Last Updated: December 12, 2024

It is part of the Independent Collection’s (collectively hereinafter “IC,” “we,” “us,” or “our”) culture and values to do the right thing and act with integrity, including respecting our guest’s concerns about privacy. We know that you care how your information is used, and we appreciate your trust that we will use it carefully and sensibly. This Privacy Policy details how we handle and maintain the information collected when you visit or use one of our websites when you access one of the mobile applications made available by us in connection with our Services, when you access or use the social media pages that we administer and control, via any of our email marketing campaigns, as well as through the managed relationships necessary for the provision of our hospitality services (collectively, the “Services”). This policy describes our disclosure policies, as well as the choices that you have regarding use, access, and correction of your information. This policy does not describe the information collection policies or practices of any third party(s), including those with whom we may contract for the provision of Services or which may be linked to or integrated within any of our websites.

  • For more information about our European Union privacy practices, click here

Some state laws allow certain rights relating to personal data. If you live in the U.S. in one of the states below, please select your state of residency to review your state’s rights and subject rights request processes.

  • For more information about our California privacy practices, click here
  • For more information about our Virginia privacy practices, click here
  • For more information about our Colorado privacy practices, click here
  • For more information about our Connecticut privacy practices, click here
  • For more information about our Nevada privacy practices, click here
  • For more information about our Texas privacy practices, click here
  • For more information about our Montana privacy practices, click here
  • For more information about our Oregon privacy practices, click here

We encourage you to review this Privacy Policy periodically. Your use of our Services constitutes consent to the terms contained herein. If you do not agree with the practices described in this Privacy Policy, you should not use our Services. We may update this Privacy Policy periodically, and any changes will be reflected here. If the changes are significant, we will provide a more prominent notice and, at our discretion, may email you a direct notification.

COLLECTING DATA

We collect data and information about our guests and other visitors in order to better provide our Services. The data collected is provided by you, either directly or via your use of the Services.

 

PERSONAL DATA WE COLLECT

Personal data applies to any data that can identify you as an individual or relate to an identifiable individual. At various points during your stay and experience with the Independent Collection, we collect certain Personal Data such as:

  • Contact information: First and last name, Email address, Phone number, Address, State, Province, ZIP/Postal code, City, etc.
  • Demographic information: Age, gender, date of birth, anniversary, primary language, etc.
  • Reservation/Visit: Date of arrival and departure, special requests, goods, and services purchased and consumed, etc.
  • Interests and Preferences: Regarding past, current and future stays at the Independent Collection properties, such as your interests, activities, hobbies, food, and beverage choices, etc.

In more limited circumstances, we also may collect:

Data about family members and companions, such as ages of children. Images and video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel.

If you submit any Personal Data about other people to us (e.g., if you make a reservation for another individual), you represent that you have the authority to do so, and you permit us to use the data in accordance with this Privacy Policy.

PAYMENT PROCESSING INFORMATION

When you make a payment in connection with purchasing any of the Services, the Independent Collection may obtain credit card or other payment information.

NOTICE OF FINANCIAL INCENTIVES

Members of IC ‘Independent Collection’ Insider Program may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see “Personal Data We Collect” in our Privacy Policy. Members of The IC ‘Independent Collection’ Insider Program may offer various loyalty or promotional programs that may be deemed a “bona fide loyalty program” under Colorado law or a “financial incentive” under California law. Please find the specific terms here. If you have any questions or require assistance, please contact us at privacy@independentcollection.com. 

USAGE DATA

Usage Data is collected automatically when you use the Service.

Usage Data may include information such as your device's Internet Protocol address (e.g. IP address), browser type (for example: Chrome, Firefox, Internet Explorer or Safari), browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may likewise collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique ID or IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you access the Service by or through a mobile device.

Usage data is collected via tracking technologies, including:

COOKIES

A cookie is a small data file which resides on your computer, and which allows us to recognize you as a user when you return using the same computer and web browser. Cookie data is used to customize your experience when you use the Services. When you visit our website, you are notified of the use of cookies for tracking and analysis and asked to provide your express consent. The notice refers to the detailed explanations in this Privacy Policy.

