Choice Hotels Canada, Inc. and members of its group of companies (“Choice”, “we” or “us”) are committed to providing you with an efficient and customized Internet experience. This Privacy and Security Policy describes how we collect, use, share and protect your personal information when you interact with Choice, either through our websites (“Choice Websites”), mobile applications and in person at our Hotels.

Personal information” is any information that identifies you or could be reasonably associated with you.  The personal information we collect may include contact information such as your name, email address, home address, and phone numbers, as well as information about the products and services that you purchase from us in-person at our Hotels or online, information provided to us in connection with our programs, products and/or services and/or information collected automatically when you interact with us at our Hotels or online.

This policy was last modified on September 15, 2022.

 

Scope of this Privacy Policy

This policy applies to Choice’s operations in Canada whenever you interact with us, including through Choice Websites, social media pages, mobile applications or otherwise. It applies, for instance, when you communicate with us by email, register as a user and create an account on Choice Websites, make bookings online, register for our Choice Privileges Rewards program, sign up for our Choice Hotels BizCount program, and sign up to receive and participate in promotional or other marketing initiatives.

Hotels franchised under Choice’s brand (“Hotels”) are independently owned and operated. Your personal information collected or maintained directly by Hotels is not subject to this policy, unless such information has been shared with us, in which case the policy only covers Choice’s collection, use, and disclosure of your personal information. If you book a reservation directly with a Hotel and that Hotel utilizes our proprietary property management system, your personal information related to that reservation will be transmitted to and processed by Choice. We do not control the collection, use, or access of your information by the Hotels and their staff. The Hotel is the merchant who collects and processes credit card information and receives payment for your stay. The Hotels are subject to the merchant rules of the credit card processors they select, which establish credit card security rules and procedures.

By submitting your personal information to us, you agree to the transfer to and processing of your personal information in the United States in accordance with the terms of this Policy.

 

How do we collect personal information?

We collect personal information from you in the following ways:

Directly from You

You may provide personal information to us in our Hotels, by mail, by email, over the telephone, through Choice Websites or mobile applications or in any other direct manner.

From Other Sources

We may receive your personal information from other sources with your consent or if the law requires or permits us to do so (e.g. to meet our legal compliance and other regulatory obligations).

From Our Technologies

We may collect personal information through various types of technologies used in our Hotels, including your image. These can include video surveillance tools or other similar types of technologies which we may use from time to time.

Through the Choice Websites and Mobile Applications

We may collect certain types of personal information electronically when you interact with the Choice Websites, email, mobile applications, social media accounts, online advertising, sweepstakes, promotions, or through the use of our or a third party’s technologies, including cookies, web beacons, single pixel gifs and similar technologies like Data Management Platforms. This information helps us understand what actions you take on the Choice Websites and mobile applications and allows our website and mobile applications to work correctly. These technologies may include functions permitting us to identify, locate, or profile you.

 

What information do we collect?

We may collect the following types of personal information depending on your interactions with us:

  • Personal Identifiers, such as name postal address, phone number, email address, account number, passport number, username, military-related identifiers, internet protocol (IP) address, and signatures. For individuals interested in franchise opportunities this could also include Hotel ownership or development experience and anticipated investment amount.
  • Demographic Data, such as date of birth or gender.
  • Internet or other electronic network information, such as browser type, operating system, internet service provider (ISP), unique device identifiers, referring/exit pages, browsing history, and pages viewed on our site and through our mobile application.
  • Financial Information, such as your credit card number and range of income.
  • Customer information, such as your room preferences, Choice Privileges number, association number (e.g., CAA), third-party loyalty program numbers (e.g. airline miles), corporate account number, and group booking number.

If you apply online for employment at Choice, you may be asked to provide us your name, address, e-mail and resume. Choice will use this information solely with respect to your job search and to determine your qualifications for a career with Choice.

 

How do we use the information we collect?

We use the personal information to administer our business activities, provide customer service, personalize your digital experience, contact you concerning your stay with a Hotel, and make other products and services available to you. We share your information with our Hotels, credit card issuers, and other companies where necessary to complete your transaction. We may also use your information to send you promotional communications by mail or e-mail, or share your information with our business partners.

Processing Reservations

We maintain a centralized reservations system that retains your personal information when you make a reservation for a Hotel via our worldwide accessible websites, mobile apps, our call centers, the Hotels, and third-party travel agents and travel websites that connect to our reservation system. The personal information collected in the reservation system is needed to secure and process your reservation. Your personal information (including credit card number) will be processed primarily in the United States to complete your transaction and to facilitate the making of future reservations. Only that personal information which is reasonably required to facilitate your reservations is collected and shared between Choice and the Hotels.

