Privacy Policy
Privacy Policy Updated and Effective Date: June 11, 2018 [archived versions]
This privacy statement does not apply to information collected by The Townsend Hotel by means other than this website, www.TownsendHotel.com.
1. INTRODUCTION
The privacy of visitors to our website, like the privacy of our hotel guests, is of paramount concern to us. We believe the discreet, respectful understanding of our visitors' personal privacy is critical to a successful guest experience. We also understand that visitors to our website may have questions about what information we collect, how we collect information, how we use the information we collect online, and how we protect that information. This privacy statement answers those questions and illustrates the high degree to which we maintain and respect our visitors' privacy.
2. DEFINITIONS
A. “You” and “your” mean the individual person using our website.
B. “The Townsend Hotel”, the “Townsend”, “we,” “us” and “our” means The Townsend Hotel.
C. “Site” or “our website” or “website” refers to Townsend’s website. www.TownsendHotel.com, and other related websites, blogs, domains, and mobile sites maintained by Townsend.
D. “Non-Personal Information” is any information that is not Personally Identifiable Information (defined below).
E. “Personally Identifiable Information” is non-public information we receive from your use of the Site or that you otherwise provide us that can be used, alone or in combination with other information in our possession, to identify you, a natural person, or another natural person, i.e., another individual. It may include information such as name, address, telephone number and other personal information you provide
3. REGISTRATION
Registration is not required in order to use the website. Visitors can visit the website without informing us who they are or revealing any personal information. Visitors always have the choice not to provide any personally identifiable information.
4. PERSONAL INFORMATION COLLECTED
The Townsend Hotel does not collect or store any Personally Identifiable Information (e.g. name, address, telephone number, e-mail address or associated company information) from the visitors of the Site unless submitted to us via our Contact Us web page, Visitor's Experience web page and form, the Townsend Concierge web page and form, or as otherwise provided in this Privacy Policy. If visitors choose to directly contact The Townsend Hotel through use of the Contact Us page, in order to fully respond to a request, visitors may be asked for personally identifiable information. If visitors choose not to supply the information, their ability to perform certain transactions or obtain the convenient, customized information they seek may be affected. In order to use the Townsend Concierge form, The Townsend Hotel may require visitors to provide us with their contact information (like first and last name). Such information is never sold, rented or given away to a third party or made available to the general public. If you are required to submit a photo identification (ID) via our third party mobile check-in app, the app will collect user uploaded images.
5. DATA COLLECTED BY OUR STRATEGIC PARTNERS & RESERVATIONS
Certain transactions and services offered while visiting the website may be processed or provided by strategic partners, even though it may appear that the visitor may not have left the website. For example, the strategic partner who processes hotel reservation transactions on our behalf through this website is Sabre SynXis. Please note, The Townsend Hotel does not control and will not be responsible for the privacy policies of third party websites, including websites owned or controlled by Sabre SynXis. Third party websites that are accessed through links on our websites have separate privacy and data collection practices, as well as security measures. Sabre SynXis’s privacy policy can be found at [https://www.sabre.com/about/privacy/]. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their websites. We encourage visitors to contact them to ask questions about their privacy practices, policies and security measures before disclosing personal information.
6. NON-PERSONAL INFORMATION COLLECTED
When you visit our website, we automatically receive certain information from your browser or mobile device, such as your browser type, the operating system of your device, the URL of the site from which you came and the URL of the site you visit when leaving the Site. We also receive your IP address and the name of your ISP or your mobile carrier. Depending on your device’s settings, we may also receive location data and other types of information sent from third party services or GPS-enabled devices. As you use the Site, we may also collect information about such usage and your actions on our website, such as pages you viewed, access times, and how long you spent on a page. We may use cookies to collect such information, as described in more detail below.
