Privacy Policy

EFFECTIVE DATE: May 17, 2018

Drury Hotels Company, LLC is sensitive to privacy issues, and wants to provide you helpful information about our privacy practices, including the kinds of information that identifies you as an individual (“Personal Information”) that we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Policy”).

This Privacy Policy applies to the Personal Information that is collected by Drury Hotels Company, LLC, including its subsidiaries, affiliates, and any individual hotel property or website, social media page, application, feature, widget or other online service that is owned or controlled by Drury Hotels Company, LLC (“Drury”, “we”, “us”). and that posts a link to this Privacy Policy (“Drury Site”), and through your communications with us and when you make reservations or stay as a guest at one of our hotels (collectively, “Services”).

This Privacy Policy only covers information collected at the Site and specifically does not cover information collected offline (including in connection with our branded credit cards) or by an individual hotel property (unless specifically stated).

Overview

You should read this Privacy Policy in its entirety before submitting any Personal Information so you know how we collect and share your Personal Information. This initial summary of our Privacy Policy highlights some important points regarding our and third parties’ collection, use, and sharing of your information.

This Privacy Policy explains:

  1. Information That We Collect
  2. Use of Information by Drury
  3. Human Resources Data
  4. Social Media
  5. Third-Party Analytics Providers, Ad Servers, and Similar Third Parties
  6. Email and Direct Marketing
  7. Cookies, Web Beacons and Other Website Monitoring
  8. Choices and Opt Outs
  9. How and When We Share With Third Parties
  10. Rights of Access, Rectification, Erasure and Restriction
  11. Retention
  12. Protection of Personal Information by Drury
  13. Contacting Us or You
  14. Other Rights and Important Information

1. Information That We Collect

Drury collects Personal Information regarding its current, prospective and former guests, visitors, website visitors and other consumers (“Consumers”), travel and other business partners (“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.

Drury collects Personal Information directly from Consumers, Business Partners, and Team Members and indirectly through third parties and Business Partners such as an online travel agencies, airline or other electronic travel reservation service, staffing agencies and recruiters, and other agencies and service providers. The types of Personal Information we may collect (directly from you or from third parties) and our privacy practices depend on the nature of the relationship you have with Drury and the requirements of applicable law.

We endeavor to collect Personal Information only relevant for the purposes of processing. Below are the legal bases and some of the ways we collect information and how we use it.

  1. 1.1 Information That You Provide

    Drury collects Personal Information directly from you when you contact us to make a room reservation or stay at a hotel, buy a gift certificate, apply for a job, or create a personal profile through our Drury Rewards loyalty program or otherwise engage directly with us. You may choose to create a personal profile, to make it more convenient for you to do business with us or stay informed you about products and special offers that may be of interest to you. In addition, in certain circumstances and if you elect, you may include credit or debit card information in your profile, to be used for subsequent reservations to increase reservation speed and eliminate the need for you to repeatedly enter your credit card information.

    We may collect other information about you, such as demographic information (for example, your age or gender), employer information (for example, travel agents and potential applicants), information about your preferences and interests (such as if you prefer a non-smoking room or tour packages) and your hotel-based activities (such as vehicle information, or use of hotel services). We may collect payment information (such as a credit or debit card number), if applicable. If we combine other information with Personal Information, we will treat the combined information as Personal Information under this Privacy Policy.

    Drury may ask you to provide Personal Information about others. For example, may ask you to provide an employment reference or you may purchase a gift certificate or make a reservation for someone else, or we may allow you to forward information about our products, services, and hotels to another person. When you provide us with such information, you represent that you have gotten any necessary consent of the other person before disclosing their information to us, which we will use in accordance with the provisions of this Privacy Policy.

  2. 1.2 Information Third Parties Provide to Us About You

    Drury may collect information about you from third party sources to provide the services you request or to supplement information provided by you.

    For example, we may receive information about you from third parties, including without limitation 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.

  3. 1.3 Research/Survey Solicitations

    From time to time, Drury may perform research (online and offline) via surveys. We may engage third party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve you by learning more about your needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Site, various types of communications, advertising campaigns and/or promotional activities. We may share anonymous individual and aggregate data for research and analysis purposes.

