Privacy policy

PRIVACY POLICY Effective Date: MAY 12, 2020 Your privacy is important to us at Essex Suites Companies. Essex Suites Companies is committed to maintaining the highest ethical standards and appropriate internal controls. This “Privacy Policy” explains Our online information practices and the choices You can make about the way Your Information is used at our Site (defined below). This Privacy Policy governs the manner in which Essex Suites Companies collects, uses, maintains and discloses information that it collects from the Site. Essex Suites Companies’ Terms of Use available at https://www.essexsuites.com (the “Terms of Use”) are incorporated and made a part of this Privacy Policy. SECTION 1 – DEFINITIONS A. “You” and “Your” mean the individual or entity visiting or using the Site. B. “Essex Suites Companies”, “We,” “Us” and “Our” means Essex Suites Companies. C. “Site” refers to Essex Suites Companies’ website at www.essexsuites.com, and other related websites, blogs, domains, and mobile sites maintained by Essex Suites Companies. E. “Non-Personal Information” is any information that is not Personally Identifiable Information (defined below). F. “Personally Identifiable Information” or “PII” is non-public information we receive from your use of the Site that can be used, alone or in combination with other information in our possession, to identify a particular person/individual. It may include information such as name, address, telephone number and other personal information you provide us. SECTION 2- INFORMATION COLLECTED AND CONSENT You do not have to provide any Personally Identifiable Information to browse the Site. We may collect PII from You in a variety of ways, including, but not limited to, when You visit the Site, register on the Site, when You provide PII in connection with other activities, services, features or resources we make available on the Site, or when You complete a transaction on the Site. We may collect Your name, mailing address, billing address, phone number, payment information, and email address. We may also collect additional information from You depending on the nature of the transaction. Essex Suites Companies also collects information about You automatically when You visit the Site. 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 the Site, 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, which 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 PII any item that, either alone or together with other information, We could use to identify an individual. Except as described below in this section and in the “WHEN WE MAY DISCLOSE YOUR INFORMATION” section below, We will not share with third-parties the link between Your IP address and Your PII without Your permission. By providing Your PII to Us, You explicitly agree to Our collection and use of such information as described in this Privacy Policy. By browsing or using the Site, You consent to this Privacy Policy. Essex Suites Companies only shares PII necessary to fulfill Our obligations under a transaction. In addition, Essex Suites Companies may also use PII for the following purposes:• To improve customer service Your information helps Us to more effectively respond to Your customer service requests and support needs.• To personalize user experience We may Use information in the aggregate to understand how Our users as a group use the services and resources provided on the Site.• To improve the Site We continually strive to improve Our website offerings based on the information and feedback We receive from You.• To process transactions We may use the information that You provide about yourself when placing or fulfilling an order for products or services. We do not share this information with outside parties except to the extent necessary to provide the product or service.• To send periodic emails The email address you provide for order processing, will only be used to send You information and updates pertaining to Your order. It may also be used to respond to Your inquiries, and/or other requests or questions.• To develop new products or services We use your PII and Non-Personal Information for research and commercial purposes. The information We collect may be used to develop new products or services. We may use Your PII and Non-Personal Information internally or, among other things, to offer Our own or third-party products and services. Only Essex Suites Companies, its subsidiaries, its suppliers and contractors involved in distributing the new product or service will have access to Your PII. Our subsidiaries, suppliers and contractors will be required to use any PII we provide to them only for that intended purpose.• For marketing Essex Suites Companies may use Your PII and Non-Personal Information to enhance its networking, marketing, social, and recruiting activities, and for other similar business purposes. We may also use Personally Identifiable Information to provide You information regarding new products or services We believe may be of interest to You. Such Personally Identifiable Information is not shared with entities outside of Essex Suites Companies other than service providers who assist Us in carrying out these business functions.• Compliance with applicable law We may disclose your PII as we may in our sole discretion determine is necessary or reasonably required to comply with the law, applicable regulations, court orders or subpoenas, to enforce our Terms of Use, or to protect our rights, property or safety, or the rights, property or safety of others.