Cookies can be "Persistent" or "Session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while Session cookies are deleted as soon as you close your web browser.

We use both Session and Persistent cookies for the purposes set out below:

  • Necessary / Essential Cookies Type:
    • Session Cookies; Administered by: Us Purpose: These cookies are essential to provide you with the Services. They help to authenticate users and prevent fraudulent use of user accounts. We only use these cookies to provide the Services.
  • Cookies Policy / Notice Acceptance Cookies Type:
    • Persistent Cookies; Administered by: Us Purpose: These cookies identify if users have accepted the use of cookies on the website(s).
  • Functionality Cookies Type:
    • Persistent Cookies; Administered by: Us Purpose: These cookies allow us to remember choices you make when you use our website(s), such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid your having to re-enter your preferences every time you use the website(s).
  • Tracking and Performance Cookies Type:
    • Persistent Cookies; Administered by: Third-Parties Purpose: These cookies are used to track information about traffic to the website and how it is used. The information gathered may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the website. We may also use these cookies to test new advertisements, pages, features, or new functionality of the website to see how our users react to them.
  • Targeting and Advertising Cookies Type:
    • Persistent Cookies; Administered by: Third-Parties Purpose: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. They use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.

Log files are deleted after 120 days. Session cookies expire and are deleted at the end of your browser session. Persistent cookies may be set to expire from 30 days to 1 year depending on the function of the cookie. After expiry of those periods, information will be deleted or made anonymous.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Most modern internet browsers allow individuals to change the settings in the ‘options’ or ‘preferences’ menu to avoid or limit cookie storage. In addition, third party cookies generated by certain advertisers may be turned off by making a request with the Network Advertising Initiative. Please visit http://optout.networkadvertising.org for more information.

In addition to cookies, we also use Web Beacons and Embedded Script. Web Beacons help us better manage content on our Services by informing us of what content is effective.

Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. This information is used to help improve the overall quality and experience of the Services.

Embedded Script is a programming code that collects information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Service.

We also collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy and opt out by downloading the Google Analytics opt out browser add-on, available at tools.google.com. You can learn more about Adobe and opt out by visiting https://www.adobe.com/privacy/policy.html.

USING AND DISCLOSING DATA

The data and other information that we collect is used and disclosed in the following manner(s) and for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage your account: to manage your registration as a user of the Service. The information you provide can give you access to different functionalities of the Service that are available only to a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Service.
  • To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage your requests: To attend and manage your requests to us.
  • To tailor content, recommendations and offers we display to you on the Services and elsewhere online.
  • Improve the Services and our products, including asking you to participate in surveys, and for other internal business purposes.

We disclose information and data, including personal data, to other companies within the Independent Collection for the purposes described in this Privacy Policy, such as providing and personalizing the Services, communicating with you, and to accomplish our business purposes. We share your personal data and other data used for making a reservation with the applicable property to fulfill and complete your reservation.

Our goal is to provide you with the highest level of hospitality and to assist us with doing so, we share personal, and other, data with the following parties:

  • Owners: We disclose data, including personal data, and other information to owners of the Independent Collection’s properties for the purposes described in this Privacy Policy, such as providing and personalizing the Services.
  • Strategic Business Partners: We disclose data, including personal data, and other information with select strategic business partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you. By sharing data with these parties, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables spa, restaurant, concierge, and other outlets at our properties to provide you with services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars, and vacation packages.
  • Service Providers: We disclose data, including personal data, and other information to third-party service providers for the purposes described in this Privacy Policy. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services.
  • Corporate Reorganization/Business Transfers: We may disclose or transfer your personal data and other information to a third party in the event of any reorganization, merger, sale of our assets, financing, joint venture, assignment, transfer or other disposition of all or any portion of the Independent Collection business, assets or stock. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business to another company. In any such case, the successor organization’s use and disclosure of your personal data will continue to be subject to this policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your personal data will be subject to the successor organization’s own policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use the website). If you submit personal data after such a transfer, that information may be subject to the successor entity’s policy.
  • Sweepstakes, Contests and Promotions: We may work with third parties that sponsor or offer sweepstakes, contests, and other promotions. By participating in a promotion, you are agreeing to the terms, conditions or official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing us and the sponsor(s) of the promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing. If you choose to enter a promotion, personal information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.
  • With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed. If you interact with other users or register through a third-party social media platform, your contacts on such social media platform may see your name, profile, pictures, and description of your activity. Similarly, other users may be able to view descriptions of your activity, communicate with you and view your profile.