We will use your e-mail address to send a confirmation and, if necessary, might use the other information to contact you regarding your reservation. We may also use your e-mail address to:

  • send you travel-related messages, stay details, and provide other information about the area and the Hotel;
  • notify you about special offers and promotions; and
  • send you periodic satisfaction or market research surveys.

Marketing, Sweepstakes & Contests

We may use your personal information to send you via e-mail, telephone or postal mail promotions, surveys, third party offers, sweepstakes and contests. We may also use your personal information to assess our customer service and to conduct marketing and performance-based research. When required by law, we will use de-identified information for these purposes.

To Manage Our Business Operations

We may use your personal information for general business purposes, including to ensure the security of our systems and Choice Websites, satisfy audits and other assessments, and to address and prevent fraud.

We will also use your personal information to manage our Choice Privileges loyalty program, e-folio program and Choice Hotels BizCount program to the extent you have enrolled in these programs.

Choice Privileges Members

If you are a Choice Privileges member, we will use your personal information to perform certain administrative tasks necessary for the administration and operation of the program such as: (1) allowing you to earn Choice Privileges points for point-eligible stays at various Hotels; and (2) redeem Choice Privileges points for free nights and other rewards offered by the program.

We may also use your personal information to send you via e-mail, telephone or postal mail program details, account summaries, satisfaction surveys, promotions, third party offers, sweepstakes and contests. We may also contact you about applying for the Choice Privileges Visa® card issued by Barclays Bank Delaware (Barclay card member FDIC, pursuant to license from Visa USA Inc.).

Choice Privileges members’ personal information may be collected through Choice Websites, mobile applications, Choice’s call centers, paper applications, or may be passed on to Choice by Hotels. Choice may transfer personal information to Hotels as a part of administering the Choice Privileges program as outlined above. Choice processes Choice Privileges members’ personal information primarily in the United States.

E-Folio

If you participate in the electronic billing e-folio program, your Hotel bill will be sent to you over the Internet in an unsecure (unencrypted) manner and could be subject to interception by third parties. If you use a corporate credit card, billing information and the details of your Hotel stay will be shared with the credit card provider who, in turn, will provide it to your employer.

Choice Hotels BizCount

If you enrol in our Choice Hotels BizCount program, we will use your personal information to provide you with price rebates. We process Choice Hotels BizCount members’ personal information in Canada.

Combining Personal Information

To serve you better, Choice may combine information you give us online, at Hotels, through the mail, or in any other way. Choice may also combine that information with publicly available information and information Choice receives from others or cross-references. Choice uses that combined information for the purposes described in this privacy statement.

As Permitted or Required by Law

To the extent required or permitted by law, we may collect, use and disclose personal information in connection with security-related or law enforcement investigations or in the course of cooperating with authorities or complying with legal requirements. We may also use your information as permitted by law to perform credit checks, report or collect debts owed, or protect the rights or property of Choice, our employees, our Hotels, our customers, this site, or its users.

 

Do you share my personal information with third parties?

We do not sell, trade, rent, or release your personal information to anyone outside our company, contractors, affiliates or Hotels, other than in compliance with this privacy and security policy.

Among Our Corporate Group Members and Hotels

Choice may transfer your personal information to members of its corporate group and to Hotels to secure your reservation or in connection with awarding or redeeming Choice Privileges points. Please note that some Hotels may be in countries other than your country of residence and may not provide an equivalent level of data protection.

Service Providers

Choice shares personal information about guests and Choice Privileges members to third party service providers such as market researchers and fulfillment houses. We also use such third parties to: (i) conduct data processing for Choice, (ii) engage in e-mail and direct mail communications on behalf of Choice, (iii) administer sweepstakes and contests, (iv) administer guest surveys, and (v) compile information for us about the type and frequency of guest stays and the use of the Choice Privileges program by members. These parties are contractually prohibited from using personal information for any purpose other than the purpose for which Choice collected the personal information from you.

If you choose to apply for a Choice Privileges Visa card, you will be linked from Choice’s website to Barclays Bank Delaware’s website and will be required to enter certain personal information as part of the credit application process. Please refer to Barclays Bank Delaware’s privacy statement posted on their website to understand how the information you supply will be used.

Choice may partner with other companies to provide co-sponsored or co-branded promotions, sweepstakes, contests, products and services and may share your information with these companies.