• Change in the Site Ownership If ownership of the Site changes, whether in whole or in part, information collected through the Site about You may be transferred to the new owner so the Site and any service provided through or related to the Site can continue. In that case, Your user information would remain subject to the terms and conditions of the applicable version of the Privacy Policy. SECTION 3 - PAYMENT INFORMATION If You choose a direct payment gateway to complete a transaction, then Essex Suites Companies will share Your credit card data with a third-party transaction service such as Stripe or Silicon Valley Bank. It is encrypted in compliance with the Payment Card Industry Data Security Standard (“PCI-DSS”). All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands such as Visa, MasterCard, American Express and Discover. SECTION 4 - WEB BROWSER COOKIES 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 the Site You have visited. We also may use this information to better personalize the content You see on the Site. Essex Suites Companies does not store unencrypted Personally Identifiable Information in the cookies. We also do not link Non-Personal Information from cookies to Your Personally Identifiable Information.To help Us optimize the Site or for marketing purposes, 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 be for enhancing Your user experience by providing more relevant marketing. Third-party services and tools We use, which may send cookies to users of the Site and may collect information from users, includes:Google Tag Manager 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).GA Audiences and DoubleClick: Google operates GA Audiences, which 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), search history, location based data, and Device ID), and PII (name, address, phone number, email address, login, EU- IP address, and EU-unique device ID). GA Audience’s privacy policy can be found at: http://www.google.com/intl/en/policies/privacy/. We do not combine the information collected through GA Audience with personally identifiable information.Facebook Custom Audience: Facebook Custom Audience, operated by Facebook Business (formerly Facebook Custom Audience), 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), search history, location based data, Clickstream Data, PII (name , address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information). Facebook Custom Audience’s privacy policy can be found at: https://www.facebook.com/full_data_use_policy. Facebook Custom Audience shares data with third-parties (specifics are undisclosed).Facebook for Developers (formerly Facebook Connect): Facebook for Developers operates Facebook Connect, which 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), search history, location based data, Clickstream Data, PII (name , address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information). Facebook for Developers’ privacy policy can be found at: https://www.facebook.com/about/privacy/. Aggregate data is shared by Facebook for Developers with third-parties. Facebook for Developers also shares anonymous data with third-parties. Facebook for Developers shares PII data with third-parties. Facebook for Developers also shares sensitive data with third-parties. We do not combine the information collected through Facebook for Developers with personally identifiable information.Analytics, LinkedIn Ads and LinkedIn Marketing Solutions (collectively, “LinkedIn Analytics”): LinkedIn Analytics collects anonymous data (ad views, analytics, browser information, cookie data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII)), Location Based Data, Device ID (EU PII), and PII (name, address, phone number, email address, login). Aggregate and anonymous data is shared by LinkedIn with third-party parties. LinkedIn’s privacy policy for LinkedIn Ads and LinkedIn Analytics can be found at: https://www.linkedin.com/legal/privacy-policy.Bing Ads: Bing Ads is operated by Microsoft Advertising. Bing Ads collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII)), search history, Clickstream Data), PII (name, address, phone number, email address, login, EU-IP Address, EU-Unique Device ID), and Sensitive (financial information). Anonymous data is shared by Bing Ads with third-party parties. Bing Ad’s privacy policy can be found at: https://privacy.microsoft.com/en-us/privacystatement/.Marketo: Marketo collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, interaction data, and page views), pseudonymous data (IP Address (EU PII)), search history, Clickstream Data), and PII (name, address, phone number, login). Aggregate data is shared by Marketo with third-party parties. Marketo’s privacy policy can be found at: https://documents.marketo.com/legal/privacy/.Calendly: Calendly collects information from you that you provide directly through our contact forms and it automatically collects data through your use of our contact forms. Calendly automatically collects anonymous data (device type, browser information, page views, serving domain, Device ID, IP Address, mobile network carrier, timezone, and location). Calendly’s privacy policy can be found at: https://calendly.com/pages/privacy.Some browsers may allow you to manage the storage of cookies on your device. If supported by Your browser, You may set your browser to refuse all cookies (or, sometimes all third-party cookies) or to alert You when a cookie is set. However, if you select these settings, You may be unable to access certain parts of the Site. Unless You have adjusted Your browser setting to refuse cookies, the Site will issue cookies. For more information about how to manage Your cookies preferences, use the ‘help’ menu of Your web browser or explore the customer support sections of Your web browser. To opt-out of all cookies or certain advertising cookies, visit the company website for Your browser for instructions.Here are links to some browsers’ websites: Google Chrome: google.com/chrome Internet Explorer: support.microsoft.com Mozilla Firefox: support.mozilla.org Safari: support.apple.com Opera: www.opera.com SECTION 5 - DO NOT TRACK 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, the Site 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. SECTION 6 - EXEMPTIONS FROM THE PRIVACY POLICY Our Privacy Policy does not apply to any information You may send to Essex Suites Companies by email or instant messaging programs (e.g., AOL, Yahoo, etc.), or through social media networks, even if You open such programs or services by clicking a link displayed on the Site. Email, social media, and instant messages are not recognized as secure communication forms. Please do not send any information You consider private to Us by email or instant message or through social media sites (e.g., Twitter, Facebook, etc.) due to the public nature of such postings. SECTION 7 - THIRD-PARTY SERVICES In general, the third-party providers used by Us will only collect, use and disclose Your information to the extent necessary to allow them to perform the services they provide to Us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information We are required to provide to them to process payments made by You to Us.For these providers, We recommend that You read