EFFECTIVE DATE: May 17, 2018
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.
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.
Drury may collect information about you from third party sources to provide the services you request or to supplement information provided by you.
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.
Depending on how you interact with Drury, we and our third party-service providers may use Personal Information in a variety of ways, including:
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.
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.
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.
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.
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.
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.
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.
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
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 analyse 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.
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.
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.
In addition to embedded scripts, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behaviour 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.
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 behavioural advertising.”
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 endeavour 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.
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.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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.
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.
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.
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 firstname.lastname@example.org 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.