AYRES HOTELS PRIVACY POLICY

Last Updated: July 2023

Overview

This Privacy Policy ("Privacy Policy") applies to the websites located at www.ayreshotels.com and any other websites owned and operated by Ayres Hotels, Ayres Rewards, Allegretto Vineyard Resort, Allegretto Wines, and Olympic Lodge (collectively, the “Ayres Hotels”) that direct the viewer or user to this Privacy Policy, as well as information collected at and in connection with our Ayres Hotels location(s) and related products.

In this Privacy Policy, the terms "Ayres Hotels," "we," and "us" refers to Ayres Hotels and its respective subsidiaries and affiliated companies. Please note that websites that are owned and operated by Ayres Hotels may contain links to digital properties that are owned and operated by other companies. This Privacy Policy does not apply to websites and services that are owned and operated by unaffiliated third parties.

1. Updates to this Privacy Policy

   This Privacy Policy went into effect on the “Last Updated” date noted near the top of this page. We may update this Privacy Policy from time to time. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version.

2. Information We Collect

   As you use our websites or visit one of our hotels, we collect information about you and the services you use. The information we collect falls into two main categories: (1) information you voluntarily provide us; (2) information we collect from you automatically; and (3) information we collect from third parties.

   Some examples of when we collect this information include when you browse or make a booking on one of our websites; create an Ayres Rewards account; use the order and pay functionality on one of our websites; or participate in a survey or promotion.

   1. Information You Give Us
      

      Some information we collect is provided when you use our services, such as when you create a booking, a rewards account, order and pay for products, or submit online forms through our websites.

      This may include your first and last name, username, password, email address, shipping address, billing address, phone number, financial account information such as a credit card number, and any other information you give us, such as to participate in a promotion or to contact Ayres Hotels customer service. In addition, we may collect driver’s license information, passport information, and license plate numbers for guests that stay at our locations.

   2. Information We Automatically Collect
      

      Device and Usage Information – Like many website operators, we collect information that your browser sends whenever you visit our websites. This includes Log Data, such as your computer’s IP address, browser type, browser version, the pages of our Sites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means.

      CCTV Information – Closed circuit video surveillance cameras (“CCTV”) may be installed at some of our physical locations to monitor building security and assist in crime prevention, detection, and investigation, and to ensure the health and safety of our staff and visitors to our hotels and facilities.

      Location Information – We may collect information about the location of your device, such as information that identifies your device’s approximate location (e.g., less precise location estimated based on a browser or device’s IP address).

      We collect this location information for purposes of enhancing or facilitating our services, such as to enable the functionality of our websites that provide you with information about hotels near you or to enable you to remotely order and pay for our products and services.

      We may also use information about the general location of the device you are using to help us understand how our websites and other services and functionality are being used, or to deliver more relevant advertising or personalized experiences for you, including tailored marketing offers or messages based on your location or related context such as the time of day or weather.

   3. Information We Collect from Third Parties
      

      Reservations and Bookings – We may collect information about your reservations and bookings from third-party bookings providers (e.g. TripAdvisor, Expedia). Please note that these third-party bookings providers have their own privacy policies with respect to your information.

      Reviews – We may collect publicly-available information about your reviews and feedback concerning your guest stay and our services.

3. How We Use Your Information

   We use your information for business and commercial purposes, including to provide the hospitality services and products you request, to perform customer service functions, for security and fraud prevention, for marketing and promotional purposes, and to perform website analytics.

