We use your personal information in order to fulfil our commitment to providing an unparalleled guest experience in connection with all of your interactions with San Antonio Stays (the “Purpose”). As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather.
As one of our guests or someone else with whom we interact, you understand and agree that we may collect, use, and share your personal information in accordance with this Policy.
2 The Application of this Policy
The term “San Antonio Stays Locations” include the various locations affiliated with San Antonio Stays that operate under or in connection with the San Antonio Stays®, its parent Santiago Entities, LLC, and also includes independently branded locations affiliated with San Antonio Stays and/or its direct and indirect subsidiaries
While this Policy is intended to describe the broadest range of our information collection, processing and sharing activities globally, some activities may be more limited in some jurisdictions based on the particular laws or regulations in those regions. For example, the laws of a particular country/region may limit the types of personal information we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.
3 Information We May Collect
We collect and process your personal information in order to provide you the best experience possible when you interact with us. The information we collect may vary by jurisdiction/region or by your preferred method of interaction with us. The categories of personal information that we may collect include:
- Contact and Identification Information: We may collect information such as your name, contact details (e.g. phone numbers, address, or email) professional title, employer or professional affiliations, and passport and visa information;
- Account Information and Marketing Preferences: We may collect your account details and credentials for the San Antonio Stays frequent guest program and any travel partner program. We may also collect information on your marketing preferences;
- Stay and Purchase Information: We may collect information such as the hotels where you have stayed or booked a stay, dates of arrival and departure, goods and services purchased or utilized at San Antonio Stays Locations or on the Website or Application, physical and digital property key usage, special requests made, service and stay preferences (including room and vacation preferences), and any feedback or content you provide to us regarding your stay. We may also collect information through the use of closed circuit television systems, internet systems (including wired or wireless networks, smart or mobile device, or your location), and other security and technology systems;
- Payment and Credit Information: We may collect credit card and other payment method details. In limited cases, we may also collect information relating to the credit of customers;
- Location Information: We may automatically collect information about your precise geolocation when you access the Website or Application to the extent permitted by applicable law. We may also collect information about your general location using your IP address and your zip code;
- Demographic Information: We may collect demographic information, such as your gender, nationality, age, and date and place of birth;
- Biometric and Health-related Information: We may collect health-related information you provide us to fulfil special requests (e.g., health conditions that require specific accommodation or services), or biometric information, such as information used for facial recognition;
- Audio and Visual Information: We may record our customer service calls and security footage of our properties, which may include your voice and/or image;
- Preferences and Inferences: We may collect your preferences or make inferences about you, reflecting what we believe to be your preferences, characteristics, and predispositions, based on other personal information we have
There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries or regions. Those laws define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation. In some very rare instances, financial records may constitute Sensitive Personal Information where you are located. If we rely on consent to process your Sensitive Personal Information, you have the right to withdraw that consent at any time. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law.
When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal information that you provide to San Antonio Stays that is considered to be Sensitive Personal Information or financial information. Save to the extent required by law, you are not obliged to provide San Antonio Stays with any of your Sensitive Personal Information, and should you choose not to, this will not prevent you from purchasing any products or services from San Antonio Stays.
4 How We Collect Your Personal Information
We collect the above-referenced categories of personal information from the following categories of sources:
- Directly from you: Much of the personal information we process is information that you or someone acting on your behalf directly provides to us. For example, you may provide us with Contact and Identification Information, Stay and Purchase Information, Payment Information, Demographic Information, and Health-related Information, when you create an account; book a reservation; complete surveys, sweepstakes, contests or promotional offers; contact customer service; or contact us via email, text, or chat, over the phone, in person, or through third parties.
- From other businesses or individuals: We work with business and marketing partners and social media platforms that give us personal information about you that they have collected either directly or indirectly from you. We also use features that let your friends and family give us your personal information, for example when a family member or friend checks in on your behalf. We also may receive your personal information from (i) someone acting on your behalf, such as your travel agent or your employer (where your employer books travel for you), (ii) your travel provider, such as an airline, or (iii) your third party card or loyalty scheme provider.
- From social media: If you post to one of our pages on a social media site, we may receive Contact and Identification Information, Stay and Purchase Information, Internet and Network Activity, and any other personal information contained in your social media posts or profile.
5 How We Use Your Information
Subject to applicable laws, we may collect, use, and disclose your personal information in order to:
- provide, charge for, and manage hotel accommodation and other goods and services;
- provide you with customer support and a better or more personalized level of service at San Antonio Stays Locations as well as through the Website, Application, frequent guest program, third party applications, products or services, or through products or services San Antonio Stays develops in the future;
- allow us to evaluate, analyze, and improve the functionality of our Websites, Applications, or goods and services;
- facilitate concierge services on your behalf, e.g., restaurant, attraction and transportation transactions;
- administer loyalty, travel, or discount programs and the San Antonio Stays frequent guest program;
- administer contests, sweepstakes, or other promotions;
- fulfil contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and vendors (e.g., credit card companies, airline operators, and third-party loyalty, travel, or discount programs);
- conduct market research, customer satisfaction and quality assurance surveys;
- conduct marketing and sales promotions and serve targeted advertising for products, services, events, or promotions you might be interested in. Where permitted by law, we may work with other companies to serve advertisements or marketing that we think you may find relevant and useful. This may include advertisements displayed on our own Websites or Applications, contained in emails or other communications sent by us, or advertisements from us displayed on other companies' websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our Websites, Applications or third-party websites;
- provide for the safety and security of staff, guests and other visitors;
- prevent, detect, and investigate fraud, cyber incidents, or other illegal activity;
- communicate with you about our relationship, such as updates to this Policy or other important legal or business changes;
- administer general record keeping;
- meet legal and regulatory requirements;
- test and evaluate new products and services;
- process credit applications;
- fulfil other purposes as disclosed to you in accordance with applicable law or with your consent; and
- use certain pieces of personal information to verify your identity if you make requests regarding your personal information pursuant to this Policy. The verification steps and the pieces of personal information that we request may vary depending on the sensitivity and nature of your request.
