In particular, BWI is committed to complying with all applicable data privacy regulations, including the European Community Directive on Data Protection, commonly referred to as the "EU Privacy Directive" and Canada's Personal Information Protection and Electronic Documents Act ("PIPEDA"), as well as other applicable data privacy regulations.
BWI has chosen to comply with a number of international regulations by joining the US Department of Commerce's "Safe Harbor" program. BWI's implementation of the Safe Harbor requirements satisfies its obligations under PIPEDA and the EU Privacy directive. In order to join the Safe Harbor Program, we have submitted certain certifications to the US Department of Commerce and details of such certifications may be found at the following website:
BWI maintains centralized reservations systems, a worldwide accessible website, call centers and database computers in the United States as well as in other locations around the world which are intended to help BWI conduct business and to facilitate the operation and maintenance of a central reservations system and its frequency marketing program known as "Gold Crown Club International" ("GCCI"). The central reservations system and GCCI are maintained for the benefit of its member hotels and properties ("BWI Properties") as well as for BWI "Affiliates" which are entities which operate groups of various BWI Properties outside of the United States. BWI Properties and Affiliates are independent entities not owned or controlled by BWI and may or may not be located in European Union member countries, Canada or countries whose privacy protection laws have been deemed "adequate" pursuant to the EU Privacy Directive, PIPEDA or other applicable regulations.
BWI may collect certain personal information from and about individuals which can be identified with such specific individual, including without limitation, contact and payment information ("Personal Information") about customers who (i) wish to stay or make reservations at BWI member properties; (ii) purchase Travel Cards (stored value cards redeemable for stays at BWI member properties) which may be used or transferred to third-party recipients for stays at BWI member properties; or (iii) are the users of Travel Cards. Direct customers, Travel Card purchasers and users shall hereinafter collectively be referred to as "Travelers". Personal Information about Travelers may be collected through our websites, by our call centers or may be passed on to us by BWI Properties, Affiliates or other third parties. Personal Information about Travelers is collected so that Travelers can make reservations at BWI Properties and so that BWI Properties can receive and have updated reservation information about Travelers who wish to stay at such BWI Properties. Some of a Traveler's Personal Information (such as a credit card number) may be stored to facilitate the making of future reservations by such Traveler. Only that Personal Information which is reasonably required to facilitate travel reservations is collected and shared between BWI, BWI Properties and Affiliates as outlined above. Personal Information for Travelers will be transferred from BWI to BWI Properties and Affiliates.
BWI may collect Personal Information from Travelers who are also members of the GCCI program ("GCCI Customers") so that BWI can perform certain administrative tasks necessary for the administration and operation of the GCCI program such as the following: (1) allow GCCI Customers to earn rewards, points or credit ("GCCI Points") for staying at various BWI Properties; (2) allow other BWI Properties and Affiliates to be aware of the GCCI Points earned by GCCI Customers so that such BWI Properties or Affiliates can redeem GCCI Points; (3) allow BWI Properties and Affiliates to receive and share Personal Information for GCCI Customers as necessary in order for such BWI Properties and/or Affiliates to satisfy contractual obligations among and between various BWI Properties and/or Affiliates. GCCI Customers' Personal Information may be collected through our various websites, by our call centers or may be passed on to us by BWI Properties, Affiliates or other third parties. BWI may transfer Personal Information to BWI Properties and Affiliates as a part of BWI administering the GCCI program as outlined above.
BWI distributes Personal Information about GCCI Customers to third parties for the purpose of having such third parties compile information about the type and frequency of use of the GCCI program by such GCCI Customers as well as to allow such third parties to conduct data processing for BWI and to engage in communications on behalf of BWI with GCCI Customers. BWI may also distribute Personal Information to airline companies upon request of the GCCI Customer, in order to allow a GCCI Customer to earn frequent customer points with such airline companies. Examples of these types of third parties include Direct Options and Cendyn.
BWI may send marketing information about BWI, BWI Properties or the GCCI program as well as marketing information about offers or information about third party products and services to GCCI Customers and Travelers based upon the Personal Information BWI has collected for such GCCI Customers and Travelers.
Although unlikely, in certain instances we may disclose your personally identifiable information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to BWI or to others. We may also disclose your personally identifiable information when we believe the law requires it.
BWI takes special care to protect the safety and privacy of children. Our web sites are general audience sites. We do not permit anyone under the age of 13 to register with us, enter the GCCI program or make hotel reservations. We also do not send email correspondence to anyone who tells us that they are under the age of 13.
Children under the age of 13 should always ask their parents or guardians for permission before providing any personal information to anyone online. We urge parents and guardians to participate in their children's online activities and use parental control or other web filtering technology to supervise children's access to the web.
3. Sensitive Information
BWI will only collect sensitive Personal Information related to your health if you submit such type of Personal Information and such sensitive Personal Information will only be used by BWI in order to allow us to help you obtain special accommodations or other health related benefits at a BWI Property. This type of Personal Information will be submitted to BWI Properties and Affiliates only if necessary for us to facilitate the reservation of a room at one of the BWI Properties which will help meet your health needs. If you do not want us to collect and use such type of Personal Information, please do not submit such type of Personal Information to us.
4. Onward Transfer
Please note that our descriptions of our activities under the "Notice" and "Choice" principles above describe certain transfers of Personal Information that BWI will be making to third parties.
