Aven Hospitality Privacy Statement

We gather information about you through your interactions with us and our Services. Some of this data is provided directly by you, while other data is collected based on how you engage with and experience our Services. The specific data collected varies depending on the nature of your interactions with us, the settings you choose, and the features and services you use. We may also receive information about you from our customers, affiliates, subsidiaries, and other third-party sources.

Information You Provide to Us:

We collect personal data when you interact with our Services or choose to share it with us directly.

• Contact, Subscription, and Registration Information. Such as your name, email address, phone number, job title, company name, and preferences when you sign up for an account, newsletter, event, or visit.
• Account Information. Details related to your user account, including login credentials, account settings, and communication preferences. 
• Content You Share Through Our Services. Any information you submit while using our Services, like messages, queries, forms, uploaded files, or other shared content.
• Content You Share on Our Websites. Information you provide through website features such as contact forms, surveys, chat or other similar tools, or feedback submissions.
• Support Requests. Information you provide when you contact us for help or other support, including your name, contact details, issue description, and any supporting materials.
• Payment Information. Data necessary to process purchases or bookings, such as your billing address, payment card or bank details, and transaction history.

Personal Data from Cookies and Similar Tracking Technologies. We may collect the following information about you using cookies and similar tracking technologies (collectively, “Cookies”) when you visit our Services and across third-party websites, applications, and other online services (“Third-party Sites”), including:

• Browser and Device Data. This includes IP address, device type, operating system and Internet browser type, screen resolution, plug-ins, add-ons, advertising identifiers, language settings, and the websites you visit.
• Usage Data. This includes how long you spend on our Services and Third-party Sites, pages you view, links you clicked, and the pages that led you to our Services or Third-party Sites.

We may work with trusted analytics partners, including Google Analytics, to help us understand how our Services are used and to improve your experience. To learn more or manage your cookie preferences, please see our Cookie Policy.

Personal Data from Other Sources:

We may collect personal data about you from our customers, travel suppliers, and other trusted third parties.

• Business Partners or Customer Business Partners. Where elected by you, at the authorized direction of a customer, or as otherwise permitted by law, we may receive information about you from a business partner.
• Authorized Third Parties. We may receive personal data from trusted third parties that we or our customers work with, including from loyalty programs, hotel systems, travel agencies, booking platforms, or other affiliated businesses. This helps us deliver our Services and support customer-approved purposes like analytics, reporting, or coordination of our services.
• Ad Partners. We may collect personal data from advertising partners and others who use Cookies to understand your preferences and show you more relevant ads or content.
• Personal Data from our Partners and Customers. We may receive personal data about you from travel agencies, hotels, and their partners or service providers to help deliver our Services or to support customer- approved purposes. 
  • Trip Information. When a travel agent or similar party facilitates booking a trip or making a reservation on your behalf, we receive information about you and your trip from them, including your reservation information, travel preferences, and any other information submitted throughout the booking process. This category includes any personal data shared with us via a global distribution system.
  • Order Information. We may collect contact, billing, shipping, and order details, including refund requests.
  • Payment Information. We may receive payment information necessary to book or facilitate the booking of a trip or otherwise facilitate the purchase of any products and services, including payment card and bank account details, billing and shipping address, order description and details, device ID, IP address, order ID, merchant-requested information, and identity documents. We may also provide this data to payment processors and other service providers to facilitate bookings or purchases.

We use the data we collect to provide innovative and engaging experiences. How we use the information we collect depends in part on which Services you use, how you use them, and any preferences communicated to us. We use data to:

• Provide and Manage our Services. We use data to support account registration, process payments, respond to your questions, and send important service updates.
• Improve and Develop our Services. We use data to understand how our Services are used, improve performance, and create new features. We may also use, compile, aggregate, or de-identify data for research and insights.
• Personalize your Experience. We may tailor your content, features, and ads based on your interests and how you use our Services.
• To Stay in Touch. We communicate with you about customer support, feedback, and questions you send to us.
• Share Relevant Updates and Offers. With your permission or where allowed by law, we’ll determine eligibility and may let you know about new features, promotions, or services from us or our partners.
• Meet Legal Requirements and Protect Rights. We comply with applicable laws, may respond to valid legal requests, and take steps to protect our services, users, and business.
• Support Essential Business Operations. We may also use personal data for internal purposes like accounting, audits, and general administration. This includes helping prevent financial loss or harm, managing risks and claims, and enabling the security and reliability of our Services.

Legal Basis for Processing for European Union Users. We collect and process personal data about you only where we have a legal basis for doing so under applicable regulations. The legal bases depend on the Services and how you use them, and may include:

• To Provide and Manage our Services. We process personal data as necessary to deliver the products and services you use, operate our business, fulfill contractual and legal obligations, and protect the security and safety of our systems and customers.
• Reliance on Legitimate Interests. Where we process personal data based on our legitimate interests, we carefully consider and balance those interests against your rights and freedoms.
• Compliance with Legal Obligations. We may process your data where required to meet applicable laws, regulations, or legal processes.
• With your Consent. In cases where we rely on your consent, you may withdraw it at any time. This will not affect processing that has already occurred based on your prior consent.

We share personal data only when necessary to deliver our Services, improve your experience, operate our business, or comply with legal obligations. This may include sharing personal data with trusted service providers, business partners, affiliates, or authorities, depending on the context.

