This Privacy Statement describes the privacy practices of the Marriott Group for data that we collect: through websites operated by us from which you are accessing this Privacy Statement, including Marriott.com and other websites owned or controlled by the Marriott Group (collectively, the Websites); through the software applications made available by us for use on or through computers and mobile devices (the Apps); through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our Social Media Pages); through email messages that we send you that link to this Privacy Statement and through your communications with us online or in person; from third parties such as Authorized Licensees, Strategic Business Partners, Owners and Franchisees, and Other Sources, such as public databases, marketing partners and other third parties; and when you visit or stay as a guest at one of our properties, or at homes and villas offered on the Homes and Villas by Marriott International platform (Homes and Villas), or through other offline interactions (collectively, Property Visits and Offline Interactions). Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with the Property Visits and Offline Interactions, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.

THE DATA WE COLLECT
At touchpoints throughout your guest journey, we collect Personal Data in accordance with law, and to serve you better. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual: Name, Gender, Postal address, Telephone number, Email address, Credit and debit card number or other payment data, Language preference, Date and place of birth, Nationality, passport, visa or other government-issued identification data, Important dates: birthdays, anniversaries and special occasions, Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations), Employer details Travel itinerary, tour group, or activity data, Prior guest stays or interactions, goods and services purchased, special service and amenity requests, Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts. In more limited circumstances, we may also collect: Data about family members and companions, names and ages of children, Biometric data, Financial information, 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.

We may also collect information about your Preferences that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information about you that we learn about during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and specific dietary or health restrictions to ensure your wellbeing. We may also collect your “Personal Preferences,” that may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship to you and your marital status.

If you submit any Personal Data about other people to us or our Service Providers (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 Statement.

COOKIES AND OTHER DATA
We may also collect “Other Data” that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data.

Other Data include: Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.

Your use of the Apps. We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers, and what data and files have been downloaded to the App based on your device number. We use this data to ensure that the Online Services function properly. Our Apps may contain software development kits (SDKs) from third parties which may collect and transmit Other Data to enable various features in the App. We may also collect mobile device advertising identifiers to enhance and personalize your experience and deliver relevant products, content or ads to show you on our Website, Apps or external advertising.

Changing Your App Preferences for Collecting Mobile Device Advertising Identifiers. You can set your preferences in our Bonvoy™ Mobile App by logging into the app, going to the “Account” section of the app, select the settings button (circle gear icon) in the lower right-hand corner of the Account section, select your “Communication Preferences” and then, “Offers from our Partners.” In addition, you can reset advertising identifiers or disable them within your mobile device’s privacy settings.

Optional App Features. Our Apps may contain optional features made available to developers by the device’s operating system. To improve your experience we may require your permission for the use of your device’s location, camera, or other functions (e.g. using your device’s camera to capture your credit card information). You may choose not to allow the use of such functions, in which case the App features relying on such functions may not be available to you. Go to your device’s settings to manage these permissions.

Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on the Online Services, pages visited, referring URL, language preferences and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical cookie data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services. We also use them to send marketing emails and to track responses to online advertisements and marketing emails.

Opting Out of Cookies. You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our home page. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser.

“Do-Not-Track” signals.
Third Party Advertising. We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites, or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags).

Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.

Analytics. We 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. We collect data through Flash LSOs and other technologies on some Websites to, among other things, collect and store data about your use of the Online Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel . You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used with the Online Services.

Your IP Address. We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.

Aggregated And Segmented Data. We may aggregate data that we collected and this aggregated data will not personally identify you or any other user. We may also use both Personal Data and Other Data to divide customers into segments, or groups, in order to provide more relevant advertising.

Location-Based Services. We may collect the precise physical location of your device by using satellite, cell phone tower, WiFi signals, or other technologies. We will collect this data if you opt-in through the App or other program (either during your initial login or later) to improve special offers and to enable location-driven capabilities on your mobile device. If you have opted-in to share your location, the App or other program will continue to collect location data based on how you chose to share the data.

Location Opt-Out: The user can specify via the device’s operating system to always share location, only when the App is in use, or never. If you choose only when the App is in use, we will have access to the data until you log off or close the application or if you use your phone’s or other device’s settings to disable location capabilities for the Bonvoy™ App or other program.

HOW AND WHERE WE COLLECT YOUR DATA
This Privacy Statement describes the privacy practices of the Marriott Group for Personal and Other Data that we collect through the following:

Online Services. We collect Personal or Other Data when you interact with our Online Services, by performing such actions as, but not limited to, browsing, making a reservation, purchasing goods and services from our Websites or Apps, communicating with us or otherwise connecting with us or post to social media pages, or signing up for a newsletter or participating in a survey, contest or promotional offer.

Property Visits and Offline Interactions. We collect Personal Data when you visit our properties, Homes and Villas, or use on-property services and outlets, restaurants, concierge services, health clubs, child care services and spas. We also collect Personal Data when you attend promotional events that we host, sponsor, or in which we participate, or when you provide your Personal Data to facilitate an event.

