Privacy Policy

Last Updated: April 25, 2019

7 Drayton Street Hotel, LLC, 7 Drayton Street Hotel MT LLC and Drayton Hotel Management, LLC (collectively “The Drayton Hotel”, “we”, “us” and “our”) takes your privacy seriously. This Privacy Notice (together with our Terms of Service and the Cookies Policy and any other policies that are referenced in this Privacy Notice) describes the information we collect from hotel and restaurant guests and visitors to the The Drayton Hotel website (our "Website"), and how The Drayton Hotel uses this information.

WHAT IS PERSONAL INFORMATION?

We define personal information as any information that can identify you as an individual. Personal information includes factual information, such as an individual's name, age, gender, passport information, address, email and phone number; financial information, itemized spending and transaction history; health information; and preferences, such as special requests, service issues and other preferences for your stay.

Personal information may also include information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information, in the case of our mobile App).

INFORMATION YOU GIVE TO US

When you visit the Hotel, its restaurants, spa, or other facilities, or contact us through our Website, or by corresponding with us by phone, e-mail, or otherwise, we may collect personal information.

INFORMATION WE COLLECT ABOUT YOU

When you visit our Website, our web server automatically collects and stores the following information:

Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, referring website address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages on our Website you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

INFORMATION WE RECEIVE FROM OTHER SOURCES

We may receive personal information about you from third parties who operate other sites or services we use to provide our products and services to you. We work closely with third parties, including, for example, business partners, promoters, affiliates, and sub-contractors in technical, payment and delivery services, advertising networks, marketing analytics providers, promotions, and search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use your personal information for the following purposes:

to enable you to use our Website and our mobile application;

to help us identify you and any accounts you hold with us;

to provide personalized customer service to you;

to assist us in making your reservation and providing the services you request at any of our properties;

to process transactions through our Website (including taking payment for purchases you may make through our Website) and to assist in any inquiries about your transaction;

to bill you for your stay with us and any charges you may incur;

to confirm prior transactions and reconcile statements or invoices;

to contact you in relation to matters that arise from your stay with us;

subject to your consent, to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you, and to conduct surveys or focus groups to receive your views of our properties and service delivery;

to respond to a specific "Information Request" from you and deal with any other enquiries, correspondence, concerns or complaints you have raised;

to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.

Occasionally we will combine information from Guests to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual.

We may also use your personal information for the following reasons:

to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;

to improve our business and minimize any disruption to the services that we may offer to you, to make our communications with you more relevant and personalized to you, and to make your experience of our services more efficient and effective;

for the establishment, exercise or defense of legal claims or proceedings.

In any other case, we would only use your personal information with your prior consent.

COOKIES

Our Site uses cookies to personalize your experience and target advertising. Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are used to “remember” you and your preferences, either for a single visit or for multiple repeat visits. They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting, or by third parties, such as those who serve content or provide advertising or analytics services on our Website. For more information, see our Cookie Policy.

HOW DO WE PROTECT PERSONAL INFORMATION?

We use reasonable security measures that are intended to protect your personal information from unauthorized access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws.

We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties.

You should remember that any unencrypted e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact Us” section of our Website). We recommend that you do not include any confidential information (i.e. credit card information) when using e-mail.

WHAT PERSONAL INFORMATION MAY BE PROVIDED TO THIRD PARTIES?

We may share certain of your personal information with:

analytics and search engine providers that assist The Drayton Hotel to improve and optimize our Website;

our professional advisors and auditors;

with third parties that help us provide our services to you; and

local or foreign regulators, governments, courts, law enforcement and national security authorities in order to comply with their requests and our legal obligations.

Where a third party is engaged by The Drayton Hotel to provide services on our behalf, The Drayton Hotel requires these parties to agree to protect your personal information in a manner consistent with the this Privacy Notice.

We do not sell or rent our subscription lists to anyone.

If The Drayton Hotel suspects any unlawful activity is taking place, it may investigate and report its findings or suspicions to the police or other relevant law enforcement agency.

LINKS TO OTHER SITES

Our Website contains links to affiliates and other websites. The Drayton Hotel does not claim nor accept responsibility for any privacy policies, practices or procedures of other such websites. We encourage all users and visitors to be aware when they leave our website and to read the privacy statements of each and every website that collects personally identifiable information. This Privacy Notice applies only and solely to the information collected by our Website or by The Drayton Hotel through other means, such as in person, by telephone or email, collected on our behalf by third parties.

YOUR RIGHTS

ACCESSING YOUR PERSONAL INFORMATION

We understand that you may want to know what personal information we hold about you. We will comply with your request, but to protect your personal information, we require that you verify your identity to us at the time your request is made.

When you make a request in person, we will require you to produce some form of photo identification such as a passport or a driver's license and you will be asked to sign a request form.

Where you make a request by other means, we request you contact us in writing via email, fax or letter including a copy of a government issued identification and signature. We require home and business addresses and phone numbers so we can check them with our files and satisfy ourselves as to your identity.

The Drayton Hotel reserves the right to decline access to your personal information under certain circumstances as permitted by law. If your personal information is not disclosed to you, you will be provided with the reasons for this non-disclosure.

OTHER RIGHTS

You may also:

request us to correct or delete your personal information;

request that we restrict our use of your personal information;

request that we not use your personal information for direct marketing purposes;

withdraw your consent to the processing of your personal information ; and

request that we transfer your personal information to another organization, in machine-readable form.

If you do not wish to receive marketing information from The Drayton Hotel, you may indicate your wishes on your registration card when you stay with us or send an e-mail to: info@thedraytonhotel.com You will always have the ability to accept or decline any form of communication from the The Drayton Hotel. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see ‘How do we use your personal information?’) or that you are unable to make use of the services offered by us.