This information is considered Non-Personal Information we can use for any purpose, including to help us improve the Site and to enhance your and other users’ experience. However, we will treat as Personally Identifiable Information any item that, either alone or together with other information, we could use to identify you as a natural person, i.e., an individual. For example, without your permission, we will not share with third parties the link between your IP address and your Personally Identifiable Information, except as otherwise provided for in this Privacy Policy.
7. OUR USE OF INFORMATION COLLECTED
We may use the information we collect from you for the following purposes, which include:
Providing our services and products;
Research analysis and auditing, in order to improve our services and products, or to protect or maintain the same;
Maintaining and ensuring the viability and integrity of our network;
Our marketing and promotional efforts;
Protecting the rights or property of the Townsend, our guests, our partners, or others;
Creating, researching and developing new services and products; and
Communications with you. The Townsend may combine Non-Personal Information you provide through the Site with information from other users to create aggregate data. Aggregate data does not (i) contain any information that could identify you, or (ii) include your personal contact information. The Townsend will not disclose your Personally Identifiable Information to any third party without your prior permission, except as otherwise permitted by this Privacy Policy.
8. THIRD PARTIES
We will neither voluntarily disclose nor sell any information we gather from our website to third parties for the purpose of additional solicitation or for any other reason, unless the visitor indicates his/her willingness to allow us to do so and except as set forth in this privacy statement.
9. SECURITY
Although "guaranteed security" does not exist either on or off the Internet, we safeguard our visitors' personally identifiable information by using industry standard practices. The personal information submitted to the website is stored on secure servers. The secure servers are protected by firewalls and other security procedures. The secure servers are not generally accessible by unauthorized third parties, but could become accessible in the event of a security breach.
Personally, Identifiable Information can be accessed and updated by the visitor during and after the registration process with the assistance of a Townsend Hotel customer service representative. Third party websites, like our hotel reservation service provider Sabre SynXis, are accessed through links on the website and have separate privacy, data collection practices, and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their websites. We encourage our visitors to contact them to ask questions about their privacy practices, policies and security measures before disclosing any personal information.
10. SALE OR MERGER
Data collected by The Townsend Hotel is an asset. It is possible that The Townsend Hotel, its subsidiaries, affiliates, joint venture companies, or any combination of the foregoing, could merge with or be acquired by another legal entity. In such event, visitors should expect that The Townsend Hotel may share some or all of the data collected from its visitors with such other entity; provided, that such other entity will be notified of the practices that apply to personally identifiable information under The Townsend Hotel's applicable privacy policy.
11. E-MAIL AND CAN-SPAM COMPLIANCE NOTICE
From time to time, The Townsend Hotel asks visitors for their e-mail address in order to provide relevant information such as concierge services and offers. E-mail addresses may be joined with other information provided at our website and may also be augmented with other data sources. By providing your e-mail address to us, you may receive e-mail regarding our products and services. You will always have the ability to accept or decline e-mail communications from The Townsend Hotel. E-mail communication is sent only to you if you have consented to receive e-mail from The Townsend Hotel. If you submit an e-mail address to us through the website via the Contact Us, Visitor's Experience, or the Townsend Concierge Service form, The Townsend Hotel may use the e-mail address for service and product information, as well as marketing and promotional communications. At any time, you may opt out of receiving e-mail communication by following the directions posted in every e-mail or by contacting a Townsend Hotel customer service representative to opt out of e-mail communication. The Townsend complies with the Federal CAN-SPAM Act. You may receive periodic offers and information from The Townsend Hotel about our services. If you do not want to receive marketing information from The Townsend Hotel, you have the option to contact us in order to decline such communication. You may either click the link on the e-mail communication you receive from us to unsubscribe or you may contact us through the information provided in the Contact Us section below. Once you have "opted-out", you can choose to "opt-in" again by contacting us in any of the above ways.
12. PERIODIC REVIEW AND MODIFICATIONS
This Privacy Policy was last modified on June 11, 2018. The Townsend recommends that visitors review this privacy policy periodically, as The Townsend Hotel reserves the right to amend, modify or revise this statement from time to time. When this privacy statement is changed, modified and/or amended, the revised privacy statement will be posted on the website. Any revised privacy statement will only apply prospectively to new information collected or modified after the effective date of the revised statement.