Customer Care Centers. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance and training.

Owners and Franchisees. We collect Personal Data from Owners of Marriott Group branded properties that we manage. We also collect Personal Data from Franchisees of Marriott Group branded properties that are independently owned and operated under a franchise agreement with us. Owners and Franchisees are independent from the Marriott Group. Franchisees include their third party operators and management companies.

Homes and Villas Property Management Companies. We collect Personal Data from companies and their service providers who manage Homes and Villas properties, your booking of Homes and Villas and provide additional support to you during your stay at Homes and Villas (“Homes and Villas Property Management Companies”). Homes and Villas Property Management Companies are independent from the Marriott Group.

Authorized Licensees. We collect Personal Data from companies when we enter into a license or similar agreement to sell goods and services under a Marriott Group brand (“Authorized Licensees”). Examples of Authorized Licensees include our time share partners, Marriott Vacations Worldwide Corporation and Vistana Signature Experiences, Inc. Examples of other Authorized Licensees include Cruise Yacht Optco Ltd. d/b/a The Ritz-Carlton Yacht Collection, developers of Marriott Group branded real estate and co-branded credit card partners. Authorized Licensees are independent from the Marriott Group.

Strategic Business Partners. We collect Personal Data from companies with whom we partner to provide you with goods, services, or offers based upon your experiences at our properties or Homes and Villas, or that we believe will be of interest to you (“Strategic Business Partners”). Examples of Strategic Business Partners include on-property outlets, travel and tour partners, time share partners, rental car providers and travel booking platforms. Strategic Business Partners are independent from the Marriott Group.

Other Sources. We collect Personal Data from public databases, joint marketing partners and other third parties.

Internet-Connected Devices. We collect Personal and Other Data from internet-connected devices available in our properties. For example, when you connect a device to the hotel’s internet, a smart home assistant may be available for your use to tailor your accommodations and experience.

WHY WE COLLECT YOUR DATA (LEGAL BASIS)
HOW AND WHEN WE SHARE YOUR DATA
Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data and Other Data with the following third parties:

Marriott Group. We disclose Personal Data and Other Data to other companies within the Marriott Group for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communication with you, facilitating the loyalty programs and to accomplish our business purposes. We share your Personal Data and Other Data used for making a reservation with the applicable property and Marriott entity to fulfill and complete your reservation.

Service Providers. We disclose Personal Data and Other Data to third party service providers including, for example, 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. To see our Privacy Shield Policy related to Disclosures to Service Providers, please go to our Privacy Shield Policy for Guest Data.

Franchisees. We disclose Personal Data and Other Data to Franchisees of Marriott Group branded properties for the purposes described in this Global Privacy Statement. Franchisees have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers for the following processing: Franchisees manage and coordinate your stay at hotels that they operate so they may use your Personal Data for that purpose. Franchisees may also use your Personal Data for compliance with their own legal obligations, including maintaining books & records.

Owners. We disclose Personal Data and Other Data to Owners of Marriott Group branded properties for the purposes described in this Global Privacy Statement. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data controllers for the following processing: Owners may use your Personal Data for complying with their own legal obligations, including maintaining books & records.

Homes and Villas Property Management Companies. We disclose Personal Data and Other Data to Homes and Villas Property Management Companies and their service providers for the purpose described in this Privacy Statement, such as providing, facilitating, and personalizing the Services, facilitating the loyalty programs and their own marketing.

Authorized Licensees. Where allowed by law we disclose Personal Data and Other Data to our Authorized Licensees, including Ritz-Carleton Yacht Collection and Marriott Vacations Worldwide, for the purposes described in this Privacy Statement, such as providing and personalizing the Services, fulfilling your requests and providing their own marketing. For example, this sharing enables you to purchase Marriott branded goods and services, including time share properties.

On-Property and/or Travel Partners. We may share your information with spa, restaurant, health club, concierge and other outlets at our properties to provide you with services and their own marketing, such as with Disney Destinations, LLC and Walt Disney Travel Company when you stay at one of our properties affiliated with Walt Disney World®. 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.

Strategic Business Partners. As allowed by applicable law, we disclose Personal Data and Other Data with select Strategic Business Partners who provide goods, services and offers that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you.

Linked Accounts and Promotional Activity. We partner with certain third parties that allow you to enroll in their services or participate in their promotions. For example, certain companies allow you to use your loyalty program number or Online Services login to receive or register for their services. These companies include airlines and rental car providers, as well as sponsors of sweepstakes and contests. Additionally, your social media account provider allows you to connect your social media account to your Online Services account or log into your Online Services account from your social media account. When you enroll in those services, we disclose your Personal Data and Other Data to those third parties. If you do not want us to share your Personal Data or Other Data in this way, do not provide your loyalty program number to third parties, do not use your Online Services login to register for third-party promotions and do not connect your Online Services account with accounts on third-party services. Data shared in this way will be governed by the third party’s privacy policy and not this Privacy Statement.

eFolio Program. If you are an employee of a company that participates in the Marriott Group eFolio Program and book your room using a company corporate code or pay for your expenses using a corporate credit card, an extract of your folio detailing the goods and services provided to you may be sent to your company and to the credit card company. This Privacy Statement does not apply to the handling of your Personal Data by your employer, credit card company or bank, and we are not responsible for their practices.

