Last updated: July 24, 2020
It is part of Hersha Hospitality Management's and the Independent Collection's (collectively hereinafter "IC," "we," "us," or "our") culture and values to do the right thing and act with integrity, including respecting our guest's concerns about privacy. We know that you care how your information is used, and we appreciate your trust that we will use it carefully and sensibly. This Privacy Policy details how we handle and maintain the information collected when you visit or use one of our websites, when you access one of the mobile applications made available by us in connection with our Services, when you access or use the social media pages that we administer and control, via any of our email marketing campaigns, as well as through the managed relationships necessary for the provision of our hospitality services (collectively, the "Services"). This policy describes our disclosure policies, as well as the choices that you have regarding use, access, and correction of your information. This policy does not describe the information collection policies or practices of any third party(s), including those with whom we may contract for the provision of Services or which may be linked to or integrated within any of our websites.
We encourage you to review this Privacy Policy periodically. Your use of our Services constitutes consent to the terms contained herein. If you do not agree with the practices described in this Privacy Policy, you should not use our Services. We may update this Privacy Policy periodically, and any changes will be reflected here. If the changes are significant, we will provide a more prominent notice, and at our discretion may email you a direct notification.
We collect data and information about our guests and other visitors in order to better provide our Services. The data collected is provided by you, either directly or via your use of the Services.
Personal data applies to any data that can identify you as an individual or relate to an identifiable individual. At various points during your stay and experience with the Independent Collection, we collect certain Personal Data such as:
In more limited circumstances, we also may collect:
Data about family members and companions, such as ages of children. Images and video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel.
If you submit any Personal Data about other people to us (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Policy.
When you make a payment in connection with purchasing any of the Services, the Independent Collection may obtain credit card or other payment information.
Usage Data is collected automatically when you use the Service.
Usage Data may include information such as your device's Internet Protocol address (e.g. IP address), browser type (for example: Chrome, Firefox, Internet Explorer or Safari), browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, we may likewise collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique ID or IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you access the Service by or through a mobile device.
Usage data is collected via tracking technologies, including:
A cookie is a small data file that resides on your computer, and which allows us to recognize you as a user when you return using the same computer and web browser. Cookie data is used to customize your experience when you use the Services. When you visit our website, you are notified of the use of cookies for tracking and analysis and asked to provide your express consent. The notice refers to the detailed explanations in this Privacy Policy.
Cookies can be "Persistent" or "Session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while Session cookies are deleted as soon as you close your web browser.
We use both Session and Persistent cookies for the purposes set out below:
Type: Session Cookies; Administered by: Us
Purpose: These cookies are essential to provide you with the Services. They help to authenticate users and prevent fraudulent use of user accounts. We only use these cookies to provide the Services.
Type: Persistent Cookies; Administered by: Us
Purpose: These cookies identify if users have accepted the use of cookies on the website(s).
Type: Persistent Cookies; Administered by: Us
Purpose: These cookies allow us to remember choices you make when you use our website(s), such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid your having to re-enter your preferences every time you use the website(s).
Type: Persistent Cookies; Administered by: Third-Parties
Purpose: These cookies are used to track information about traffic to the website and how it is used. The information gathered may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the website. We may also use these cookies to test new advertisements, pages, features, or new functionality of the website to see how our users react to them.
Type: Persistent Cookies; Administered by: Third-Parties
Purpose: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. They use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites.
Log files are deleted after 120 days. Session cookies expire and are deleted at the end of your browser session. Persistent cookies may be set to expire from 30 days to 1 year depending on the function of the cookie. After expiry of those periods, information will be deleted or made anonymous.
You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Most modern internet browsers allow individuals to change the settings in the ‘options' or ‘preferences' menu to avoid or limit cookie storage. In addition, third party cookies generated by certain advertisers may be turned off by making a request with the Network Advertising Initiative. Please visit http://optout.networkadvertising.org for more information.
In addition to cookies, we also use Web Beacons and Embedded Script.
Web Beacons help us better manage content on our Services by informing us of what content is effective. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. This information is used to help improve the overall quality and experience of the Services.
Embedded Script is a programming code that collects information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Service.
We also collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps, and online resources. You can learn about Google's practices by going to https://policies.google.com/privacy and opt out by downloading the Google Analytics opt out browser add-on, available at tools.google.com. You can learn more about Adobe and opt out by visiting https://www.adobe.com/privacy/policy.html.
