ChoiceU.com Privacy Policy | ChoiceU.com Privacy Policy (EU) | ChoiceU.com Cookies
This notice was last modified on 7 September 2018.
Who we are
Choice Hotels International, Inc. Choice University
Choice Hotels International, Inc. and its subsidiaries (“Choice”, “we” or “us”) are committed to providing you with an efficient and customized Internet experience. Choice complies with applicable privacy and data protection laws, including the European Union’s (EU) General Data Protection Regulation. This Privacy and Security Notice (“Notice”) explains who we are, how we collect, share, and use personal information about you, and how you can exercise your privacy rights.
Our website address is: http://choiceuniversity.net/
We recommend that you read this Privacy and Security Notice in full to ensure you are completely informed. However, if you prefer to access only a particular section of this Notice, you can click on the relevant link below to move directly to that section.
ChoiceU.com Privacy & Security
How Do I Contact The Data Protection Officer?
If you have questions about this notice, concerns or complaints about how we collect, use, disclose, store, delete, or protect your personal information, Choice’s Data Protection Officer can be reached at:
Choice Hotels International
Attn: Data Protection Officer
6811 E. Mayo Blvd., Suite 100
Phoenix, AZ 85054
dpo@choicehotels.com
How do I contact Choice Hotels International, inc.?
For general inquiries, we can be reached at:
Choice Hotels International
Attn: Privacy Officer
6811 E. Mayo Blvd., Suite 100
Phoenix, AZ 85054
privacy@choicehotels.com
Children’s Privacy
Our websites are not intended for children and we do not knowingly solicit or collect personal information for persons under the age of 18.
Who Is The Data Controller?
With respect to the personal information we collect, use, disclose, store, delete, protect, or receive from Franchised Hotels, Choice Hotels International, Inc. is a data controller as defined under the General Data Protection Regulation. See FRANCHISED HOTELS & YOUR PRIVACY for information about Franchised Hotels as data controllers.
What If There’s A Difference Between Versions Of The Privacy And Security Notice?
As a service to our customers, we make this Notice available in several different languages. In the event of any discrepancies between the various translations of the notice, the English version of the Notice is the authoritative one.
How Do You Resolve Complaints?
We will work with you to address complaints, which may include contacting applicable authorities as part of the resolution process.
What About Changes To The Privacy And Security Notice?
Choice reserves the right to modify this Notice and related business practices at any time by posting updated text on this site. Please review the “last updated” at the top of the Notice to see when this privacy notice was last revised. If we make a material change we will post a notice on our website at least 30 calendar days prior to its implementation.
Does This Notice Cover Other Sites Linked From This Website Or Choice’s Mobile Apps?
This privacy notice covers only the ChoiceU website, although it may redirect to third-party websites and mobile apps. Those websites and mobile apps are not covered by this Notice, and we are not responsible for the privacy practices or the content of those websites and mobile apps.
How Long Do You Keep My Personal Information?
Your personal information related to training and reporting will be stored by us for the period of time required by law in the jurisdiction of the Franchised Hotel to which the information relates or for a longer period if there is a legitimate business purpose for doing so. Your personal information collected for other uses (see HOW IS PERSONAL INFORMATION USED? ) will be retained for the period necessary for the purposes set out in this Notice unless a longer retention period is required or permitted by law or there is a business purpose for doing so.
Do You Use Interest-Based Advertising?
Choice does not employ interest-based advertising on the ChoiceU website.
Google Analytics
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help analyze how users use the site. The information generated by the cookie about your use of the website (including your Internet Protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Because of the present activation of the IP anonymization, Google will truncate/anonymize the IP address within the area of the European Union or a member state of the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the United States. On behalf of the website provider, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google.
You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout .
Further information concerning Google’s data privacy and terms of use can be found at http://www.google.com/intl/en/analytics/learn/privacy.html .
Please note that on this website, Google Analytics code is supplemented by “anonymizeIp();” to ensure an anonymized collection of IP addresses (so called IP-masking).
Do You Use “Cookies” And Similar Technologies?
Choice’s websites 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. Choice uses cookies to remind us of who you are, tailor our services to suit your personal interests, track your training status, and/or analyze your visiting patterns.