RETENTION OF DATA

We will retain data, including personal data, and other information for the purposes set out in this Privacy Policy.

We will retain and use such data and information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain usage data for internal analysis purposes.

THIRD-PARTY LINKS

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

CONSENT TO TRANSFER

The Independent Collection is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our website(s) or the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

Information Security The security of your data is important to us, and the Independent Collection takes commercially reasonable security and backup measures to protect the information submitted to us. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security. We encourage our customers and partners to retain copies of all uploaded information on their own systems.

CHILDREN’S PRIVACY

The Services are general audience services and are not intended for individuals younger than the age of 13. We do not knowingly collect personal data from individuals younger than the age of 13 without parental consent. If we discover that a child under the age of 13 has provided us with personal data, or that we have otherwise inadvertently collected personal data from anyone younger than the age of 13, we will delete it in accordance with applicable law.

CALIFORNIA PRIVACY

California residents have additional rights regarding our use of your personal data and are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year.

California residents under the age of 18 who are registered users of online sites, services or applications also have the right under California law to request and obtain removal of content or information they have publicly posted. If you are a California resident and wish to request removal of such data, you can contact us using the contact information provided below.

California residents are also entitled to exercise certain rights as expressly set forth by the California Consumer Privacy Act, including the right to give the instruction ‘Do Not Sell My Personal Information’ to third parties. For additional details on your California Privacy rights, see our California Privacy notice.

VIRGINIA PRIVACY 

Under the Virginia Consumer Data Protection Act (CDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial available information.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with us and our Services. To find out more, please visit the following links:

  • Personal data we collect
  • How we use your personal data
  • When and with whom we share your personal data

Your rights with respect to your personal data:

  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling*)

We have not sold any personal data to third parties for business or commercial purposes. We will not sell personal data in the future belonging to website visitors, users, and other consumers.

Exercise your rights provided under the Virginia CDPA

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at info@independentcollection.com, by visiting https://www.independentcollection.com, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at privacy@independentcollection.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

YOUR RIGHTS RELATED TO THE FOLLOWING STATES: COLORADO, CONNECTICUT, NEVADA, TEXAS, MONTANA, OREGON  

The state-level legislation grants you specific rights in and to your personal information. Specifically, you have the rights set forth below and may exercise them, as applicable, as further described below.

Right of Access to Collected Information; Data Portability

You have the right to request that the Independent Collection disclose the categories and specific pieces of personal information that we have collected about you. Upon receipt of any request, we will send you a verification notice and once your identity has been verified, we will disclose to you: 

  • The categories of your personal information that we have collected.
  • The specific pieces of your personal information that we have collected.
  • The categories of sources from which we have collected your personal information.
  • The commercial reason for our collection or sale of your personal information.
  • The categories of third parties, if any, with whom we have shared your personal information. 

The Independent Collection will disclose this information to you either electronically or by mail. If provided electronically, the information will be in a portable and, to the extent feasible, readily useable format so as to allow you to transmit the information to another party without hindrance. 

Right of Access to Information Sold or Disclosed for a Business Purpose

You have the right to request that the Independent Collection disclose the categories of personal information that we have sold or otherwise disclosed to a third party about you. Upon receipt of any request, we will send you a verification notice and once your identity has been verified, we will disclose to you:

  • The categories of your personal information that we have collected.
  • The categories of your personal information that we have sold.
  • The categories of your personal information that we have otherwise disclosed to a third party for a business purpose.
  • The categories of third parties to whom we have sold your personal information.

Right to Request Deletion

You have the right to request that the Independent Collection delete any of your personal information that we have collected and retained about you, subject to certain exceptions. Upon receipt of any request, we will send you a verification notice and once your identity has been verified, we will delete (and direct any third-party service providers to delete) your personal information. 