Other Uses and Disclosures. We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations, such as in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Marriott Group business, assets or stock (including any bankruptcy or similar proceedings); (f) to protect the rights, privacy, safety or property of the Marriott Group, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law.

YOUR DATA, YOUR CHOICES: YOUR PRIVACY PREFERENCES & RIGHTS
At Marriott, we believe that you should have choices with respect to your data. We provide you with the options, information and choices below to express your preferences: what and how much you share with us and when and how you hear from us.

Communications and Preferences. To change how, how often, we or our partners communicate with you, please sign into your loyalty account profile and select Communication Preferences. You can also use the unsubscribe link at the bottom of any of our communications. If you no longer wish to receive marketing-related emails, you may opt out by visiting our unsubscribe page or by following the instructions in any such email you receive from us. In addition, you can opt out from marketing-related emails by sending a letter to: Internet Customer Care – Unsubscribe, 1818 North 90 Street, Omaha, Nebraska 68114-1315 USA. NOTE: Even if you choose to opt out of marketing-related emails, we will continue to send you transactional messages about your reservations or stays, including pre-arrival, confirmation and guest satisfaction surveys. If you want to adjust your Stay Preferences, log into your loyalty account and choose Room Options, Stay Preferences.

Cookies and Other Data. For information on your choices related to Cookies and Other Data, please see the Section on Cookies and Other Data, above.

How You Can Request to Access, Change, Delete, Restrict the Use or Object to the Processing of Your Personal Data. If you would like to request to access, change, delete, restrict the use of, or object to the processing of your Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent these rights are provided to you by law), please visit our Individual Rights Portal and complete this form . If you have any questions about the form or our process, feel free to contact us at privacy@marriott.com. For your protection, we only fulfill requests for the Personal Data associated with the email address and/or loyalty account number that you identify in your request, and we may need to verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request. Marriott acknowledges and respects our guests’ privacy and we will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Notice for California Residents: Customers who reside in California and have provided their Personal Data to us can request, once per calendar year, information about our sharing of certain categories of Personal Data to third parties and within the Marriott Group, for direct marketing purposes. Such requests should be submitted to us at privacy@marriott.com. California residents can find more information on exercising their rights under the CCPA by reading our California Consumer Privacy Statement or by calling 1-800-218-9316. Notice for Nevada Residents: To exercise your individual rights under the Nevada Privacy Law (NRS Ch. 603A, Sec. 2(2)), please visit our Individual Rights Portal. If you have given us consent in relation to particular action or activities, you can withdraw your consent at any time by contacting us.

OTHER IMPORTANT PROVISIONS
Non-Marriott Group Entities. This Privacy Statement does not address, and we are not responsible for the privacy, data, or other practices of any entities outside of the Marriott Group, including Franchisees, Owners, Homes and Villas Property Management Companies, Authorized Licensees, Strategic Business Partners, or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We generally have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data. In addition, we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through or the Apps or our social media pages.

Security. We seek to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.

Retention. We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services). Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them). Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

Sensitive Data. Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Data (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

Use of Services by Minors. The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Data through the Services.

Cross-Border Transfer. The Marriott Group is a global organization and provides a global service. Sharing data cross-border is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer Personal Data and Other Data collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By making a reservation, visiting or staying at a Marriott branded property or using any Marriott Group branded service, you understand that we transfer your Personal Data globally. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Data.

Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here) . The Marriott Group enters into Standard Contractual Clauses or another approved mechanism for cross-border transfer where appropriate.

Prior Privacy Shield Certification. Marriott International, Inc. and certain of its U.S. affiliates previously have certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, regarding the collection, use, and retention of personal information transferred from the EEA, Switzerland, and the United Kingdom to the United States, prior to July 16, 2020. Our certifications can be found at: www.privacyshield.gov/list. For more information about the Privacy Shield principles, please visit: www.privacyshield.gov. In some circumstances, we may also transfer data by entering into Standard Contractual Clauses.

For additional information about our complaints management practices and contacts, please refer to our Privacy Shield Guest Privacy Policy. Because your email communications to us may not always be secure, please do not include credit card or Sensitive Data in your emails to us.

Updates to This Privacy Statement. The “Last Updated” legend at the top of this page indicates when this Privacy Statement was last revised. Any changes will become effective when we post the revised Privacy Statement on the Online Services. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, please contact us at privacy@marriott.com.