Privacy

BEST WESTERN INTERNATIONAL, INC. PRIVACY POLICY

LAST UPDATED: May 2018

Best Western International, Inc. (referred to herein as "BWI," "we," and "us") is committed to protecting your privacy and wants you to be familiar with how we collect, use, and disclose Personal Information (as defined below). References to “BWI,” “we” and “us” throughout this Policy, depending upon the context, collectively refer to BWI and any subsidiary of BWI, including but not limited to SureStay, Inc.

By using this website or a mobile application (“Site”), including text message, providing Personal Information (as defined below) to BWI, or otherwise indicating your consent to receipt of marketing or other information from us, you consent to all actions taken by us with respect to your Personal Information as set forth in this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site or provide any Personal Information to BWI through our Site or otherwise.

This Policy does not describe the collection, use, or disclosure of information by third parties, including third parties that own or operate Best Western® branded hotels and properties ("Licensed Hotels"), and third-party affiliated organizations permitted to sublicense Licensed Hotels outside the United States in various countries and territories throughout the world ("Affiliates"). Please be aware that Licensed Hotels and Affiliates are independent entities neither owned nor controlled by BWI or BWI Subsidiaries. Licensed Hotels and Affiliates might have their own privacy policies, which might be different from this Policy. To learn about the privacy practices of any of the Licensed Hotels or Affiliates, please review their respective privacy policies, not this Policy.

While this Policy is intended to describe the broadest range of our information processing activities globally, those activities may be more limited in some jurisdictions based on the restrictions of their laws. To the extent any of the activities described herein are not permitted under the laws of your country, state, or province, you agree that the remaining portions of this Policy that are permissible shall apply to the maximum extent permitted by law.


PERSONAL INFORMATION WE COLLECT
BWI may collect "Personal Information" from you, meaning information that identifies you as an individual or from which you may be identified. For example, we may collect:

• contact information, such as your name, mailing address, e-mail address, and telephone number;
• credit card number or other payment account number, billing address, and other payment and billing information (“Payment Information”);
• Best Western Rewards® ("BWR®") loyalty program member information, online user account details, profile or password details and any frequent flyer or travel partner program affiliation;
• records and copies of your correspondence if you contact us;
• information necessary to fulfil special requests (e.g., health conditions that require specific accommodation);
• guest stay information, including the hotels where you have stayed, date of arrival and departure, and goods and services purchased;
• information collected through the use of closed circuit television systems, card key and other security systems; and
• in limited cases, information relating to the credit of customers. We may collect Personal Information from a variety of sources including:
• through the Site;
• through reservation and call centers;
• through social media and brand channels (e.g. Facebook, Twitter);
• from BWI Subsidiaries and from Licensed Hotels, Affiliates, or other third parties; or
• when you otherwise voluntarily provide it to us, including in connection with our loyalty program (i.e. BWR).


We may also combine Personal Information we collect with publicly available Personal Information and Personal Information we receive from others or cross-reference with others. The collection and use of Personal Information, whether separately or combined, is done in accordance with and for the purposes described in this Policy.

If you voluntarily share "Sensitive Information" (e.g., Personal Information related to your health) with us, that information will only be used as necessary to fulfill special requests (e.g. health conditions that require specific accommodations). For example, if you voluntarily convey a health-related need to us, we may store and use that information in order for a Licensed Hotel to provide a room with appropriate amenities. We do not collect or store Sensitive Information unless it is voluntarily provided by you. By providing such Sensitive Information, you expressly consent to our collection, processing and storage of that information in accordance with the terms of this Policy.


BEST WESTERN REWARDS® (“BWR®”) PROGRAM
In order to enroll in the BWR program, you must provide us with some of your Personal Information, such as your name, e-mail address, mailing address, and phone number, which is required in order to create and manage your account, administer the BWR program, and provide the benefits of the BWR program to you.

Enrolling in or maintaining a membership in the BWR program constitutes your acceptance of the BWR terms and conditions (available at www.bestwesternrewards.com) and your express written consent to all actions taken by us with respect to your Personal Information in compliance with this Policy.
Your continued use of the Site after expiration of the BWR program constitutes your implied consent to all actions taken by us with respect to your Personal Information in compliance with this Policy.


