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Privacy Policy

Banyan Tree Management, LLC, doing business as Aperture Hotels (hereinafter “Aperture Hotels”), is a third-party hotel manager that oversees the operations of hotel properties on behalf the owners of those hotel properties.
At Aperture Hotels, we hold user privacy and data protection as paramount responsibilities. Safeguarding personal data is not merely a choice but an obligation we willingly uphold.  We believe that data, while valuable, should be collected and processed only when absolutely necessary, ensuring the utmost respect for individual privacy.
As a distinguished hospitality company committed to safeguarding your privacy and ensuring the protection of your personal information, we want you to be familiar with how we collect, use and disclose data.  
This privacy policy outlines our practices concerning the collection, usage, and protection of your data (the “Privacy Policy”), so we encourage you to read this document carefully to understand how we handle your information.  

PRIVACY PRACTICES  

This Privacy Policy describes the privacy practices of Aperture Hotels for data that we collect:
  • When you access websites operated by us from which you are viewing this Privacy Policy, including www.aperturehotels.com and other websites owned or controlled by Aperture Hotels on behalf of itself or its owners (collectively, the “Websites”)
  • When you access social media pages that we control on behalf of ourselves or our owners from which you are viewing this Privacy Policy (collectively, “Social Media Pages”)
  • Via HTML-formatted email messages that we send you that link to this Privacy Policy and through your communications with us.
Collectively, we refer to the Websites and Social Media Pages as the “Services.”  By using the Services, you agree to the terms and conditions of this Privacy Policy.

RELEVANT LEGISLATION

Along with our business practices, this website is designed to comply with the following international and national legislation regarding data protection and user privacy:
  • EU General Data Protection Regulation 2018 (GDPR)
  • California Consumer Privacy Act 2018 (CCPA)

WHAT INFORMATION WE COLLECT AND WHY

Here we describe what information is collected and the reasons for collecting it. The categories of information collected are as follows:
Site Visit Trackers
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to track their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer's IP address, which could be used to personally identify you, but Google does not grant us access to this. We consider Google to be a third-party data processor (see section below on Disclosure of Data).
GA makes use of cookies, details of which can be found on Google's developer guides. Our website uses the analytics.js implementation of GA. Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
In addition to Google Analytics, this website may collect information (held in the public domain) attributed to the IP address of the computer or device that is being used to access it.
Reviews And Comments
Should you choose to add a comment or review on our site (if such option is available), the name and email address you enter with your comment will be saved to this website's database, along with your computer's IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third-party data processors detailed below. Only your name and email address that you supplied will be shown on the public-facing website.
Your comments and the associated personal data will remain on this site until we see fit to either remove the comment or remove the blog post.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.
Forms And Email Newsletter Submissions On The Website
If you choose to subscribe to our email newsletter or submit a form on our website, the email address that you submit to us will be forwarded to a third-party marketing platform service company. Your email address will remain within their database for as long as we continue to use the third-party marketing company’s services for the sole purpose of email marketing or until you specifically request removal from the list.
You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
Personal Information
Listed below are the pieces of information (“Personal Data”) that we may collect as part of servicing requests on our website:
  • Name
  • Gender
  • Email ID
  • Phone
  • Mobile
  • Address
  • City
  • State
  • Postal Code
  • Country
  • IP Address
Email Links
We only receive an email when a user mails us using an email link. There are no third-party data processors or intermediaries involved.  The data is collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted before being sent across the internet. The email content is then decrypted by our local computers and devices.

DISCLOSURE OF PERSONAL DATA AND OTHER DATA

We do not sell your personal information to third parties. We may, however, share a limited amount of data with listed third-party data processors, such as Google, but only towards servicing your requests or improving our offering.  Furthermore, in order to provide you with the highest level of hospitality, we may also share Personal Data with the following:
  • Aperture Hotels. We disclose Personal Data to other companies within Aperture Hotels for the purposes described in this Privacy Policy, such as providing and personalizing the Services, communicating with you, and to accomplish our business purposes.
  • Owners and Franchisors. We may disclose Personal Data to Owners and Franchisors of Aperture Hotels for the purposes described in this Privacy Policy, such as providing and personalizing the Services and facilitating the loyalty programs of such Owners and/or Franchisors.
  • Strategic Business Partners. We may disclose Personal Data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you.
  • Service Providers.  We may disclose Personal Data to third-party service providers for the purposes described in this Privacy Policy. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.
  • Corporate Reorganization. We may disclose or transfer your Personal Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Aperture Hotels’ business, assets or stock (including any bankruptcy or similar proceedings).

