Privacy Notice

Overview

What Information Do We Collect?

            Information You Share With Us

            Information Collected Automatically

            Information Obtained From Third Parties

How Do We Process Personal Data?

            Legal Bases for Processing

            Operational Uses

            Marketing Uses

            Sharing of Personal Data

Protecting Personal Data

Retention of Personal Data

Your Rights Regarding Personal Data

            Accessing, Modifying, Rectifying, and Correcting Collected Personal Data

            Your California Privacy Rights

            Your European Union Privacy Rights

            Your Canadian Privacy Rights

Your Choices

            Communications Opt-Out

            Cookies, Web Tracking, and Advertising

Other Important Information About Personal Data and the Services

            Collection of Personal Data from Children

            Third-Party Websites and Services

            Business Transfer

            Do Not Track

            International Use

Modifications and Updates to this Privacy Notice

Applicability of this Privacy Notice

Additional Information and Assistance

 

  1. Overview

 

BridgeStreet Corporate Housing LLC d/b/a BridgeStreet Global Hospitality, BridgeStreet Accommodations London Ltd., and each of their affiliates (collectively, “BridgeStreet,” “we,” “us,” “our”) respect your privacy and are committed to protecting the personal data we hold about you. If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us. BridgeStreet is the data controller of the personal data collected, and is responsible for the processing of your personal data.

 

This Privacy Notice explains our practices with respect to personal data we collect and process in connection with your relationship with us. This includes information we collect through, or in association with, our websites that link to this Privacy Notice, and any related apps or functionality (including chat functionality) that we may provide, together with all products and services we may offer from time to time via our websites and/or related apps, our related social media sites, or otherwise through your interactions with us (the website, apps, products, services, and social media pages, collectively, the “Services”).

 

If you are providing information through the Services for a third party (e.g., customer, client, employee, family member, friend) you hereby represent that you have the right to do so and that you have provided such party with a copy of this Privacy Notice, and all references to “you” or “your” data or personal data herein refers to the data or information of both you and such individual, as applicable.

 

Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.

 

  1. What Information Do We Collect?

 

We collect a variety of personal data from and about you through the Services, including:

 

  • When you provide it to us directly;

 

  • Automatically through logging and analytics tools, cookies, pixel tags, and as a result of your use of and access to the Services; and

 

  • From third-party sources, including properties where you book stays; service providers; individuals or entities who book stays or order services on your behalf, including but not limited to online travel agencies, corporate travel managers, and travel agents; ad networks that provide online behavioral advertising services, service providers such as Google Analytics, and through your interactions with us on social media websites.

 

You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services. In addition, as noted below in the section captioned Your Choices it is possible to change your browser settings to block the automatic collection of certain information.

 

Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.

 

Information You Share With Us. We collect personal data from you when you provide it to us, including through website forms, online chat functionality, booking stays, placing orders, or contacting us with questions or comments.

 

For example, if you book stays or order products or services through the Services, you must provide us with information to process that request and/or enter into or carry out a contract with you (including but not limited to email address, first and last name, mailing address, billing address, payment information, telephone number, and any other information you may optionally provide. In addition, you can choose to sign up for email notifications about BridgeStreet through the Services by providing us with your email address.

 

You must create an account to use certain Services or functionality on the Services, including the www.myaccount.bridgestreet.com, www.clientportal.bridgestreet.com, and bridgestreet.appiancloud.com (for suppliers) portions of the Services. To create an account, you must provide your job title, first and last name, mailing address, billing address, mobile phone number, and email address. Additional variable fields may also be requested on a client-by-client basis. You have the ability to update all such information by contacting us as provided in this Privacy Notice or through email addresses and/or phone numbers we provide to you.

 

If you contact us with questions, requests, or complaints, or to exercise your legal rights, including through our online chat functionality, we collect personal data sufficient to answer your questions, address your requests, and/or handle your complaints, as applicable. In certain situations, we may also require you to provide personal data to authenticate your identity in order to carry out your requests.

 

We also collect information from you that, depending on applicable law, may not constitute personal data.

 

Information Collected Automatically. When you browse or use the Services, we utilize commonly-used logging and analytics tools, including Google Analytics, to collect information about your device, the network used to access the Services, and information about your use of the Services (such as how you navigate and move around the Services).