HOW WE USE THE PERSONAL INFORMATION WE COLLECT
BWI collects Personal Information about guests, visitors to the Site, and others, so that we can provide an experience that is responsive to the needs of such individuals. BWI may collect, use, and disclose Personal Information for one or more of the following purposes:

• Fulfillment of Reservation or Information Requests. To fulfill your requests such as completing a credit card transaction or booking a reservation at any Licensed Hotel worldwide through our central reservation system, or responding to your requests that we send marketing, informational or other newsletters to you (and to personalize such newsletters and the Site to your preferences). For example, when you make a reservation through BWI's central reservation system, we may collect Payment Information from you, and may use and disclose such Payment Information to fulfill your reservation. BWI maintains a worldwide accessible website, call centers, and database computers in the United States and other locations around the world, which are intended to help BWI conduct business and to facilitate the operation and maintenance of its central reservation system.

• Membership Programs. To administer and operate voluntary membership programs, including loyalty programs such as BWR, which allow members to earn and redeem rewards, points, or credits in connection with the programs. For complete BWR program terms and conditions, visit www.bestwesternrewards.com.

• Best Western Travel Card®. To process and ship a Best Western Travel Card, which is a stored value card redeemable for lodging charges (room rate and applicable taxes) for stays at Licensed Hotels worldwide. We may also use your Personal Information as necessary to permit your use and redemption of a Best Western Travel Card. For complete Best Western Travel Card terms and conditions, see www.travelcard.bestwestern.com.

• Administrative and Other Communications. To send you important information regarding the Site, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your travel reservations, such as reservation confirmations and pre-arrival communications). We may also use your Personal Information to determine whether you are eligible for and/or inform you, if you have provided your consent, to send marketing communications or tell you about products, programs, enhancements, events, special offers, and services of BWI, BWI Subsidiaries, and third parties (including Licensed Hotels and Affiliates) that might be of interest to you. For more information, see the “Your Choices” section of this Policy below.
Promotions. To operate sweepstakes, contests, or other marketing or promotional activities (collectively, "Promotions"). We typically ask you for certain Personal Information when you enter or participate in such Promotion and, if applicable, win a prize, and we use such Personal Information to administer the Promotion. Participation in these Promotions is completely voluntary, and you have a choice whether to disclose your Personal Information. You should carefully review the rules, if any, of each Promotion in which you participate, as it may contain additional important information about BWI's use of your Personal Information. To the extent that the Promotion’s rules concerning the treatment of your Personal Information conflict with this Policy, the Promotion’s rules shall control.

• Surveys. To conduct or facilitate surveys and to ask for your responses to questionnaires in order to provide better products and services to guests and Site visitors. Completion of any surveys or questionnaires is strictly voluntary.
• Customer Care. To track, process, and respond to customer care inquiries and to enhance and improve the customer’s experience. We may also transmit your Personal Information to third party service providers, Affiliates, and Licensed Hotels to allow those third parties to track, process, and respond to customer care inquiries.
• Internal Business Purposes. For our internal business purposes, such as data analysis, audits, developing new products, enhancing the Site, improving our services, identifying usage trends and visiting patterns, determining the effectiveness of our Promotions, and meeting contractual obligations (e.g., a contractual obligation with regard to earning or redeeming BWR points or miles through our airline partners).

• Our Legal Duties. To comply with legal and regulatory requirements or demands in accordance with applicable law, a court order, subpoena, or other legal process.

• Terms of Use. We may enforce or apply our Terms of Use and/or other agreements and policies.

• E-mails to Friends. To permit you to forward information about our products, services, and Licensed Hotels to another individual, such as a friend or co-worker. If you wish to use this feature, you may be required to provide to us, and we may use, the applicable individual's name and e-mail address to facilitate your sending of such messages to such individual (and any Personal Information ‒ such as your name and your email address ‒ provided in connection with sending such information, will be disclosed to such individual). By using this functionality, you affirm that you are entitled to use and to provide to us the recipient's name and e-mail address for this purpose. We will not seek to use the recipient’s Personal Information for any purpose other than to allow the e-mail to be sent, unless we disclose such other purpose to you at the time that you provide such Personal Information to us or unless we have separately collected such Personal Information through other means.

• Co-brand credit card. To promote and assess eligibility for Best Western’s co-brand credit cards.

• Additional Uses. We may also use your Personal Information in other ways as described when you provide such information to us or for other purposes with your consent.



HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION
• BWI Subsidiaries. We may share your Personal Information with BWI Subsidiaries so that they may use such Personal Information for the purposes described in this Policy. BWI Subsidiaries are required to protect your Personal Information consistent with this Policy. BWI is the entity that is responsible for the management of such jointly used Personal Information.

