Privacy Policy

Effective Date: June 29, 2023

We at CQ Hotels have created this Policy on Privacy and Cookies (“Privacy Notice”) to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business. To view our full Privacy Notice, you may click on any of the “tell me more” links or scroll down.

Email us at legal@clubquarters.com if you have questions about our Privacy Notice.

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How We Collect Information

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We collect information by various means:

Information We Collect

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The information we collect may include:

How We Use Your Information

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We use the information we collect to:

How We Disclose Information

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We may disclose the information we collect:

This Privacy Notice describes the privacy practices of Club Quarters Hotels and the hotels it operates, which include The Jewel Hotel, World Center Hotel, Hotel Boutique at Grand Central, Central Loop Hotel, River Hotel, and The Grand at Trafalgar Square. (collectively, “CQ Hotels,” “we,” or “us”). This Privacy Notice describes how we handle personal information we collect online and offline in connection with operating our company.

This Privacy Notice explains the types of personal information that CQ Hotels collects and processes, how CQ Hotels may use and disclose the information, and the choices that are available to individuals with respect to CQ Hotels’ handling of the information. Please note, this Privacy Notice does not apply to CQ Hotels’ processing of employee or contractor data.

Click on the links below to jump to sections of the Privacy Notice:

Personal Information We Collect

Whose information we collect

We may collect information about a variety of individuals who interact with CQ Hotels – website and mobile app users, guests at our hotels, individuals who attend meetings or events at our hotels, employees or guests of our corporate members who are authorized to use the corporate membership, meeting and event planners, travel agents and corporate travel coordinators, job applicants, and others.

How we collect the information

We may collect information about individuals:

Types of information we collect

The types of information we collect include:

We, our service providers, and our business partners may also collect certain information about the use of our websites and mobile apps by automated means. In addition, we and our service providers may collect certain information about the use of our hotels, including the wireless network at our hotels, by automated means. Please see the “Cookies And Other Information Collected By Automated Means” section of this Privacy Notice for more information.

Cookies And Other Information Collected By Automated Means

We, our service providers, and our business partners may collect certain information about the use of our websites and mobile apps by automated means, such as cookies, web beacons and other technologies. A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Please see our Cookies Policy for further information. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. We and our service providers and business partners may collect information about individuals’ online activities over time and across third-party websites when an individual uses our websites and mobile apps.

In addition, at our hotels, we and our service providers may collect certain information by automated means. For example, we may monitor activity on the wireless network at our hotels by automated means, engage in video monitoring of the public areas of our hotels, and monitor when individuals use room keys (or similar methods of access) assigned to their rooms.

The information that may be collected by automated means includes:

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. For information about how to disable cookies, please see our Cookies Policy below.

How We Use The Personal Information We Collect

We may use personal information for the following purposes:

Providing and supporting the services. We use personal information to operate, maintain, and provide you with the services. In particular we will use personal information to perform our contractual obligation towards our business partners or customers, such as our corporate members, including to:

Improving, monitoring, personalizing, and protecting our services and communications. It is in our legitimate interests to improve and keep our services safe for our users, including to:

Complying with law. To enforce our agreements, to comply with legal obligations and to defend us against legal claims or disputes, including to:

We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.

Personal Information We Disclose

CQ Hotels may disclose personal information as described in this Privacy Notice. In all cases, we take measures to disclose only the information that is needed to fulfill the purposes for which we disclose the information.

When you make a room reservation with one of our hotels, you direct us to disclose your information to that hotel in connection with that reservation.

We may further disclose personal information to:

Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets (or during the negotiations of any of such sale or transfer). If we engage in such a sale or transfer (or related negotiations), we will – where required by applicable law – make reasonable efforts to direct the recipient to use the personal information we provide in a manner that is consistent with this Privacy Notice. After such a sale or transfer, individuals may contact the recipient with any inquiries concerning the processing of their personal information.

In addition, we may disclose personal information to comply with legal and regulatory requirements, and protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile apps), and claims and other liabilities.

Data Retention

Our retention periods for personal information are based on business needs and legal requirements. We retain personal information only for as long as is necessary to fulfill the processing purpose(s) for which the information was collected, and any other permissible, related purpose, depending on the purpose(s) for which the information was collected, the nature of the information, any contractual relationship that may govern the retention of the data, and our legal or regulatory obligations. When we no longer need the personal information we collect, we either anonymize the information (in which case, we may further retain and use the anonymized information) or securely destroy the information, in accordance with applicable law.