2. Use of Information by Drury

Depending on how you interact with Drury, we and our third party-service providers may use Personal Information in a variety of ways, including:

  1. 2.1 Providing information and Services you requested

    Drury may use the Personal Information about you to respond to your requests, for example, to fulfil transactions or process reservations and orders, to assess your employment application, to support your hotel stay, profile or use of our Website(s) or other computer services, or provide you information that you may request e.g. information about our company, a Drury partner, a hotel or program we are offering like our Drury Rewards loyalty program or Drury Rewards Visa. Drury may also use your Personal Information to deliver a specific program or service to you, when you partner with us or enrol to receive the program or service.
  2. 2.2 Administrative Purposes

    Drury may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in Drury’s Site, programs or services; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the Drury Site, hotels, programs or services, your account, or any changes to any Drury policy or Terms of Service; (e) process payments; (f) prevent potentially prohibited or illegal activities; (g) enforce our Terms of Service; or (h) to comply with regulatory and legal obligations.
  3. 2.3 Marketing Products and Services

    Drury may use the Personal Information about you to provide you with materials about offers, hotels, travel or related services offered by us or our partners, including new content or services on the Drury Site. Drury may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.
  4. 2.4 Research and Development

    Drury may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing services or develop new processes and services.
  5. 2.5 Information Submitted Via Websites

    You agree that Drury is free to use the content of any communications or other information submitted by you via the Drury Site, including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services. However, Drury does not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a site will be published or otherwise used with your name on it; or (c) we are required to do so by law.
  6. 2.6 Sharing Content with Friends or Colleagues

    Drury’s Site may offer various tools and functionality. For example, Drury may provide functionality on its Website(s) that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Drury or any other third parties for any other purpose.
  7. 2.7 Other Uses

    Drury may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3. Human Resources Data

Drury collects Personal Information from current, prospective and former Team Members, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a resume, CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health or disability, including mental health, medical leave, and maternity leave.

We acquire, hold, use and process Human Resources-related Personal Information for a variety of business purposes including:

If you apply for a job through the Drury Site, Drury or its third party-service provider may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission and other federal, state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, Drury or its third party-service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaint.

4. Social Media

Generally, online social media resources are interactive tools that enable individuals to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share website content and tools with a friend or colleague.

Drury may collect Personal Information to enable individuals to use online social media resources offered either by Drury or a third party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.

If you use on online social media resource offered by a third party through the Drury Site you acknowledge that Drury may be able to access any information you make public through such third party (such as your username, comments, posts and contacts) and other information your privacy settings on such third party social media resources permit Drury to access. Drury will comply with the provisions of this Privacy Policy and the privacy policies applicable to the social media resources it uses.

5. Third-Party Analytics Providers, Ad Servers, and Similar Third Parties

Drury works with network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Site (including pages viewed and the actions taken when visiting the Site), to serve our advertisements elsewhere online, and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Site and other websites and services and may use this information to target advertising to you.

These service providers may set and access their own tracking technologies on your device (including cookies and local storage) and may otherwise collect or have access to information about you. Some of these parties may collect Personal Information over time when you visit the Site or other online websites and services. Cookies, including those set by third-party network advertisers, may be used to (among other things): 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 companies, analytics providers, and other vendors for similar purposes.

For example, we use Google Analytics to collect data about traffic to our Site, to deliver advertisements when you visit other websites, and to share data about traffic to our website with Google and other Google Analytics program participants. Additional information about how Google Analytics collects and shares data when you visit this website is available at http://www.google.com/analytics/learn/privacy.html. You can opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout.

Users are bound by the Google Maps/Google Earth Additional Terms of Service (including Google Privacy Policy).

Although we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program.

If you are accessing the Site through an application (i.e., mobile phone or tablet) you can download the AppChoices application from your device’s application store (i.e., Google Play, Apple App Store, and Amazon Store). This DAA application allows participating companies to offer an opt-out of customized advertisements that are based on predictions about your interests generated from your application usage. For more information, visit http://www.aboutads.info/appchoices.

Please note that these companies may still collect information from you and opting out through these mechanisms does not opt you out of being served advertising. You will continue to be served generic ads while online or on your device.

6. Direct Mail, Email and Outbound Telemarketing

Consumers and Business Partners who provide us with Personal Information, and other individuals whose Personal Information we obtain from third parties, may receive periodic emails, newsletters, mailings or phone calls from us with information on Drury or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to you by following the instructions below.

7. Information We Collect Automatically

In addition to any Personal Information or other information that you choose to submit to Drury, we and our third-party service providers (including any third-party content, advertising, and analytics providers) may use a variety of technologies that automatically or passively collect certain information about your use of the Drury Site, software, mobile application or computer services as described below.