The Independent Collection may deny your deletion request if retaining your personal information is necessary for us to: complete the transaction for which we originally collected your personal information; provide a service that you requested; take reasonably anticipated actions within the context of our ongoing business relationship; to comply with a legal obligation; or otherwise as set forth. If we deny your deletion request, we will provide you with the reason(s) for such denial. 

Right to Opt-Out of the Sale of Your Personal Information

You have the right to request that the Independent Collection not sell your personal information. This right is also referred to as the right to “opt-out” of the sale of your personal information. The Independent Collection does not sell consumers’ personal information. 

To submit a request to “opt out” of “targeted advertising” or the “sale” of your “personal data,” you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.

Right of Non-Discrimination

You have the right to exercise any or all of the rights identified above free of discrimination. The Independent Collection will not discriminate against you for exercising your rights.

NOTICE ABOUT OUR LOYALTY PROGRAMS

Members of IC ‘Independent Collection’ Insider Program may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see “Personal Data We Collect” in our Privacy Policy. Members of The IC ‘Independent Collection’ Insider Program may offer various loyalty or promotional programs that may be deemed a “bona fide loyalty program” under Colorado law. Please find the specific terms here. If you have any questions or require assistance, please contact us at privacy@independentcollection.com. 

Exercising Your Privacy Rights

To exercise your rights to access your personal information that is collected and/or sold by the Independent Collection or to request the deletion of your personal information or an opt-out from the sale of your personal information, you can submit a verifiable request by:

Email: info@independentcollection.com

Mail:

Independent Collection

ATTN: Legal

2001 Market Street, Suite 3500

Philadelphia, PA 19103

Only you or an individual authorized to act on your behalf may make a valid request as relates to your personal information. If you are a parent or guardian of a minor child, you may make a request on their behalf. 

The Independent Collection uses commercially reasonable efforts to respond to any verifiable consumer request within 45 days of our receipt of such request. If we require additional time, we will inform you of the same along with our reason(s) and any extension period in writing via the contact information that you provide to us upon request. Any information disclosure that we provide will cover the 12-month period immediately preceding our receipt of your request. You may make a request for disclosure at any time, but we will not provide any such disclosures more than two times in a 12-month period. 

EUROPEAN UNION PRIVACY

We comply with the provisions of the European Union’s General Data Protection Regulation (“GDPR”) as to any information in its possession regarding EU-based persons (“data subjects”). Accordingly, we only process personal information on data subjects where we have a lawful basis to do so, which may include the consent of each person (especially in the case of website visitors who provide their information) or compliance with a legal obligation. For additional details on your European Union Privacy rights, please see our European Union Privacy notice.

ADDITIONAL INFORMATION ON THE PROCESSING OF PERSONAL DATA

ADVERTISING

We may use third party service providers to show advertisements to you to help support and maintain our Service. Such third parties include, but are not limited to:

  • Google AdSense & DoubleClick Cookie: Google uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.
  • Bing Ads: Bing Ads Opt-out page: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads For more information about Bing Ads, please visit their Privacy Policy: https://privacy.microsoft.com/en-us/PrivacyStatement.

To submit a request to “opt out” of “targeted advertising” or the “sale” of your “personal data,” you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.

EMAIL MARKETING

We may use the email address that you provide to us in order to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email we send or by contacting us as set forth below. We may use certain third-party email marketing service providers, such as Cendyn, to manage and send emails to you. Cendyn’s Privacy Policy can be viewed at https://www.cendyn.com/privacy-policy/.

BEHAVIORAL REMARKETING

We use remarketing services to advertise on third party websites to you after you have visited one of our websites. In the course of doing so, we use cookies and non-cookie technologies to inform, optimize and serve ads based on your past visits to our Service.

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

Google Ads (AdWords): Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

Bing Ads Remarketing: Bing Ads remarketing service is provided by Microsoft Inc. You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads. You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement.

Twitter: Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy.

Facebook/Instagram: Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/769828729705201. To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

AdRoll: AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy.

FACEBOOK FAN PAGE

Data Controller for the Facebook Fan Page: We are the Data Controller of personal data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/StayIndependentCollection, the Independent Collection and Facebook are Joint Controllers. Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights: We use the Facebook Insights function in connection with the operation of the Facebook Fan Page in order to obtain anonymized statistical data about our users. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period. Facebook receives, records, and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services. For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy.

