LAST UPDATED: January 17, 2012
This Policy does not address the collection, use or disclosure of information by third parties, which shall include entities granted a sub-license, directly by BWI or by an authorized licensee of BWI, to operate BWI hotels and properties ("Licensed Hotels") and third-party affiliated organizations which are entities permitted to sublicense Licensed Hotels outside the United States in various countries/territories throughout the world ("Affiliate Organizations"). Please be aware that Licensed Hotels and Affiliate Organizations are independent entities neither owned nor controlled by BWI or BWI Subsidiaries. In fact, Licensed Hotels and Affiliate Organizations may have their own privacy policies, which may be different from ours. To learn about the privacy practices of any of the Licensed Hotels or Affiliate Organizations, you should review their privacy policies, not this Policy.
By providing Personally Identifiable Information to BWI, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not provide any Personally Identifiable Information to BWI through our Site or otherwise. We reserve the right to change this Policy without prior notice. You can determine when this Policy was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect.
BWI complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. BWI has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view BWI's certification, please visit http://www.export.gov/safeharbor.
BWI gathers three basic types of information from you: "Personally Identifiable Information" (or "PII"), "Non-Personally Identifiable Information" (or "Non-PII") and "IP Addresses". Personally Identifiable Information is information that identifies you as an individual. Non-Personally Identifiable Information is aggregated information, demographic information and any other information that does not reveal your specific identity. An IP Address is the Internet Protocol address of the computer that you are using to access our Site.
We may collect PII, such as your name, postal address, telephone number, e-mail address, credit card number or other payment account number through the Site, through reservation and call centers, from BWI Subsidiaries, Licensed Hotels, Affiliate Organizations or other third parties, or when you otherwise voluntarily provide it to us, including in connection with our various programs such as Rewards ("BWR"). We may also combine that PII with publicly available PII and PII we receive from others or cross-reference with others. We use that combined PII for the purposes described in this Policy. If you voluntarily share with us "Sensitive Information", for example, information related to your health or your affiliation with a particular group, that information may be stored in your reservation record for the sole purpose of serving you better and meeting your particular needs. For example, if you voluntarily convey a health-related need to us, we may store and use that information to provide a room with appropriate amenities. We do not collect or store Sensitive Information unless it is voluntarily provided by you.
BWI collects PII about our guests and visitors to the Site so that we can provide an experience that is responsive to our guests' and visitors' needs. BWI may use collected PII:
Because Non-PII does not personally identify you, we may use, and share with BWI Subsidiaries, Licensed Hotels, Affiliate Organizations and other third parties, Non-PII for any purpose, including to facilitate your ongoing access to and use of our Site, to best tailor our services to suit personal interests and/or to analyze visiting patterns. We and our service providers may collect Non-PII from sources such as environmental variables, including computer type (Windows or Macintosh), screen resolution, OS version, Internet browser and Internet browser version.
We may also collect Non-PII from sources such as "cookies" and so-called "pixel tags," "web beacons," "clear GIFs" and other similar technologies, and may engage third party tracking and advertising providers to act on BWI's behalf to track and analyze your usage of our Sites through the use of such technologies. These third parties collect and share with us, as we may request, Site usage information about visits to our Sites, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through our Sites, help us target and track use of our Internet banner advertisements on our Sites and on other sites, and track use of other links from our marketing partners' sites to our Sites.
In instances where Non-PII is combined with PII (such as combining your name with your geographical location) the combined information will be treated by us as PII.
Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever users visit the Site, along with the time(s) of such visit(s) and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems and administering the Site. Please note that we treat IP Addresses, server log files and related information as Non-PII, except when we are required to do otherwise under applicable law.
BWI believes that we have implemented security measures that provide reasonable precautions against the unauthorized access, disclosure, alteration or destruction of PII. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us credit card information or Sensitive Information through e-mail or any undesignated area (such as, for example, submission of your credit card number in a "comment" field). If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting our Customer Care Department as set forth below in this Policy (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
If you change your mind, and no longer wish to receive marketing-related e-mails from us and the BWI Subsidiaries on a go-forward basis, or if you would prefer that we do not share your PII on a go-forward basis with Licensed Hotels, Affiliate Organizations and/or with other third parties (other than BWI service providers), you may opt-out of receiving such marketing-related e-mails or from such sharing by contacting our Customer Care Department as set forth below in this Policy.
Please keep in mind that if BWI cannot disclose your PII to Licensed Hotels and/or Affiliate Organizations, we may be unable to provide you with all or certain reservation services, other services or membership-program-related benefits. Similarly, if BWI cannot disclose your PII to other third parties, such as BW R company partners (e.g., airlines), then we may not be able to provide all of the available membership program services to you (e.g., earning of frequent customer points with such companies) or such services may not be delivered as quickly or not at all.
We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your PII from the databases of Licensed Hotels, Affiliate Organizations or other third parties with which we have already shared your PII.
We take reasonable steps to ensure that the PII we use is accurate, complete and current to the extent necessary for the purposes for which we use the PII. We make a good faith effort to allow you the right to access and request that erroneous or inaccurate PII that is held by us be rectified. BWI may allow you to review certain PII through the Site or through other online means. Information about the availability of online means for reviewing your PII is generally available at the Site or on the printed materials where such type of PII was first submitted. You may also review your PII by contacting us through the Customer Care Department, as noted below. BWI will make all corrections and/or deletions of erroneous PII brought to its attention within a reasonable time period and as required by applicable data privacy regulations. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. Finally, we are not responsible for removing or suppressing information from the databases of Licensed Hotels, Affiliate Organizations and other third parties with whom we have already shared your PII, or for limiting their use of your PII.
BWI only collects the personal information that it believes is necessary to perform the services that you seek from BWI and to comply with its obligations as otherwise outline in this Policy. We will keep your PII only as long as we need it for the purposes for which we collected it, or as permitted by law.
The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide PII through the Site.
BWI does not represent or warrant that the Site or any part thereof is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. By submitting any PII to us, you consent to the transfer of PII to other countries, which may provide a different level of data security than in your country of residence. In addition, if we need to transfer any PII to Licensed Hotels, Affiliate Organizations and/or other third parties pursuant to this Policy please be advised that such entities may or may not be located in countries that are considered "adequate" pursuant to the EU Data Protection Directive or other laws. For individuals who are located in the EEA, you should be aware that because we comply with the Safe Harbor Principles, our transfers of PII from the EEA to the United States meet the adequacy requirements of the EU Data Protection Directive.
If you feel that BWI has mishandled your PII in violation of Safe Harbor requirements, you should contact BWI through its Customer Care Department with a written description of your complaint. After receiving such written description, a representative from BWI's Customer Care Department will contact you to set up a time and manner to discuss your complaint. BWI is interested in addressing all legitimate complaints about its adherence to this Policy and the principles of Safe Harbor and will make a good faith effort to engage in communications to address any complaints. BWI has further committed to refer unresolved privacy complaints under the US-EU [and EU-Swiss] Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by BWI, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Customer Care Department
P.O. Box 10203
Phoenix, AZ 85064
Attn: Customer Care
Please note that e-mail communications will not necessarily be secure; accordingly, you should not include credit card information or Sensitive Information in your e-mail correspondence to us.
1 As of December 1, 2008, BWI Subsidiaries consist of the following entities: B-W Advertising Agency, Inc., B-W Financial Services, Inc., BW GCCI, Inc., B-W Insurance Agency, Inc., B-W International Licensing, Inc., BW Worldwide Reservations, Inc., BWI Latin America Service Co., BWI Latin America Reservations Co., BWI Asia, Inc. and BWI Denmark, Inc.