   We may use the information we collect about you in a variety of ways, including to:

   1. To Provide Our Services. We process certain personal information when you access or use our services, including to:
      • process your hotel bookings and guest requests
      • process your purchases of, or requests for, products and services;
      • register and verify user accounts;
      • facilitate the functionality of our websites, including payment-related functionality; and,
      • customize experiences and personalization when you are in and around our hotels.
   2. To Communicate With You. We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:
      • communicate with you about your bookies, stay, orders, purchases, returns, services, accounts, programs, contests, and sweepstakes;
      • respond to your customer service inquiries and requests for information;
      • send you personalized promotions, content, and special offers;
      • communicate with you about our brands, products, events, or other promotional purposes; and,
      • provide important guest and product safety information.
   3. For Research, Development, and Improvement of Our Services. We want to ensure that our website and services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain personal information, including to:
      • maintain, improve, and analyze our websites, ads, and the products and services we offer; and,
      • detect, prevent, or investigate suspicious activity or fraud.
   4. To Enforce our Terms, Agreements, or Policies. To maintain a safe, secure, and trusted environment for you when you use our hospitality services and websites, we use your personal information to ensure our terms, policies, and agreements with you and any third parties are enforced.
   5. To Comply with Applicable Laws. We may be required to process certain personal information under certain laws and regulations, such as tax laws, as well as to:
      • maintain appropriate records for internal administrative purposes; and,
      • comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.
   6. With Your Consent. We may process certain personal information in order to fulfill any other business or commercial purposes at your direction or with your consent.
4. How We Share Your Information

   We share your information as needed to fulfill the purposes described in this Privacy Policy and as permitted by applicable law. This includes sharing with service providers to help perform business functions at our direction, sharing with your consent, sharing for marketing purposes, sharing as part of corporate transactions, and sharing to protect lawful interests. We may share your information in the following circumstances:

   1. When We Work with Service Providers. We may share your information with service providers that provide us with support services, such as credit card processing, guest and room management, website hosting, email delivery, product and service delivery, or marketing and analytics services. We strive to contractually prohibit these service providers from retaining, using, or disclosing your confidential personal information for any purpose other than performing agreed upon services for us.
   2. When We Work on Business Transactions. If we become involved with a merger, corporate transaction or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
   3. When Sharing Is Necessary to Protect Safety and Lawful Interests. We may disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
   4. When We Work with Marketing Service Providers. We may share your information with marketing service providers to assess, develop and provide you with promotions and special offers that may interest you, administer contests, sweepstakes and events or for other promotional purposes.
   5. When You Give Consent. We may share information about you with other companies if you give us permission or direct us to share the information.
   6. When the Information Does Not Identify You. We may share your information in a way that does not directly identify you. For example, we may share information about your use of our websites and services in a manner that does not identify you, or we may combine information about the nature or frequency of your visits or purchases with similar information about other people and share the aggregated information for statistical analysis and other business purposes.
   7. When You Post on Our Websites or Social Media Pages. If you post information on a blog, social media page, or another part of our websites, the information that you post may be seen by other visitors to our websites, including your username.
5. Cookies, Web Beacons and Similar Technologies

   To make our Sites and services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another. To learn more, please see our Cookie Policy

   Google Analytics. We use Google Analytics. We use the information we get from Google Analytics only to improve the Sites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

   You may wish to restrict the use of cookies. Please be aware that some of the features of our website may not function correctly if you disable cookies.

   Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

   • Cookie settings in Chrome
   • Cookie settings in Firefox
   • Cookie settings in Internet Explorer
   • Cookie settings in Safari web and iOS

   Google Ads/Facebook Pixel. We also use Google Ads and Facebook Pixel to deliver tailored advertising on our Sites and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

6. Your Choices

   You have control over your promotional communications preferences, cookie settings, and more.

   Promotional Communication Choices

   We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Us” section below. You will continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

   Privacy Rights

   Ayres Hotels believes in putting you in control of your personal information. Upon request we will provide you with information about whether we hold any of your personal information and how it is used. You may access, correct, or remove your personal information by contacting us as described in the “Contact Us” section below. As required by law for taxes and other record keeping purposes, we are unable to completely delete an account from our internal records.

   "Do Not Track" Technology

   Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

7. How We Protect Your Information

   We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of personal information obtained through the websites, we cannot ensure or warrant the security of any information you transmit to us. You are responsible for protecting your password(s) and maintaining the security of your devices.