The site may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties, for example Facebook or Google. If you use these tools to share personal information or you otherwise interact with social media features on the site, those social media companies may collect information about you and may use and share such information in accordance with your account settings, including sharing such information with the general public. Your interactions with third-party social media companies and the use of their features are governed by the privacy notices of the social media companies that provide those features.
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 our websites, which enables us to provide you with a more convenient and personal digital experience.
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.
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.
If you would like to know more about cookies, the website www.allaboutcookies.org provides useful information.
Click here for additional information about the cookies used on this site.
How Do You Store And Secure My Personal Information?
Our vendor’s learning management system and ChoiceU databases are maintained in the United States; therefore, your personal information will be collected (or transferred) and maintained in the United States. We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
For example, when you provide us with information through this site, such as your name, work address, and work phone number, your information will be encrypted using a Transport Layer Security connection. You can tell if your information is encrypted online by looking for the locked padlock icon on the lower right-hand or left-hand corner of your website screen and a change in the site address from “http” to “https.”
What Are My Data Rights?
Accessing personal information
With some limited exceptions, you have the right to access (i.e., view) the personal information we maintain about you by accessing your profile in ChoiceU. You can also send us a request by letter or email to the address in the Contact the Data Protection Officer section of this notice.
Restricting or objecting to processing
You have the right to request that we restrict or stop processing personal information that we hold about you by sending a letter or email to the address in the Contact the Data Protection Officer section of this notice. If we are unable to cease processing your personal information (e.g., because of a legal obligation), we will document that you made such a request and the reason we are unable to honor it.
Updating your personal information
You have the right to request the update or correction of the personal information we hold about you, where it is factually incorrect. If we agree the information is incorrect or that the processing can be stopped, we will correct the information or cease processing the information, as appropriate. If we do not agree that the personal information is incorrect, we will still record the fact that you consider the personal information to be incorrect in the relevant file(s). You can request updates to personal information that we hold about you by sending a letter or email to the address in the Contact the Data Protection Officer section of this notice.
Deleting personal information
You can request deletion of your personal information by sending a letter or email to the address in the Contact the Data Protection Officer section of this notice. Note that if you are a current employee of Choice or a Franchised Hotel it may not be possible to delete your personal information.
Data portability
Under the General Data Protection Regulation, EEA residents have the right to data portability. Choice satisfies this obligation by providing you access to the personal information we have about you in a structured, commonly used and machine-readable format. You can also ask us to provide the information to another data controller. You can request your data by sending a letter or email to the address in the Contact the Data Protection Officer section of this notice.
Supervisory authorities
If you are unhappy with the resolution of your requests or complaints, you have the right to contact your local Data Protection Authority for assistance. The European Commission provides a list of the contact details of the National Data Protection Authorities, found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .
You also have the right under EU law not to be subject to a decision based solely on automated processing, including profiling, which may have a legal impact on you. Note that Choice does not currently perform automated processing that would affect individuals in this way.
With any request to exercise your data rights, be sure to include your name, address, e-mail address and employee ID number (if applicable) so that we can confirm your identity and the personal information we maintain about you. We may not disclose data that you are not entitled to receive under applicable laws (e.g., data revealing information about another individual).
Does Choice Process My Personal Information Outside The European Economic Area?
Like most multi-national businesses, we have centralized certain aspects of our data processing, allowing us to better manage our business as a whole. That centralization will result in the transfer of personal information from one country to another. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Our Website servers, as well as those of our LMS vendor, are located in the United States, and our group companies and third-party service providers and partners operate around the world. This means that when we collect your personal information we may process it globally.
To facilitate transferring European Economic Area (EEA) citizens’ personal information out of the EEA countries, Choice incorporates the Standard Contractual Clauses approved by the EU Commission into applicable contract agreements to ensure that the necessary levels of protection and care are required of all parties. Information about the European Commission’s Standard Contractual Clauses and a copy of the Standard Contractual Clauses can be found at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
Additional information about Choice’s incorporation of the Standard Contractual Clauses in its contract agreements or the data protection measures associated with data transfers can be requested by sending us a letter or email to the address in the Contact Choice Hotels International section of this notice.
