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:
- Boutique St. Sophia Honors Participation: When you enroll in our Boutique St. Sophia Honors program, you will receive an Boutique St. Sophia Honors number and we will ask you to create a user ID and password. We also collect information to administer the Boutique St. Sophia Honors program and profiles, including transaction and correspondence details, and to provide you with our Boutique St. Sophia Honors App functionality (where available). The Boutique St. Sophia Honors App allows you to do such things as use your mobile device to check-in, select your room, receive a room key, and check out. When you manage your profile online, you have the opportunity to provide additional information, such as your preferred airlines and your loyalty program account numbers with them, your room type preferences, your language preferences, your payment card account(s), and your email subscription preferences for receiving news, offers and information from us and our partners. Also, when you book a reservation, including a Rewards Reservation, or purchase Boutique St. Sophia Honors Points online, we may ask for additional specific account information such as corporate account number, group or convention code, travel agent number or AAA number. If you apply for a payment card or other account with one of our partners via one of our advertisements or on our properties, you may have the option to automatically add this information as part of your Boutique St. Sophia Honors profile.
- Surveys: We may request demographic data or other personal information in customer surveys.
- On-property Collection: We collect additional personal information during registration/check-in at our properties, including such information as may be required by local laws. We may also use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies). We may also use closed-circuit television and other technologies that record sound or video for the protection of our staff, guests and visitors to our properties. In addition, we may collect personal information in connection with on-property services, such as concierge services, health clubs, spas, activities, child care services, equipment rental, and our Digital Key functionality in the Boutique St. Sophia Honors App (where available).
- Event Profiles: If you plan an event with us, we collect meeting and event specifications, the date of the event, number of guests, details of the guest rooms, and, for corporate events, information on your organization (name, annual budget, and number of sponsored events per year). We also collect information about the guests that are a part of your group or event. If you visit us as part of a group, we may have personal information about you provided to us by the group and may market to you as a result of your stay with a group or attendance at an event. If you visit us as part of an event, we may share personal information about you with the event planners. If you are an event planner we may also share information about your event with third-party service providers who may market event services to you.
- Boutique St. Sophia Grand Vacations Timeshare: If you submit an online “pre-application” for a timeshare or if you submit a reservation or information request online, or participate in an online “click-to-chat” type feature, we may ask you to provide your annual income range or reservation information. If you attend a Boutique St. Sophia Grand Vacations event, or preview tour, or enter a sweepstakes, we may ask you to provide information about your family composition, travel preferences, frequency of travel and other vacation history information. If you register for an online account with Boutique St. Sophia Grand Vacations Club and/or The Boutique St. Sophia Club, or other club products or programs introduced from time to time, we also ask you to provide a user ID and password and may ask you to provide your member or reservation number and security codes. If you finance the purchase of a timeshare, we may collect loan application and servicing information.
- Social Media: If you choose to participate in Boutique St. Sophia-sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as location, check-ins, activities, interests, photos, status updates and friend list. We may also allow you to enter into contests to provide photos, such as of your stay with us, which you may share with your connections on social media for votes, shared offers or other promotions.
- Forward-to-a-Friend: From time to time, we may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend, whether via the Internet, a stand-alone kiosk or mobile device. If you choose to use this feature, we will ask you for the recipient’s name and email address, along with the text of any message you choose to include. By using this feature, you represent that you are entitled to use and provide us with the recipient’s name and email address for this purpose.
- Franchise and Ownership Opportunities: If you are interested in obtaining more information about franchise or ownership opportunities, we may collect information about you in order to assess your suitability to become a franchisee or owner. We may combine the information you provide to us with information we obtain from third parties, such as credit reporting agencies and public records databases. We use this information to conduct due diligence on potential franchisees and owners.
- Employment Applications: If you choose to apply online for employment with Boutique St. Sophia, please see our Applicant Privacy Notice.
- WMBE Suppliers: If your U.S. company is a Women’s/Minority Business Enterprise interested in participating in Boutique St. Sophia’s Supplier Diversity Program, you may complete the Supplier Diversity Profile Application Form online. If you choose to apply, you will be asked to provide information about your company and its principals, including the principal’s name, address, email address, ethnicity, contact person’s name and email address, company’s tax identification number and legal structure, and evidence of Women’s/Minority Business Enterprise certification.
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:
- Boutique St. Sophia Honors Members: If you are an Boutique St. Sophia Honors member, we use your information to administer the Boutique St. Sophia Honors loyalty program, to personalize your experience across our services and applications, and in connection with our Boutique St. Sophia Honors App and Digital Key functionality (where available). We also use your information to communicate news, promotional, and transactional materials across different Boutique St. Sophia services and to personalize advertising and content delivered to you through online, email, mobile, and display advertising, as well as on our website and applications and through our customer service call center.
- Service Administration: We use your personal information to administer programs in which you participate, including providing you with access to your account information, such as rewards status and offers for which you are eligible; to fulfill services that are part of such program; to enable direct communication between properties within the Boutique St. Sophia Portfolio of Brands; and between the Boutique St. Sophia Portfolio of Brands and you; and to facilitate collections.
- Meeting and Event Planning: We may use your personal information to provide you with information about meeting and event planning.