With Your Consent

Choice may also share personal information with airlines and other companies upon your request, in order to allow guests to: (i) earn frequent customer miles/points with such airline and other companies for stays at Hotels, or (ii) redeem Choice Privileges points for goods and services of such airline and other companies.

As Permitted by Applicable Law

Although unlikely, in certain instances, Choice may disclose your personal information when Choice has 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 Choice or to others. Choice may also disclose your personal information when Choice believes the law requires it.

We may disclose your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

 

How do you manage my consent?

By subscribing to our programs, products and services and/or submitting information to us in connection with using our programs, products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.

We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy or in the terms and conditions of a specific service you signed up for or have agreed to participate in.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent to the collection, use and disclosure of personal information for purposes that are necessary to provide our Services, we may limit the Services that we are able to provide to you.

 

Do I have any rights with respect to my Personal Information?

Under Canadian privacy laws, you have certain rights with respect to the personal information we collect.

You have the right to access the personal information we hold about you, subject to any legal restrictions. Upon request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws.

It is your responsibility to provide accurate, correct and complete information. If you notice any errors in your personal information or need to update it, please let us know through the steps outlined below. 

Some of the personal information we hold about you is accessible to you through your online account(s). You can access and update or correct your personal information by logging into your account(s) and making updates to your profile information and your preferences.

For personal information that is not available through your online account(s), or for more information on how to exercise your rights, you can contact the applicable Privacy Office through email or postal address. For more information see “How do I Contact You?”.

 

How do I opt-out of marketing communications or otherwise change my privacy preferences?

We respect the right of each visitor to control how his or her personal information is used. If you do not want us to provide your information to our business partners, or if you do not wish to receive promotional communications from us or our affiliates concerning special offers, discounts, airline bonuses, or contests, select one of the following options to provide us with your privacy preferences:

Click here (LINK: https://www.choiceHotels.com/en-ca/choice-privileges/account/update) if you have an Online Account and edit your privacy preferences within your account.

– OR –

If you do not have an online account and do not wish to create one, click here [insert hyperlink] to provide us with your privacy preferences.

– OR –

Use the “Unsubscribe” function in the e-mail you received from us.

You can also contact us using the information under “How can I contact You?”. Please include your name, address, e-mail address and Choice Privileges number (if applicable) and clearly state the nature of your request.

Choice makes every reasonable effort to maintain the accuracy of personal information. If you become aware that information Choice maintains about you is incorrect or if you would like to update your information, please contact us as indicated above.

 

How do you store and secure my personal information?

We take the storage and security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. These measures include multi-factor authentication, masking, encryption, logging and monitoring, described below.

Storing Your Personal Information

We use all reasonable safeguards, including contractual requirements with out service providers, to protect your personal information wherever it is used or stored. In general, we store, access and use personal information in Canada. Some of our service providers may access, process or store your personal information outside of your province, territory, or Canada in the course of providing their services to us. For example, our reservation system and other databases are maintained in the United States; therefore, certain personal information will be collected (or transferred) and maintained in the United States.  In these cases, the personal information is subject to the law of the jurisdiction in which it is used or stored, including any law permitting  or requiring disclosure of the information to the government, government agencies, courts of law and law enforcement in that jurisdiction. The countries where our service providers may be located include Canada and the United States.

We store your personal information for as long as it is necessary to fulfill the purposes for which it was collected, including to provide you with our programs, products, and services and for a reasonable time thereafter, or as permitted or required by law. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

Securing Your Personal Information

When you provide us with information through a Choice Websites, such as your name, address, phone number, credit card information, email address and room preference, your information will be encrypted using a Transport Layer Security or a Secure Sockets Layer connection. You can tell if your information is encrypted by looking for the locked padlock icon on the lower right-hand or left-hand corner of your screen and a change in the site address from “http” to “https.”

 

Do you use “cookies” and similar technologies?

Choice and our service providers use cookies and other technologies to track information about your use of our services. We may combine this information with other personal information we collect from you (and our service providers may do so on our behalf).

Cookies

Choice Websites, mobile applications and e-mails may use “cookies” and other computer code processes. These are small amounts of computer code that interact with your computer, mobile device, browser or e-mail. The types of cookies Choice uses are referred to as “session” cookies and “persistent” cookies. Session cookies are temporary and are automatically deleted once you close your internet browser. Persistent cookies remain on your computer hard drive or mobile device until you delete them or are otherwise removed upon expiration. Cookies are required for the online reservation process so that we can keep your information on multiple pages throughout the process. Additionally, Choice uses cookies to remind us of who you are, tailor our services to suit your personal interests, track your status in our promotions, contests and sweepstakes, and/or analyze your visiting patterns. Choice does not use cookies to ascertain any personal information about you apart from what you voluntarily provide Choice.

