1. The Types of Personal Information We Collect And What We Do With It
As a hotel operator, it is necessary for Steele Mansion LLC to collect and store Personal Information in connection with the delivery of lodging and related services. Although we endeavor to collect only that information which is relevant, we also must comply with many laws that require hotel operators to collect and retain Personal Information.
Steele Mansion LLC collects Personal Information regarding its current, prospective and former guests, hotel property visitors, website visitors and other consumers (“Consumers”) travel and other business partners such as franchisees (“Business Partners”), and individuals who work for us including current, prospective and former employees, contractors and temporary and other seasonal workers (“Team Members”) based on the legal grounds and legitimate business purposes outlined in this Privacy Policy. The types of Personal Information we collect and our privacy practices depends on the nature of the relationship you have with Red Roof and the requirements of applicable law. Below are some of the ways we collect Personal Information and how we use it:
a. Information You Provide Directly: When Consumers, Business Partners and Team Members contact us directly through telephone or website, sign up for our news letter, or submit an application or other form, they may be asked to provide Personal Information such as name, email address and payment information like a credit or debit card number. We will use this information to respond to requests, manage our relationship with you, and /or communicate about our programs and our promotions.
b. Hotel Stay Information: During a hotel stay, we will have access to reservation information and may collect additional information to authenticate the reservation such as a driver’s license or passport ID, or other information to manage and enhance the guest experience including vehicle information, onsite purchases, internet, media and wireless service usage and other information to support safety and security or as required by law. We may collect other related information such as demographic information, travel agent information and information about preferences and interests (such as if you prefer a non-smoking room) and hotel-based activities (such as vehicle information, or use of hotel services). If we combine other information with Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.
c. Technology and Device Information: We may automatically collect information from when you use technology including IP address, mobile device ID, and similar device identifiers, and information about how you use these services. We use this information for a variety of purposes, including to provide wireless services to guests and enhancing or otherwise improving our website.
d. Applicant and Team Member Information: If you apply to be a Steele Mansion LLC employee or independent contractor we may ask you to provide self-identifying information (such as gender, and ethnicity and other background information). Steele Mansion LLC may use this information to determine your partnership or employment eligibility and share this information with government or regulatory agencies to fulfill reporting requirements or defend against related litigation and complaints.
e. Supplemental Information from Third-Parties: We may collect information about Consumers, Business Partners and Team Members from Third-Party sources to provide the services you request or to supplement information we received.
For example, we may receive information about you from Third-Parties, including without limitation employment service providers, airlines, travel agents and companies (for example, booking.com and expedia.com) and event planners. In addition, we may supplement the information we collect with outside records such as from your travel agent in order to provide you with information, services, or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may interest you, and for other purposes, including marketing demographics. We may combine the information we receive from those other sources with information we collect. In those cases, we will apply this Privacy Policy to the combined information.
f. Promotional Analytics and Similar Advertising Information: Steele Mansion LLC works with network advertisers, ad agencies, social media services, analytics service providers, and other vendors to advertise our services and provide us with information regarding the effectiveness of our advertisements. These service providers may set and access their own tracking technologies (including cookies and local storage) and may otherwise collect or have access to information about you which we may use to: target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share usage information about visitors with third-party advertising and social media companies, analytics providers, and other vendors for similar purposes.
2. What We Share With Others
We use a limited number of Third-Parties to help us respond to your requests and provide services such as processing payments, monitoring online activity at steelemansion.com (“Website”), communicating with you about your stay, conducting customer satisfaction surveys; maintaining our database, taking and processing employment and business partner applications, taking and processing orders and reservations, administering emails, and administering drawings or contests. Third-Parties also provide us with aggregate and comparative information on the performance of our Website.
