Privacy Policy

This Privacy Policy governs the manner in which CHRC, LLC (“CHRC,” “we,” “us,” or “our”) collects, uses, and shares personal information when you use our website at www.curatorhotelsandresorts.com (the “Site”), including all content, information, and functionality availability through the Site, as well as our related products and service (collectively referred to as the “Services”). We are committed to protecting your privacy and hope that this Privacy Policy helps you make an informed decision about sharing personal information with us.

Your Acceptance of These Terms

By using our Site, you agree to the terms of this Privacy Policy, as we may amend them from time to time in our sole discretion by posting an updated Privacy Policy on our Site. By providing information to us, you understand and consent to the collection, maintenance, processing, and transfer of such information in and to the United States and other countries and territories, in accordance with United States law.

In order to visit our Site, and to provide our Services, we may need to collect and process some Personal Information. “Personal Information” is information that is reasonably capable of identifying you, and we have provided specific examples of the Personal Information we may have collected about you below. Personal Information does not include de-identified or aggregated information, which is information in which identifiable information is removed and that cannot reasonably be used to identify an individual. We may use and share de-identified or aggregated information for any purpose.

Categories of Personal Information we Collect

Identifiers, such as name, telephone number, email address, or other similar identifiers.
Internet or other similar network activity, including browsing history, search history, links, and information regarding your interaction with an internet website, application, or advertisement. This information may be collected notwithstanding the use of do-not-track browser signals or settings. Our Site utilizes cookies, which are pieces of information that a website transfers to your computer’s hard drive for record-keeping purposes. More information about our use of cookies can be found at our Cookie Policy.
Commercial information, such as information relating to your purchases and services, and purchasing or consuming histories, tendencies or interests.
Geolocation data is gathered when users interact with our Sites as IP addresses are obtained during such interaction, and IP addresses provide information about users’ approximate location.
Inferences drawn from other personal information, such as profiles reflecting your preferences, characteristics, predispositions, or behavior.

Categories of Sources for Personal Information We Have Collected:

We have collected Personal Information from:

users of the Site through their direct interactions with the Site, including user content and log data.
affiliated legal entities.
Hotels that are members of our network,
service providers and third parties who assist us to provide the features or advertisements on our Site, including Flip.to.

Our Business or Commercial Purposes for Collecting Personal Information and Categories of Third Parties to Whom the Information was Disclosed:

Identifiers are collected to market to individuals, to improve the quality, safety, customization, and security of the Site, and to respond to direct inquiries. We may share identifiers with affiliated companies, service providers that assist us to provide users with the Site and Services, advertising networks, and data analytics providers. We additionally may share identifier with member hotels to assist with joint marketing and other marketing efforts. We additionally may share identifiers with marketing partners, including for targeted marketing.
Internet or other similar network activity is collected to market to individuals, to improve the quality, safety, customization, and security of the Site, to detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity. We may share internet or other similar network activity with affiliated companies, service providers that assist us to provide users with the Site and Services, data analytics providers, and advertising service providers to serve relevant advertisements and obtain analytics information concerning our advertising. These third parties may use technologies, including cookies, web beacons, and other technologies to collection information about your use of our services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information. We additionally may share identifier with member hotels to assist with joint marketing and other marketing efforts. We additionally may share identifiers with marketing partners, including for targeted marketing.
Commercial information is collected to market to individuals, to improve the quality, safety, customization, and security of the Site, and to respond to direct inquiries. We may share identifiers with affiliated companies, service providers that assist us to provide users with the Site and Services, advertising networks, and data analytics providers. We additionally may share identifier with member hotels to assist with joint marketing and other marketing efforts. We additionally may share identifiers with marketing partners, including for targeted marketing.
Geolocation data is collected to market to individuals, to improve the quality, safety, customization, and security of the Site and Services, to detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity. We may share geolocation information with affiliated companies, service providers that assist us to provide users with the Site, data analytics providers, and advertising service providers to serve relevant advertisements and obtain analytics information concerning our advertising. We additionally may share identifier with member hotels to assist with joint marketing and other marketing efforts. We additionally may share identifiers with marketing partners, including for targeted marketing.
Financial information is collected to provide you our Services. We may share financial information with our service providers or with member hotels to provide you with our Services.
Inferences are collected to market to individuals, to improve the quality, safety, customization, and security of the Site, and to respond to direct inquiries. We may share identifiers with affiliated companies, service providers that assist us to provide users with the Site and Services, advertising networks, and data analytics providers. We additionally may share identifier with member hotels to assist with joint marketing and other marketing efforts. We additionally may share identifiers with marketing partners, including for targeted marketing.

In addition, where consistent with applicable laws and regulations, we may disclose Personal Information in all categories above:

to prepare, negotiate, or perform a contract with you;
to respond to subpoenas, court orders, or other legal process otherwise required by law or the competent government or judicial authorities;
to establish or preserve a legal claim or defense;
in connection with a sale, merger, or consolidation of our business or other transfer of our assets, whether voluntary or by operation of law, or with an entity who is otherwise deemed to be our successor or transferee; or
to prevent fraud or other illegal activities, such as willful attacks on our information technology systems.

