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This statement (“Privacy Policy”) is applicable to all of the information collected by Hospitality Marketing Consultants LLC (“HMC,” “we,” “us”) from you during your use of our web sites, including vhr.com (collectively, the “Site”).  By using the Site, you signify your acceptance of this Privacy Policy.

What types of personal information do we collect on the Site?

We constantly seek to provide an experience that is responsive to our visitors’ needs.  As part of these efforts, we collect, use and analyze certain information.  In particular, we collect the following information: 

Request for Information. When you request information related to our services or properties, we will request your name and contact information such as street address, phone number and email address.

Contacting Us by Email with Questions or Comments. When you send us an email from the Site, we may retain information such as the content, your email address, our response, and the text of any follow-up questions you may have.  We may use this information, for example, to measure how effectively we address customer concerns online, to personalize your experience, and to continuously improve our service.

Electronic Postcards and Forwarding to Friends. From time to time this Site may offer a feature that allows you to send an electronic postcard or otherwise share a message with a friend.  If you choose to do so, we will ask you for your name and email address, and the recipient’s name and email address, along with the text of any message you choose to include.

Online Surveys. Occasionally, we may conduct online surveys to better understand the effectiveness of the Site. Your participation in these surveys is voluntary.  Information collected by us when you participate in a survey may include your name, street address and email address.

Browsing. This Site does not collect personal information when you browse this Site and request pages from our servers unless you voluntarily and knowingly provide it to us.  This means that we will not know your name, your email address, or any other personal information just because you browse the Site unless you access the Site from a link in an email that we sent, or you are a StayWell Rewards member and have logged in to your account.  In these cases, we will know who you are based on the information you previously supplied to us.  When you request a page from the Site, our servers log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTP header.  We collect the HTTP request header information in order to make the Site function correctly and provide you the functionality that you see on the Site.  We also use this information to better understand how visitors use the Site and how we can better tune it, its contents, and functionality to meet your needs.

When choosing to become a StayWell Rewards member, you will have consented to provide and receive all of the kinds of information described in the StayWell Rewards Membership Privacy Policy.  If you are a member, you should also refer to the StayWell Rewards Terms and Conditions for more information.

What Information is Collected Through Web Technologies?

We use “cookies” and other technologies on the Site to automatically track information.  Cookies are small pieces of information that our server places on a visitor’s computer hard drive to enable that person to more easily communicate and interact with the Site and to provide us with important information on how visitors use the Site.  Cookies can collect information such as the following:  a user’s ID and password, personalize home pages, and identify which parts of a site have been visited or keep track of previous selections or purchases.  Cookies are used to measure usage of various pages on the Site to help us make our information more pertinent to your needs and easy for you to access. 

Web browsers are automatically set to accept cookies.  You may change your browser settings to either reject cookies or notify you when a cookie is about to be placed on your computer.  Please note, however, that rejecting cookies while visiting the Site may result in certain parts of the Site not operating correctly or as efficiently as if they were allowed.

HMC and its third-party service providers also use pixel tags (also known as “clear gifs”, “beacon gifs” etc.).  Pixel tags are not visible to the user of the Site and consist of a few lines of computer coding delivered with the Web page.  Pixel tags are not used to collect any personal information about you apart from what you voluntarily provide us in your dealings with HMC.  Pixel tags are used to track customer response to advertisements and website content, to determine your ability to receive HTML-based email messages, to compile aggregated statistics about an email campaign for us, and to better target interactive advertising, enhance customer support and Site usability.

Can Minors Use the Site?

We encourage parents to use the Site with their children.  However, this Site is not directed towards children under the age of 13, and children under 13 should not provide personal information to the Site.

How Do We Secure Transmission and Storage of Information?