Other than as described below, we will not sell, trade or rent Personal Information to non-affiliates of Steele Mansion LLC.
a. We may share your Personal Information with Third-Parties to offer goods and services or ask you to sign up for promotions, our affiliate or loyalty program or other programs that we believe may be of interest you. Our partners may also contact you to inquire about your experience as a guest in one of our hotels and the prospect of future stays or improvements needed to attract additional business. We and our partners may also create and use aggregate information that is not personally identifiable to understand more about the common traits and interests of our Customers and Business Partners. We will ask your permission to use your location to provide accurate maps or other information on your mobile device.
b. We may utilize one or more third-party service providers to send email or other communications to you on our behalf, including guest satisfaction surveys. These service providers are prohibited from sharing or using your email address or other contact information for any purpose other than to send communications on our behalf.
If you make a purchase on our Website, create or modify an account (including a credit card account) or sign up for our rewards program, your name, mailing address, phone number or purchase information may be made available to our co-brand partners who may provide you with information about their products or services or the products and services of their affiliates.
c. In the event Steele Mansion LLC goes through a business transition (such as a merger, acquisition by another company, bankruptcy or sale of all or a portion of its assets, including, without limitation, during the course of any due diligence process), your Personal Information will likely be among the assets transferred. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.
3. Communications of Special Offers and Promotions and Opting-Out
Email Promotions and Offers: It is our intention to send communications to you that would be useful and that you want to receive. When you provide us with your email address or mobile telephone number as part of the reservation or check-in process, you may receive informational and promotional communication. In addition, customers and visitors to our website and mobile services are given the opportunity to “opt-in” to receive promotional communications from us or to join other programs that enhance the points you earn when you stay with us.
Updating Your Preferences: You are responsible for maintaining and updating, your account registration data with current, accurate, and complete information, including your preferences. You may view, update, delete, and/or edit the registration data you have provided to Steele Mansion LLC by logging in to your account and following the appropriate instructions. Each time you receive a promotion, you will be provided the choice to “opt-out” of future promotions by following the instructions provided You may also contact customer service or Unsubscribe via email.
“Do Not Track”. 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. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Advertising Choices. We may use certain tools offered by Third-Parties that enable such Third-Parties to collect or receive information about actions users take on: (a) the Steele Mansion LLC Site and elsewhere on the internet through use of cookies, pixel tags and other storage technologies; or (b) a Steele Mansion LLC mobile application and other mobile applications, in order to provide interest-based advertising. Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes. You can opt out of the collection and use of your information for interest-based advertising by going to http://optout.aboutads.info or http://www.youronlinechoices.eu/ to limit collection through the Steele Mansion LLC Site or by configuring the settings on your mobile device to limit ad tracking through the mobile applications. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Websites and/or information from the advertisements on third-party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
4. Cookies
Our Website, SteeleMansion.com, utilizes “cookie” technology. “Cookies” are encrypted strings of text that a Website stores on a user’s computer. The Website uses cookies throughout the online reservation process to keep together information entered on multiple pages. For example, cookies enable our Website to “remember” dates entered at the start of a search for room availability at multiple locations. In addition, cookies are used to:
1. Measure usage of various pages on our Website to help us make our information more pertinent to your needs and easy for you to access; and
2. Provide functionality such as online reservations and mapping functionality that we believe would be of interest and value to you.
The two (2) types of cookies that we use are referred to as “session” cookies and “persistent” cookies. Session cookies are temporary and are automatically deleted when you leave our Website. Persistent cookies remain on your computer hard drive until you delete them. We do not use cookies to gather any personally identifiable information about you apart from what you voluntarily provide us. You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so will adversely affect your ability to perform certain transactions, use certain functionality and access certain content on our Website.
5. Rights of Access, Rectification, Erasure and Restriction
Individuals from the EU may inquire as to whether Steele Mansion LLC is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may click on the following link https://www.steelemansion.com/privacy-form or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Steele Mansion LLC. Such requests will be processed in line with local laws.
