Starwood Hotels & Resorts Worldwide, Inc. Online Privacy Statement

Revised as of December 22, 2011
Effective as of January 22, 2012

Our Mission

At Starwood Hotels & Resorts Worldwide, Inc. (“Starwood”), we are dedicated to protecting your privacy and safeguarding your personally identifiable information. Starwood's mission is to consistently exceed our guests' expectations in terms of the products and services we provide to our business and leisure travelers. We strive to create an experience that is responsive to our guests' needs by using the information you entrust us with responsibly. Starwood is committed to respecting your privacy and adhering to the principles of applicable data protection and privacy laws throughout the world.

We have provided this Privacy Statement as an explanation of the information we collect, how we use it, how the use of this information can benefit your experience on our web sites and during your relationship with us, with whom and for what purposes we may share the information, and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. We wish to help you make informed decisions, so please take a moment to read the sections below. 

• THE WORLD OF STARWOOD
• STARWOOD VACATION OWNERSHIP
• TYPES OF INFORMATION WE COLLECT
• PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE
• CONSENT
• DATA TRANSFERS ACROSS INTERNATIONAL BORDERS
• SAFE HARBOR
• ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION
• SECURITY SAFEGUARDS
• ON-LINE TECHNOLOGIES
• LINKS TO OTHER WEB SITES
• MINORS
• CONTACT US
• UPDATES TO THE PRIVACY STATEMENT

THE WORLD OF STARWOOD:

In order to provide multiple access points to the services and products we offer, Starwood Hotels & Resorts Worldwide, Inc. operates directly, or through its affiliates or service providers, many web sites, including www.starwood.com, www.starwoodhotels.com, www.starwoodvo.com, www.sheraton.com, www.stregis.com, www.westin.com, www.luxurycollection.com, www.whotels.com , www.alofthotels.com,  www.lemeridien.com, www.starwoodhotels.com/element, www.fourpoints.com, www.preferredguest.com, and www.spg.com. Any one of these web sites may ask for and collect personally identifiable information in order to enhance your experience and provide you with relevant information.

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STARWOOD VACATION OWNERSHIP:

If you visit the Starwood Vacation Ownership web site, please note that a separate privacy statement governs the use of that site, available at www.starwoodvacationownership.com/legal/privacy.jsp.

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TYPES OF INFORMATION WE COLLECT:

Starwood collects information about our guests and visitors to our web sites so that we can provide an experience that is responsive to our guests' and visitors' needs. Information may be collected as part of: (i) fulfilling reservation or information requests, (ii) purchasing products or services, (iii) registering for program membership, (iv) submitting a job application, (v) responding to communications from us (e.g., surveys, promotional offers, or reservation confirmations), (vi) accommodating your personal preferences, (vii) fulfilling requests for services or recommendations we provide you, (viii) working with third party sources, including collecting publicly available information from social networking web sites, to better assist us with understanding your interests and to serve you better, (ix) your use of our apps on your electronic devices, (x) updating your contact information including your address (through such services as the National Change of Address Service in the United States), or (xi) facilitating the transmission of forward to a friend email at your request. The types of personally identifiable information (sometimes referred to as “PII”) that we collect may include your name, home, work and e-mail addresses, telephone, mobile telephone, and fax numbers, credit card information, date of birth, gender, and lifestyle information such as room preferences, leisure activities, names and ages of children, and other information necessary to fulfill special requests (e.g., health conditions that require special room accommodations).

Starwood may also collect non-personally identifiable information about you, such as your use of our web sites, communication preferences, travel habits, aggregated data relative to your stays, and responses to promotional offers and surveys.

Please note, to better safeguard your information, please do not include any credit card information in your electronic communication unless it is specifically required by us as part of the reservation or transaction fulfillment process on our branded reservation web sites, or our customer contact centers.

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PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE:

Collection & Use

Starwood is fully committed to providing you with information about the collection and use of PII furnished by, or collected from, visitors while using our web sites, products and services. It is our practice not to ask you for information unless we need it or intend to use it. Some of the primary purposes for collecting your PII are as follows:

• providing services such as processing a transaction (e.g., making a reservation, fulfilling a request for information, or completing a product order)
• marketing and communications with you in relation to the products and services offered by Starwood, our strategic marketing partners, and other trusted third parties
• performing market research via surveys to better serve your needs, improve the effectiveness of our web sites, your hotel experience, our various types of communications, advertising campaigns, and/or promotional activities

You may opt out of marketing emails and Starwood surveys at any time by clicking on the link included in such communications, or by contacting us directly to opt out of direct marketing, telemarketing, emails or surveys. Please click here to see the Updating Your Communication Preferences in the Contact Us section of this privacy statement. You will always be offered the choice not to submit your PII or to decide what communications you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing a name will prevent the processing of reservations.