We treat the personal information you provide to us as confidential information; it is, accordingly, subject to our company’s security procedures and policies regarding protection and use of confidential information.  When we ask you for credit card data, it is transferred over a Secured Sockets Layer (SSL) line, provided you are using a SSL enabled browser such as Microsoft Internet Explorer, Netscape Navigator, or Fire Fox.   We also use SSL on other pages where you would enter personal information.  This helps to ensure that your information is encrypted as it travels over the Internet.  You will know you are in “secure” mode when the padlock or key icon in the lower right-hand or left-hand corner of the computer screen appears in the locked position.  In addition, when accessing an SSL-secured server, the first characters of the Site address will change from “http” to “https.” After information reaches HMC, it is stored on a server that resides behind firewalls designed to block unauthorized access from outside of HMC.  In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development.  If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email.

Where Will We Store and Maintain the Information?

We maintain this Site in the United States.  By providing personal information and other information to this Site, you understand and consent to the collection, use, processing and transfer of such information to the United States and other countries or territories which may not offer the same level of data protection as the country where you reside, in accordance with the terms of this Privacy Policy. 

Due to the global nature of our business, personal information will also be shared with affiliated companies, hotels, third party services providers, and as described below in this StayWell Rewards Membership Privacy Policy (“Does HMC Share Personal Information With Other Companies?”) which may be located in countries or territories which may not offer the same level of data protection as the country in which you reside.

How Will We Use Personal Information?

We will use personal information provided by visitors to fulfill the purpose for which it was provided, as otherwise described in this Privacy Policy, and as disclosed at the time the visitor information is requested.

Does HMC Share Personal Information With Other Companies?

We may share the information with our affiliated companies, and we contract with other companies to perform various functions necessary to meet your specific requests, administer the Site, and to communicate news and deliver promotional materials.  We will share with these other companies only that personal information they require to fulfill your orders.  These companies agree that they will not use or disclose that personal information for any other purpose.

Other than as explained in this policy, we will not disclose any personal information we collect from you to others without your permission, except in certain limited circumstances: (a) to protect the security of our websites; (b) to protect ourselves against liability; (c) in response to legal process’ (d) if we believe in good faith that the law requires it; or (e) in connection with a sale of our business or company. 

If I Link to Another Website and Provide Information to that Website, How Will that Information be Handled?

We do not control and shall not be responsible for the collection of personal information by third party websites, including websites owned or controlled by franchises, third party owners or participating StayWell Rewards hotel properties, hotel room distributors, or websites not controlled or authorized by HMC.  Third party websites that are accessed through links on the Sites have separate privacy practices.  We have no responsibility or liability for the practices and policies implemented by third parties on their websites.  Third party websites may have received permission from HMC to use StayWell Rewards logos or trademarks but will not offer a link to this Privacy Policy.  If you enter or choose to leave the Sites via links to other non-HMC sites (including those of our advertisers, content providers, vendors, independent hotels, affiliates and partners), your visits to those sites are not covered by this Privacy Policy.

What if the Privacy Policy Changes?

This Privacy Policy is effective as of November 1, 2006. HMC may amend this Privacy Policy from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our members, participating hotels, or strategic marketing. A notice will be posted on this the Site whenever the Privacy Policy is changed in a material way.

Can I Review or Change My Information?

Yes.  If you want to review, correct, or change personal information that you have previously provided to us, please send us an email atprivacy@vhr.com. If you wish to review your preferences, you can do so by logging into your StayWell Rewards account atwww.vhr.com. If you have comments or questions regarding HMC’s data privacy practices or this StayWell Rewards Membership Privacy Policy, you may contact us via e-mail atprivacy@vhr.com, by telephone (+1 949-833-8000), or postal mail (4701 Von Karman Avenue, Suite 300, Newport Beach, CA, 92660, United States of America).

SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS: Although HMC does not share personal information with unrelated third parties for their own direct marketing purposes, many participating StayWell Rewards hotels, which are separately owned and operated, are permitted to use the personal information they receive from HMC to market their hotels.  If you are a customer who resides in the State of California, you may request from HMC information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes.  Such requests must be submitted to us by email at 4701 Von Karman Avenue, Suite 300, Newport Beach, CA, 92660, United States of America orprivacy@vhr.com. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.