Although Steele Mansion LLC makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Steele Mansion LLC is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Steele Mansion LLC determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Steele Mansion LLC will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
6. Protection of Personal Information by Steele Mansion LLC
The security of Personal Information is very important to us and we are committed to protecting the information we collect. We collect Personal Information only in a manner deemed reasonably necessary to serve our legitimate business purposes and comply with our legal obligations. We use commercially reasonable efforts to make our collection of Personal Information consistent with all applicable laws and regulations. We exercise care in providing secure transmission and storage of information.
Unfortunately, no data transmission or storage is 100% secure. We cannot warrant that all data we transmit, store and collect will be completely secure. We use commercially reasonable efforts to create and maintain firewalls, restricted access and secure socket layers and other appropriate safeguards to ensure that, to the extent we control Personal Information, it is used only as authorized by us and consistent with this Policy and that Personal Information is not improperly altered or destroyed. Our privacy protection practices help us maintain accurate, timely, complete and relevant information for our business purposes. Our communication systems, software and database practices have been designed to aid us in supporting authenticity, integrity and confidentiality.
7. Compliance with Law
We may disclose Personal Information to law enforcement agencies, or may be required to disclose it during the discovery process in litigation, pursuant to a court order or in compliance with any applicable law, regulation, rule or ordinance.
a. Information Regarding Children. Due to the nature of Steele Mansion LLC’s business, services and benefits are not marketed to minors. Steele Mansion LLC does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). If we learn that we have collected Personal Information directly from a child under the age of 13 (and in certain jurisdictions under the age of 16), we will promptly delete that information. If you are under the age of 13 (and in certain jurisdictions under the age of 16), please do not submit any Personal Information to Steele Mansion LLC. If a parent or guardian becomes aware that his or her child under the age of 13 (and in certain jurisdictions under the age of 16), has directly provided us with Personal Information without his or her consent, he or she should contact us at info@steelemansion.com and we will delete such information from our files.
b. California Residents. Your California Privacy Rights: Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information relating to Third-Parties to which the company has disclosed certain categories of Personal Information during the preceding year for the Third-Parties’ direct marketing purposes. Alternatively, the law provides that a company may comply, as Steele Mansion LLC does, by disclosing in its privacy policy that it provides consumers choice (opt-out or opt-in) regarding sharing Personal Information with Third-Parties for those Third-Parties’ direct marketing purposes, and information on how to exercise that choice. As stated above in this Privacy Policy, Steele Mansion LLC provides you with a choice prior to sharing your Personal Information with Third-Parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time Steele Mansion LLC offers that choice, Steele Mansion LLC does not share your information with that identified Third-Party for its direct marketing purposes.
If you are a California resident and you have questions about our practices with respect to sharing information with Third-Parties for their direct marketing purposes and your ability to exercise choice, please send your request by email to info@steelemansion.com. You must put the statement “Your California Privacy Rights” in the subject field of your email. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. Please note that we are only required to respond to one request per person each year.
c. Personal Information About Individuals Residing Outside of the United States and Consent to Transfer. Steele Mansion LLC, the Steele Mansion Website are based on the United States. All Personal Information sent or collected via or by Steele Mansion LLC may be stored in the U.S. or anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Steele Mansion LLC, you consent to the storage of your Personal Information in these locations.
d. Third-Party Links and Content. Please note that the Red Roof Website(s) may contain links to other websites. Steele Mansion LLC does not control these third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Steele Mansion LLC is not responsible for the privacy practices of Third-Party sites and does not endorse or make any representations about the Third-Parties website privacy practices. Any Personal Information you choose to give to unrelated Third-Parties is not covered by this Privacy Policy. Steele Mansion LLC encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third-Parties may choose to share their users’ Personal Information with Steele Mansion LLC; that sharing is governed by that company’s privacy policy, not this Privacy Policy.
8. Questions or Comments
Any questions or comments that relate to the Steele Mansion LLC Privacy Protection Policy may be directed to us at 440-639-7948, 348 Mentor Avenue, Painesville, Ohio 44077 and info@steelemansion.com.
9. Privacy Protection Policy Changes
In the future, we may need to change this Policy. All changes will be included on this Website so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. This Policy was last updated on September 23, 2018.