Privacy Preferences, Rights, and Choices

CQ Rewards profile

You may review, update, or modify your profile information, including contact information, by logging into your CQ Rewards profile. You may delete your CQ Rewards profile by emailing privacy@clubquarters.com.

Location information

Your mobile device may provide you with the ability to prevent us from automatically collecting your location information. For example, you may be able to disable location services on your mobile device or to configure your mobile device not to allow the App to collect location information. However, this will limit your ability to use certain features of the App.

Marketing emails

Individuals may unsubscribe from receiving marketing or other commercial emails from CQ Hotels by following the instructions included in the email or by contacting CQ Hotels using the contact information below. However, even if an individual opts out of receiving such communications, we retain the right to send them non-marketing communications (such as confirmation of a reservation or purchase, or changes in our website or mobile app terms).

Text messages

Individuals may unsubscribe from receiving recurring text messages from CQ Hotels sent by automated means by responding STOP to the message.

Online Tracking

For information about the rights and choices users have with respect to cookies and online advertising and tracking, please see the Cookies Policy below.

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.

General Objections to the Processing of Personal Information

To the extent provided by applicable law, individuals may withdraw any consent previously provided to us, or object at any time on legitimate grounds, to the processing of their personal information. We will apply these preferences going forward. In some circumstances, withdrawing consent to CQ Hotels’ use or disclosure of personal information will mean that CQ Hotels will not be able to provide products or services to you or otherwise to engage with you.

Privacy Rights

Individuals have certain rights and may make certain choices regarding CQ Hotels’ processing of their personal information:

Access to or correction of personal information

Individuals may request access to the personal information CQ Hotels maintains about them. If we grant this request, we will provide the individual with a copy of the personal information we maintain about them in the ordinary course of business, in a commonly used format. Individuals may request to correct any errors in their personal information. We may reject such request to access or correct personal information, as permitted by applicable law. If we reject such request, we will notify the requestor of the reason(s) for the rejection.

Portability of personal information

Individuals may request that we transfer their personal information to another data controller. We may reject such request, as permitted by applicable law. If we reject such request, we will notify the requestor of the reason(s) for the rejection.

Deletion of personal information

Individuals may request that we delete their personal information. We may reject such request, as permitted by applicable law. If we reject such request, we will notify the requestor of the reason(s) for the rejection.

Opt out of the sale or sharing of personal information for targeted advertising

We do not sell personal information.  As we explain in this privacy policy, we use cookies and other tracking tools to analyze website traffic and facilitate advertising. If you would like to opt out of our (and our third party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided in our Cookies Policy.

Exercising Your Rights

To make a request, please visit https://clubquartershotels.com/privacy-request-form, email us at legal@clubquarters.com, or call us at 1-800-CQWorld. You are entitled to exercise the rights described above free from discrimination. If we deny your request, you may appeal our denial by emailing or calling us as set out above.

We reserve the right to verify the identity of the individual in connection with any requests regarding personal information to help ensure that we provide the information to individuals to whom it pertains, and allow only those individuals or their authorized representatives to exercise rights with respect to that information.

California residents can empower an “authorized agent” to submit requests on their behalf.  We will require the authorized agent to have a written authorization confirming that authority, in accordance with applicable laws.

Please note that if the exercise of these rights limits our ability to process personal information, we may be precluded from providing the individuals who exercise such rights with our products or services or from otherwise engaging with such individuals going forward.

International Data Transfers

We collect certain information directly from you, including via our mobile apps and website.  We are headquartered in the United States, so this information comes directly to us in the United States, from wherever you are based.  We will apply the same data protection measures to the data we collect directly from you that we deploy inside the EEA and the UK  to ensure that your data is kept secure.  We may otherwise transfer personal information to CQ Hotels parent entities, and subsidiaries and third parties located in countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. The countries to which we transfer personal information may not have the same data protection laws as the country in which we initially collected the information. If we transfer personal information of a resident of the European Economic Area (EEA) outside of the EEA, or of a resident of the United Kingdom outside of the UK, we will implement appropriate safeguards in accordance with applicable law to ensure that your data is kept secure.

