CCPA Privacy Policy

Privacy Notice For California Residents

California Consumer Privacy Notice

Last Updated: October 18, 2023

This California Consumer Privacy Notice (“Notice”) supplements the information contained in The Garland’s Privacy Policy, and is provided pursuant to the California Consumer Privacy Act (“CCPA”) and other California privacy laws. This Notice describes how The Garland (“us,” “we,” or “our”) processes personal information of California consumers, vendors, and business contacts. Additional policies may apply in other contexts and to other relationships you may have with us. For example, we have a separate Privacy Policy for California job applicants, which is available here.

As used in this Notice, the term “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

1. Personal Information We Collect and Why We Collect It

Generally, we collect the following categories of personal information from the sources listed and for the purposes listed:

Category of Personal Information	Categories of Sources	Purposes for Collection
Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.	·.     Directly from you. ·      Service providers that help us to run our business. ·      Advertising networks, social networks, internet service providers, and data analytics providers. ·      Automatically when you use our website.	·       To communicate with you. ·       To process purchases, transactions, and payments. ·       To provide you with customer service and support. ·       To facilitate your stay. ·       For marketing, advertising, and promotions. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To develop new services that may be of interest to you. ·       To customize or tailor your experience. ·       To detect and prevent fraud against you and/or us. ·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Personal information described in Cal. Civ. Code § 1798.80(e), including name, signature, address, telephone number, passport number, driver’s license or state identification card number, credit card number, debit card number, or any other financial information, medical information.	·       Directly from you. ·       Service providers that help us to run our business. ·       Advertising networks, social networks, internet service providers, and data analytics providers.	·       To communicate with you. ·       To process purchases, transactions, and payments. ·       To provide you with customer service and support. ·       To facilitate your stay. ·       For marketing, advertising, and promotions. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To develop new services that may be of interest to you. ·       To customize or tailor your experience. ·       To detect and prevent fraud against you and/or us. ·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Protected classification characteristics under California or federal law, including age and date of birth, citizenship, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).	·       Directly from you.	·       To provide you with customer service and support. ·       To facilitate your stay. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To customize or tailor your experience. ·       To detect and prevent fraud against you and/or us. ·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	·       Directly from you. ·       Service providers that help us to run our business. ·       Advertising networks, social networks, internet service providers, and data analytics providers. ·       Automatically when you use our website.	·       To communicate with you. ·       To process purchases, transactions, and payments. ·       To provide you with customer service and support. ·       To facilitate your stay. ·       For marketing, advertising, and promotions. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To develop new services that may be of interest to you. ·       To customize or tailor your experience ·       To detect and prevent fraud against you and/or us. ·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Internet or other similar network activity information, including browsing history, search history, information about a consumer’s interaction with a website, application, or advertisement.	·       Directly from you. ·       Automatically when you use our website. ·       Service providers that help us to run our business. ·       Advertising networks, social networks, internet service providers, and data analytics providers.	·       To communicate with you. ·       To process purchases, transactions, and payments. ·       To provide you with customer service and support. ·       To facilitate your stay. ·       For marketing, advertising, and promotions. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To develop new services that may be of interest to you. ·       To customize or tailor your experience. ·       To detect and prevent fraud against you and/or us. ·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Geolocation data, including physical location inferred from your device IP address.	·       Automatically when you use our website. ·       Service providers that help us to run our business. ·       Advertising networks, social networks, internet service providers, and data analytics providers.	·       To process purchases, transactions, and payments. ·       To provide you with customer service and support. ·       To facilitate your stay. ·       For marketing, advertising, and promotions. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To develop new services that may be of interest to you. ·       To customize or tailor your experience. ·       To detect and prevent fraud against you and/or us. ·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Sensory data, including CCTV footage and audio recordings of customer care calls.	·       Directly from you. ·       Automatically when you visit our property or contact us on a recorded line. ·       Service providers that help us to run our business.	·       To communicate with you. ·       To process purchases, transactions, and payments. ·       To provide you with customer service and support. ·       To facilitate your stay. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To develop new services that may be of interest to you. ·       To customize or tailor your experience. ·       To detect and prevent fraud against you and/or us. ·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
Inferences reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	·       Drawn from the other categories of personal information we collect ·       Service providers that help us to run our business. ·       Advertising networks, social networks, internet service providers, and data analytics providers	·       To provide you with customer service and support. ·       To facilitate your stay. ·       For marketing, advertising, and promotions. ·       To support our operations, and to improve our Service, including through research and analysis. ·       To develop new services that may be of interest to you. ·       To customize or tailor your experience. ·       To detect and prevent fraud against you and/or us.
Sensitive Personal Information, including: ·       Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. ·       Personal Information collected and analyzed concerning a consumer’s health (e.g., as related to accommodations for a disability).	·       Directly from you	·    When necessary to provide our Service ·    To process purchases, transactions, and payments. ·    To detect and prevent fraud against you and/or us. ·    To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

We may also use, and disclose personal information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or for other purposes described in any other privacy notice or with your consent. Additionally, we may use and disclose personal information to third parties in connection with a sale, assignment, merger, reorganization, or other corporate transaction relating to all or part of our business.

