Hotel St. Regis Detroit and its affiliates ("HSR", "we", or "us") has adopted this Privacy Notice to inform you of its policies and practices with respect to information collected from all websites owned and operated by HSR (collectively, the "Site"). Your use of the Site constitutes your acceptance of this Privacy Notice and your consent to the practices it describes. This Privacy Notice applies only to information gathered on and through the Site and does not apply to any other information or websites not owned or operated by HSR or information collected by HSR by other means.
Please review this Privacy Notice periodically as we may update it from time to time. Each time you visit the Site, or provide us with information, you are, by doing so, accepting the practices described in this Privacy Notice at that time.
We value your privacy, and we do not sell your personal information. In addition, we will only share your personal information with third parties as set forth in this Privacy Notice or with your consent. This section gives a brief overview of our data collection and use policies. Please see below for a more detailed discussion of each topic.
We collect the following information:
- Personal information that you provide us on a voluntary basis.
- Information that your browser routinely shares with websites.
- Information that your mobile device shares when you access the site from a mobile device.
We use and disclose the information we collect for the following purposes:
- To provide you information about products and services that you request or that may interest you.
- To answer inquiries that you may submit through the Site.
- To help us improve our Site, understand its users and their preferences, and to market our services.
- To protect our business interests or the rights of others, when required by law, to cooperate with law enforcement, or in connection with the sale or merger of all or part of our business.
The Site uses the following tracking technologies:
- Cookies and other similar technology track movement across our website and keep track of our users and their preferences.
Other details about our practices:
- Although the Site may contain links to other websites, this Privacy Notice applies only to websites owned and operated by HSR.
- We use your personal information only for the purposes for which it is collected and consistent with this Privacy Notice, and we retain your information only as long as permitted by applicable law.
- We may update this Privacy Notice from time to time, but we will allow you to opt in to any material changes in how we use your previously collected personal information.
We have several different legal grounds on which we collect and process your personal information, including:
- As necessary to perform a transaction (such as when you register for an event);
- As necessary to comply with a legal obligation (such as for tax record keeping);
- Consent (where you have provided consent to the use of your information for a particular purpose); and
- As necessary for HSR’s legitimate interests (such as when we act to maintain our business generally).
- _ga - Google Analytics. used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports.
- _gat_UA - Google Analytics. Used to throttle request rate.
- _gid - Google Analytics. Stores and update a unique value for each page visited to distinguish users.
Personal Information That You Provide in Relation to Requests for Information or Submitting Inquiries
What information is collected? When you request to receive our newsletter or submit information regarding an event inquiry, you will need to provide personal information, which may include your name, physical address, email address, phone number, and specific details about an event you would like to host. You do not have to provide additional information that is not explicitly requested; however, additional information may help you get more from our services. It is your choice whether to include sensitive information in your requests or submissions and to make that sensitive information public. Please do not post or add personal data to your requests or submissions that you would not want to be publicly available.
How is this information collected? Personal information you provide is collected when you voluntarily provide the information. You therefore consent to the collection and processing of that data for the purposes set forth below.
How is this information used and shared? When you voluntarily provide information, you consent to its collection, and we process such information to fulfill your requests and respond to your event inquiries. We allow our business partners to see information that you have provided to facilitate connections between users of this Site and our business partners. This information is only shared if you choose to include such information as part of your request or submission on our Site.
Personal Information Related to Interaction with Our Site and Services
What information is collected? Personal information is created and collected when you provide it, ask questions, share information, or opt-in to Site features, and to help our partners improve their online offerings. Additionally, we log usage data when you visit or otherwise use our Site, such as when you view or click on content or ads, perform a search, or share information from other users.
How is this information collected? This information is collected when you give it to us and as you interact with our Site and services. When you use our Site, opt-in to certain features, or use communication services in connection with our Site, you are creating personal data that we collect. We also collect information related to the general use of our Site using cookies, device information, and IP addresses to identify and log your use. The cookie and mobile device policies are discussed further below.
How is this information used and shared? This information is used and shared to customize your experience with our Site and to communicate with you about events, products, and services that may interest you. Specifically, we may use the information we have about you to provide and personalize some of the Site’s features or services (such as ads) including with the help of automated systems and inferences we make, so the Site can be more relevant and useful to you and others. However, we do not use automated decision-making without human intervention, including profiling, in a way that would significantly affect you. Additionally, if you opt-in, we may use your personal information collected through the Site to provide you information about products, services, and events that we believe you may be interested in. You will always be given the opportunity to unsubscribe or opt out of receiving further communications or marketing emails by following the unsubscribe instructions in the email communication.