BWI has conducted an internal review of its data collection and processing practices and the security measures it has implemented and believes that such security measures provide reasonable precautions against the unauthorized access, disclosure, alteration or destruction of Personal Information that BWI collects.
BWI's Systems Architecture group has also conducted an internal review of its computer network and its data protection measures and believes that it has implemented a reasonable level of technology and software to protect against the loss of Personal Information. Such measures include without limitation, the following: the use of several firewalls to separate user network traffic from server network traffic; the use by BWI web applications of SSL encryption whenever sensitive information is being accessed; the use of the Secure File Transfer Protocol (SFTP) when exchanging data with third parties so that files, usernames and passwords are encrypted; the use of intrusion detection software at eleven different points in the internal BWI network and the use of virus protection software on BWI's e-mail servers and client computers.
BWI has also implemented certain physical security measures to protect against the unauthorized access to Personal Information. All server rooms are protected through a keycard system that checks user privileges against a central database and these server rooms are locked at all times.
6. Data Integrity
BWI has conducted an internal review of its data collection and processing practices and believes that only that Personal Information is collected and processed which is required in order for BWI to provide services for or to fulfill its contractual obligations with Travelers, GCCI Customers, BWI Properties and BWI Affiliates. BWI will be implementing a periodic review of its data collection and processing practices to ensure that it only collects or processes Personal Information which is required in order for BWI to provide services for or to fulfill its contractual obligations with Travelers, GCCI Customers, BWI Properties and BWI Affiliates.
BWI will make a good faith attempt to allow all Travelers, GCCI Customers or others who BWI collects Personal Information from, to have the opportunity to view the Personal Information it has collected for such individuals, to the extent required by applicable regulations. BWI may make certain Personal Information available through an on-line program, website or procedure ("On-Line Procedure") for inspection by the individual associated with such Personal Information. If Personal Information is available through the On-Line Procedure devised by BWI, the Personal Information can only be reviewed through such On-Line Procedure. The On-Line Procedure will also contain information about how to request any corrections or deletions of any erroneous Personal Information. Information about the availability of On-Line Procedures for viewing certain types of Personal Information is generally available at the website or on the printed materials where such type of Personal Information was first submitted.
If BWI has not set up an On-Line Procedure to allow the viewing of Personal Information, then those Travelers, GCCI Customers or others who submitted Personal Information to BWI for use by BWI can review the Personal Information collected for them by contacting the BWI Customer Relations department through the contact information provided below. BWI will make all corrections and/or deletions of erroneous Personal Information brought to its attention within a reasonable time period and as required by applicable data privacy regulations. To the extent permissible and in compliance with applicable data privacy regulations, BWI shall make all corrections and/or deletions of erroneous Personal Information in a manner which does not impose undue burden or expense on BWI.
9. Dispute Resolution
All Travelers, GCCI Customers or others who submit Personal Information to BWI and who feel that BWI has mishandled their Personal Information in violation of the Safe Harbor requirements and/or PIPEDA ("Disputing Party") should contact BWI through its Customer Relations department (with such contact information provided below) with a written description of their complaint. After receiving such written description, a representative from BWI's Customer Relations department will contact the Disputing Party to set up a time and manner to discuss the Disputing Party's complaint. BWI is interested in addressing all legitimate complaints about its adherence to the Safe Harbor and/or PIPEDA, and believes that a Disputing Party and BWI should make a good faith effort to engage in communications to work out or settle any of a Disputing Party's complaints. If these good faith efforts fail to resolve the dispute, then the Disputing Party shall have the opportunity to make use of an independent, dispute resolution procedure. Currently, BWI is a member of the BBBOnline Dispute Resolution Program and has agreed to allow Disputing Parties to bring privacy complaints against BWI pursuant to the rules and procedures of such program. Any Disputing Parties who wish to lodge a complaint through the BBBOnline Dispute Resolution Program will be provided with information from BWI about how to proceed with lodging a complaint.
A Disputing Party and BWI may agree to use an independent dispute resolution body or procedure to resolve disputes about BWI's compliance with the Safe Harbor and/or PIPEDA upon mutual written agreement of both parties.
If it is determined by an independent dispute resolution body or procedure that BWI has engaged in behavior not in compliance with the requirements of the Safe Harbor and/or PIPEDA, BWI may be ordered to engage in actions necessary to reverse or correct any actions taken by BWI which were in violation of the Safe Harbor and/or PIPEDA and which were harmful to the Disputing Party. BWI may also be required to take all actions deemed necessary for BWI to be in compliance with the Safe Harbor and/or PIPEDA in the future. BWI's non-compliance with the Safe Harbor and/or PIPEDA may be reported to the appropriate governmental authorities if BWI has engaged in a pattern of persistent failure to comply with the Safe Harbor and/or PIPEDA.
11. Links to Third Party Sites
Last updated: September 9, 2004
CONTACTING BEST WESTERN INTERNATIONAL, INC. IF YOU HAVE QUESTIONS OR COMMENTS If you have any questions or comments about the manner in which we use or share your Personal Information, please contact our customer relations department through the contact information included below. Our customer relations department will coordinate with our designated Privacy Officer or others to best address any comments, questions or requests that you may have:
Best Western International, Inc.
Customer Relations Department
Regular Mail: PO Box 10203
Phoenix, AZ 85064
Attn: Customer Service