 

We also use certain technologies on the Services, including cookies and pixel tags, that allow us, our service providers, and other third parties to store information locally on your device, identify your device, track your interactions with other sites or with our email campaigns, and track activity over time and across websites.

 

We use ad networks, such as DoubleClick and AppNexus, to serve advertisements across the Internet. These advertisers use cookies, pixel tags, and other tracking technologies to collect information about your online activity and provide online behavioral advertising.

 

Information collected automatically includes the software and hardware attributes of the device you use to access the Services, unique device ID information, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files and third-party analytics (including Google Analytics) that record website activity. For example, log file entries and analytics data are generated every time you visit a particular page on our website, and track the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, and other similar usage information, and general data (including the name of the web page from which you entered our website).

 

  • Cookies, Web Tracking, and Advertising. We use cookies and pixel tags, including those placed and activated by Google Analytics, DoubleClick, AppNexus, and TripAdvisor, to personalize and enhance your experience in regard to our Services, to collect data about your visit to our Services, to help diagnose problems with our servers, to administer the Services, to evaluate the effectiveness of our marketing and advertising campaigns, to permit analytics providers to gather information about your visit to the Services, to permit advertisers to collect information about your online activity and target advertising to you that is relevant to your interests as determined from your online activity (also known as “online behavioral advertising”), and to gather broad demographic information about our users. Please see our Cookie Notice and the “Your Choices” section of this Privacy Notice for more information about cookies and other web tracking technologies on the Services; for information about how you can reject, delete, or prevent cookies from being placed on your system; and how you can opt out of, limit, or prevent certain web tracking technologies and/or advertising providers from collecting information about you.

     

    Information Obtained from Third Parties. We receive personal data from online travel agencies, corporate travel managers, and travel agents, properties where you book stays, other accommodation providers, as well as third parties that we have engaged to provide services to us, including our suppliers and vendors, as well as from third parties that provide web analytics and usage information to us such as Google Analytics.

     

    In addition, if you choose to interact with us or our partners on social media by posting to our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, we may collect certain information from the social media account you use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which we are tagged, and other information that may be contained on your social media profile to allow us to respond to the posts and understand and engage with our audience.

     

    For the purposes of this Privacy Notice, “partners” means affiliates, service providers, accommodation providers, licensors, vendors, manufacturers, distributors, or other third parties with which we have a business relationship.

     

  • How Do We Process Personal Data?
  •  

    We process personal data for two general purposes, pursuant to various legal bases:

     

  • For our business operations (including communicating with you, fulfilling orders, providing information about our products and services, improving the Services, and complying with applicable legal requirements); and

     

  • To market and promote our, and our partners’ products and offerings.

 

We disclose personal data to our service providers to allow them to provide services to us and assist in carrying out your requests, and to our partners in aggregate, demographic form in connection with our marketing and business development efforts.

 

In addition, we may disclose information we maintain, including personal data: when permitted or required to do so by law; in response to a request from a law enforcement agency or authority or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.

 

See the Your Choicessection below for information about how you can make decisions about how we process personal data, including how to opt out of certain marketing communications.

 

Legal Bases for Processing. We process personal data for, or based on, one or more of the following legal bases:

 

  • Performance of a Contract. We may use personal data to enter into, or perform under, the agreement between us, such as when you book stays or purchase products or services.

     

  • Legitimate Interests. We may use personal data for our legitimate interests and those of certain third parties, including improving our service; providing appropriate reports to corporate travel managers and relocation and accommodation providers; providing information about our products and/or services; to the extent necessary and proportionate for the purposes of ensuring network and information security; and for administrative, fraud detection, and legal compliance purposes.

     

  • Compliance with Legal Obligations and Protection of Individuals. We may use personal data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.

     

  • Your Consent.  We may process certain personal data based on your consent to process it in that manner.