Data Privacy Framework

Shared Mutual Services, LLC and Shared Operating Services, LLC (collectively, “we,” or “us”) comply with the EU-U.S. Data Privacy Framework and the UK Extension of the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Frameworks (collectively, the “Data Privacy Framework”) as set forth by the U.S. Department of Commerce and the European Commission regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and Switzerland to us in the United States. We have certified to the Department of Commerce that we adhere to the Data Privacy Framework Principles (described below). If there is any conflict between the policies in this Privacy Notice and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification page, please visit https://www.dataprivacyframework.gov/.

General. We process personal information that we receive from the EEA, UK, and Switzerland in accordance with the Data Privacy Framework Principles, as described below.

Notice And Choice. This Privacy Notice provides notice of the personal information collected and transferred under the Data Privacy Framework, the purposes for the transfer and the choice that you have with respect to the collection, use, and sharing of your personal information (please see the “Privacy Preferences, Rights and Choices” section of this Privacy Notice for more information).

Accountability for Onward Transfers. We may be accountable for the personal information that we transfer to third-party service providers (described in the “Personal Information We Disclose” section of this Privacy Notice). We maintain contracts with our third-party service providers restricting their access, use, and disclosure of personal information in compliance with our obligations under the Data Privacy Framework. If such service providers process personal information in a manner inconsistent with the Data Privacy Framework Principles, we are responsible for the harm caused.

Security. We maintain security measures to protect personal information as described in the “How We Protect Personal Information” section of this Privacy Notice.

Data Integrity and Purpose Limitation. We take reasonable steps to ensure that personal information is reliable for its intended use, and that it is accurate, complete and current for as long as we retain it. Our data retention practices are described in the “Data Retention” section of this Privacy Notice.

Access. EEA, UK, and Swiss individuals have certain rights to access, correct, amend, or delete personal information where it is inaccurate, or has been processed in violation of the Data Privacy Framework Principles. Please see the “Privacy Preferences, Rights and Choices” section of this Privacy Notice for more information on the rights of individuals in the EEA, UK, and Switzerland.

Sensitive Data. We provide individuals with an opt-out choice, or opt-in for sensitive data, before we share their personal information with third parties other than our agents, or before we use it for a purpose other than the purpose for which it was originally collected or subsequently authorized. To request to limit our use and disclosure of your personal information, please submit a request as set out in the “Privacy Preferences, Rights and Choices section” of this Privacy Notice or by written request to legal@clubquarters.com.

Recourse, Enforcement, Liability. In compliance with the Data Privacy Framework Principles, we commit to resolve complaints about our collection or use of your personal information. EEA, UK, and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact us at legal@clubquarters.com.

We have further committed to refer unresolved Data Privacy Framework complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. We will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at https://www.jamsadr.com/international-mediation-rules/.

If your complaint is not resolved through these channels, under certain conditions a binding arbitration option may be available before a Data Privacy Framework Panel. For additional information, please visit the Data Privacy Framework website at https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.

We are subject to investigatory and enforcement powers of the U.S. Federal Trade Commission with respect to personal information received or transferred pursuant to the Data Privacy Framework. As described in the “Personal Information We Disclose” section of this Privacy Notice, we may disclose personal information to comply with legal and regulatory requirements, which includes the requirement to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Information for California Residents

Here is a summary of how we currently collect, use and disclose personal information, and how we have collected used and disclosed the information in the preceding 12 months.

Personal information we collect

CCPA categories (Definitions are available here)

Sources of personal information

Purposes for which we may collect, use, and disclose personal information

Please note that we may also disclose personal information to comply with law, and for compliance, fraud prevention, and safety purposes; in the event of business transfers; and to our professional advisors, as further described above in the “Personal Information We Disclose” section.

How We Protect Personal Information

CQ Hotels maintains reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot guarantee that the measures we maintain will ensure the security of the personal information.

Links To Websites And Third-Party Content

We may provide links to websites and other third-party content that is not owned or operated by CQ Hotels. The websites and third-party content to which we link may have separate privacy notices or policies. CQ Hotels is not responsible for the privacy practices of any entity that it does not own or control.

Updates To Our Privacy Notice

CQ Hotels reserves the right to change this Privacy Notice at any time. When we make any updates to this Privacy Notice that are deemed material under applicable legal requirements, we will notify individuals of such changes by updating the date of this Privacy Notice and providing other notification as required by applicable law. We may also provide notification of such changes to the Privacy Notice in other ways, such as via email or using other contact information provided to us.