  1. 7.1 Usage Information

    Usage information may include the type of device you are using, the browser and operating system you are using, the URL or advertisement that referred you, the search terms you entered into a search engine that led you to the Drury Site, time of day you visit the Drury Site, among other information. Usage Information also includes the IP address or other unique identifiers (“Device Identifier”) for any computer, mobile phone, or other device used to access the Drury Site, computer software or applications, or wireless services. A Device Identifier is a number that is automatically assigned to your device and our servers identify your device by its Device Identifier. We may use usage information for a variety of purposes, including enhancing or otherwise improving the Drury Site, computer software or applications, wireless service delivery and our products and services. The usage information we collect is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.

  2. 7.2 Third-Party Analytics Providers, Ad Servers, and Similar Third Parties

    Drury works with network advertisers, ad agencies, analytics service providers, and other vendors to provide us with information regarding traffic on the Drury Site (including pages viewed and the actions taken when visiting the Drury Site), to serve our advertisements elsewhere online, and to provide us with information regarding the use of the Drury Site and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Drury Site and other websites and services and may use this information to target advertising to you. These service providers may set and access their own tracking technologies on your device (including cookies and local storage) and may otherwise collect or have access to information about you. Some of these parties may collect Personal Information over time when you visit the Drury Site or other online websites and services. Cookies, including those set by third-party network advertisers, may be used to (among other things): 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 companies, analytics providers, and other vendors for similar purposes

  3. 7.3 Cookies and Local Storage

    Cookies and local storage are data files placed within a browser on your device when the device is used to visit the Drury Site. These technologies are able to store a unique identifier for your device that can be used to recognize your device whenever you visit the Drury Site and may be used for many purposes, including, without limitation, to evaluate and improve the functionality of the Drury Site, to help us deliver content specific to your interests, to process your reservations or requests and/or to analyze your visiting patterns. Cookies can only access Personal Information that you have provided on our Site and cannot be accessed by other websites. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser and/or deleting your cookie files from your hard drive at any time by clicking on the privacy or history tab typically found on the settings or options menu in your internet browser. If you choose to disable cookies on your device, you will not be able to use all of the features of the Drury Site, including the features associated with creating a user profile or making an online reservation. You can find more information about cookies and how they work at www.allaboutcookies.org.

  4. 7.4 Web Beacons

    Small graphic images or other web programming code called web beacons (also known as “pixel tags,” “1x1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Drury Site, to monitor how users navigate the Drury Site, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

  5. 7.5 Embedded Scripts

    An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Drury Site, and is deactivated or deleted thereafter.

  6. 7.6 Security and Fraud Scripts

    In addition to embedded scripts, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

  7. 7.7 Analytics Information

    We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of the Drury Site, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

  8. 7.8 Interest-Based Advertising

    Through the Drury Site, Drury may in the future allow third-party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Drury related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

8. Choice and Ways You Can Opt Out

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

  1. 8.1 General

    Where you have consented to Drury’s processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this section.

    Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

    Prior to disclosing sensitive Personal Information to a third party or processing sensitive Personal Information for a purpose other than its original purpose or the purpose authorized subsequently by you Drury will endeavor to obtain your e explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, Drury will comply with the law or contract.

  2. 8.2 Email and Telephone Communications

    An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by Drury so that you can opt-out. However, we may continue to send transaction-related emails regarding reservations, programs or services you have requested in response to such request. We may need to send you certain communications regarding the Drury programs and services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service or this Privacy Policy. We maintain telephone “do not call” lists and “do not mail” lists as mandated by law. We process requests to be placed on do not mail, do not phone and do not contact lists within 60 days after receipt, or such shorter time as may be required by law.

  3. 8.3 Human Resources Data

    With regard to Personal Information that Drury receives in connection with the employment relationship, Drury will use such Personal Information only for employment-related purposes as more fully described in section 3 above. If Drury intends to use this Personal Information for any other purpose, Drury will provide the individual with an opportunity to opt-out of such uses.

  4. 8.4 “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. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Drury does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

  5. 8.5 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 Drury Site and elsewhere on the internet through use of cookies, pixel tags and other storage technologies; or (b) a Drury 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 Drury 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.

9. How and When We Disclose Information to Third Parties

In addition to receiving your Personal Information from third parties, Drury may so share or disclose the Personal and non-Personal information we collect or receive. Drury endeavors to require third parties to which it discloses Personal Information to protect Personal Information using substantially-similar standards to those required by Drury and to notify Drury if they make a determination that they can no longer meet this obligation.

