Introduction

This Privacy Policy will help you understand what information we collect and use at HotelBetter, and the choices you have associated with that information. When we refer to “HotelBetter,” “we,” “our,” or “us” in this policy, we are referring to HotelBetter, LLC which provides the Services to you. The “Services” refers to the applications, services, and websites (marketing and product) provided by HotelBetter. HotelBetter may, from time to time, introduce new products and services. To the extent that these new products and services affect this policy, we will notify you as described in Section 10 below. The use of information collected through our service shall be limited to the purpose of providing the Services for our customers and as specified herein.

If you have any questions about this privacy policy or our practices, please contact us.

Contents:

1. Information We Collect and Receive
2. How We Use the Information We Collect and Receive
3. Analytics, Cookies and Other Web Site Technologies
4. Information Sharing
5. Communicating
6. Accessing Your Data
7. California Privacy Rights
8. Security
9. Changes to this Statement
10. Questions or Complaints

1. Information We Collect and Receive

We collect several different types of information to provide Services to you, including:

Customer Account and Registration Data: This includes information you provide to create your account with us and may include, first and last name, third party loyalty reward program information (which includes account access information), travel reservation information, a password and a valid email address.

Service Data (including Session and Usage data):

When you use our Services, we receive information generated through the use of the Service, or from the Service infrastructure itself, (for example, duration of session, connection information, etc.) We may also collect usage and log data about how the services are accessed and used, including information about the device you are using the Services on, IP addresses, location information, language settings, what operating system you are using, unique device identifiers and other diagnostic data to help us support the Services. Please see Section 3 “Analytics, Cookies and other Website Technologies,” for more information on Service Data.

Third Party Data: We may receive information about you from other sources, including third party reward or loyalty programs (of which you have given us permission to access) publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. We may also receive information from other affiliated companies that are a part of our corporate group. This helps us to update, expand and analyze our records, identify new prospects for marketing, and provide products and services that may be of interest to you.

Location Information: We collect your location-based information and IP address for the purpose of providing and supporting the service and for fraud prevention and security monitoring.

Device Information: When you use our Services, we automatically collect information on the type of device you use, operating system version, and the unique device identifier (or “UDID”).

Legal Basis for Processing (EEA Individuals Only): If you are from the EEA, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. If you are from the EEA, “personal information” is defined as any personally identifiable information or other data collected that could directly or indirectly identify you.

However, we will normally collect personal information from you where we have your consent to do so, where we need the personal information to perform Services, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question.

If we ask you to provide personal information to comply with a legal requirement or to provide you with Services, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already listed above, we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us.

2. How We Use the Information We Collect and Receive

HotelBetter may access (which may include, with your consent, limited viewing or listening) and use the data we collect as necessary (a) to provide and maintain the Services; (b) to address and respond to service, security, and customer support issues; (c) to detect, prevent, or otherwise address fraud, security, unlawful, or technical issues; (d) as required by law; (e) to fulfill our contracts; (f) to improve and enhance the Services; (g) to provide analysis or valuable information back to our customers and users.

Some specific examples of how we use the information:

• Create and administer your account
• Send you an order confirmation
• Facilitate and improve the usage of the services you have ordered
• Send you product updates, marketing communication, and service information
• Respond to customer inquiries and support requests
• Conduct research and analysis
• Display content based upon your interests
• Analyze data, including through automated systems and machine learning to improve our services and/or your experience
• Provide you information about your use of the services and benchmarks, insights and suggestions for improvements
• Market services of our third-party business partners

HotelBetter will retain your information as long as your account with us is active, to comply with our legal obligations, to resolve disputes, and enforce our agreements.

If you wish to cancel your account or for us to stop providing you services, or if we hold personal information about you and you want it to be removed from our database or inactivated, you may do so by emailing us here.

3. Analytics, Cookies and Other Web Site Technologies

HotelBetter is continuously improving our websites and products through the use of various third party web analytics tools, which help us understand how visitors use our websites, desktop tools, and mobile applications, what they like and dislike, and where they may have problems.

Geolocation and Other Data:

We may utilize precise geolocation data but only if you specifically opt-in to collection of that data in connection with a particular service. We also use information such as IP addresses to determine the general geographic locations areas of our visitors. The web beacons used in conjunction with these web analytics tools may gather data such as what browser or operating system a person uses, as well as, domain names, MIME types, and what content, products and services are reviewed or downloaded when visiting or registering for services at one of our websites or using one of our mobile applications.

Google Analytics:

We use Google Analytics as described in “How Google uses data when you use our partners’ sites or apps.” You can prevent your data from being used by Google Analytics on websites by installing the Google Analytics opt-out browser add-on here. We also employ IP address masking, a technique used to truncate IP addresses collected by Google Analytics and store them in an abbreviated form to prevent them from being traced back to individual users.

Tracking Technologies:

HotelBetter and our partners use cookies and similar tracking technologies to track user traffic patterns and hold certain registration information. Tracking technologies also used are beacons, tags and scripts to collect and track information and to improve and analyze our service. If you wish to not have the information these technologies collect used for the purpose of serving you targeted ads, you may opt-out in your account profile. The Help menu on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can still review the website if you choose to set your browser to refuse all cookies; however, you must enable cookies to establish an account and to install the Services.

Examples of Cookies We Use:

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Social Media: Our sites include social media features, such as joining our group page on Facebook. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These services will also authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign-up form or provide feedback. Your interactions with these features are governed by the privacy policy of the company providing them.