1. How Long We Keep Your Personal Information

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply: 

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected; 
• The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or 
• We are otherwise required or permitted to keep your information by applicable laws or regulations. 

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

1. Disclosure of Personal Information for Business or Commercial Purposes

We may disclose each of the categories of personal information we collect to our service providers and contractors for the following business and commercial purposes:

• Performing services (including processing, maintaining, or collecting personal information) on our behalf related to the operation of our business and/or the Service (e.g., providing communications, technical, analytical, web hosting, data storage, application support, vendor management, reservations, billing, credit card processing, customer support, property management, accounting, auditing, insurance, legal, security, or other services)
• Auditing related to ad impressions
• Ensuring security and integrity of personal information
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, non-personalized advertising
• Providing advertising or marketing services on our behalf
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of our Service
• To comply with applicable laws and regulations
• For safety and security
• Detecting, protecting against, or addressing malicious, deceptive, fraudulent, or illegal activity

We disclose sensitive personal information for more limited purposes, including: when necessary to provide our Service; services performed on our behalf related to the operation of our business and/or the Service; ensuring security and integrity of personal information; short-term, transient use; undertaking activities to verify or maintain the quality or safety of our Service; to comply with applicable laws and regulations; for safety and security; detecting, protecting against, or addressing malicious, deceptive, fraudulent, or illegal activity.

1. Behavioral Advertising and Sales of Personal Information

Although we do not sell personal information in exchange for money, some of the ways in which we share personal information for targeted advertising or analytics may be considered “sales” or “sharing” under the CCPA.

The chart below shows the categories of personal information we share for purposes of targeted/cross-context behavioral advertising or otherwise “sell” for non-monetary consideration. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

Categories of Personal Information	Categories of Third Parties to which Sold or Shared	Purposes for Selling / Sharing
Identifiers. Personal information described in Cal. Civ. Code § 1798.80(e). Internet or other electronic activity information. Geolocation data. Inferences.	Third-party advertising networks and social networks. Certain types of analytics providers.	To show you relevant ads while you browse the internet or use social media. Analytics services where the vendor does not strictly agree to limit its use of the personal information is processes on our behalf.

1. Your Rights and Choices

If you are a resident of California, you have the right to submit certain requests relating to your personal information as described below. To exercise any of these rights, please submit a request through our webform [link] or call us at (800) 238-3759. Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to provide 2-3 pieces of personal information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.

Right to Know. You have the right to know what personal information we have collected about you, which includes:

1. The categories of personal information we’ve collected about you, including:
• The categories of sources from which the personal information was collected.
• Our business or commercial purpose for collecting, selling, or sharing personal information.
• The categories recipients to which we disclose personal information.
• The categories of personal information that we sold, and for each category identified, the categories of third parties to which we sold that category of personal information.
• The categories of personal information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of personal information.
2. The specific pieces of personal information we’ve collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete personal information that we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.

Right to Correct Inaccurate Information. If you believe that personal information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your personal information, and to request that we do not share your personal information for cross-context behavioral advertising. To opt-out, please click here [link to cookie-based sale opt-out mechanism]. [To submit a request to opt out of offline sales and sharing, please use our webform.]

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

1. Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

1. 8. Notice of Financial Incentive

Summary. We sometimes offer discounts, special offers, and promotions like a discounted stay in connection with you opting in to receive marketing emails. We may also participate in rewards programs offered by other companies. For example, we provide discount codes or perks because we want to show you that we are excited you want to hear from us and because we hope you will want to stay with us.

Material Terms. The details of each program are contained in the program offering but in general, we invite you to provide us with your name, email address, and zip code, and we provide you with a sign of our appreciation such as a special offer or and promotion like a discounted room rate. We also collect commercial information in connection with these programs, such as the rooms you book. We value the opportunity to market to you.

How To Opt In. You can opt in using a prompt on our website that links to this notice.

Right to Withdraw. You can withdraw from participation at any time by emailing us at [email protected]. You may also opt out of our marketing email communications by clicking on the unsubscribe link in our emails.

Value of Financial Incentive. The incentives we offer vary – for example, the value of coupons providing a percentage discount off of a room rate depends on the specific coupon and the room you choose to book. Generally, the value of your personal information associated with the program is reasonably related to the incremental administrative costs of maintaining the program, including storage of your personal information.

1. Contact Information

If you have any questions about this Notice, please do not hesitate to contact us at:

Phone: (800) 238-3759

Website: www.thegarland.com

Email: [email protected]