Last modified and effective May 24th, 2018
Click on one of the links below to jump to the listed section.
- Who we are
- Collecting personal information
- Information you provide directly
- Information we collect electronically
- Children’s information and privacy
- Using your personal information
- Third-party service providers
- Data transfers
- Sharing information
- How we protect information
- How long we keep information
- Your rights
- Links to other websites
- How to contact us
1. Who we are
Charlestowne Hotels, Inc. and its subsidiary companies (“we,” “us,” “our”) are located in and formed under the laws of the State of South Carolina, USA. Our operations and services consist of the ownership and/or management of, and/or provision of services by contract to, various hotels (the “Properties”), all of which are located in the United States. All of the Properties and we provide all of the services and products that we or they offer only in the United States. We, they, and our website www.charlestownehotels.com, are governed exclusively by the laws of the United States and its several jurisdictions in which Properties are located; and all obligations incurred to us or in connection with the Properties are payable only in lawful currency of the United States.
3. Collecting personal information
Information you provide directly
We collect, store, and process information about you that you provide to us in connection with the following:
- filling in a form on any of our websites;
- filling in a physical registration card;
- contacting us by telephone or in person (for example, while making a reservation);
- sending us a letter, e-mail, or social media message;
- subscribing to receive a service from us (for example, a newsletter or blog) or following us on social media);
- requesting promotional information from us;
- participating in a survey, competition, or prize draw; or
- contributing content to us (for example, a review or comment to our website).
The types of information we may obtain include:
- your name, gender, title, birthdate, and contact information (such as e-mail address, mailing address, telephone number);
- details of food allergies/dietary requirements and special requests made (for example, relating to a disability) you provide to us;
- driver’s license or travel information, payment information, history of stays at our properties, and details of joint guests;
- dates of your stay with us and associated charges;
- purchase or delivery of products or services;
- reviews and opinions about our brands, products and services;
- information we receive about you from any third parties through whom you have booked your arrangements; and
- information we receive about you from other properties that we own, manage, or operate (which may include any of the above).
We do not collect “sensitive information” (that is, information on racial or ethnic origin; opinions such as on politics or religion; health; criminal background; or membership in organizations (for example, interest groups or labor unions) unless you volunteer it.
Information we collect electronically
When you visit our website, we may also collect certain information through the use of “cookies” and other automated means. (To learn more about cookies, how they are used and how to exercise your choice with respect to their collection of information on this site, see Section 4 below.) Such information may include:
- The date and time of your website visit;
- The pages that you visit on our website and the time that you spend on them;
- The internet protocol (IP) address of your computer or other device, and/or other unique device identifiers;
- The internet domain name associated with your computer or other device;
- The browser type and version that you use, and the operating system if that is provided by the browser;
- The web address (URL, or “uniform resource locator”) of the webpage that referred you to our website (if provided by your browser);
- Object requested;
- Completion status of any request that you make;
- Geographic location; and
- Cookies and other electronically available diagnostic or usage data.
Children’s information and privacy
Our services are not intended for anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under that age. If you are a parent or guardian and you are aware that your Child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a Child without verification of parental consent, we will take steps to remove that information from our servers.
A cookie is a text file with a small amount of data that may include a unique identifier. A website that you view can place a cookie on your computer or other device. Through them and other similar technologies (such as “beacons,” “tags,” and “scripts”), information can be collected and stored about the online activities of the personal computer or other device that you use. They can, for example, store and manage user preferences, deliver targeted advertising, enable your access to certain content, and gather analytic and usage data to help us refine and improve our understanding of your interests and your experience on, and resulting from your visits to, our website. Cookies may be “session” cookies that last for the duration of your Internet browsing session; or they may be “persistent” cookies that remain on your computer and are active whenever you begin a new browsing session, until you delete them.
You can manage website cookies in your browser settings; and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:
Cookies may be one of five types.
One type is “essential.” These are necessary for you to navigate around a website and to use its features, for example adding items to an online shopping cart.
A second type is “performance.” These collect information about how you use the website. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, duration of visit, and pages viewed. Performance cookies help us to improve our website’s user-friendliness and to enhance your experience.
A third type is “functional” or “preference” cookies. Functional cookies remember choices you have made related to our website (such as your username and your region, and your preferences as to user-customizable aspects of a web page’s appearance, such as text size and fonts) in order to provide enhanced, more personal features.
A fourth type is “targeted advertising.” These cookies track your browsing activities and enable advertisers to send to you (that is, to pop-up on your screen) advertising related to things in which your browsing history indicates that you likely have an interest. They can also track and control the number of times you see an ad and so can measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with advertisers. As an example, if you visit a page on our website related to one of our services or products, you may begin to see pop-up notices related to that or other products in your future Internet browsing. For more information about such interest-based advertising, you can visit: http://www.iab.net/public_policy/behavioral-advertisingprinciples. If you opt out of interest-based advertising, you may still receive advertising when you visit our website or advertising about our products when you are on other websites, but we will not be using information collected about you so that the advertising that you do see will not be customized to your interests. You can exercise your online advertising choices at http://optout.aboutads.info or by clicking the AdChoices icon in an ad and following the instructions. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative’s (NAI) Opt Out Tool (http://www.networkadvertising.org/choices) and at http://www.youronlinechoices.com/. Another tool you can use to control advertising on your mobile device is the AppChoices App: http://youradchoices.com/appchoices. Remember, if you delete cookies, use a different device, or change web browsers, you may need to opt out again.
The fifth type is “security” cookies, which are used to protect the security of our website’s servers and systems.
