Hotel ZaZa Privacy Policy

We are committed to maintaining the privacy and security of your user information. This Privacy Policy (this “Policy”) explains the types of personal information ZaZa Holdings LLC (“ZaZa”) collects and how we collect, use, and disclose this information.

This Privacy Policy also tells you about how we protect your personal information and the rights and choices you may have when it comes to your personal information.
This Policy applies to ZaZa, its affiliates, and any hotels, restaurants, spas, or other properties or programs that are managed by ZaZa (collectively, “Company,” “we,” “us,” or “our”). This Policy applies to the information we collect when individuals, including guests, and customers who interact with the Company, including at our physical locations and through our websites and any apps where this Policy is referenced.

By using any of our products or services (our “Services”) and/or by providing personal information to us, you understand and acknowledge that we will collect and use personal information as described in this Policy. If you do not agree to our Privacy Policy, you may not access or use the Services. If you have entered into a specific agreement with us for certain services we provide, the terms of that agreement will control to the extent there is any conflict with these terms.

We collect and process personal information based on your transactions and interactions with the Company and our Services, both online (e.g., website, email, social media) and offline (e.g., phone, hotels). We may collect this information directly from you or from third parties to provide, improve, and personalize our Services, respond to your requests, and communicate with you.

What We Collect

The types of personal information we may collect about you may include:

• Contact information: Name, telephone number, email, and postal address;
  
  
• Information about your stay: Booking and reservation details and history, dates of stay, preferences with respect to rooms, communication methods and other personal preferences, dietary needs and other special requests, feedback about our Services, location information (e.g., when using WiFi), and information about other personal needs that we collect to ensure your wellbeing;
• Financial information and related transactional data: Credit card and other payment information, billing information, and payment history;
• Identifiers and Online activity: Date and time of your visit to our websites, webpages visited, links clicked, browser ID, browser type, device ID, system and file access logs, browsing history, search history.
• Account information: Username, password, and access credentials for Company accounts and systems, as well as profile information such as date of birth, account settings and preferences;

• Communications: Interactions between you and us, such as via email, mail, phone, or other channels, including your responses to any surveys and questions we may send you, such as for feedback and research purposes;

• Inferences: Analysis of information about your stay, which we use to develop inferences regarding individual preferences and characteristics; and
  
• Transactional data: Purchase history and other transactions.

If you provide us with personal information relating to another individual (e.g., family member, employee, customer), you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We may collect personal information about you from various sources, including:

• Direct interactions with you: We collect personal information when you use our Services, including when you visit our websites, check-in and otherwise interact with us at our physical locations, enter into a contract with us, make bookings, inquire about our offerings, engage with us on social media, provide feedback or complete surveys for us
  
  

• Automatically: We may collect personal information automatically, including through cookies when you visit our websites or apps, as well as data from surveillance cameras at our locations, and information collected when you use Company networks and devices; and/or

• Third parties: We may also collect personal information from third parties, including business partners and service providers, such as marketing and hotel operations support vendors, social media platforms, lead generators, event sponsors, reservation and booking systems or agents, data firms, joint marketing partners, and public databases.

We may also collect and use information that does not identify you or your devices, or de-identify your personal information so it no longer identifies you (collectively, “Anonymous Information”). Since Anonymous Information does not include personal information, it is not subject to this Privacy Policy.

We may use personal information for the following purposes:  

• Service or request fulfillment: To process bookings, manage reservations, confirm stays, provide accommodations and other hotel guest services, manage your account, process payments and complete transactions, provide customer support, and otherwise to provide the Services or fulfill the purpose for which you provide personal information, and where we need to perform the contract we are about to enter into or have entered into with you;
• Communications: To notify you about transactions, policy changes, updates, offers, and other relevant information regarding the Company and our Services;
• Operational management: To support and improve hotel management operations and our Services, personalize and enhance user and customer experience, conduct analytics, process and maintain payments and records on transactions;
• Marketing and advertising: To send you marketing and advertising communications, including to personalize advertising and promotional content, manage promotions and events, and send targeted communications;
• Other business purposes such as data analysis, market research, surveys, customer satisfaction, audits, diagnose or fix technology issues, fraud monitoring and prevention, developing new products and services, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
• Compliance: To meet legal obligations and respond to requests from regulatory authorities, as well as address industry standards, our policies, and contractual rights; and/or
• Security: To detect and prevent fraud, identity theft, and other malicious activities, and to ensure the physical safety of guests, customers, and other individuals.

