Privacy Policy

Last Updated: December 12, 2024

It is part of 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.

• For more information about our European Union privacy practices, click here

Some state laws allow certain rights relating to personal data. If you live in the U.S. in one of the states below, please select your state of residency to review your state’s rights and subject rights request processes.

• For more information about our California privacy practices, click here
• For more information about our Virginia privacy practices, click here
• For more information about our Colorado privacy practices, click here
• For more information about our Connecticut privacy practices, click here
• For more information about our Nevada privacy practices, click here
• For more information about our Texas privacy practices, click here
• For more information about our Montana privacy practices, click here
• For more information about our Oregon privacy practices, click here

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.

COLLECTING DATA

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 WE COLLECT

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:

• Contact information: First and last name, Email address, Phone number, Address, State, Province, ZIP/Postal code, City, etc.
• Demographic information: Age, gender, date of birth, anniversary, primary language, etc.
• Reservation/Visit: Date of arrival and departure, special requests, goods, and services purchased and consumed, etc.
• Interests and Preferences: Regarding past, current and future stays at the Independent Collection properties, such as your interests, activities, hobbies, food, and beverage choices, etc.

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.

PAYMENT PROCESSING INFORMATION

When you make a payment in connection with purchasing any of the Services, the Independent Collection may obtain credit card or other payment information.

NOTICE OF FINANCIAL INCENTIVES

Members of IC ‘Independent Collection’ Insider Program may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the “Programs.”

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, geolocation data, or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see “Personal Data We Collect” in our Privacy Policy. Members of The IC ‘Independent Collection’ Insider Program may offer various loyalty or promotional programs that may be deemed a “bona fide loyalty program” under Colorado law or a “financial incentive” under California law. Please find the specific terms here. If you have any questions or require assistance, please contact us at privacy@independentcollection.com.

USAGE DATA

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:

COOKIES

A cookie is a small data file which 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:

• Necessary / Essential Cookies 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.
• Cookies Policy / Notice Acceptance Cookies Type:
  • Persistent Cookies; Administered by: Us Purpose: These cookies identify if users have accepted the use of cookies on the website(s).
• Functionality Cookies 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).
• Tracking and Performance Cookies 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.
• Targeting and Advertising Cookies 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.

USING AND DISCLOSING DATA

The data and other information that we collect is used and disclosed in the following manner(s) and for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage your account: to manage your registration as a user of the Service. The information you provide can give you access to different functionalities of the Service that are available only to a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Service.
• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.
• To tailor content, recommendations and offers we display to you on the Services and elsewhere online.
• Improve the Services and our products, including asking you to participate in surveys, and for other internal business 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:

• Owners: We disclose data, including personal data, and other information to owners of the Independent Collection’s properties for the purposes described in this Privacy Policy, such as providing and personalizing the Services.
• Strategic Business Partners: We disclose data, including personal data, and other information with select strategic business partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you. By sharing data with these parties, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables spa, restaurant, concierge, and other outlets at our properties to provide you with services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars, and vacation packages.
• Service Providers: We disclose data, including personal data, and other information to third-party service providers for the purposes described in this Privacy Policy. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services.
• Corporate Reorganization/Business Transfers: We may disclose or transfer your personal data and other information to a third party in the event of any reorganization, merger, sale of our assets, financing, joint venture, assignment, transfer or other disposition of all or any portion of the Independent Collection business, assets or stock. We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business to another company. In any such case, the successor organization’s use and disclosure of your personal data will continue to be subject to this policy unless (i) a court orders otherwise, for example a bankruptcy court; or (ii) the successor organization gives you notice that your personal data will be subject to the successor organization’s own policy, along with an opportunity for you to opt out (which may cause you not to be able to continue to use the website). If you submit personal data after such a transfer, that information may be subject to the successor entity’s policy.
• Sweepstakes, Contests and Promotions: We may work with third parties that sponsor or offer sweepstakes, contests, and other promotions. By participating in a promotion, you are agreeing to the terms, conditions or official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing us and the sponsor(s) of the promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing. 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.
• With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed. If you interact with other users or register through a third-party social media platform, your contacts on such social media platform may see your name, profile, pictures, and description of your activity. Similarly, other users may be able to view descriptions of your activity, communicate with you and view your profile.

RETENTION OF DATA

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.

THIRD-PARTY LINKS

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.

CONSENT TO TRANSFER

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.

Information Security 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.

CHILDREN’S PRIVACY

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.

EUROPEAN UNION PRIVACY

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 have 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 European Union Privacy notice.

ADDITIONAL INFORMATION ON THE PROCESSING OF PERSONAL DATA

ADVERTISING

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:

• Google AdSense & DoubleClick Cookie: Google uses cookies to serve ads on our Service. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Service or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.
• Bing Ads: Bing Ads Opt-out page: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads For more information about Bing Ads, please visit their Privacy Policy: https://privacy.microsoft.com/en-us/PrivacyStatement.

To submit a request to “opt out” of “targeted advertising” or the “sale” of your “personal data,” you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). We will process the GPC signal as a request to opt out.

EMAIL MARKETING

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/.

BEHAVIORAL REMARKETING

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 and non-cookie technologies to inform, optimize and serve ads based on your past visits to our Service.

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN 

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

Google Ads (AdWords): Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.

Bing Ads Remarketing: Bing Ads remarketing service is provided by Microsoft Inc. You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads. 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.

Twitter: Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy.

Facebook/Instagram: Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/769828729705201. 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.

AdRoll: AdRoll remarketing service is provided by Semantic Sugar, Inc. You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy.

FACEBOOK FAN PAGE

Data Controller for the Facebook Fan Page: We are the Data Controller of personal data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/StayIndependentCollection, the Independent Collection and Facebook are Joint Controllers. Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights: We use the Facebook Insights function in connection with the operation of the Facebook Fan Page in order to obtain anonymized statistical data about our users. For this purpose, Facebook places a Cookie on the device of the user visiting our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period. Facebook receives, records, and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services. For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy.

USAGE, PERFORMANCE AND MISCELLANEOUS

We may use third-party service providers to improve our Service.

• Invisible reCAPTCHA
  • 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/.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

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.

CONTACT US

If you have any questions about this Privacy Policy, the practices, or use of the website(s) or Services, you can contact us:

By email: privacy@independentcollection.com

By mail: Independent Collection ATTN: Legal 2001 Market Street, Suite 3500, Philadelphia, PA 19103