We may share the information we have collected about you (including Personal Information): (i) as disclosed at the time you provide your information, (ii) with your consent, (iii) as described elsewhere in this Privacy Policy, or (iv) in any of the following circumstances:

  1. 9.1 Provide You Services

    Drury may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) sending email or other communications or providing customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. Drury has executed appropriate contracts with the service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

  2. 9.2 Drury Rewards Credit Card

    Drury may share your personal information and other information about you with Commerce Bank for purposes related to our cobranded Drury Rewards Credit Card. For example, we may share information in order to send joint offerings, including information on how to apply for the Drury Rewards Credit Card, and in connection with your use of a Drury Rewards Credit Card, such as to maintain or service accounts and to effectuate transactions.

  3. 9.3 When You Agree to Receive Information from Third Parties or Request That We Share Your Information

    You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared (by opting in or choosing not to opt out at that time), your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. We are not responsible for the privacy policies and practices of third parties.

  4. 9.4 Administrative and Legal Reasons

    We reserve the right to disclose any information (including Personal Information) if we believe such action is necessary: (i) to conform to legal requirements, to comply with legal process or a subpoena, or at the request of a governmental entity conducting an investigation; (ii) to collect amounts owed to Drury (iii) to enforce Drury policies or contracts or protect and defend the legal rights or property of Drury, our Consumers, Partners, the Drury Site or its users, or any other party; (iii) if we in good faith believe that such action is permitted by law; or (iv) in an emergency, to protect the health and safety of our Consumers, Partners, users or the general public. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Site. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

  5. 9.5 Business Transfers & Transitions

    Drury may share your information, including Personal Information, with its parent, subsidiaries, and affiliates, primarily for business and operational purposes. In the event Drury 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.

  6. 9.6 Sweepstakes, Contests, & Promotions

    We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions or official rules that govern that Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules (such as on a winners list).

  7. 9.7 Administration of the Drury Rewards Program Points System

    If you choose to participate in Drury Rewards loyalty program, we may share your information with third parties in order for you to redeem your points or for us to otherwise administer the program’s points system.

10. Rights of Access, Rectification, Erasure and Restriction

You are responsible for maintaining and updating, as applicable, your account registration data with current, accurate, and complete information. You may view, update, delete, and/or edit the registration data you have provided to Drury by logging in to your account and going to “My Profile” section, and following the appropriate instructions.

At any time you may seek confirmation regarding whether Drury is Processing Personal Information about you, request access to Personal Information, and ask to receive (port), amend or delete your Personal Information where it is inaccurate by calling 1-888-324-1851. Drury will make good faith efforts to implement requested changes in our active databases. Note, however, that we may keep information you update or change for Drury’s administrative purposes. Also, it is not always possible to completely remove or delete all of your information from our databases, and such requests will be processed in line with local laws.

Although Drury makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Drury 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 Drury 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, Drury will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

11. Retention

Drury retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Website(s)s or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

12. Protection of Personal Information by Drury

The security of all Personal Information provided to Drury is important to us, and we employ commercially reasonable security methods and technologies to help secure your Personal Information. However, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Drury strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to Drury, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Drury as provided in Section 12 below.

13. Redress/Compliance and Accountability

If you have any questions about this Privacy Policy or privacy concerns, please send an email to legal@druryhotels.com, call 1-888-324-1851, or write to us at 721 Emerson Road, Suite 400, St. Louis, MO 63141 ATTN: Legal Department. If Drury needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.

Drury will respond to your concerns and try to resolve any privacy issues in a timely manner. If you are an EU citizen and feel that Drury is not abiding by the provisions of this Privacy Policy, please contact Drury at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.

14. Other Rights and Important Information

  1. 14.1 Information Regarding Children

    Due to the nature of Drury’s business, services and benefits are not marketed to minors. Drury 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 Drury.

    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 and we will delete such information from our files.

  2. 14.2 Third-Party Links and Content

    Please note that Drury Website(s) may contain links to other websites, including to our Drury branded credit card partners, for your convenience and information. Drury does not control these third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Drury 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. Drury 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 Drury; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

  3. 14.3. Users Residing Outside of the United States and Consent to Transfer

    Drury Hotels Company, LLC, the Drury Site and all of our hotels are based on the United States. All Personal Information sent or collected via or by Drury 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 Drury, you consent to the storage of your Personal Information in these locations.

  4. 14.4 Changes to this Privacy Policy

    Drury reserves the right to change or modify this Privacy Policy in its discretion at any time and will notify you of material changes by posting the changed or modified Privacy Policy on our Site. We may also provide notice to you in other ways in our discretion, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified and your continued use of the Site after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

  5. 14.5 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 Drury 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, Drury 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 Drury offers that choice, Drury 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 legal@druryhotels.com or write to us at: 721 Emerson Road, Suite 400, St. Louis, MO 63141 Attn: Legal Department. You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. 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.