8. Retention and Disposal of Your Information

   Ayres Hotels stores personal information as needed to accomplish the purposes identified in this Privacy Policy and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. Our retention of your personal information is governed by applicable law. When the information is no longer necessary for any of these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. This storage period may extend beyond the term of your relationship with Ayres Hotels.

9. Children’s Privacy

   Our websites are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact details provided in the “Contact Us” section below. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.

10. Additional Disclosures for California Residents

    We have listed the privacy rights for several U.S. state jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.

    Categories of Personal Information

    In the preceding twelve months we may have disclosed these categories of personal information for a business purpose:

    • Identifiers:
      • Sources of Information – We collect identifiers from the information you voluntarily provide to us; and from the information we automatically collect, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We collect identifiers to provide our services; to communicate with you; for development and services improvement; and to comply with applicable laws, and as otherwise outlined in this Privacy Policy.
      • How we share it – We share identifiers with our service providers; to protect lawful interests; and for any other purpose with your consent, as otherwise outlined in this Privacy Policy.
    • Personal information under California Civil Code section 1798.80:
      • Sources of Information – We collect Section 1798.80 information from the information you voluntarily provide to us; and from the information we automatically collect, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We collect Section 1798.80 information for the purposes outlined in this Privacy Policy.
      • How we share it – We share identifiers with our service providers; to protect lawful interests; and for any other purpose with your consent, as otherwise outlined in this Privacy Policy above.
    • Commercial information:
      • Sources of Information – We collect commercial information from the information you voluntarily provide to us; and from the information we automatically collect, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We collect commercial information to provide our services; to communicate with you; for development and services improvement; to comply with applicable laws, and as otherwise outlined in this Privacy Policy.
      • How we share it – We share commercial information with our service providers and Ayres Hotels affiliates, as outlined in this Privacy Policy.
    • Electronic network activity information:
      • Sources of Information – We collect network information through the information you voluntarily provide to us; and from the information we automatically collect, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We collect network information to provide our services; to communicate with you; for development and services improvement; and to comply with applicable laws, and as otherwise outlined in this Privacy Policy.
      • How we share it – We share network information with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in this Privacy Policy.
    • Visual information:
      • Sources of Information – We may automatically collect visual information such as CCTV information, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We collect visual information to enforce our terms, agreements, or policies; and with your consent, as otherwise outlined in this Privacy Policy.
      • How we share it – We share visual information to protect lawful interests, as outlined in this Privacy Policy.
    • Inferences:
      • Sources of Information – We develop inference data through the information you voluntarily provide to us; and from the information we automatically collect, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We develop inference data to provide our services; to communicate with you; for development and services improvement; and as otherwise outlined in this Privacy Policy.
      • How we share it – We share inference data with our service providers and to protect lawful interests, as outlined in this Privacy Policy.
    Sensitive Categories of Personal Information
    • Financial account data:
      • Sources of Information – We collect financial account information from the information you voluntarily provide to us, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We collect financial information to provide our services; and as otherwise outlined in this Privacy Policy.
      • How we share it – We share financial account information with our payment service providers, as outlined in this Privacy Policy.
    • Account log-in data:
      • Sources of Information – We collect account log-in information from the information you voluntarily provide to us; and from the information we automatically collect, as outlined in this Privacy Policy.
      • Purpose of Information Collected – We collect account log-in information to provide our services; to communicate with you; for development and services improvement; and to comply with applicable laws, and as otherwise outlined in this Privacy Policy.
      • How we share it – We share account log-in information with our service providers and to protect lawful interests, as outlined in this Privacy Policy.

    How We Sell Your Information – In the preceding twelve months we have not sold personal information. We do not sell personal information, but we recognize that some state privacy laws define “personal information” in such a way that some sharing of personal information necessary to provide you with personalized ads may be considered a “sale,” even if no money is exchanged. You may learn more about how to opt out of such personalized ads through our Cookie Policy.