For all other changes, please review the Privacy Notice from time to time to stay informed of how we are processing personal information.

How To Contact Us

CQ Hotels is the data controller of your personal information. Individuals may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or to or to exercise any of the rights or choices they may have under applicable law. Our contact information is as follows:

CQ Hotels
Attn: Legal Department – Privacy
333 Ludlow Street, 3rd Floor
Stamford, CT 06902
legal@clubquarters.com

Residents within the EEA also have the right to file a complaint with the data protection authority (also known as a supervisory authority) of the resident’s member state.

CQ Hotels Cookies Policy

Effective Date: January 17, 2020

Consent

By using the CQ Hotels website and any other website (including mobile-optimized websites) owned or controlled by CQ Hotels and which links to this Cookies Policy (collectively, the “Website”) you consent to the use of cookies in accordance with this Cookies Policy.

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating web domain on your subsequent visits to that domain. Most web pages contain elements from multiple web domains so when you visit the Website, your browser may receive cookies from several sources.

Cookies are useful because they allow a website to recognize a user’s device. Cookies allow you to navigate between pages efficiently, remember preferences and generally improve the user experience. They can also be used to tailor advertising to your interests through tracking your browsing across websites.

Session cookies are deleted automatically when you close your browser and persistent cookies remain on your device after the browser is closed (for example to remember your user preferences when you return to the site).

What types of cookies does CQ Hotels use?

We describe the categories of cookies CQ Hotels and its contractors use below.

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have asked for (such as navigating between pages) cannot be provided.

Performance Cookies

We make use of analytics cookies to analyse how our visitors use our Website and to monitor Website performance. This allows us to provide a high quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of which pages are most popular, which method of linking between pages is most effective, and to determine why some pages are receiving error messages. We might also use these cookies to highlight articles or site services that we think will be of interest to you based on your usage of the website. The information collected by these cookies is not associated with your personal information by us or by our contractors.

We permit Google Analytics (opt-out information) and Hotjar (opt-out information) to set performance cookies on the Website.

Website Functionality Cookies

We make use of cookies to provide you with certain functionality. For example, to remember choices you make (such as your user name, language or the region you are in), or to recognize the platform from which you access the site, and to provide enhanced and more personal features. These cookies are not used to track your browsing on other sites.

Advertising cookies

Advertising cookies (or targeting cookies) collect information about the browsing habits associated with your device and are used to make advertising more relevant to you and your interests. They are also used by services provided by third parties on this Website, such as Like or Share buttons in addition to providing the requested functionality. Third parties provide these services in return for recognizing that you (or more accurately your device has) have visited a certain website. These third parties put down advertising cookies both when you visit our Website and when you use their services and navigate away from our Website.

We permit DoubleClick (opt-out information), Bing Ads (opt-out information), and Facebook (opt-out information) to set advertising cookies on the Website.

Local Shared Objects (“flash cookies”)

In addition to the above cookies, we may use Local Shared Objects, also referred to as “flash cookies,” on our Website. These are used to enhance your user experience, for example, by storing your user preferences and settings. Local Shared Objects are similar to browser cookies, but can store data more complex than simple text. By themselves, they cannot do anything to or with the data on your computer. Like other cookies, they can only access personally identifiable information that you have provided on this Website, and cannot be accessed by other websites.
To find out more about flash cookies or how to disable them, please click here: http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Disabling cookies

If you do not agree to the use of these cookies, you may disable them by following the instructions for your browser as explained at http://www.allaboutcookies.org/manage-cookies/. Please note that some of our services may not function properly if cookies are disabled. You may also opt-out of third-party cookies where available by using the links provided in this Cookies Policy.

Furthermore, some parties that set cookies via our site may offer the ability to opt-out of cookies via the Network Advertising Initiative’s consumer opt-out tool, the European Interactive Digital Advertising Alliance’s consumer opt-out tool, or the Digital Advertising Alliance’s Consumer Choice Page.

Some of the business partners that collect information about users’ activities on our websites and in our mobile apps may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. For example, users may opt-out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt-out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Mobile app users may opt-out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

Cookies policy does not cover third party websites

Please note that this cookies policy does not apply to, and we are not responsible for, the cookie practices of third party websites which may be linked to this Website.

Changes to the Cookies Policy

We may update this cookies policy and we would encourage you to review the policy from time to time to stay informed of how we are using cookies.