PRIVACY

This privacy statement (“Statement”) applies to BOUTIQUE ST. SOPHIA its subsidiaries and all of the hotels within the Boutique St. Sophia Portfolio of Brands (collectively, “we,” or “us”). At Boutique St. Sophia, we strive to deliver outstanding products, services, and experiences around the world. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, when you visit one of our properties, or from other sources. While this Statement broadly describes the practices we have adopted across Boutique St. Sophia globally, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require an express consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements.

By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you agree to the collection and use of Personal Information as described in this Statement.

Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, companies that organize or offer packaged travel arrangements, marketing partners, or corporate customers.

PERSONAL INFORMATION WE COLLECT
At every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include: your contact information; information related to your reservation, stay or visit to a property; participation in a membership or loyalty program (including Boutique St. Sophia co-branded payment cards or other co-branded programs); participation in a contest, sweepstakes, or marketing program (even if you do not stay at one of our hotels); information related to the purchase and receipt of products or services; personal characteristics, nationality, income, passport number and date and place of issue; travel history; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; guest preferences; marketing and communication preferences; information about vehicles you may bring onto our properties; reviews and opinions about our Portfolio of Brands or properties (if they are identified or associated with you); frequent flyer or travel partner program affiliation and member number; hotel, airline and rental car packages booked; groups with which you are associated for stays at hotels; information provided on membership and account applications; and other types of information that you choose to provide to us or that we may obtain from third parties.

We may ask for details on joint travelers, including their names and frequent flyer numbers, and the age of the driver of the rental car. We may also collect information related to conversations, including recording or monitoring customer service calls and other communications such as in-app messages and SMS.

In addition, we collect other personal information in certain cases, such as:

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from Other Information we collect.

PERSONAL INFORMATION WE COLLECT FROM THIRD PARTIES
We may also collect information about you from third parties, including information from our airline, payment card, and other partners; from your social media services consistent with your settings on such services; and from other third-party sources. We may append this information to the information we have on file for you and share it with others consistent with this Statement.

USE OF PERSONAL INFORMATION COLLECTED ABOUT YOU
We use your personal information in a number of ways, including to provide and personalize the services you request and expect from Boutique St. Sophia, to offer you the expected level of hospitality in-room and throughout our properties, administer the Boutique St. Sophia Honors program, conduct direct marketing and sales promotions and as set forth below in more detail:

PERSONAL INFORMATION WE SHARE
In order to offer you the expected level of hospitality and to provide you with the best level of service, we may share your personal information among members of the Boutique St. Sophia Worldwide Portfolio of Brands, our service providers, third parties and others as set forth in detail below:

OTHER INFORMATION
When you visit and interact with Boutique St. Sophia websites and apps, we collect other, non-personally identifying information about your use of the site, such as a catalog of the site pages you visit, and the number of visits to our sites (“Other Information”). We use Other Information, as well as data received from third parties, to deliver you email, online (on our sites and other sites) and mobile advertisements. We may also use Other Information to allow third-party partners to recognize you as an Boutique St. Sophia Honors member when you visit the partner’s website or app, or to recognize you as one of their customers when you visit Boutique St. Sophia websites or apps so that they may provide more relevant offers to you.

We use cookies and other technologies to collect this information. At this time, we do not respond to Do Not Track signals or other, similar mechanisms.  Please see our Cookies Statement for more information, including how to opt out of interest-based advertising.

We may use information we have collected and aggregated, or anonymized personal information received from third parties, to understand more about our users (for example, we may use aggregated information to calculate the percentage of our users who have a particular telephone area code). This includes demographic data, such as date of birth, gender and marital status, inferred commercial interests, such as favorite products or hobbies, and other information we may collect from you or from third parties.

Because Other Information does not personally identify you, such information may be disclosed for any purpose.  In some instances, we may combine Other Information with personal information. If we do combine any Other Information with personal information, the combined information will be treated by us as personal information in accordance with this Statement.

SENSITIVE INFORMATION
The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health or sex life, criminal background or trade union membership. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you to serve you better and meet your particular needs.

PERSONAL INFORMATION FROM CHILDREN
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

MOBILE AND LOCATION-BASED SERVICES
We provide mobile apps that can be downloaded to your smartphone or mobile device. These apps have a variety of functionalities that enhance the customer experience. In addition to providing services, our apps may collect personal and Other Information that will be used in accordance with this Statement. For example, to book or change a reservation, including a reward stay, you will be required to provide some personal information, such as your Boutique St. Sophia Honors credentials or other information as necessary. Our Digital Key functionality within the Boutique St. Sophia Honors App collects information we already have about you, including your Boutique St. Sophia Honors number and user ID, and additional information, including use of the key. We provide a link to this Statement to customers prior to their downloading of any of our apps.