such third-party privacy policies so You can understand the manner in which Your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either You or Us. So, if You elect to proceed with a transaction that involves the services of a third-party service provider, then Your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if You are located in Canada and Your transaction is processed by a payment gateway located in the United States, then Your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.When You click on links on the Site, the links may direct You away from the Site. You also may be automatically directed from the Site to another website. Once You leave the Site or are redirected to a third-party website or application, You are no longer governed by this Privacy Policy or the Terms of Use. We are not responsible for the privacy practices of other third-party sites and encourage You to read their respective privacy statements. SECTION 8 – SECURITY To protect Your personal information, We take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.If You provide Us with Your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, We follow all PCI-DSS requirements. SECTION 9 - AGE OF CONSENT Essex Suites Companies takes special care to protect the privacy needs of children under the age of 13 and We encourage parents to be an active participant in their child’s online activities. Essex Suites Companies abides by the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The Site does not target and is not intended for children under the age of 13, and Essex Suites Companies will not knowingly collect Personally Identifiable Information from them. If Essex Suites Companies discovers personal data from a child gathered through the Site, Essex Suites Companies will eliminate that data. This Site is only intended for persons 18 years of age or older. If you are under 18 you must ask a parent or legal guardian for permission prior to submitting any information to this Site.If you have knowledge that a child 13 years of age or younger has submitted Personally Identifiable Information to us, please contact us and we will delete the PII information collected belonging to that child. You may contact us via email or by writing to us at the address below. Parents and guardians can also email us at [email protected], but before any information is disclosed, the parent will be required to provide the parent's name and email address for verification. We will only send the information to the parent email address in the registration file.We will never require the disclosure of a minor’s personal information. SECTION 10 - WHEN WE MAY DISCLOSE YOUR INFORMATION Except as set forth below or as specifically agreed to by You, Essex Suites Companies 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 10.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 Essex Suites Companies. 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 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 cases, such as 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 via email or by writing to Us at the address below. An opt-out of information sharing will not apply to information sharing arrangements described Section 10.B.Finally, Essex Suites Companies may provide content and services to You through websites other than Our own. We will only disclose Your Personally Identifiable Information to these third-party websites to the extent necessary to provide You with the products or services You requested. Essex Suites Companies may also provide links on our Site to other third-party websites. Any information You disclose on such sites is NOT subject to this Privacy Policy. SECTION 11 - NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE OF THE UNITED STATES OF AMERICA Essex Suites Companies is headquartered in the United States of America. Personally Identifiable Information may be accessed by Us or transferred to Us in the United States or to Our affiliates, business partners, merchants, or service providers elsewhere in the world. By providing Us with Personally Identifiable Information, You consent to this transfer. We will protect the privacy and security of Personally Identifiable Information according to Our Privacy Policy, regardless of where it is processed or stored. SECTION 12 - CALIFORNIA PRIVACY RIGHTS 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. Although Essex Suites Companies does not consider the California Civil Code to control its use of information collected on or through the Site and Essex Suites Companies disputes any assertion that the California courts have jurisdiction over it, Essex Suites Companies will nonetheless provide the foregoing information shared upon request by contracting Us at the email address or street address provided below. SECTION 13 - ACCESS If You are an individual You may have certain rights under applicable data protection legislation, including the right to review and correct the personal data We hold about You. Unless You reside in California or another jurisdiction that requires Us to provide the information without charge, We may charge You a fee to receive a copy of this data. For a copy of or reasonable access to Your personal data please contact Us via email or by writing to Us at the address below. SECTION 14 - CAN-SPAM COMPLIANCE NOTICE Essex Suites Companies fully complies with the federal CAN-SPAM Act. You can always opt out of receipt of further email correspondence from Us by clicking on the link at the bottom of any marketing emails or contacting Us via email or by writing to Us at the address below. SECTION 15 - CHANGES TO THIS PRIVACY POLICY We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on Our website. If we make material changes to this policy, We will notify You here that it has been updated, so that You are aware of what information We collect, how We use it, and under what circumstances, if any, We use and/or disclose it. SECTION 16 - INCORPORATION OF TERMS OF USE Please also visit Our Terms of Use establishing the use, disclaimers, and limitations of liability governing the Site, which are incorporated into this Privacy Policy by reference. SECTION 17 - QUESTIONS AND CONTACT INFORMATION If You have a privacy question about the Site, please contact us at:Essex Suites Companies Attn: Privacy Compliance Officer 25 Pompton Avenue, Verona, NJ 07044 www.essexsuites.com [email protected]