After you have chosen to withdraw your consent The Drayton Hotel may be able to continue to process your personal information to the extent required or otherwise permitted by law.

If at any time you wish to exercise any of these rights, you can do so by:

Contacting our Reservations Manager:
via e-mail at concierge@thedraytonhotel.com

via letter to:
General Manager
The Drayton Hotel
7 Drayton Street, Savannah, GA 31401

HOW LONG IS MY PERSONAL INFORMATION RETAINED?

Your personal information will be stored for the period of time required by law in the jurisdiction of any hotel holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer required for any of the purposes described above.

We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving The Drayton Hotel.

Any financial information The Drayton Hotel retains will be protected under the terms of this Privacy Notice and, where financing is arranged in the United States, under the Financial Services Modernization Act.

VISITORS AND CUSTOMERS OUTSIDE THE UNITED STATES

Our website and the servers that make our Website available worldwide are located in the United States. The laws of the United States govern all matters relating to our Website. Any information you provide in subscribing to our Website or registering or ordering at our Website will be transferred to the United States. By visiting our Website and submitting information, you authorize this transfer, processing and use.

CHANGES IN CORPORATE STRUCTURE

In developing our business, we may engage in the sale of certain assets and the company itself, or parts of it, may be sold, merged or otherwise transferred. In such transactions and changes in ownership, user information, whether personally identifiable or otherwise, may constitute one of the transferred assets. We will notify affected users in accordance with the procedure for changing this Privacy Notice described below.

CALIFORNIA PRIVACY RIGHTS

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of personal information, such as name, address, e‐mail address, and the type of services provided to that customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at concierge@thedraytonhotel.com.

Some internet browsers have incorporated "Do Not Track" features. Most of these features, when turned on, send a signal or preference (a "DNT Signal") to the web sites you visit indicating that you do not wish to be tracked. Because there is not yet a common understanding of how to interpret DNT Signals, and there is no common definition of "tracking," we d o not currently respond to DNT Signals on our Website.

CHILDREN’S PRIVACY

None of the information on our Website is intended for the use of children under 13, and we do not knowingly register any person or accept information from any person under the age of 13.

CHANGES TO OUR PRIVACY NOTICE

We will occasionally update this Privacy Notice as necessary to protect our users and to comply with a changing environment. We recommend that you check the Privacy Notice when you visit our Website to be sure that you are aware of and understand our current policy. If we make material changes to this policy, or in how we use or collect your personal information, we will prominently post such changes prior to implementing the change. We will not make any retroactive material changes in how we handle previously collected personal information unless you allow us to do so, or unless we are legally required to do so, and in such a case we will e-mail registered website visitors information on material changes to this Privacy Notice.

ACCEPTANCE OF TERMS

Through the use of our Website, and by providing to us any personal information, you accept the terms and conditions stipulated within this Privacy Notice. If you do not agree with our terms and conditions, then you should refrain from further use of our Website. In addition, your continued use of our Website following the posting of any updates or changes to our Privacy Notice, Terms of Use, and Cookies policy shall mean that you are in agreement and acceptance of such changes.

CONTACT US

If you have any questions or concerns regarding this Privacy Notice, please contact our Manager by writing to the following address:

via e-mail at concierge@thedraytonhotel.com

via letter:

General Manager

The Drayton Hotel

7 Drayton Street

Savannah, GA 31401

The Drayton Hotel Cookie Policy

Effective: April 25, 2019

A browser cookie is a small piece of data that is stored on your device to help websites and mobile apps remember things about you. Other technologies, including Web storage and identifiers associated with your device, may be used for similar purposes. In this policy, we say “cookies” to refer to all of these technologies.

Our Privacy Notice explains how we collect and use information from and about you. This policy explains more about how we use cookies and your related choices.

How We Use Cookies

The Drayton Hotel uses cookies, including third-party cookies, for a number of reasons, like protecting your data and account, helping us see which features are most popular, counting visitors to a page, improving our users’ experience, keeping our services secure, providing relevant advertising, and generally providing you with a better, more intuitive, and satisfying experience. The cookies we use generally fall into one of the following categories.

CATEGORY OF COOKIES | WHY WE USE THESE COOKIES

Necessary – We use these cookies to run our site, and to identify and prevent security risks. For example, we may use these cookies to store your session information to prevent others from changing your password without your username and password.

Preferences – We use these cookies to remember your settings and preferences, and to improve your experience on our site. For example, we may use these cookies to remember your language preferences.

Performance – We use these cookies to collect information about how you use our site, monitor site performance, and improve our site performance, our services, and your experience. For example, we can use these cookies to learn more about which features are the most popular with our users and which ones might need some tweaks.

Marketing – We use these cookies to deliver advertisements, to make them more relevant and meaningful to consumers, and to track the efficiency of our advertising campaigns, both on our services and on other sites or mobile apps. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites.

YOUR CHOICES

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. For more information about how to manage browser cookies, please follow the instructions provided by your browser.

BROWSER COOKIES

MOBILE DEVICE IDENTIFIERS

Your mobile operating system may let you opt-out from having certain device identifiers used for interest-based advertising. You should refer to the instructions provided by your mobile device’s manufacturer; this information is typically available under the “settings” function of your mobile device.

And of course, if your mobile device offers an uninstall process, you can always stop us from collecting information through the app by uninstalling The Drayton Hotel app.

CHANGE YOUR SETTINGS

You can also block certain cookies by adjusting your settings on our site.