13. COOKIES AND INVISIBLE PIXELS
The Site may send a “cookie” to your computer. A cookie is a small piece of data sent to your browser from a web server and stored on your computer’s hard drive. A cookie cannot read data off your hard disk or read cookie files created by other sites. Cookies do not damage your system. Cookies allow us to recognize you as a user when you return to the Site using the same computer and web browser. We use cookies to identify which areas of our site you have visited. We also may use this information to better personalize the content you see on the Site. The Townsend does not store unencrypted Personally Identifiable Information in the cookies. To help us optimize the Site, we may allow other authorized third parties to place or recognize unique cookies on your browser. Any information provided to third parties through cookies will not be Personally Identifiable Information, but may provide general segment information to enhance your user experience by providing marketing that is more relevant. Third party services and tools we use may send cookies to users of the Site that collect certain information from users, which include:
DoubleClick, Google Tag Manager, Google AdWords Conversion, Google Dynamic Remarketing, Google AdWords User Lists, GA Audiences and Google Analytics (collectively referred to as “Google”): Google collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), Device ID (EU PII), PII (name, address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information). Aggregate data, anonymous data, PII data and sensitive data is shared by Google with third party parties. We use the information we get from Google only to improve this website and for marketing purposes. Google collects only the IP address assigned to you on the date you visit this website, rather than your name or other identifying information. You can review Google’s privacy policy at https://www.google.com/policies/privacy/. Although Google plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google about your visits to this website is restricted by the Google Terms of Use and the Google Privacy Policy. You can prevent Google from recognizing you on return visits to the website by disabling cookies on your browser (see below).
Criteo: Criteo collects: anonymous data (ad views, analytics, browser information, cookie data, hardware/software type, interaction data, page views), pseudonymous (IP Address (EU PII), search history, location based data, device ID (EU PII)), PII (email address, EU-IP address). Criteo collects aggregate data and shares that data with third parties. Criteo’s privacy policy can be found at http://www.criteo.com/privacy/full-privacy-text/.
Outbrain: Outbrain collects: anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, serving domains), pseudonymous (IP Address (EU PII), location based data, Clickstream Data, device ID (EU PII)), PII (name, phone number, email address, login, EU-IP address, EU-Unique Device ID). Outbrain collects aggregate data and shares aggregate, anonymous and PII data with third parties. Outbrain’s privacy policy can be found at http://www.outbrain.com/legal/privacy.
AppNexus: AppNexus collects: anonymous data (analytics, browser information, cookie data, demographic data, hardware/software type, interaction data, page views), pseudonymous (IP Address (EU PII), location based data, device ID (EU PII)), PII (PII collected via 3rd parties). AppNexus collects aggregate data and shares aggregate and anonymous data with third parties. AppNexus’s privacy policy can be found at https://www.appnexus.com/en/company/platform-privacy-policy.
Adara: Adara collects: anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, serving domains), pseudonymous (IP Address (EU PII), search history, location based data, Clickstream Data, device ID (EU PII)), PII (name, email address, PII collected via 3rd parties, login), sensitive (financial information). Adara data is shared with third parties. Adara’s privacy policy can be found at http://adara.com/privacy-promise.
StatHat: StatHat collects: anonymous data (cookie data), PII (email address) and other data not disclosed. StatHat’s privacy policy can be found at http://www.stathat.com/docs/privacy.
Each of the above-listed services and tools is governed by the privacy policy established by the respective third party provider. We encourage you to refer to such policies, which are linked to above in the description of each service.
If you do not want the benefits of these cookies, you can set your browser to reject the cookies. You should consult the instructions for your particular browser on how to do this. However, you should understand that rejecting cookies might affect your ability to perform certain transactions on our website and our ability to recognize your browser from one visit to the next. The Townsend Hotel also uses invisible pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate without personally identifiable information. The Townsend Hotel may use this information to improve marketing programs and content.