USAGE, PERFORMANCE AND MISCELLANEOUS

We may use third-party service providers to improve our Service.

  • Invisible reCAPTCHA
    • We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google. The reCAPTCHA service may collect information from You and from Your Device for security purposes. The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your personal data, we will display a notice on our website(s), or through other means. You are encouraged to review this Privacy Policy periodically for any changes. Continued use of our website(s) or our Services after any update will constitute your agreement to the new policy.

CONTACT US

If you have any questions about this Privacy Policy, the practices, or use of the website(s) or Services, you can contact us:

By email: privacy@independentcollection.com

By mail: Independent Collection ATTN: Legal 2001 Market Street, Suite 3500, Philadelphia, PA 19103

EUROPEAN UNION PRIVACY

If you are a resident of the European Union (the “EU”) or reside in the European Economic Area (the “EEA”) and we collect personal data relating to you in the context of the offering the Services, your personal data will be subject to Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”).

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GDPR

We may process your personal data pursuant to one of the following conditions:

  • Consent: You have given your consent for processing personal data for one or more specific purposes.
  • Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
  • Vital interests: Processing personal data is necessary in order to protect your vital interests or those of another natural person.
  • Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests of the Independent Collection.

In any case, upon reasonable request we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

YOUR RIGHTS UNDER THE GDPR

The Independent Collection undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

  • Request access to your personal data. You can access, update or request deletion of your personal data, please contact us and we will attempt to assist you as possible. You also have a right upon request to receive a copy of the personal data we hold about you.
  • Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation which makes you want to object to our processing. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • Request erasure of your personal data. You have the right to ask us to delete or remove personal data from further processing.
  • Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

EXERCISING YOUR GDPR DATA PROTECTION RIGHTS

You may exercise your rights of access, rectification, cancellation, and opposition by contacting us via email at privacy@independentcollection.com or mail at Independent Collection, ATTN: Legal, 2001 Market Street, Suite 3500, Philadelphia, PA 19103. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the EEA.

CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (“Notice”) supplements the Independent Collection’s (hereinafter “Independent Collection,” “we,” “us,” or “our”) Privacy Policy and applies specifically to visitors and users who are California residents (“consumer(s)” or “you”). This Notice details the Independent Collection’s compliance with, and the rights of consumers under, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA), as well as other California privacy laws. Any terms defined in the CPRA have the same meaning when used herein.

YOUR RIGHTS AS A CONSUMER

The CPRA grants you specific rights in and to your personal information. Specifically, you have the rights set forth below and may exercise them, as applicable, as further described below.

RIGHT OF ACCESS TO COLLECTED INFORMATION; DATA PORTABILITY

You have the right to request that the Independent Collection disclose the categories and specific pieces of personal information that we have collected about you. Upon receipt of any request, we will send you a verification notice, and, once your identity has been verified, we will disclose to you:

  • The categories of your personal information that we have collected.
  • The specific pieces of your personal information that we have collected.
  • The categories of sources from which we have collected your personal information.
  • The commercial reason for our collection or sale of your personal information.
  • The categories of third parties, if any, with whom we have shared your personal information.

The Independent Collection will disclose this information to you either electronically or by mail. If provided electronically, the information will be in a portable and, to the extent feasible, readily usable format so as to allow you to transmit the information to another party without hindrance.

RIGHT OF ACCESS TO INFORMATION SOLD OR DISCLOSED FOR A BUSINESS PURPOSE

You have the right to request that the Independent Collection disclose the categories of personal information that we have sold or otherwise disclosed to a third party about you. Upon receipt of any request, we will send you a verification notice and once your identity has been verified, we will disclose to you:

  • The categories of your personal information that we have collected.
  • The categories of your personal information that we have sold.
  • The categories of your personal information that we have otherwise disclosed to a third party for a business purpose.
  • The categories of third parties to whom we have sold your personal information.

RIGHT TO REQUEST DELETION

You have the right to request that the Independent Collection delete any of your personal information that we have collected and retained about you, subject to certain exceptions. Upon receipt of any request, we will send you a verification notice and, once your identity has been verified, we will delete (and direct any third-party service providers to delete) your personal information.