- Marketing and Communications: We may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages. We use your information to provide in-stay messaging, account alerts, and reservation confirmations; to send you marketing messages; and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means (including on-property messaging, such as your in-room television). We also use user-generated content (such as photos) from social media services to deliver display advertising or on our website and apps. We may also collect information from your payment card, which can be appended to personal information and used by Boutique St. Sophia or its business partners to recognize what type of card you have, such as whether or not it is a Boutique St. Sophia co-branded card and/or the bank or network of the card, and present and/or send you targeted marketing messages based on your payment method. We may also partner with third parties to learn whether a visitor to our site has a cash-back offer associated with their payment card and to deliver the visitor advertising and information that explains how to take advantage of that offer through a stay at a hotel within the Boutique St. Sophia Portfolio of Brands.
- Service Improvements: We may use your personal information to improve Boutique St. Sophia’s services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of hospitality in-room and throughout our properties. This may include providing you with the ability to control your in-room technology through our website or apps on your personal devices.
- eFolio Program: We may automatically enroll you in our eFolio program and use your email address to send you your hotel bill via email. It is your responsibility to ensure that we have the correct (and preferred) email address for you. If you make a reservation for another person using your email address, that person’s eFolio will be sent to your email address.
- Data Correctness, Analytics and Personalization: We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Statement.
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:
- Boutique St. Sophia Portfolio of Brands, Including Franchised Hotels, Managed Hotels, Timeshare and Fractional Resorts: We may share personal information within the Boutique St. Sophia Portfolio of Brands, including Boutique St. Sophia Grand Vacations, as well as with owners and operators of franchised hotels, owners of hotels that we manage but do not own, and timeshare or fractional ownership resorts that may individually or jointly use the personal information to provide you with services, personalization, and for the purposes described above. BOUTIQUE ST. SOPHIA is the party responsible for the management of the jointly used personal information. In addition, when we cease managing a hotel that we do not own or end a franchise relationship, we may provide the hotel’s owner with certain information about past or future guests of that hotel.
- Electronic Billing Program: If you receive an eFolio by email (as discussed above), a summary detailing the goods and services provided to you during your stay will be shared with the payment card provider and, if you participate in a corporate billing program and use a corporate payment card, the payment card provider may share that summary with your employer. Additionally, if you participate in a special rate plan, we may share lists of Boutique St. Sophia Honors numbers that used the plan with the entity that provided the special rate plan to you. The privacy policies of your employer, the relevant payment card provider and card issuer apply once we have transferred your information.
- Group Events or Meetings: If you visit Boutique St. Sophia as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
- Business Partners: We may partner with other companies to provide you with products, services, or offers based upon your experiences at our properties and may share your information with our business partners accordingly. For example, we may help to arrange rental cars or other services from our business partners, and share personal information with our business partners in order to provide those services. If you are an Boutique St. Sophia Honors member, we may share your personal information with our business partners in order to credit you with mileage or other benefits earned through your participation in the Boutique St. Sophia Honors program. We may also share your personal information, such as your email address, with our corporate travel partners to help them assess compliance with travel policies or participation in special rate plans or to engage in co-branded marketing with our corporate travel partners. We may also work with third parties, such as our airline and payment card partners, to allow us and our partners to deliver advertisements to our shared customers. Our partners may be able to provide more relevant offers to you based upon anonymous information that we share about your experiences at our properties, as well as information in your Boutique St. Sophia Honors profile. Additionally, we may allow third-party partners to recognize you when you visit that 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 may share your email address with third parties using available security measures that may match it with their own email addresses so that they can send online and email advertisements to you on our behalf.
- Co-Sponsors of Promotions: We co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, and we provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
- On-property Services: We may share personal information with third-party providers of on-property services that services such as concierge services, spa treatments, golf, or dining experiences.
- Service Providers: We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate. Our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. We may use service providers to communicate news and deliver promotional and transactional materials to you, including personalized online and mobile advertising. Please see our Cookies Statement for more information. Boutique St. Sophia will only work with parties that offer a method to opt-out of such matching. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists that we have personalized for you based on your preferences and third-party data.
- Business Transactions: As we develop our business, we might sell, buy, restructure or reorganize businesses or assets, or cease being the manager or franchisor of a hotel that is currently part of our portfolio. In such circumstances, Boutique St. Sophia may transfer, sell or assign information collected, including, without limitation, Other Information and personal information, to one or more affiliated or unaffiliated third parties. To the extent that local laws require it, we will provide notice of our intent to transfer personal data to a third party for this purpose, and explain how you can object to such transfer.
- Telemarketing: If you stay at one of our hotels and are an Boutique St. Sophia Honors member, we may share your telephone number among the Boutique St. Sophia Portfolio of Brands, including Boutique St. Sophia Grand Vacations, for purposes of telemarketing. We may also receive your telephone number from our partners or from other sources, which we may use for telemarketing purposes.
- Other: In addition, Boutique St. Sophia may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Boutique St. Sophia, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites’ terms and conditions, and (vii) respond to an emergency.
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 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.
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
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 [email protected] 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 [email protected].
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: [email protected] 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 [email protected]. 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.
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.
If you have any questions about this Statement or how Boutique St. Sophia processes your personal information, please contact us by email at [email protected] or by postal mail to Boutique St. Sophia Customer Privacy Department, Alemdar Cd. No:2 34122 Sultanahmet Istanbul/Turkey.