When we process your personal information as one of our guests or someone else with whom we do business, we do so in our legitimate interests (as detailed above), because of legal obligations we are subject to, or because the information is required to fulfil contractual obligations either to you, to anyone involved in making your travel arrangements (e.g., travel agents, group travel organizers, or your employer) and/or to vendors (e.g., credit card companies, airline operators, and third party loyalty, travel, or discount programs).
San Antonio Stays uses and retains your personal information for as long as is necessary to fulfil the purpose for which it is being processed, and in line with our legal and regulatory obligations and risk management guidelines.
6 Disclosures of your Personal Information
From time to time, we may disclose your personal information. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the purpose and to the extent stated in this section and as described in Section 5 above.
Circumstances where we might make such disclosure (in addition to those described in Section 5 above) include:
6.1 Our Agents, Service Providers, and Suppliers
Like most international hotel brands, we may outsource the processing of certain functions and/or information to third parties. When we do outsource the processing of your personal information to third parties or provide your personal information to third-party service providers, we oblige those third parties to protect your personal information in accordance with the terms and conditions of this Policy, with appropriate security measures.
6.2 Consumer Insights
Where we hold personal information about you, we may disclose this personal information to other companies that also hold information about you. These companies may combine the information in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal information is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 11 below. Further information about how we conduct direct marketing may be found at Section 9 below.
6.3 Credit Authorization
When you request credit, your personal information will be used and disclosed to appropriate third parties in accordance with applicable laws for the purpose of determining whether to grant and maintain a line of credit to you.
6.4 Business Transfers
As we continue to develop our business, we may sell properties and other assets, or cease being the manager of a San Antonio Stays Location. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected about you, or control of such information, may be one of the transferred assets.
6.5 Legal Requirements
We reserve the right to disclose any personal information we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal information collected and to process such personal information to comply with accounting and tax rules and regulations and any specific record retention laws.
7 Interacting with us online
If you interact with us online, you may wish to know the following:
7.1 You Can Browse Without Revealing Who You Are
You can always visit our websites without logging in or otherwise revealing who you are.
7.2 Cookies and Related Technologies
Further information about cookies and related technologies and how they work is available at allaboutcookies.org.
7.3 Social Media
Our websites may also contain plug-ins and other features that integrate third party social media platforms into our websites. You will be able to activate them manually. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
7.5 Links to Other Websites
If you visit a San Antonio Stays website and decide, for example, to purchase a gift certificate or other service, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. If you click on a link found on our websites or on any other website, you should always look at the location bar within your browser to determine whether you have been linked to a different website. This Policy, and our responsibility, is limited to our own information collection practices. We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.
Because the security of your personal information is important to us, we require Transport Layer Security (“TLS”) software in order to encrypt the personal information that you provide to us. When using TLS, your transmission of personal information to us online is encrypted. You can verify whether your personal information is transmitted using TLS encryption by confirming the symbol of a closed lock or solid key inside your browser address bar. You can also verify that your personal information will be encrypted using TLS encryption by making sure that the prefix for the web address listed for that page has changed from "http" to "https". If you do not see the appropriate symbol and/or the "https" prefix, you should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission.
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.
7.7 Minor Children
Our websites do not sell products or services for purchase by children and we do not knowingly solicit or collect personal information from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites), you may only use our websites with the involvement of a parent or guardian.
You may always choose what personal information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
If you provide us with your contact details (e.g., postal address, email address, telephone number or fax number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. We may also share your personal information with carefully-selected third parties, who may communicate directly with you. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 11 below or following the “unsubscribe” instructions contained in the communications.
In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g., where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g., where the information collected is regarded to be Sensitive Personal Information under local regulations).
We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be "suppressed" rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
10 Changes to this Policy
Just as our business changes constantly, this Policy may also change. To assist you, this Policy has an effective date set out at the end of this document.
11 Request for Access to Personal Information/Questions or Complaints
If you have any questions about this Policy, about the processing of your data described, or any concerns or complaints with regard to the administration of the Policy, or if you would like to submit a request (in the manner described in Section 10 above) to exercise your rights in relation to the personal information that we maintain about you, please contact San Antonio Stays at:
- Santiago Entities, LLC
- Attn: Personal Information, Legal Department
- PO Box 830354
- San Antonio, TX 78283
All requests for access to your personal information must be submitted in writing by letter or email. We may respond to your request by letter, email, telephone or any other suitable method.
Effective Date: September 2021