The data and other information that we collect is used and disclosed in the following manner(s) and for the following purposes:
We disclose information and data, including personal data, to other companies within the Independent Collection for the purposes described in this Privacy Policy, such as providing and personalizing the Services, communicating with you, and to accomplish our business purposes. We share your personal data and other data used for making a reservation with the applicable property to fulfill and complete your reservation.
Our goal is to provide you with the highest level of hospitality and to assist us with doing so, we share personal, and other, data with the following parties:
In addition to the above scenarios, we may also disclose information about you to certain third parties if we have a good-faith belief that we are required to do so by law or legal process, to respond to legal claims, or to protect our rights, property, or safety, or the rights, property, or safety of others. We will only use your payment processing information with your explicit consent.
We will retain data, including personal data, and other information for the purposes set out in this Privacy Policy. We will retain and use such data and information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain usage data for internal analysis purposes.
Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
The Independent Collection is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our website(s) or the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
The security of your data is important to us, and the Independent Collection takes commercially reasonable security and backup measures to protect the information submitted to us. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security. We encourage our customers and partners to retain copies of all uploaded information on their own systems.
The Services are general audience services and are not intended for individuals younger than the age of 13. We do not knowingly collect personal data from individuals younger than the age of 13 without parental consent. If we discover that a child under the age of 13 has provided us with personal data, or that we have otherwise inadvertently collected personal data from anyone younger than the age of 13, we will delete it in accordance with applicable law.
California residents have additional rights regarding our use of your personal data and are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year.
California residents under the age of 18 who are registered users of online sites, services or applications also have the right under California law to request and obtain removal of content or information they have publicly posted. If you are a California resident and wish to request removal of such data, you can contact us using the contact information provided below.
California residents are also entitled to exercise certain rights as expressly set forth by the California Consumer Privacy Act, including the right to give the instruction ‘Do Not Sell My Personal Information' to third parties. For additional details on your California Privacy rights, see our .
We comply with the provisions of the European Union's General Data Protection Regulation ("GDPR") as to any information in its possession regarding EU-based persons ("data subjects"). Accordingly, we only process personal information on data subjects where we has a lawful basis to do so, which may include the consent of each person (especially in the case of website visitors who provide their information) or compliance with a legal obligation. For additional details on your European Union Privacy rights, please see our notice.
Additional Information on the Processing of Personal Data
We may use third-party service providers to show advertisements to you to help support and maintain our Service. Such third parties include, but are not limited to:
For more information about Bing Ads, please visit their Privacy Policy: https://privacy.microsoft.com/en-us/PrivacyStatement.
We may use the email address that you provide to us in order to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications by following the unsubscribe link or instructions provided in any email we send or by contacting us as set forth below.
We may use certain third-party email marketing service providers, such as Cendyn, to manage and send emails to you. Cendyn's Privacy Policy can be viewed at https://www.cendyn.com/privacy-policy/.
We use remarketing services to advertise on third party websites to you after you have visited one of our websites. In the course of doing so, we use cookies to inform, optimize and serve ads based on your past visits to our Service, such as:
You can learn more about the privacy practices and policies of Microsoft by visiting their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.
We may use third-party service providers to improve our Service.
We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google. The reCAPTCHA service may collect information from You and from Your Device for security purposes. The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/.
Changes to this Privacy Policy
We may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your personal data, we will display a notice on our website(s), or through other means. You are encouraged to review this Privacy Policy periodically for any changes. Continued use of our website(s) or our Services after any update will constitute your agreement to the new policy.
If you have any questions about this Privacy Policy, the practices, or use of the website(s) or Services, you can contact us:
510 Walnut St 9th floor
Philadelphia, PA 19106
If you are a resident of the European Union (the "EU") or reside in the European Economic Area (the "EEA") and we collect personal data relating to you in the context of the offering the Services, your personal data will be subject to Regulation (EU) 2016/679 (General Data Protection Regulation, "GDPR").
We may process your personal data pursuant to one of the following conditions:
In any case, upon reasonable request we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
The Independent Collection undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.
You have the right under this Privacy Policy, and by law if you are within the EU, to:
You may exercise your rights of access, rectification, cancellation and opposition by contacting us via email at or mail at Independent Collection, ATTN: Legal, 510 Walnut St 9th Floor, Philadelphia, PA 19106. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information please contact your local data protection authority in the EEA.
CALIFORNIA PRIVACY NOTICE
This California Privacy Notice ("Notice") supplements the Independent Collection's (hereinafter "Independent Collection," "we," "us," or "our") Privacy Policy and applies specifically to visitors and users who are California residents ("consumer(s)" or "you"). This Notice details the Independent Collection's compliance with, and the rights of consumers under, the California Consumer Privacy Act of 2018 ("CCPA") as well as other California privacy laws. Any terms defined in the CCPA have the same meaning when used herein.