    Your Rights

    Access to Specific Information and Data Portability Rights – Subject to certain exceptions, you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:

    • The categories of personal information we have collected about you;
    • The categories of sources for the personal information we have collected about you;
    • Our business or commercial purpose for the information collection;
    • The categories of third parties with whom we share that personal information;
    • The specific pieces of personal information we collected about you.

    Deletion Request Rights – You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

    Opting Out – As described in “How We Sell Your Information” above, residents of certain states have the right to opt-out of having their personal information sold.

    Non-Discrimination – Residents of certain states may not receive discriminatory treatment by the business for exercising your privacy rights.

    Exercising Access, Data Portability, and Deletion Rights – To exercise the access, data portability, and deletion rights described above as a California resident, please submit a verifiable consumer request to us by either calling us at 888-342-9737; or by contacting us at ccpa@ayreshotels.com. Please note that to verify your request, we may require you to verify personal information that we already have on file for you or to provide additional information.

    Use of an Authorized Agent to Submit a Request – Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

11. Additional Disclosures for Data Subjects in the EEA and the U.K.

    Residents in the European Economic Area and the United Kingdom (together, for purposes of this section of the Privacy Policy, “EEA”), as well as certain other jurisdictions, are entitled to certain rights and disclosures with respect to their personal information.

    This section provides general information about how Ayres Hotels collects, stores, uses, transfers, and otherwise processes personal data in or from certain countries in the EEA, in accordance with the General Data Protection Regulation (GDPR) and its local implementations. This section does not supersede the applicability of any privacy policy found on the website of an EEA-based Ayres Hotels affiliate with whom you have engaged, as that entity would be the data controller with respect to your personal data and the entity to which your data subject rights requests should be directed.

    Lawful Bases of Processing – Where an Ayres Hotels entity is acting as a data controller that determines the purposes and means of processing your personal data, such as when we collect, use, and share personal data as described in the “Information We Collect,” “How We Use Your Information,” and “How We Share Your Information” sections above, we must have a lawful basis for processing or doing so. Our lawful bases for processing personal data include:

    • to conclude or perform a contract with you, for example to:
      • process your hotel reservation and purchases of or requests for products and services;
      • communicate with you about reservations, orders, purchases, returns, services, accounts, programs, contests, and sweepstakes;
    • for our legitimate business purposes, including to:
      • respond to your customer service inquiries and requests for information;
      • maintain, improve, and analyze our websites, ads, and the products and services we offer;
      • detect, prevent, or investigate security breaches or fraud; and
      • facilitate the functionality of our websites;
    • to comply with our legal obligations, for example to maintain appropriate records for internal administrative purposes and as required by applicable law, and provide important product safety information and notice of product recalls; and
    • on the basis of your consent, for example to send you via email and other electronic means personalized promotions and special offers or informing you about our brands, products, events, or other promotional purposes.
    You can withdraw your consent at any time by contacting us as described in the “Contact Us” section below.

    Your Data Subject Rights – In some countries, and in particular if you are located in the EEA, you may have the right to:

    • Access your personal information;
    • Correct inaccurate personal information;
    • Request erasure of your personal information without undue delay;
    • Request the restricted processing of your personal information;
    • Request portability of the personal information that you have given us; and
    • To object to the processing of your personal information.
    To exercise any of these rights, please contact us as set forth in the “Contact Us” section below and specify which privacy right(s) you wish to exercise. We must verify your identity in order to honor your request, which we will respond to within 30 days of receipt.

    Retention – As described in the “Retention and Disposal of Your Information” section above, as a general rule, we retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period.

    Transfers Outside the EEA – Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including the United States. It may also be processed by staff operating outside the EEA who work for Ayres Hotels or for our third-party service providers. This may entail a transfer of your personal information across international borders. The data protections standards may differ and be lower than the standards enforced in your jurisdiction.

    Complaints – If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the “Contact Us” section below.

12. Contact Us

    If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details: 888-342-9737, 714-540-6060 or ccpa@ayreshotels.com