14. CHILDREN ONLINE PRIVACY PROTECTION ACT
The Townsend takes special care to protect the privacy needs of children under the age of 13 and The Townsend encourages parents to be an active participant in their child’s online activities. The Townsend abides by the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The website does not target and is not intended for children under the age of 13, and The Townsend will not knowingly collect personal information from them. In fact, the Site is not intended for anyone under the age of 18. If The Townsend discovers personal data from a child under the age of 13 is gathered through the Site, without parental consent, The Townsend will eliminate that data. If you are under the age of 13, you must ask a parent or legal guardian for permission prior to submitting any information to this Site.
15. CALIFORNIA PRIVACY NOTICE
Under Section 1798.83 of the California Civil Code, residents of California can obtain certain information from companies with whom they have an established business relationship. That information is about the Personally Identifiable Information those companies have shared with third parties for direct marketing purposes during the preceding calendar year. The law requires companies to inform consumers about the categories of Personally Identifiable Information shared with third parties, the names and addresses of those third parties, and examples of the services or products marketed by those third parties. To request a copy of the information disclosure provided by The Townsend under Section 1798.83 of the California Civil Code, please contact us by email at webmaster@townsendhotel.com. Additional contact information is provided below.
For further information, go to www.consumercal.org
16. THIRD PARTY DISCLOSURE AND INFORMATION SHARING
Except as set forth in this Privacy Policy or as specifically agreed to by You, The Townsend will not disclose any Personally Identifiable Information gathered from you on the Site.
A. We may share Personally Identifiable information in a limited fashion to our contractors, consultants and service providers that perform services on our behalf, including operation of the Site technology, marketing services, and other related services. Unless you have opted-out (see Section 16.C. below) of such sharing, these contractors, consultants and service providers also may have access to your email address to send newsletters or other information to you on our behalf. Access to your Personally Identifiable Information by such contractors, consultants and service providers is limited to the information reasonably necessary for the contractor, consultant or service provider to perform its limited function for The Townsend. We also contractually require that such contractors, consultants and service providers: (i) protect the privacy of your Personally Identifiable Information consistent with this Privacy Policy, and (ii) not use or disclose your Personally Identifiable Information for any purpose other than providing us with products and services or as required by law.
B. We may share Personally Identifiable Information we collect (i) when required or advised to do so in response to a valid legal requirement, such as a state or federal law, regulation, search warrant, subpoena, or court order; or (ii) in special and exceptionally rare cases, in response to a physical threat to you or others, to protect property, or assert legal rights or defend ourselves in litigation. If we are legally compelled to disclose your Personally Identifiable Information to a third party, we will attempt to notify you unless doing so would violate the law or a court order.
C. If you do not want us to share your information with our contractors and service provider, as described above, you can direct us not to share that information by contacting us. However, if you choose to opt-out, we may not be able to continue to provide you with some or any of the services. An opt-out of information sharing will not apply to information sharing arrangements described Section 16.B.
D. Finally, The Townsend may provide content and services to you through websites other than our own. The Townsend will not disclose your Personally Identifiable Information to these third party websites without your consent. However, any information you choose to disclose on such sites is NOT subject to this Privacy Policy.
17. DO NOT TRACK NOTICE
Your browser may provide you with the option to send a “Do Not Track” signal to websites you visit. This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation. At the current time, our website is not programmed to recognize Do Not Track signals, so the Site will not treat you differently if we receive such signals from your browser and we may not comply with Do Not Track settings on your browser.
18. CONTACT US
The Townsend Hotel invites all website visitors to contact us with any further questions or concerns about our hotel or this privacy statement. Visitors may contact us by mail at the following address:
The Townsend Hotel
100 Townsend Street
Birmingham, MI 48009
Visitors may also contact us by e-mail at webmaster@townsendhotel.com or call us at: 248.642.7900.