• Licensed Hotels, Affiliates, and Third Parties. We may also share your Personal Information with Licensed Hotels, Affiliates, and other third parties located around the world for the purposes described in this Policy (e.g., to send your reservation information to the applicable Licensed Hotel or Affiliate, to provide Licensed Hotels, Affiliates, or other third parties with information on the rewards, points, or credits earned by you in connection with BWR, and to allow Licensed Hotels, Affiliates, and third parties to determine whether you are eligible for and/or inform you, if you have provided your consent, of products, programs, services, and promotions that they believe might be of interest to you).

• Third-Party Service Providers. BWI relies on numerous third-party service providers to provide certain products and services on our behalf, including reservation services, credit card/payment processing and billing, IT services, customer care, e-mail delivery services, text messaging services, communication and delivery of promotional and marketing materials via e-mail, direct mail, and text message, administering guest surveys and Promotions, administration, data analysis, and other similar services. We may share your Personal Information for the purpose of enabling these third parties to provide such services or as otherwise necessary for the ongoing operation of BWI's business, including operation of programs such as BWR and Best Western Travel Card. When we do outsource the processing of your Personal Information to third parties or provide your Personal Information to third party service providers, we require those third parties to protect your Personal Information with reasonable security measures and to limit their use only to the purposes for which we have disclosed it to them.

• BWR Partners. BWI may also share your Personal Information with companies that we have partnered with or that are participants in our BWR program to allow you to earn and redeem rewards, points, or credits in connection with your BWR membership and in accordance with your chosen earning and spending preferences (e.g., selection of a particular airline partner through which you can earn BWR points).

• Promotions. Personal Information submitted in connection with Promotions may be shared with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to such Promotion.

• Assignment. In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of BWI's or the BWI Subsidiaries' business, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may transfer any and all information that we collect pursuant to this Policy. Any successor, assignee, or transferee may use your Personal Information as described in this Policy.

• Social Networking Forums. BWI may make available interactive services (e.g., message boards, forums, and blogs) through which you may post information and materials on the Site. Please note that any information you disclose through such services becomes public information and may be available to visitors to the Site and to the general public. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, through these services. If you choose to voluntarily disclose your personal Information through such a forum it may be available to the public and might be used by others for any purpose.

• Law Enforcement; Emergencies; Compliance. We may disclose your Personal Information: (i) when we have reason to believe that it is necessary to identify, contact, or bring legal action against persons or entities that may be causing injury to you, BWI, BWI Subsidiaries, Licensed Hotels, Affiliates, or others; (ii) when we believe that applicable law or regulation (including laws and regulations outside your country of residence) requires it; (iii) as mandated by subpoena, court order, or legal process; (iv) to establish or exercise our legal rights, defend against legal claims, or protect our operations or those of any BWI Subsidiaries, Licensed Hotels, or Affiliates; (v) to protect the rights, privacy, safety, or property of BWI, BWI Subsidiaries, Licensed Hotels, Affiliates, you, or others; (vi) to investigate, prevent, or take action regarding suspected illegal activities, (vii) to investigate, 5
prevent, or take action regarding suspected fraud, (viii) to investigate, prevent, or take action regarding situations involving potential threats to the physical safety of any person, (ix) to investigate, prevent, or take action regarding violations of our Terms of Use or other agreements or policies, or (x) as otherwise required or permitted by law.

• Credit Authorization. When you apply for a Best Western co-brand credit card, your Personal Information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether you are eligible for the credit card and whether the card issuer will grant and/or maintain a line of credit to you.

• Responsibility When Information Is Transferred. If a service provider that receives Personal Information from us about an EU data subject or Swiss data subject takes an action that is contrary to the principles of the EU-US Privacy Shield or Swiss-US Privacy Shield, we shall be liable for those actions unless we prove that we are not responsible for causing them.


NON-PERSONAL INFORMATION
BWI may also collect “Non-Personal Information,” meaning aggregated and/or anonymized information, demographic information, and any other information that does not reveal your specific identity. Because Non-Personal Information does not personally identify you, we may use and share such information with BWI Subsidiaries, Licensed Hotels, Affiliates, and other third parties for any purpose, including without limitation to facilitate and improve your ongoing access to and use of our Site, to best tailor our services to suit personal interests, to analyze visiting patterns, enhance and improve customer service, and for our other business purposes. As you navigate the Site, we and our service providers may collect certain Non-Personal Information such as your computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version using automatic data collection technologies. In addition, we may engage third party tracking and advertising providers to act on BWI's behalf to track and analyze your usage of our Site through the use of such automatic data collection technologies. These third parties collect and share with us, as we may request, Site usage information about visits to our Site, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our Site, help us target and track use of our Internet banner advertisements on our Site and on other sites, and track use of other links from our marketing partners' sites to our Site. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.