Personal Information Related to Browser and Analytics Data
What information is collected? Like many other websites, and regardless of which section of the Site you are visiting, we may record information that your browser routinely shares, and we may automatically track certain information based upon your behavior on the Site ("Aggregate Information"). This information may include, for example, the URL that you have just come from (whether this URL is on our Site or not), the URL you go to next (whether this URL is on our Site or not), your computer’s browser information, mouse clicks, mouse movements, scrolling activity, text that is typed, and your IP address. We may also collect information such as your number of visits to the pages of the Site. If you have signed up to receive any of our e-mail communications, we use similar technology to count how many recipients have opened the message and clicked on one of its links.
How is this information collected? This information is collected as a result of your browser sharing the information with us through the use of web beacons and cookies. Web beacons (also known as an action tags, clear gifs or pixel tags) are pixel images embedded in a website page used to transparently collect information. As mentioned above, a "cookie" is a small text file containing alphanumeric characters that is stored on your computer and uniquely identifies your browser. If you are simply browsing on this Site, the cookies that we use last only about as long as your session on this Site. We may allow business partners who provide services to this Site to place cookies on your computer that assist us in analyzing usage data. For example, we use Google Analytics to provide us with demographic information about our visitors and to help us analyze how people use our website, as further described below. We do not allow these business partners to collect your personal information from this Site except as may be necessary for the services that they provide.
How is this information used and shared? This information is used to keep track of users and their preferences and to provide analysis about the visitors to our Site. Specifically, cookies are used to keep track of users and the services they have collected. Web beacons (or similar technology) help us track the effectiveness of our communications. For example, we may use a web beacon to count the number of visits to the pages of this Site.
Statistical analyses of the information: We use Google Analytics and Adobe Analytics to help us gather statistical information about the visitors to our Site and how they use the Site on an anonymous, aggregate basis. But, we will not associate this data with personally identifiable data unless required to do so to cooperate with law enforcement activity or other governmental request or to comply with law. We may use this information to gain a better understanding of the users of our Site, to improve our Site, and to improve our services and product offerings. Depending on the type of browser and device that you use, you may have the ability to control the type of information that Google Analytics and Adobe Analytics use. To understand how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners/. To understand how Adobe Analytics collects and processes data, please visit https://www.adobe.com/privacy/opt-out.html. We reserve the right to license or sell Aggregate Information about the visitors to our Site, but this information will not contain your personal information or otherwise be individually identifiable.
- Google: https://support.google.com/ads/answer/2662922?hl=en
- Facebook: https://www.facebook.com/ads/website_custom_audiences/
- Adobe: https://www.adobe.com/privacy/opt-out.html
Geographic Information Collected From Mobile Devices
What information is collected? We may operate a version of this Site and applications specifically designed to work with mobile devices. The mobile Site and applications may include a feature that uses geographic location information.
How is this information collected? This information is provided by your mobile device.
How is this information used and shared? We do not collect or store your geographic information except to temporarily provide this Site. Your geographic information may be used to identify services in your vicinity in which you may be interested.
Other Ways We May Share Your Personal Information
Information shared with our business partners and processors: We may use business partners to help us design and operate the Site, provide services to support the Site, process your information, and provide promotional and marketing activities on our behalf. For example, we may partner with restaurants, event centers, and other entities to obtain information that you have requested or hire a company to run certain website applications, help us analyze our data, or send information on our behalf about products, services and events in which you may be interested. Unless otherwise indicated at the time we collect your information, if we allow our business partners to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this Privacy Notice. A list of our current business partners that have access to certain personal information we collect is available upon request.
Business operations, law enforcement and legal actions: We may release your information without prior notice when we believe it is appropriate to prevent fraud; to comply with law or to cooperate with law enforcement activity or other governmental request; to respond to subpoenas, court orders or administrative agency requests for information; to enforce our policies; to protect the rights, property and safety of our business and of others; or when required or otherwise permitted by law. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons. If there is a sale or merger of our organization, we may also transfer the information we have collected in connection with such sale or merger.
CROSS BORDER TRANSFERS OF INFORMATION
Any information you provide to us through the use of the Site may be stored, processed, transferred among, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your personal information in accordance with this Privacy Notice regardless of where your personal information is kept. Regarding transfers from the European Economic Area ("EEA") to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions outside the EEA, your use of the Site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified above. If you have questions about cross-border transfers, please contact us as detailed below.
We typically retain your personal information related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with, and to the extent permitted by applicable law, upon request. For personal information that we collect and process for other purposes, we typically retain such personal information for no longer than for the period necessary to fulfill the purposes outlined in this Privacy Notice and as otherwise specified in applicable record retention policies and procedures. We may retain your personal information even after you have unsubscribed from our communications if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or enforce our terms and conditions. We will retain de-personalized information after we have otherwise deleted your personal information.