When Is Personal Information Disclosed To Others?
We need to transfer your information to Franchised Hotels, as well as our third-party Learning Management System (LMS) vendor in order to manage your training, including running the training content and tracking course completion. LI
Choice distributes personal information to third party service providers such as web analytics companies. We also use such third parties to:
- conduct data processing for Choice; LI
- provide additional training content (e.g., general skills and knowledge); LI
- engage in e-mail and other communications on behalf of Choice; LI
- administer surveys; LI
- compile information for us about the type and frequency training accessed; and LI
- compile information for us about the use of Choice’s websites. LI
These parties are contractually prohibited from using personal information for any purpose other than the purpose that Choice specifies.
Some information, such as information about the website you were on when you clicked the link to visit ChoiceU’s website, is exchanged to verify the link. LI
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. LO
We may also use your information as permitted by law to protect the rights or property of Choice, our employees, our Franchised Hotels and their employees, our customers, this site, or its users. LI, LO
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. LI, LO
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). LI, LO
How Is Personal Information Used?
Training:
- We use your business contact information and employee identification information to offer training necessary to you and your employer to maintain the service levels expected for each Choice brand and the individual roles at each Franchised Hotel. To do so, each employee must create a profile within ChoiceU to allow the assignment and completion of such training. LI
- We will use your e-mail address to send informational messages, assignments, status updates, course completion confirmations and, if necessary, might use the other information to contact you regarding your training. LI
Reporting:
- We may use your personal information to provide reports to your employer (Franchised Hotel) regarding the status of any trainings assigned to you, or notification that you have requested a specific training which may need approval. LI
What Personal Information Does Choice Collect And Process And For What Purposes?
Purposes for Processing
We and our affiliates use the personal information to administer our business activities, provide customer service, personalize your digital experience, and contact you concerning your assigned and completed training. We share your information with our Franchised Hotels, the third-party Learning Management System, and other companies where necessary to provide you with training. We may also use your information to send you communications by e-mail or message board or share your information with our business partners..
Legal Basis for Processing
When Choice processes personal information, we do so under one of the following legal bases:
- Consent – as applicable, we offer individuals a choice on whether to participate in a program, and/or an option of how much personal information to provide. Where the processing is based on your consent, you have the right to withdraw consent at any time. Processing based on consent is marked below with “C.”
- Compliance with legal obligations – some of the personal information we collect is required by the laws of the countries where individuals live and in which we do business. These are marked below with “LO.” When personal information is processed because Choice has a legal obligation to do so, your failure to provide such information may have negative consequences, including the inability to maintain a customer relationship with Choice.
- Legitimate interests – often, the personal information we collect is processed because Choice has a legitimate interest in doing so, which is not outweighed by your fundamental rights. This includes information necessary to administer the programs and services we offer. Legitimate interest processing is marked below with “LI.”
What we collect and process
The types of personal information Choice collects and processes may include any or all of the below.
Our website may receive and store information based on your browser settings, which may include your browser type and operating system, the various ChoiceU web pages you view, Internet Protocol (“IP”) addresses, unique device identifiers, and sites visited before viewing our website. LI
We collect personal information and other information that you supply, such as your name, job title, work address, work telephone number, work e-mail address, employee ID number, LAN ID and password when you:
- Create an online account; C
- Access ChoiceU to take training or interact with the system; C
- Elect to receive communications. C
Choice may occasionally conduct surveys about a training you participated in or the functionality of the website. C
Franchised Hotels & Your Privacy (EU)
Hotels franchised under Choice’s brands (“Franchised Hotels”) are independently owned and operated. As a result, your personal information collected or maintained directly by Franchised Hotels is processed by those Franchised Hotels as a data controller of your personal information. Your personal information is not subject to this notice unless such information has been shared with us. If your information has been shared with us, we will process your information in accordance with this Notice. For example, the information necessary for you to complete mandatory brand and role-specific training will be transmitted to and processed by Choice. The Franchised Hotel is the employer who collects and processes personal information relative to your employment. Information collected by Choice University (“ChoiceU”) may be shared with the Franchised Hotel regarding training requests and the completion status of any assigned training.
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