5. Using your personal information
We are the entity that will make decisions about how information that you provide to us is processed and used. We may use and process the information that we obtain either directly from you or electronically through your use of our website, for the following purposes.
- To enable you to make reservations and payments;
- To provide the services or products you request from us (including special requests related to medical, dietary, or other sensitive information that you voluntarily provide to us);
- To provide for the safety and security of our guests and visitors;
- To provide customer support;
- To remind you of, and to notify you about changes to, your reservations, our services, and our products;
- To enable us to provide, bill, and receive payment for services and products that you request;
- To personalize your access to our website;
- To allow you to participate in interactive features of our website when you choose to do so;
- To help us create content that is relevant to our guests and website visitors;
- To improve our website and our customer service;
- To send email notifications, marketing, and/or non-marketing commercial communications, including news, special offers, and general information about other services, products, and events that are similar to those that you have purchased or enquired about unless you have opted not to receive such information (you may opt out of receiving email communications from us by selecting the opt-out link at the bottom of each email communication);
- To provide information to third parties with your consent;
- To monitor the usage of our website and our services and products;
- To detect, prevent and address technical issues;
- To assess and help us understand general trends and patterns relating to our business;
- To manage general record keeping;
- To enable us to compile anonymous, aggregated statistics that allow us to understand how users use our website and to help us improve the structure of our website;
- To meet any legal and/or regulatory requirements; and
- For other similar purposes that are not incompatible with those listed above.
We may use your information in other ways for which we provide specific notice at the time of collection.
At the time you allowed cookies in your website visits and at the time you entered information through this website, you have consented to the above uses of that information. Your decision to provide your information for marketing and other purposes not directly related to a stay at a Property is optional and will have no consequence on your ability to stay with us or benefit from the requested services. Your decision to provide your information for all purposes concerning your booking, your stay, and to provide you with the services you have requested is voluntary; however, if you do not provide such information, you may no longer be able to benefit from our services.
We may process your personal information by both automated and manual means.
6. Third-party service providers
We may employ third parties (“Service Providers”) to facilitate the management and operation of our website or to host or manage and operate it on our behalf, to perform website-related services, or to assist us in analyzing how our website is used. These Service Providers have access to your personal information only to perform these tasks on our behalf; and they are obligated to protect it and not to disclose or use it for any other purpose.
We may use Service Providers, including Google Analytics, to monitor and analyze the use of our website. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/.
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. If you wish to opt-out, Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
In addition, we may provide to Facebook information regarding a significant number of our guests and/or website users (possibly including you) consisting of either (i) their email addresses, or (ii) some combination of their names, cities and states, postal codes, and other information not including their email addresses. If those persons have a Facebook account to which Facebook can identify them with the information provided, Facebook will then create a group of other Facebook users who have the characteristics most often shared by the group whose information we have provided, for purposes of sending them information about our services and products.
7. Data transfers
Information that you provide to us through this website or otherwise and either directly or indirectly through cookies or similar technology, is collected by us and processed by us or by our agents, including Service Providers, that we have selected in the United States or third countries of our choosing. Consequently, your personal information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your home jurisdiction.
8. Sharing information
We may also disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation, imposed by statute, regulation, a court, or regulatory agency;
- To protect the safety of users of the website or of the public;
- To protect and defend our legal rights and property;
- To prevent or investigate possible wrongdoing in connection with our website; and
- To protect against legal liability.
9. How we protect information
The security of your information is important to us; but remember that no method of transmission over the Internet and no method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. Use of this and any other website or other means of electronic communication is at your own risk.
We maintain administrative, technical and physical safeguards designed to protect the information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We will use our safeguards to protect your information and try to prevent unauthorized access to our systems. Services Providers and contractors who might have access to your information in order to provide services on our behalf will be contractually obliged to keep such information in confidence, provide adequate data security measures, and may not use that data for any other purpose.
For your own protection, we encourage you not to include sensitive personal information, credit card or similar data in any e-mails you send us or our staff.
10. How long we keep information
We will also retain electronically-collected data on usage on an aggregated, anonymized basis for internal analysis purposes for a period not longer than 26 months. Such usage data is generally retained for a shorter period of time, except when it is used to strengthen the security or to improve the functionality of our website or when we are legally obligated to retain it for longer periods.
11. Your rights
We will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. At any time, you may review, correct, modify, and/or delete your information that we hold. For information reflected in your website account with us, you may do so by accessing your account in the “Settings” section. For any other information, you may do so by contacting us in the manner shown below. If you determine that any such information is incorrect, we encourage you to correct it promptly.
At any time, you may contact us and request the deletion of all of your information that we hold and the cessation of all processing thereof; and we will comply with that request except to the extent necessary to perform to completion any contract that you have entered into with us. Please note that any cessation of processing will not affect any processing already begun; nor will deletion extract non-identifiable information about you from any aggregated, anonymized data set. Also, please note that if you request such deletion, we will not be able to remove your information from the databases of third parties with whom we have already shared your information, with your consent. You should contact such third parties to opt out directly. You also have the right to a copy of your personal information that we hold in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.
You also have the right to request that we cease sending marketing communications, whether by email or otherwise, to you. You can do this by (i) leaving un-checked the applicable box(es) on any form used to collect information from individuals, or (ii) clicking the unsubscribe link displayed in any of the marketing e-mails you receive, or (iii) otherwise requesting that we do not process your information for marketing purposes.
Pursuant to California’s “Shine the Light Act,” California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use.
12. Links to other websites
13. How to contact us
Attn: Data Privacy Officer
28 Bridgeside Boulevard
Charleston, South Carolina 29464