We may disclose personal information with others in the following circumstances:

• At your request: We may disclose personal information when you direct us to do so, including when necessary to provide you with our Services or to otherwise fulfill the purpose for which you provide it;
• Online cookie tools: Limited information (e.g., IP address, pageview, etc.) may be collected through third party online tools such as cookies, as described below, and you can take certain steps to prevent such collection;
• Legal compliance: We may disclose personal information when required by law or to respond to legal process;
• Exigent circumstances and to protect rights: We may disclose personal information to protect our property, rights, safety, and that of our employees, guests, customers, or others, and in connection with an investigation of suspected or actual fraudulent, or illegal activity; 
• Affiliates and owners of properties: for the purposes described in this Privacy Policy. We work in conjunction with our affiliates and owners of the hotel properties we manage, and may share your personal information with such affiliates and owners, including so they can work with us in the operation of our business, and so they can provide you with information about other services and amenities that may be of interest to you. Any commercial email sent by an affiliate or owner will include an opportunity to not receive such email messages in the future;
• Service providers: We disclose personal information to service providers who assist us in performing business functions, including by providing property management services, customer relationship services, guest services support, financial and tax services, website hosting, order fulfillment, payment processing, marketing services, information technology and cybersecurity services, and data analytics. These parties only have access to the data needed to perform their functions and cannot use it for other purposes;
• Business partners:  We may disclose personal information to business partners, including but not limited to airlines, retail stores, and other third parties to facilitate reservations, assist you in making arrangements or with requested purchases of products or services, or in connection with one of our partners’ loyalty programs (e.g., to earn or redeem points). We may also co-sponsor promotions, sweepstakes, or events with a third party and share your information when you provide it to facilitate these events. Further, we may share your information with third-party providers of ancillary services on-site at hotels or resorts to fulfill your service requests, such as Valet companies, concierge, and dining providers. If you provide additional information to such third parties, it will be subject to their privacy practices;
• To third-party sponsors of sweepstakes, contests and similar promotions; 
• By you, on message boards, chat, profile pages, blogs and other services to which you are able to post information and materials. Please note that any information you post or disclose through these services will become public and may be available to other users of the Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services; and 
• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). 

We do not share your text message program enrollment or consent information with third parties for their own purposes. We may provide such information to our service providers so they can provide services to us.

Cookies are a commonly-used web technology that allows websites to store and retrieve certain information on a user’s system, and track user’s online activities. We, together with the vendors we use, may collect information about your use of our Services by such automated means, including but not limited to cookies, pixels and other similar technologies.

Cookies and similar technologies can help us automatically identify you when you return to our website. Cookies help us review traffic patterns, improve the website, and determine what Services are popular. We can also use such information to deliver customized content and advertising to users of the Services whose behavior indicates that they are interested in a particular subject area.

When you use the Services, the information we may collect by automated means, include, for example:

• Usage details about your interaction with our Services (such as date, time, and length of visits, and specific pages or content accessed during the visits, search terms, frequency of the visits, referring website addresses);
• Device information, including the IP address and other details of a device that you use to connect with our Services (such as device type and unique device identifier, operating system, browser type, mobile network information, and the device’s telephone number); and
• Location information where you choose to provide the website with access to information about your device’s location.

We may also ask advertisers or other partners to serve ads or services to you, which may use cookies or similar technologies placed by us or the third party. If a user does not want information collected through the use of cookies, most browsers allow the visitor to reject cookies, but if you choose to decline cookies, you may not be able to fully experience the interactive features our Services provide. We may share non-personal information we obtained via cookies with our advertisers and affiliates. Because there is not yet a consensus on how companies should respond to browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.

We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.

• Marketing Emails: From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. You may choose not to receive marketing emails from us by clicking on the unsubscribe link in the marketing emails you receive from us or by emailing us at Privacy@HotelZaZa.com. Even if you opt out of receiving such communications, we will continue sending you non-marketing email communications, such as administrative or transaction alerts, or information about changes to our Terms or this Privacy Policy, when necessary. 
• Text messages: If you affirmatively consent to receive text messages from us and enroll in such a program, you will receive updates via text unless you opt-out of the text message program. These messages may be unencrypted. Message frequency may vary based on the Services. If at any time you would like to stop receiving text message notifications, please text “STOP” in reply to our message, we will send you a reply message to confirm that you have been unsubscribed and you will no longer receive messages from us. If you want to join again, just sign up as you did the first time and we will start sending messages to you again. If at any time you forget what keywords are supported, just text “HELP” back to us and we will respond with instructions on how to use our service as well as how to unsubscribe.
• Cookies: Web browsers may offer users the ability to disable certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly. 
• Targeted Advertising: We may potentially work with advertising partners who collect information about your online activities and provide you with choices regarding the use of your browsing behavior for purposes of targeted advertising. Popular advertising services you may opt out of targeted advertising from include Google, Facebook, the Network Advertising Initiative, and Digital Advertising Alliance. 