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Processing and Disclosure

In most cases, the information you provide is added to a local or global database. In the course of processing your information, it may be necessary to transfer your PII to Starwood's affiliates, properties within the Starwood system and/or third party service providers located in the United States and throughout the world for the purposes outlined within this Privacy Statement. Unless otherwise precluded or governed by legal requirements and/or process, Starwood subsidiaries, affiliates and property owners that may receive your information are required to abide by substantially similarprivacy requirements relating to your PII.  As a general practice, Starwood does not sell, rent, or give physical possession of your PII to unaffiliated third parties outside the Starwood system. Situations in which Starwood may disclose your information to others include:

• when we have received your consent to do so
• in situations where sharing or disclosing your information is required in order to offer you products or services you desire (e.g., a vacation package)
• when companies or services providers that perform business activities on behalf of Starwood require such information (e.g., credit card processing, customer support services, market research administration or database management services)
• when a hotel or other property leaves the Starwood system and access to your PII is necessary to facilitate business operations or meet contractual obligations
• in the event Starwood is merged or acquired by another company
• to comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena
• in case of emergency such as to safeguard the life, health, or property of an individual

If information is shared as mentioned above, we seek to limit the scope of information that is furnished to the amount necessary for the performance of the specific function. Unless otherwise precluded by legal process, we require third parties to protect your PII and abide by applicable privacy laws and regulations.

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CONSENT:

As part of our commitment to keep you informed, we may mail, e-mail, telephone, or contact you by other means to notify you of new Starwood products and services, or upcoming Starwood special offers, events, enhancements, or other relevant information that may be of interest to you.  You may also receive mailings or other communications from carefully selected third parties. We offer you the option to decline any or all of these Starwood communications by following the directions included in our e-mails or other communications, or by contacting Starwood directly.

If you are a Starwood Preferred Guest (“SPG”) program member, you may also change your communication choices by updating your communication preferences in your individual membership profile.

We would like to keep all of our guests and visitors informed and equally able to take advantage of the benefits offered by Starwood and its strategic marketing partners. However, if you reside outside of the United States, certain data privacy regulations may require us to obtain your permission before we send you information that you have not requested from us.

In some cases your permission will be implied from the nature of the service requested or transaction undertaken. For example, Starwood may collect and use PII that you volunteer, or behavioral data or information collected in the aggregate. In addition, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request.

In certain circumstances, we will seek your express permission when we collect information that is regarded under certain data privacy regulations to be sensitive in nature (e.g., information revealing racial or ethnic origin, political opinions, or health conditions).

You may object to Starwood disclosing your PII with third parties except when: (i) service providers have been retained to perform services on behalf of Starwood; (ii) disclosure is required by law; (iii) disclosure concerns national, legal or public interest grounds; (iv) disclosure is necessary to protect the vital interests of the guest; (v) information has been collected from publicly accessible sources; (vi) disclosure concerns the retrospective processing of the information for historical, statistical or enhancement of guest experiences; or (vii) disclosure is authorized by a supervisory authority (such as a Privacy Commissioner, Data Protection Authority, or other similar authority).

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DATA TRANSFERS ACROSS INTERNATIONAL BORDERS:

As a global company, we endeavor to provide you with the same outstanding service in New York City, as you would find in Paris or Beijing. To achieve this goal, we have established a global network comprised of properties, offices, data centers, trusted marketing partners, service providers, customer contact centers, and trained associates around the globe. The nature of our business and our operations require us to transfer your information, including PII, to other group companies, properties, centers of operations, data centers, or service providers that may be located in countries outside of your own. We may transfer the PII we collect about you to countries other than the country in which the information was originally collected. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, Starwood will take appropriate steps to ensure that your PII is protected and handled as described in this Privacy Statement. Japan residents, please click here for information regarding the Japan Personal Information Protection Act.