     

    Operational Uses. We process your personal data as part of our operations, which include:

     

  • Providing you with information tailored to your requests, responding to inquiries, and delivering services and products;

     

  • Operating, maintaining, and improving the quality of the Services and such content, products and/or services as we may make available through the Services;

     

  • Communicating with you by email, mail, text message (SMS, MMS), telephone, social media messaging, online chat functionality, and other methods of communication, in each case with your consent, if such consent is required in accordance with applicable laws, about products, services, order status, and other topics;

     

  • Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;

     

  • Endeavoring to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties; and

     

  • For other purposes, as permitted or required by law.

 

Marketing Uses. We process your personal data to send messages to you about us, our partners, and the content, products and services we and our partners offer, which may from time to time include contests, rewards, events, and special offers for products and services. These communications are tailored based on the communications preferences you select when providing us with your information and will only occur with your prior consent, if such consent is required in accordance with applicable laws; for example, we will not call you or send you text messages unless you both consent to receive such communications and provide us with your telephone number. We process personal data collected through social media platforms and web tracking technologies to market to and understand our audience.

 

Sharing of Personal Data. Some of the above processing involves sharing collected personal data with third parties, including service providers, affiliates, and other partners.

 

  • We share personal data with third parties when you ask us to do so;

     

  • We share personal data among our affiliated entities;

     

  • We share contact information with the supply partner (e.g., property, managing company) responsible for providing accommodations that you have booked;

     

  • We share personal data with our service providers, including payment processors, software and Web developers, order processing and fulfillment services, commercial email providers, security consultants, properties where you book stays, and other vendors we engage so that they may provide services to us or on our behalf;

     

  • We share personal data we collect in aggregated, demographic form, with certain customers, partners, prospective partners, and service providers in order to provide us and/or our affiliates and partners with information about the use of the Services and levels of engagement with the Services, to allow us to enter into new business relationships, and to allow us to market products or services on their behalf. For example, stay data for guests staying under the same company or client may be aggregated and provided to that party based on our contractual obligations or to address informational request or requirements of that party; and

     

  • We share personal data with third parties when we believe it is required by, or necessary to comply with, applicable law.

 

  1. Protecting Personal Data

 

We employ reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. Those safeguards include: (i) the pseudonymization and encryption of personal data where we deem appropriate; (ii) taking steps to ensure personal data is backed up and remains available in the event of a security incident; and (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards.

 

However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.

 

  1. Retention of Personal Data

We retain your personal data for as long is necessary or appropriate to fulfil the purpose for which it was collected, and to the extent necessary or appropriate to carry out the processing described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we deem reasonably necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties. We take into account and consider multiple factors, including the scope and nature of the personal data, potential risk of harm to data subjects from a data breach, and legal requirements, in determining the appropriate retention period. If you have a specific question regarding retention of your personal data, you may contact us as described in Additional Information and Assistance.

  1. Your Rights Regarding Personal Data

 

You have a variety of legal rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us as provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you. Please be prepared to provide reasonable information to identify yourself and authenticate your requests.

 

Note, however, that we may request certain reasonable additional information (that may include personal data) to help us authenticate the request and/or to clarify or understand the scope of such requests.

 

These rights vary depending on the particular laws of the jurisdiction applicable to you, but may include:

 

  • The right to know whether, and for what purposes, we process personal data about you;

     

  • The right to be informed about the personal data we collect and/or process about you;

     

  • The right to learn the source of personal data about you we process, where we obtain that personal data from a source other than you.

     

  • The right to access, modify, and correct personal data about you (as set forth in more detail below under Accessing, Modifying, Rectifying, and Correcting Collected Personal Data)

     

  • The right to know with whom we have shared personal data about you, for what purposes, and what personal data has been shared (including whether personal data was disclosed to third parties for their own direct marketing purposes);

     

  • Where processing of personal data about you is based on consent, the right to withdraw your consent to such processing; and

     

  • The right to lodge a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

     

    See Your California Privacy Rights and Your Privacy Rights for more information about certain legal rights.

     

    Accessing, Modifying, Rectifying, and Correcting Collected Personal Data. We strive to maintain the accuracy of any personal data collected from you, and will use commercially reasonable efforts to respond promptly to update our database when you tell us the information in our database is not accurate. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.

     

    In accordance with applicable law, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, you may do so at any time by contacting us as provided below. Please note, however, that we reserve the right to deny access as permitted or required by applicable law.

     

    Your California Privacy Rights. California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal data (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge.