Your Rights as a Consumer
The CCPA grants you specific rights in and to your personal information. Specifically, you have the rights set forth below and may exercise them, as applicable, as further described below.
Right of Access to Collected Information; Data Portability
You have the right to request that the Independent Collection disclose the categories and specific pieces of personal information that we have collected about you. Upon receipt of any request, we will send you a verification notice and, once your identity has been verified, we will disclose to you:
The Independent Collection will disclose this information to you either electronically or by mail. If provided electronically, the information will be in a portable and, to the extent feasible, readily useable format so as to allow you to transmit the information to another party without hindrance.
Right of Access to Information Sold or Disclosed for a Business Purpose
You have the right to request that the Independent Collection disclose the categories of personal information that we have sold or otherwise disclosed to a third party about you. Upon receipt of any request, we will send you a verification notice and, once your identity has been verified, we will disclose to you:
Right to Request Deletion
You have the right to request that the Independent Collection delete any of your personal information that we have collected and retained about you, subject to certain exceptions. Upon receipt of any request, we will send you a verification notice and, once your identity has been verified, we will delete (and direct any third-party service providers to delete) your personal information.
The Independent Collection may deny your deletion request if retaining your personal information is necessary for us to: complete the transaction for which we originally collected your personal information; provide a service that you requested; take reasonably anticipated actions within the context of our ongoing business relationship; to comply with a legal obligation; or otherwise as set forth in the CCPA. If we deny your deletion request, we will provide you with the reason(s) for such denial.
Right to Opt-Out of the Sale of Your Personal Information
You have the right to request that the Independent Collection not sell your personal information. This right is also referred to as the right to "opt-out" of the sale of your personal information. The Independent Collection does not sell consumers' personal information.
Right of Non-Discrimination
You have the right to exercise any or all of the rights identified above free of discrimination. The Independent Collection will not discriminate against you for exercising your CCPA rights.
Exercising Your California Privacy Rights
To exercise your rights to access about your personal information that is collected and/or sold by the Independent Collection, or to request the deletion of your personal information or an opt-out from the sale of your personal information, you can submit a verifiable request by:
510 Walnut St 9th floor
Philadelphia, PA 19106
Only you or an individual authorized to act on your behalf with the California Secretary of State's office may make a valid request as relates to your personal information. If you are a parent or guardian of a minor child, you may make a request on their behalf.
The Independent Collection uses commercially reasonable efforts to respond to any verifiable consumer request within 45 days of our receipt of such request. If we require additional time, we will inform you of the same along with our reason(s) and any extension period in writing via the contact information that you provide to us upon request. Any information disclosure that we provide will cover the 12-month period immediately preceding our receipt of your request. You may make a request for disclosure at any time, but we will not provide any such disclosures more than two times in a 12-month period.
Information That We Collect
The Independent Collection has collected the following categories of personal information about consumers in the last 12 months.
| Category | Examples |
| Identifiers: | Real name, postal address, online identifier, email address, Internet Protocol address, or other similar identifiers. |
| Categories of personal information listed in the California Customer Records statute: | Name, address, telephone number, education, employment, employment history. Information included in this category is specifically set forth by California statutory law and may overlap with information in other categories. |
| Commercial information: | Information or details of products or services purchased, obtained, or considered. |
The Independent Collection collects your information in order to better provide hospitality services at our portfolio of hotels.
Information That We Sell
The Independent Collection collects consumer personal information directly from consumers and uses it solely for the purpose(s) for which it is collected. We do not sell consumer personal information.
Information That We Disclose for a Business Purpose
The Independent Collection discloses personal information to certain third party(s) for business purposes. When we do so, we enter into contracts that describe the business purpose and which require such third party(s) to keep the personal information confidential and to only use personal information as set forth in and explicitly allowed by the contract.
We have disclosed to a third party for a business purpose the following categories of personal information about consumers in the last 12 months.
The Independent Collection discloses personal information for a business purpose only to our third-party service provider(s).
Changes to this California Privacy Notice
We may update this Notice at any time and the changes will be effective upon posting. This Notice will be reviewed and updated as necessary at least once every 12 months.
Contact Information
If you have questions or comments about this Notice or our California privacy practices generally, please feel free to contact us via email at or mail at the Independent Collection, ATTN: Legal, 510 Walnut St 9th Floor, Philadelphia, PA 19106.