If you allow our mobile apps to access your location information on your device, our mobile apps may use your mobile device’s Global Positioning System (GPS) technology and other technology (such as wireless transmitters known as beacons) to provide you with information and offers based on the location of your device. Beacons allow us to collect information about your location within participating hotels by communicating with mobile devices that are in range. We may use this location information to enhance your on-property experience by delivering push notifications and other content to your mobile device, providing navigation assistance as you move around our locations, and sending you information and offers about products, services, or activities we believe may be of interest to you. We may share this information with third parties, including business partners and service providers, to provide information, offers, and services that may be of interest to you. To the extent any location data is combined with personal information, that information will be treated as personal information in accordance with this Statement. You may prevent or limit collection of location information by changing the settings in the Boutique St. Sophia Honors app, or by changing your device’s settings.

For certain properties, we also make available real-time or virtual “concierge” features, which may be pre-loaded onto a Boutique St. Sophia-owned device, downloadable to your web-enabled mobile device, or available as part of the Boutique St. Sophia Honors App. For example, you can communicate directly with the hotel; order services from the hotel, such as room service or valet parking; access our websites; access third-party websites, including local attractions and social media; and book a reservation. The hotel will access and use your personal information (such as your name, Boutique St. Sophia Honors tier, confirmation number, check-in and checkout dates, and room number) in providing these concierge services. If you request SMS (text) communications, you will be required to provide your phone number and carrier. We may also communicate with you by means of third-party digital messaging apps. If we do so, the privacy policies of those services apply.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES
Our site and our mobile applications may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Boutique St. Sophia may also partner with a limited number of Internet providers to offer Internet access to our guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy policy. You can access those terms and policies using the links on the service sign-in page, or by visiting the Internet provider’s website.

PROTECTING PERSONAL INFORMATION
Boutique St. Sophia will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email.

We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package. We will not contact you to ask for your Boutique St. Sophia Honors account log-in information. If you receive this type of request, you should not respond to it. We also ask that you please notify us at ISC@Boutique St. Sophia.com.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
As a global company, we endeavor to provide you with the same level of service that you have come to expect at Boutique St. Sophia whether you are in San Francisco, London or Tokyo. To provide this service, you agree that we may share your personal information among members of the Boutique St. Sophia Portfolio of Brands, our service providers, and other third parties, which may be located in countries outside of your own. Although the data protection laws of these various countries may differ from those in your own country, we will take appropriate steps to ensure that your personal information is handled as described in this Statement.

CHANGING AND ACCESSING YOUR PERSONAL INFORMATION
If you are an Boutique St. Sophia Honors member, the information you provided to us at the time of registration may be accessed, reviewed and updated at any time by signing in to your Boutique St. Sophia Honors profile.

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. Such requests must be submitted in writing to the following address: Boutique St. Sophia Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.

In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that Boutique St. Sophia cease using personal information about you on the grounds that such personal information was acquired by unjust means or used in violation of law by sending your written request to Boutique St. Sophia Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA. We will seek to honor those requests consistently with applicable law.

RETAINING PERSONAL INFORMATION
We retain personal information about you for the period necessary to fulfill the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law.

CHOICES – MARKETING COMMUNICATIONS
If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you about our products and services or invite you to events via email, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call center, and other means (including on-property messaging, such as your in-room television).

If you are an Boutique St. Sophia Honors member, you may change the communications you receive from us by logging on to your online account and managing your subscriptions, or by writing to us (and including your email address) at Boutique St. Sophia Customer Privacy Department, 7930 Jones Branch Drive, McLean, VA 22102, USA.

To opt out of text messages, tell the hotel front desk that you do not want to receive text messages from the hotel or reply “STOP” to the message you received.

To be added to Boutique St. Sophia’s internal do not call list, send a message to info@boutiquesaintsophia.com.

You may control whether our mobile apps send you push notifications by changing your notification settings on your mobile device. If we engage in sending you in-app messages, we will allow control for those in our apps’ settings. For more information about cookies and interest-based advertising and to learn about how to manage these technologies, please see our Cookies Statement.

Please note, however, that if you change the communications you receive from us as described above, we will not be able to remove your personal information from the databases of affiliates, franchisees or business partners with whom we have already shared your personal information (i.e., to whom we have already provided your personal information as of the date of your opt-out request).

Special Notification for California Residents. Individual customers who reside in California and have provided their personal information to the Boutique St. Sophia Portfolio of Brands may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following addresses: info@boutiquesaintsophia.com or BOUTIQUE ST. SOPHIA, 7930 Jones Branch Drive, McLean, VA 22102, USA. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info@boutiquesaintsophia.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

STATEMENT MODIFICATIONS
We may modify this Statement from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. You can tell when this Statement was last updated by looking at the link and at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.

>CONTACT US
If you have any questions about this Statement or how Boutique St. Sophia processes your personal information, please contact us by email at info@boutiquesaintsophia.com or by postal mail to Boutique St. Sophia Customer Privacy Department, Alemdar Cd. No:2 34122 Sultanahmet Istanbul/Turkey.