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SAFE HARBOR:

If you are located in the European Economic Area or Switzerland, we comply with applicable legal requirements providing adequate protection for the transfer of PII to countries outside of the European Economic Area or Switzerland. Starwood is certified under the Safe Harbor privacy frameworks as set forth by the U.S. Department of Commerce, European Commission and Switzerland regarding the collection, storage, use, transfer and other processing of PII transferred from the European Economic Area or Switzerland to the U.S. click here to view our Safe Harbor Privacy Statement.

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ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION:

To ensure that your PII is accurate and up to date, we encourage you to regularly review and update your information as appropriate (e.g., in the event your home or e-mail address changes, or you wish to add an additional method for us to communicate with you). If you are an SPG program member, you can review and update your individual membership profile on-line or with the assistance of a Starwood customer service representative. If you are not a SPG program member you can review and update your PII by contacting our Consumer Affairs Privacy Office and requesting an access form. Please note that in an effort to prevent the unauthorized disclosure of your PII, you may be asked to provide proof of identity (or other authentication materials) together with the completed access request form. Access to PII for non-SPG program members cannot be provided by telephone.

If, upon review, you wish to deactivate your SPG program member profile, or update your PII, we will endeavor to do so in a timely manner. Occasionally, information that you request to be removed will be retained in certain files for a period of time in order to properly resolve disputes or to troubleshoot problems. In addition, some types of information may be stored indefinitely on "back up" systems or within log files due to technical constraints, or financial or legal requirements. Therefore, you should not always expect that all of your PII will be completely removed from our databases in response to your request.

Please refer to the appropriate contact information below to contact us about updating your communication preferences, removal from our marketing lists, or to submit a general question or request.

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SECURITY SAFEGUARDS:

Starwood recognizes the importance of information security, and is constantly reviewing and enhancing our technical, physical, and logical security rules and procedures. All Starwood owned web sites and servers have security measures in place to help protect your PII against accidental, loss, misuse, unlawful or unauthorized access, disclosure, or alteration while under our control. Although "guaranteed security" does not exist either on or off the Internet, we safeguard your information using appropriate administrative, procedural and technical safeguards, including password controls, "firewalls" and the use of up to 256-bit encryption based on a Class 3 Digital Certificate issued by VeriSign, Inc.  This allows for the use of Secure Sockets Layer (SSL), an encryption method used to help protect your data from interception and hacking while in transit.

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ON-LINE TECHNOLOGIES:

Starwood and its third party marketing partners may use cookies, invisible pixels, and web beacons to obtain information about you while visiting our web sites. A cookie is a very small text file that is sent to your browser from a web server and stored on your computer's hard drive. Starwood cookies assign your computer with a unique identifier, which in turn, becomes your identification card whenever you return to a Starwood web site.

Cookies are designed to save you time because they help us to provide you with a customized experience without you having to remind us of your preferences each time you return to our web pages. Starwood cookies are not designed to damage your files, nor can they read information from other files on your computer hard drive.

Cookies can also help us provide you with a personalized on-line experience in the following ways:

• they remember your user name and password for future visits so log-in is easier and faster.
• they ensure you are provided with the appropriate frames and content.
• they ensure you obtain all requested information.
• they help us deliver communications that are relevant and responsive to your interests and location.

Starwood cookies are limited to our web sites only, and are not designed to follow you when traveling on the Internet after leaving Starwood owned web sites. We track the usage of our web sites in order to better meet your needs and to help make it easier for you to find information in the future. Please note that in addition to Starwood cookies, various third parties may also place cookies on your computer's hard drive. Starwood is not responsible for the presence or absence of third party cookies, or for the technological capabilities or practices employed by third parties in connection with third party cookies.

If you would prefer not to have the benefits of cookies, your Internet browser can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our web sites and our ability to recognize your browser from one visit to the next.

Starwood also uses invisible pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain PII. Starwood may use this information to improve marketing programs and content.

We also work with vendors and marketing partners to help deliver advertisements and personalized content that we believe will be of interest to you. These vendors and other partners include advertisers, advertising agencies, advertising networks, audience segment providers, data exchanges, analytics providers, and other similar providers.Please click here for a current list of the agencies and providers with which we work. These partners and vendors use cookies and web beacons to collect information about your online activity (e.g., the sites and pages you have visited at Starwood sites and other third party sites) in order to help Starwood (and in some cases, third party advertisers) deliver personalized content and advertising to you while you are on Starwood or other sites.

For example, if you go to a Starwood site to look at one of our properties or to book a hotel room, you may later see an advertisement from us when you visit another web site.  We may also engage one of these vendors to deliver our advertisements to consumers whose online behaviors on sites other than the