NON-APERTURE HOTELS ENTITIES

This Privacy Policy does not address, and we are not responsible for the privacy, data or other practices of any entities outside of Aperture Hotels, including Franchisors, Owners, Strategic Business Partners or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.
In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through our Social Media Pages.

OTHER USES AND DISCLOSURES

We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of Aperture Hotels, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

 COOKIE POLICY

This section describes our use of cookies and other technologies. The types of cookies we use fall into three categories:

  1. Essential Cookies and Similar Technologies

    • These are vital for the running of our services on our websites. Without the use of these cookies parts of our websites would not function. For example, session cookies allows a navigation experience that is consistent and optimal to user's network speed and choice of device.

  2. Analytics Cookies and Similar Technologies

    • These collect information about your use of our websites and apps and enable us to improve the way it works. For example, analytics cookies show us which are the most frequently visited pages. They also help identify any difficulties you have accessing our services, so we can fix any problems. Additionally, these cookies allow us to see overall patterns of usage at an aggregated level.

  3. Tracking, Advertising Cookies and Similar Technologies

    • We use these types of technologies to provide advertisements that are more relevant to your interests. This can be done by delivering online adverts based on your previous web browsing activity. Cookies are placed on your browser which will store details of websites you have visited. Advertising based on what you have been looking at is then displayed to you when you visit websites that use the same advertising networks.
    • We may also use cookies and similar technologies to provide you with advertisements based on your location, offers you click on, and other similar interactions with our websites.

“DO NOT SELL MY DATA” OPTION – WHY WE DON’T HAVE IT

We do not sell personal information of our customers or of minors below the age of 16 years to third-party data collectors and hence the “Do not sell my data” opt-out button is optional on our website.  As disclosed elsewhere in this Privacy Policy, however, we may collect your data for the sole purpose of completing a service request or for marketing communications. If you wish to access or erase your personal information, see the section below on “How You Can Access, Change Or Suppress Your Personal Data.”

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. We will report any unlawful data breach of this website's database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below.

IMPORTANT NOTICE FOR MINORS SHARING PERSONAL INFORMATION

If you are under 16 years of age you MUST obtain parental consent before:
  • Submitting a form
  • Posting a comment on our blog or website
  • Subscribing to any offer we may include on our website or social media pages
  • Subscribing to our email newsletter

CHOICES, ACCESS AND RETENTION

You have choices when it comes to how we use your Personal Data and we want to ensure you have the information to make the choices that are right for you.
If you no longer want to receive marketing-related emails, you may opt out by visiting https://explore.aperturehotels.com/hs/manage-preferences/unsubscribe or by writing an email to info@aperturehotels.com or by following the instructions in any such email you receive from us.
We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out.
Special Notice for California Residents: Customers who reside in California and have provided their Personal Data to us can request, once per calendar year, information about our sharing of certain categories of Personal Data to third parties and within Aperture Hotels for their direct marketing purposes.  Such requests should be submitted to us at info@aperturehotels.com or in writing at:
Aperture Hotels  
c/o Banyan Tree Management, LLC
3344 Peachtree Rd NE Suite 800  
Atlanta, GA 30326  
ATTN: Chief Technology Officer
We will provide a list of the categories of Personal Data disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA

If you would like to review, correct, update, suppress, restrict or delete Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us at info@aperturehotels.com so or by mail:
Aperture Hotels  
c/o Banyan Tree Management, LLC
3344 Peachtree Rd NE Suite 800  
Atlanta, GA 30326  
ATTN: Chief Technology Officer
In your request, please make clear what Personal Data you would like to have changed, whether you would like to have your Personal Data suppressed from our database, or other limitations you would like to put on our use of your Personal Data. For your protection, we only fulfill requests for the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or reservation, or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase, reservation, or promotion).  There may also be residual data that will remain within our databases and other records, which will not be removed.  In addition, there may be certain data that we may not allow you to review for legal, security or other reasons.

RETENTION

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
The criteria used to determine our retention periods include:
  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation, etc.)

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may change from time to time to conform with legislation and/or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes.  

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at info@aperturehotels.com, or by mail:
Aperture Hotels
c/o Banyan Tree Management, LLC
3344 Peachtree Rd NE Suite 800
Atlanta, GA 30326  
ATTN: Chief Technology Officer