We engage in personalized or targeted advertising. In connection with such advertising, we may share or sell the following categories of information with advertising networks and providers, analytics providers and social media networks: device information and identifiers, such as unique advertising identifiers, cookies and IP address; usage information, such as browsing history; location history, such as city; and inference data.

We have no actual knowledge of selling or sharing personal information of minors under 16 years of age to non-affiliated third parties without affirmative consent.

We do not use or disclose sensitive personal information, as defined by the California Consumer Privacy Act, for purposes other than those specified in Section 7027 of the California Consumer Privacy Act regulations.

EU and UK Data Subjects

The EU’s General Data Protection Regulation and the UK Data Protection Act and UK General Data Protection Regulation provide EU and UK data subjects with the additional rights described below.

Use of Personal Data

We generally act as a data controller of EU and UK data subject’s Personal Information submitted to us. We rely on that Personal Data for the legitimate commercial purposes of providing our Services. Where we need to collect Personal Data by law or under the terms of a contract we have with you, and you fail to provide that Personal Information when requested, we may not be able to provide you with our Services. We consider and balance any potential impact on you and your rights before we process your Personal Data. We do not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted to by law. In certain circumstances, we act as a data processor, and, in those circumstances, we process your Personal Information for the purposes set out in this Policy consistent with the data processing terms of those partners. If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time by contacting us at the information below. We will only use your Personal Information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you are located in the EU or UK and have any complaints regarding our privacy practices as a data controller, you have the right to make a complaint at any time to your local Supervisory Authority. However, we would appreciate the chance to address your concerns before you approach your Supervisory Authority, so please contact us first at the information below.

Data Subject Requests

If you would like to request a copy of your Personal Data being held by us, or request that data be deleted, corrected or transferred to another data controller, please follow the process detailed in the “Your Rights and Choices” section below. Please note that there are certain exemptions and restrictions of these rights under the data privacy laws that enable personal data to be retained, processed or withheld from access, and we will inform you of these exemptions and restrictions, if applicable.

International Data Transfers

We offer EU and UK Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the European Union and the United Kingdom, and make transfers of Personal Information from those jurisdictions to the United States and other countries that lack adequacy determinations. Please contact us as detailed in the “Contact Us” section below for more information.

Data Security

The security of your Personal Information is important to us. We employ reasonable organizational, technical, and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Information.

Data Relating to Children Under 13

Our Site is not directed at, and we do not knowingly collect Personal Information from, anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

Third Party Links and Websites

Our Site may contain links to other websites to allow you to book hotel visits or utilize other features. If you use these links to leave our Site, please note that we do not have control over that website, and that website’s privacy practices are not governed by this Privacy Policy. You should exercise caution and review the privacy statement applicable to such websites to learn more.

Your Rights and Choices

Your choices regarding our use and disclosure of Personal Information

We give you certain choices regarding our use and disclosure of your Personal Information for promotional purposes. You may opt-out from receiving electronic communications from us by contacting us at privacy@curatorhotelsandresorts.com . If you no longer want to receive promotional-related emails from us, you may opt-out according to instructions in such communications. Please note that if you opt-out of receiving marketing-related messages, we may still send you important administrative messages.

Access, change or deletion of Personal Information

If you are a California resident, California law also provides you with the following rights with respect to your personal information:

The right to know what personal information we have collected, used, disclosed and sold about you. To submit a request to know, you may email us at privacy@curatorhotelsandresorts.com.
The right to request that we delete any personal information we have collected about you. To submit a request for deletion, you may email us at privacy@curatorhotelsandresorts.com.
The right to request that we correct inaccurate personal information that we maintain about you. To submit a request for correction, you may email us at privacy@curatorhotelsandresorts.com.
The right to opt-out of the sale or sharing of your personal information by emailing us at privacy@curatorhotelsandresorts.com. You also may designate an authorized agent to make a request to opt-out of the sale or sharing of your personal information on your behalf. Please see above for the categories of personal information we have sold or shared about you for targeted advertising purposes.

When you exercise these rights and submit a request to us, we will verify your identity, which may include asking you to log in to your account if you have one with us. If you do not have an account with us, we may ask for your email address, order numbers of previous orders of our products and services, the last four digits of a credit or debit card or a bank account number used to make a purchase, the date of your last purchase from us, or other information that we believe you will know that will allow us to verify that the request is coming from the person named in the request. You may designate an authorized agent to submit your request on your behalf. Your authorized agent will need to provide documentation supporting the agent’s authority to make the request on your behalf. We may also require you to verify your identity directly with us and confirm the request before we will process it.

We will not discriminate against you for exercising any of the privacy rights above. Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

To the extent required by law, we will take steps to act on browser preference signals aimed at opting out of the “sale” or “sharing” of your Personal Information for targeted advertising purposes. Please note that where you have made a choice to accept sharing for cross contextual behavioral advertising when you first enter our Website, we will abide by that consent over the more general preference signal of your browser settings.

Changes to this Policy

Please note that this Privacy Policy may change from time to time. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. We recommend that users of our Services periodically review the most up-to-date version of the Privacy Policy available at the Site. If you have any additional questions or concerns about the Privacy Policy, please contact us at: info@curatorhotelsandresorts.com

Updated: September 2023