The Independent Collection may deny your deletion request if retaining your personal information is necessary for us to: complete the transaction for which we originally collected your personal information; provide a service that you requested; take reasonably anticipated actions within the context of our ongoing business relationship; to comply with a legal obligation; or otherwise as set forth in the CPRA. If we deny your deletion request, we will provide you with the reason(s) for such denial.

RIGHT TO OPT-OUT OF THE SALE OF YOUR PERSONAL INFORMATION

You have the right to request that the Independent Collection not sell your personal information. This right is also referred to as the right to “opt-out” of the sale of your personal information. The Independent Collection does not sell consumers’ personal information.

RIGHT OF NON-DISCRIMINATION

You have the right to exercise any or all of the rights identified above free of discrimination. The Independent Collection will not discriminate against you for exercising your CPRA rights.

NOTICE ABOUT OUR LOYALTY PROGRAMS

Members of IC ‘Independent Collection’ Insider Program may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see “Personal Data We Collect” in our Privacy Policy. Members of The IC ‘Independent Collection’ Insider Program may offer various loyalty or promotional programs that may be deemed a “financial incentive” under California law. Please find the specific terms here. If you have any questions or require assistance, please contact us at privacy@independentcollection.com. 

EXERCISING YOUR CALIFORNIA PRIVACY RIGHTS

To exercise your rights to access about your personal information that is collected and/or sold by the Independent Collection, or to request the deletion of your personal information or an opt-out from the sale of your personal information, you can submit a verifiable request by:

Email: privacy@independentcollection.com

Mail:

Independent Collection

ATTN: Legal

2001 Market Street, Suite 3500

Philadelphia, PA 19103

Only you or an individual authorized to act on your behalf with the California Secretary of State’s office may make a valid request as relates to your personal information. If you are a parent or guardian of a minor child, you may make a request on their behalf.

The Independent Collection uses commercially reasonable efforts to respond to any verifiable consumer request within 45 days of our receipt of such request. If we require additional time, we will inform you of the same along with our reason(s) and any extension period in writing via the contact information that you provide to us upon request. Any information disclosure that we provide will cover the 12-month period immediately preceding our receipt of your request. You may make a request for disclosure at any time, but we will not provide any such disclosures more than two times in a 12-month period.

 

INFORMATION THAT WE COLLECT

The Independent Collection has collected the following categories of personal information about consumers in the last 12 months.

Category Examples
Identifiers: Real name, postal address, online identifier, email address, Internet Protocol address, or other similar identifiers
Categories of personal information listed in the California Customer Records statute: Name, address, telephone number, education, employment, employment history. Information included in this category is specifically set forth by California statutory law and may overlap with information in other categories.
Commercial information: Information or details of products or services purchased, obtained, or considered.

The Independent Collection collects your information in order to better provide hospitality services at our portfolio of hotels.

INFORMATION THAT WE SELL

The Independent Collection collects consumer personal information directly from consumers and uses it solely for the purpose(s) for which it is collected. We do not sell consumer personal information.

INFORMATION THAT WE DISCLOSE FOR A BUSINESS PURPOSE

The Independent Collection discloses personal information to certain third party(s) for business purposes. When we do so, we enter into contracts that describe the business purpose and which require such third party(s) to keep the personal information confidential and to only use personal information as set forth in and explicitly allowed by the contract.

We have disclosed to a third party for a business purpose the following categories of personal information about consumers in the last 12 months.

  • Identifiers
  • Personal information listed in the California Consumer Records statute
  • Commercial information

The Independent Collection discloses personal information for a business purpose only to our third-party service provider(s).

CHANGES TO THIS CALIFORNIA PRIVACY NOTICE

We may update this Notice at any time and the changes will be effective upon posting. This Notice will be reviewed and updated as necessary at least once every 12 months.

CONTACT INFORMATION

If you have questions or comments about this Notice or our California privacy practices generally, please feel free to contact us via email at privacy@independentcollection.com or mail at the Independent Collection, ATTN: Legal, 2001 Market Street, Suite 3500, Philadelphia, PA 19103.