4. Information Sharing

Ensuring your privacy is important to us, we take our responsibility to protect your personal information very seriously. As permitted, we may share certain information and aggregated research data with third parties as described in this Privacy Policy. These third parties include the following:

Third party service providers and vendors. We use third party services which help us run our day-to-day business operations, here are some examples of such operations:

• Hosting and delivering HotelBetter services
• Providing customer support
• Delivering email communications
• Performing data storage, data analytics and maintenance
• Providing cloud computing infrastructure

Such third-party service providers have access to personal information only as needed to perform their functions and they must process the personal information in accordance with this Privacy Policy. If we transfer any of your personal information to a third party acting as an agent, we will be responsible for any acts of those third-party agents that are inconsistent with this Privacy Policy, unless otherwise provided by law.

Marketing and Analytics Partners. We use certain marketing and analytics partners such as Google Analytics, Facebook Analytics, Sparkpost, etc. to help us market our products and to help us understand how our users use our services to make our services better. Such third-party partners may receive information about your use of our services and potentially information about your visits to other online services. These third-party providers are only authorized to use your information to provide their services to us.

Advertising Partners. We work with advertising partners to enable us to customize the advertising content you may receive on our Services. Please see Section 3 “Tracking Technologies,” for more information on this topic.

HotelBetter Research. We may share anonymized and de-identified data (that does not contain any personally identifiable information) with third parties. For example, we conduct research using aggregate data collected from our users to create, use and share certain industry reports such as analyzing well-being of a loyalty program or overall analysis of travel trends. The aggregate data does not identify you personally, and will not be treated as personal information under this Privacy Policy. We may also disclose your personal information to any third party, but only with your prior consent. HotelBetter’s use of information received from Google APIs or Verizon Media oAuth APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements and Verizon Media Limited Use Requirements, respectively.

Legal Compliance. In certain cases, HotelBetter may be required by law to disclose personal information. For example, we may disclose your information to comply with a valid subpoena or other legal process; when we believe in good faith that disclosure is necessary to protect our rights, or to protect your safety (or the safety of others); to investigate fraud; to respond to a government request; or to meet national security or law enforcement requests. We may also disclose your information to a third-party as part of a merger, sale of company assets, financing or acquisition of all or a portion of our business by another company where customer information will be one of the transferred assets.

5. Communications

HotelBetter may need to communicate with you for a variety of different reasons, including:

• Responding to your questions and requests. If you contact us with a problem or question, we will use your information to respond.
• Sending you Service and administrative emails and messages. We may contact you to inform you about changes in our Services, our Service offerings, and important Service related notices, such as security and fraud notices. These emails and messages are considered a necessary part of the Services and you may not opt-out of them.
• Sending emails about new products or other news about HotelBetter that we think you’d like to hear about either from us or from our business partners. You can always opt out of these types of messages at any time by clicking the unsubscribe link at the bottom of each communication.
• Offering referral programs and incentives, which allow you to utilize email, text, or URL links that you can share with friends or colleagues.

6. Accessing Your Data

Our customers can always review, update or change personal information from within their account. HotelBetter will also, when you request, provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. Please contact us here if you need assistance in reviewing your information. HotelBetter will respond to your access request to review the information we have on file for you within a reasonable time.

If you are from the EEA, “personal information” is defined as any personally identifiable information or other data collected that could directly or indirectly identify you. You may have additional rights under their data protection laws, such as the following:

• Access: Right to request access to and a copy of your personal information;
• Restriction: You can ask us to restrict processing of your personal information in certain circumstances;
• Rectification: You can have any inaccuracies in your personal information corrected;
• Deletion: You can ask us to delete your personal information in certain circumstances (e.g. if the information is no longer necessary for the purposes for which it was collected);
• Objection: You can object to further processing your personal information in certain circumstances;
• Withdrawal of consent: Where we rely on your consent to process your personal information, you have the right to decline consent and/or if provided, to withdraw it at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent.
• Portability: You can ask us to provide your personal information in a structured, commonly used and machine-readable format in certain circumstances.

You can exercise the above rights by contacting us and we will consider such requests in accordance with applicable data protection laws. We may ask you to verify your identity before we respond to your request.

You may also have the right to raise questions or complaints with your data protection authority at any time.

We may transfer personal information to companies that help us provide our service, and when we do, these transfers to subsequent third parties are covered by appropriate transfer agreements. We will retain personal data we process on behalf of our customer as needed to provide services to our customer. Also, we will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

HotelBetter is headquartered in the United States of America. Information that we collect and maintain may be transferred to, or controlled and processed in, the United States and/or other countries around the world. When you provide us with information, or use our website(s) and services, you consent to this transfer. We will protect the privacy and security of personal information we collect in accordance with this privacy policy, regardless of where it is processed or stored.

7. California Consumer Privacy Act

Click here to read additional disclosures required under the California Consumer Privacy Act.

8. Security

HotelBetter follows generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received, however, no security measure is perfect. We recommend safeguarding your password and implementing two-factor authentication on your account, as it is one of the easiest ways you can manage the security of your own account – remember that if you lose control over your password, you may lose control over your personal information.

9. Changes to this Statement

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will provide notice on this website, and we may notify you by email (sent to the e-mail address specified in your account), prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. If you continue to use the Services after those changes are in effect, you agree to the revised policy.