• Aven Hospitality Entities and Affiliates. We share personal data with other Aven Hospitality entities, including affiliates to provide and improve our Services, for business operations, and to comply with legal obligations.
• Service Providers. We use service providers to perform services on our behalf, including website hosting, marketing automation, analytics, customer service, information security, and payment services (e.g., payment processing, chargebacks, and orchestration layer services).
• Customers. If you access our Services through a business customer, we may share your personal data with that customer and any authorized representatives. This may include travel agents, travel management companies, corporate travel departments, online travel platforms, and travel suppliers, like airlines, hotels, cruise lines, car rental companies, rail providers, and tour operators, as needed to deliver or facilitate the Services. We may also share compiled, aggregated, or de-identified reports and business intelligence outputs with customers.
• Business Partners. We may share personal data with trusted business partners to deliver, support, and enhance our Services, or to offer programs, promotions, or features.
• Authorized Third Parties. We share personal data with third parties that our customers have a relationship with such as loyalty providers, hotel systems, and other authorized businesses to deliver our Services or fulfill customer instructions.
• Ad Partners. With your consent or as permitted by law, we share personal data on your visits to our websites with others so that we can advertise and market products and services. These third parties may use this information to market third-party products and services to you, including through interest-based advertising. We do not share your personal data with third parties for their marketing or advertising unless legally allowed or with your permission.
• Third party Services. If you choose to share content through a third party platform, like a social media site, we may send your personal data to that platform to enable the sharing feature.
• Third party Sites. Our Services may link to or be accessible from websites we do not operate. If you choose to share information with those sites, your data is governed by their privacy policies. We encourage you to review their privacy statements, as we are not responsible for their practices.
• Professional advisors. We may share personal data with professional advisers acting as service providers, processors, or joint controllers, including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Corporate Transactions. We may share personal data as part of a business transaction, like a merger, acquisition, or reorganization, where it is necessary to support or complete the change in company structure.
• With your Consent. We may share information about you with third parties when you give us consent to do so. 
• Legal and Security Purposes. We may share personal data when necessary to comply with the law, respond to legal requests, enforce our rights, or protect the safety, privacy, and property of our Services, users, and others. This may include sharing information to help detect and prevent fraud or reduce credit risk.

We are committed to respecting your privacy and providing you with meaningful choices about how your personal data is collected, used, and shared. Depending on your location or residence and applicable data protection laws, you may have the following rights:

• Access and Correction. You may request access to the personal data we hold about you and request that we correct any inaccuracies.
• Deletion. You may request that we delete your personal data, subject to certain legal or contractual obligations.
• Objection and Restriction. You may object to or restrict the processing of your personal data in certain circumstances.
• Data Portability. You may request a copy of your personal data in a structured, commonly used, and machine-readable format, and you may have the right to transmit that data to another controller.
• Consent Withdrawal. If we process your personal data based on your consent, you may withdraw that consent at any time. A withdrawal will not affect the lawfulness of any prior processing.
• Automated Decision-Making. Where we use automated decision- making that produces legal or similarly significant effects, you may have the right to request human intervention, express your point of view, and contest the decision.
• Marketing Preferences. You can opt out of receiving direct marketing communications from us at any time by following the unsubscribe instructions in our communications or by adjusting your preferences in your account settings. We will process your request as soon as reasonably practicable. If you opt out of receiving promotional related emails, you may still receive transactional messages from us or our partners regarding our Services.  

We use a combination of organizational, technical, and physical safeguards to help protect your personal data from accidental or unlawful destruction, loss, alteration, or unauthorized access and disclosure. While we work hard to keep your information safe, no system or method of transmission over the internet is completely secure. Because of this, we cannot guarantee absolute security but we continuously monitor and endeavor to improve our protections to reduce risk.

We keep your personal data only for as long as we provide our Services to you or if we have a legal or business reason to do so. When those reasons no longer apply, we follow the retention timelines allowed by law to securely delete your data. If any information cannot be fully removed from our systems, we take steps to ensure that it is protected and no longer used.

We collect information globally and may transfer, process, and store your information outside of your country of residence to wherever we or our third- party service providers operate for the purposes of providing our Services. Whenever we transfer your information, we take steps to protect it.

To facilitate our global operations, we transfer personal data to and from the European Economic Area, the United Kingdom, and Switzerland to countries that may not be recognized by the European Commission as providing an adequate level of data protection. For example, local laws in those countries may not guarantee the same privacy rights, or there may be no supervisory authority capable of addressing privacy concerns. To safeguard your data during these transfers, we rely on the European Union’s Standard Contractual Clauses (“EU SCCs”) as set out in the Commission Implementing Decision 2021/194. These contractual safeguards are designed to ensure your rights travel with your data and remain protected regardless of where it is processed.

Unless otherwise indicated, our websites and Services are not intended for use by children or minors as specified by law in the applicable jurisdiction.

We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “Last Updated” date at the top of this Privacy Statement. If we make a material update, we may provide you notice prior to the update taking effect, such as by posting a notice on our websites or by contacting you by email.

We encourage you to review our Privacy Statement to stay informed about our privacy practices.

We value your opinion. If you are a traveler, please refer to the privacy statement of your travel provider for information regarding the travel provider’s privacy practices, your rights and choices, and how to contact them.

Please direct any other questions or comments related to this Privacy Statement to privacy@avenhospitality.com  or send us postal mail by using the contact information below.

Data Protection Officer

IHS US Inc.

3150 Sabre Drive

Southlake, Texas 76092