     

    We do not disclose personal data protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

     

    Your Privacy Rights. In addition to the above-listed rights, certain privacy laws provide individuals with enhanced rights in respect of their personal data. These rights may include, depending on the circumstances surrounding the processing of personal data:

     

  • The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;

     

  • The right to request restriction of processing of personal data or object to processing of personal data carried out pursuant to (i) a legitimate interest or (ii) performance of a task in the public interest (including, but not limited to, processing for direct marketing purposes);

     

  • In certain circumstances, the right to data portability, which means that you can request that we provide certain personal data we hold about you in a machine-readable format; and

     

  • In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain personal data we process about you.

 

Note that we may need to request additional information from you to validate your request. To exercise any of the rights above, you may contact us as described in the Additional Information and Assistance

 

  1. Your Choices

 

In addition to your choices with respect to the collection of personal data (see What Information Do We Collect? above), you have the ability to make certain choices about how we communicate with you, and how we process certain personal data.

 

Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Notice, or by informing our customer service representatives of your desire to opt out. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email.

 

Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).

 

Cookies, Web Tracking, and Advertising. Consult our Cookie Notice for more information about how to control and/or opt out of certain web tracking technologies.

 

  1. Other Important Information About Personal Data and the Services.

 

Our Privacy Notice also includes information about other practices with respect to personal data, including:

 

  • Collection of personal data from children;

 

  • Links and references to third-party websites and services on our Services:

 

  • What happens to personal data in the event we sell or transfer some or all of our business;

 

  • How we respond to “Do Not Track” requests; and

 

  • Information about where we process and transfer personal data.

 

Collection of Personal Data from Children. Children under 16 years of age are not permitted to use the Services, and we do not knowingly collect information from children under the age of 16. By using the Services, you represent that you are 18 years of age or older, or are 16 years of age or older and have valid parental consent to do so. With respect to minors, when information is collected, it is generally only the age of the child, and in certain cases the child’s name, gender, and/or school district, as is appropriate to provide specific elements of our services.

 

Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business, including, but not limited to, travel-related services, packing services, transportation and automobile rental providers, food delivery services, co-working providers, and tourism services. When you access these third-party services, you leave our Services, and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Notice does not apply to any third-party services; please refer to the Privacy Notices or policies for such third-party services for information about how they collect, use, and process personal data.

 

Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

 

Do Not Track. We use analytics systems and providers and participate in ad networks that process personal data about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We do not currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

 

Note, however, that you may find information about how to opt out of Google Analytics, online behavioral advertising, and/or block or reject certain tracking technologies in our Cookie Notice.

 

International Use. Your personal data will be stored and processed in the United States. If you are using the Services from outside the United States, by your use of the Services you acknowledge that we will transfer your data to, and store your personal data in, the United States, which may have different data protection rules than in your country, and personal data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States. For transfers of personal data out of the European Economic Area, we use standard contractual clauses and, as applicable, other applicable mechanisms, to provide appropriate safeguards.

 

  1. Modifications and Updates to this Privacy Notice

 

This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Notice, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.

 

  1. Applicability of this Privacy Notice

 

This Privacy Notice is subject to the Terms and Conditions that govern your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services.

 

This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.

 

  1. Additional Information and Assistance

 

If you have any questions or concerns about this Privacy Notice and/or how we process personal data, or would like to exercise any of the legal rights set forth above, please contact us at:

 

Privacy Office

BridgeStreet

11180 Sunrise Valley, Suite 400

Reston, VA 20191

privacy@bridgestreet.com

 

In addition, we have appointed a data protection officer (“DPO”) who is responsible for, among other things, responding to questions, requests, and concerns in relation to this Privacy Notice and our use of personal data. You may contact the DPO as follows:

 

Data Protection Officer

BridgeStreet

1st Floor

8 Harewood Row

London NW1 6SE

dpo@bridgestreet.com

 

If you are located in the European Economic Area, and you wish to raise a concern regarding our use of your

personal data, you have the right to do so with our lead supervisory authority, the U.K. Information Commissioner’s

Office (the “ICO”) at www.ico.org.uk, or your local supervisory authority. We would, however, appreciate the

chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Effective May 24, 2018