Privacy laws in certain states including California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia provide additional rights with respect to the collection and use of personal information collected by businesses.  

We provide the following additional rights with respect to your personal information:

• You may request a copy of the following: (1) the categories of personal information we collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting or selling (if applicable) the personal information; (4) the categories (or in some states, the identity) of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about you.
• You may request that we correct your personal information if it is inaccurate or delete your personal information. Note that deletion requests are subject to a number of limitations, for example, we may keep personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, to process transactions and facilitate customer requests, and for other internal business purposes consistent with the terms under which it was collected.
• You have the right in certain states to opt out of (i) any selling or sharing of your personal information to a third party (excluding service providers or other exceptions permitted by law); and (ii) any third-party targeted advertising (i.e., cross-context behavioral advertising).

You may make any of these requests by contacting us at Privacy@HotelZaZa.com. To the extent our website includes third party targeted advertising cookies, we will endeavor to provide a means to opt-out of such cookies as well as process “Global Privacy Control” (GPC) signals from web browsers by automatically opting-out such visitors from any third party targeting cookies, although GPC technology is not fully developed and it is not yet supported by all browsers.

You may authorize another person (your "Agent") to submit a request on your behalf the same way. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it. 

Please be advised that we will aim to fulfill any privacy requests as required by applicable law and otherwise in in our reasonable discretion. If we deny a request in regard to a privacy right provided by applicable law, you may appeal the decision to us at Privacy@HotelZaZa.com. To the extent possible, please describe the basis for your appeal and if there is any specific personal information that concern you. We will endeavor to provide a prompt response and within the timeframe provided by any applicable law.

If you are unsatisfied with our response to an appeal, you can raise your concerns with your state’s Office of the Attorney General.

We do not use or sell customers’ sensitive personal information (such as financial information) except for the purposes it was collected and as otherwise permitted by law. 

NEVADA RIGHTS

For Nevada residents, please note that we do not sell personal information as defined by Nevada law (Nevada Revised Statutes, Chapter 603A, Section 1.6). You can submit a request to us regarding the sale of such information at Privacy@HotelZaZa.com. 

Certain rights under California privacy laws apply to all individuals (not just guests and other customers), including job applicants, current and former employees, contractors and business partners. Due to the nature of these relationships, the collection and use of personal information can vary, but in general terms and in addition to all the disclosures above: (i) job applicant information is used in the employment application review process and includes contact information, education and employment history, resume and cover letter, and background checks; and (ii) contractor and business partners information is used ad reasonably necessary to engage and work with such individuals in the course of the business relationship. Such individuals who are California residents can request additional information about our privacy practices with respect to their information, as well as make the privacy described above, by contacting us the form at Privacy@HotelZaZa.com. We may employ a more extensive authentication process for non-customers before responding to a request.

Our websites are not intended for use by children under 18 years of age, and we do not knowingly collect, sell, or share for cross-context behavioral advertising purposes any personal information of children under 18. If you are under 18, do not use or provide any information on our websites. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information received from a child under 18, please contact us at Privacy@HotelZaZa.com.

We keep your personal information for different lengths of time depending on the type of information and the business and legal requirements. In deciding how long to retain personal information, we consider many criteria, including the business purposes for which the personal information was collected, relevant federal, state, and local recordkeeping laws, applicable statutes of limitations for claims to which the information may be relevant, and legal preservation of evidence obligations. Some information is deleted automatically after a set period of time, often set by law, unless we are legally required to hold it longer, such as for pending litigation.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services is solely for your convenience, and the inclusion of such links does not imply endorsement of the linked site or service by us or by our affiliates. You access linked sites at your own risk and by accessing them you leave the Website.

We are not responsible for the information collection, use and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, and we encourage you to check the applicable privacy policy to determine how these linked sites will handle any of your personal information.