Choice may also use cookies to form an association between multiple devices such as your smartphone, desktop computer and tablet.  This is often referred to as device fingerprinting.  A unique identifier, or fingerprint, is created on your devices, which enables the association. Choice uses the device association to link your devices’ searches on Choice Websites, which enables us to provide you with a more convenient and personal digital experience.

You can generally set your browser to not accept cookies or to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. Not accepting cookies will adversely affect your ability to perform certain transactions and functions on Choice Websites.

Single Pixel and Transparent Gifs

Choice uses pixels or transparent GIF files to help manage its online advertising. These files enable Choice and its advertising partners to recognize unique codes on your web browser, which in turn, enable Choice to learn which advertisements bring users to the Choice Websites. The information that Choice collects and shares is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or e-mail address.

Do Not Track Signals: Some web browsers offer a “Do Not Track” (“DNT”) signal that is an HTTP header field indicating your preference regarding tracking or cross-site user tracking. We currently do not recognize DNT signals; however, we do allow you to exercise some choice in the information collected by adjusting your browser’s cookie settings.

Google Analytics

Choice Websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to identify you as a unique user and help analyze how users use this site. The information generated by the cookie about your use of a Choice Website (including your IP address, but not your name of other identifying information) will be transmitted to and stored by Google on servers in the United States. This information is used for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage. The ad formats we utilize through Google include Audience Remarketing on Google’s Display and Search Network.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore, you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available for various browsers located at https://tools.google.com/dlpage/gaoptout.

Additional information concerning Google’s data privacy policy and other associated topics can be found at https://support.google.com/analytics/answer/6004245.

Interest-Based Advertising

Choice partners with third party ad networks to either display advertising on Choice Websites or to manage its advertising on other sites. Choice’s ad network partners use cookies and web beacons to collect non-identifiable information about your activities on Choice Websites and other sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences-mgr.truste.com. Please note this does not opt you out of being served advertising. You will still receive generic ads. Also, opting out of ad network cookies does not opt you out of cookies used for device association described above.

If you would like to know more about cookies, the website www.allaboutcookies.org provides useful information.

We also work with third parties that use tracking technologies on our Web sites in order to provide tailored advertisements on our behalf and on behalf of other advertisers across the Internet. These companies may collect information about your activity on our sites and your interaction with our advertising and other communications, and use this information to determine which ads you see on third party websites and applications. If you wish for more information about this practice and to understand your options, please visit www.aboutads.info.

Geo-Location Data

Our mobile apps may use your device’s Global Positioning System (GPS) technology to locate a Hotel near you and/To the extent any geo-location data is combined with personal information, that information will be treated as personal information in accordance with this policy.

 

Does this policy cover other sites linked from the Choice Websites?

Choice is only responsible for the privacy and security policy and content on the Choice Websites. Our sites may contain links to other websites. Those sites are not covered by this privacy and security policy, and we are not responsible for the privacy practices or the content of those other sites.

 

What about changes to the Privacy and Security Policy?

By using a Choice Website you consent to our collection and use of your personal information as described in this policy. Choice may modify this privacy policy and related business practices from time to time, and when doing so will post updated text on this website. Any changes to this policy become effective upon posting of the revised policy to this website. Use of the site following such changes constitutes your acceptance of the revised policy then in effect, subject to any additional requirements which may apply.

If you do not agree to the changes in our policy, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the policy. The “Effective Date” at the top of the policy indicates when it was last updated.

If we make any changes which materially change the ways we collect, use or disclose your personal information, we will provide additional notification of changes.

 

What if there’s a difference between versions of the Privacy Policy?

As a service to our customers, we make this privacy policy available in several different languages. In the event of any discrepancies between the various translations of the policy, the English version of the policy is the authoritative one.

 

How can I contact You? What if I have questions or concerns?

Thank you for visiting this Choice Website and for taking the time to read this policy. Should you wish to communicate with our Privacy Officer for any of the reasons mentioned in this Policy, or should you have any questions or concerns relating to our Policy or how we collect, use or disclose your personal information, please contact our Privacy Officer at:

Choice Hotels Canada, Inc.

Choice Hotels Canada Inc.
5015 Spectrum Way, Suite 400
Mississauga, ON L4W0E4

Attention: Karen Tam, Privacy Officer

Privacy@ChoiceHotels.ca