information that you have provided to us, or ask us to send
that
information to another company (the “right of data portability”); (iv) restrict our uses of your
Personal
Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly
Processed
Personal Information; and (vi) request erasure of Personal Information held about you by
TCCHM,
subject to certain exceptions prescribed by law. If you would like to exercise any of these rights,
please
contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy,
TCCHM
will take steps to verify your identity before fulfilling your request.
6. Data Retention
TCCHM retains the Personal Information we receive as described in this Privacy Policy
for as
long as
you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide
our
Services,
resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes,
enforce our
agreements, and comply with applicable laws. TCCHM will delete your biometric information within
thirty days
after we collect it.
7. Security of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy
Policy.
Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant
the
security
of any information you provide to us. To the fullest extent permitted by applicable law, we do not
accept
liability for unintentional disclosure.
By using the Services or providing Personal Information to us, you agree that we may communicate with
you
electronically regarding security, privacy, and administrative issues relating to your use of the
Services.
If
we learn of a security system’s breach, we may attempt to notify you electronically by posting a
notice on
the
Services, by mail or by sending an e-mail to you.
8. Children’s Information
The Site and Services are not directed to children under 13 (or other age as required by local law),
and we
do
not knowingly collect Personal Information from children. If you learn that your child has provided
us with
Personal Information without your consent, you may contact us as set forth below. If we learn that
we have
collected any Personal Information in violation of applicable law, we will promptly take steps to
delete
such
information and terminate the child’s account.
9. California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year,
free of
charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any)
for their
direct marketing purposes in the prior calendar year, as well as the type of Personal Information
disclosed
to
those parties. Except as otherwise provided in this Privacy Policy, TCCHM does not
share
Personal
Information with Third Parties for their own marketing purposes.
10. Supervisory Authority
If you are located in the European Economic Area, you have the right to lodge a complaint with a
supervisory
authority if you believe our Processing of your Personal Information violates applicable law.
11. Changes to Our Privacy Policy
We may revise this Privacy Policy from time to time in our sole discretion. If there are any material
changes
to
this Privacy Policy, we will notify you as required by applicable law. You understand and agree that
you
will be
deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new
Privacy
Policy takes effect.
12. Terms of Service
This Privacy Policy is incorporated by reference into the TCCHM Terms of Service (the
“Terms”).
All
other terms not defined in this Privacy Policy will have the meanings set forth in the Terms.
13. Contact Us
If you have any questions about our privacy practices or this Privacy Policy, please contact us at:
Choo Choo Hotel Manager LLC
174 Beach Road
Glencoe, IL 60022
14. Definitions
“Personal Information” is any information relating to an identified or identifiable
natural
person. Personal Information does not include aggregated or de-identified data.
“Process” or “Processing” means any operation which is performed
upon
Personal
Information, whether or not by automatic 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.