CONSEQUENCES OF NOT PROVIDING PERSONAL INFORMATION
You are not required to provide all personal information identified in this Notice to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We maintain technical and organizational measures to protect the integrity of this Site and the personal information we collect from you from loss, misuse, alteration or unintentional destruction. However, we cannot provide absolute assurances against, and will not be liable for, any breaches of data security or confidentiality due to system failures or unauthorized access by third parties, or other causes beyond our reasonable control. You also have an important role in in protecting your information.
VERIFYING, CHANGING, AND DELETING YOUR INFORMATION
If the information you provided us is incorrect or if you have an issue with your information that we have collected, you can contact us as detailed below and ask us to change, update or fix your information in certain cases. You can also request that we erase or delete all or some of your personal information or otherwise object to, limit, or restrict the use of such information (if we have no legal right or legitimate business interest in retaining such information).
Our Site is not directed at children under the age of 13 and we will not knowingly collect information about children under the age of 13. If you are under the age of 13, please do not submit your personal information. If you are a parent who believes that we have collected information about a child under age 13, please contact us as detailed below and we will be happy to delete the information.
CALIFORNIA PRIVACY RIGHTS
For California residents: We may share your personal information with affiliated third parties, some of which do not share the HSR name, for their direct marketing purposes. These categories of affiliate are considered unaffiliated parties under California law, you may request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as detailed below. Please include your name and email address in such request.
We do not sell your information. However, as a California resident, under the California Consumer Privacy Act ("CCPA") you still have certain rights. These rights include:
- Right of disclosure: We must disclose the personal information collected, sold, or disclosed for a business purpose about you, and cannot collect person information if you have not been informed that it will be collected and consent to its use. This Privacy Notice is intended to serve as our disclosure to you.
- Right to access: You may request copies of specific personal information that we have collected, sold, or disclosed about you, and we must provide you with the personal information you request.
- Right to be forgotten: You may request that we delete certain personal information we have collected about you, and we must delete that information once we verify your request, with certain exceptions.
- Right to opt out: You may opt out of the sale of their personal information to third parties, and we must honor that request. Because we do not sell your information, you do not need to separately opt out of any sale by us.
- Right to equal services: We may not discriminate against you if you choose to exercise the rights outlined above. This means we cannot deny you goods or services, charge you different prices or rates for goods or services, providing you with a different level or quality of goods or services, or suggesting you will receive a different price or rate for the goods or services or a different level or quality of goods or services.
If you wish to exercise any of your rights under the CCPA, you may contact us using the contact details below. Please include in your email a sufficiently detailed description of the CCPA right with which you seek assistance. We may need to contact you for further information, and we will notify you if your request has been granted or declined, or if exceptions apply.
YOUR RIGHTS UNDER THE GDPR
For EU residents: Under the GDPR, EU residents have the right to request access to personal information we collect and share about you; corrections to or deletion of such personal information; restriction or suspension of our processing of your personal information; and a copy of your personal information we hold about you in a structured commonly used, and machine readable format.
If you have provided consent for the processing of your personal information, you may have the right (under certain circumstances) to withdraw that consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn.
If you wish to invoke any of your rights under the GDPR, you may contact us using the contact details below. Please use the subject line "GDPR Query" in the subject line. Please include in your email a sufficiently detailed description of the GDPR right with which you seek assistance. We may need to contact you for further information, and we reserve the right to charge a fee for certain requests. We will notify you if your request has been granted or declined, or if exemptions apply.
Please note that you always have the right to make privacy complaints directly to a supervisory authority in your country.
THIRD PARTY SITES
The website may contain links to other websites. For example, if you are applying for a job with HSR, you will be directed to a third party website to complete an application. In the US, this website is owned and operated by ADP, LLC. Additionally, if you are booking a reservation with a restaurant associated with HSR, you will be directed to Open Table to complete and finalize your reservation. We are not responsible for the privacy practices or content of any linked sites. We encourage our users to be aware when they leave our website and to read the privacy statements of each website to which we may link that may collect Personal Information.
CHANGES TO THIS NOTICE
We reserve the right to change this Privacy Notice. But, if we do change this Notice, we will post the revised version on the Site. And, if we are going to change this Privacy Notice in a way that would permit us to make additional uses of the personal information that we have previously collected about you, we will obtain your affirmative, express consent before using your information in a materially different way.
If you have any questions or comments about our policies and practices, please contact us using the contact information below. You may also file a complaint or ask to review any of the information that we have retained about you, how we have used it, or to whom we have disclosed it at any time by contacting us.
3071 W. Grand BLVD.
Detroit, MI 48202
Last updated: September 21, 2020