LodgIQ Privacy Policy

Effective Date: May 1, 2016

Overview
LodgIQ provides a software product enabling hotel companies to manage their business forecast and analytical reporting. LodgIQ RM extracts intelligent revenue insights through deep analysis of big data to maximize price optimization and simplify everyday revenue management tasks.

This Privacy Policy identifies the purposes for which personal information is collected, used and disclosed by LodgIQ.

Definition of Terms
In the context of this Privacy Policy document, the phrase “Personal Information” refers to information identifying a specific individual, such as his/her name, postal address, email address or telephone number.

Non-personal information such as product preferences or system browsing history is directly associated with personal information and that information also becomes Personal Information for the purposes of this policy document.

“Sensitive Information” means Personal Information revealing race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or information concerning an individual’s health.

Personal Information Collection
As a third-party software service provider to hotel companies, LodgIQ might receive Personal Information that was initially disclosed to the hotel companies during the creation of a hotel reservation or a hotel room allocation. The information received might include name, postal address, email address and telephone number, booking preferences, loyalty membership and special request information. The responsibility for providing notice and choice to individuals from whom personal information is collected belongs to the hotel companies.

Consent
Any Personal information which is collected, used and disclosed in accordance with the form of consent required by applicable law and its use will be limited to the objectives for which it was collected. The form of consent can vary from implied consent to express consent, depending upon the circumstances and the sensitivity of the type of information collected. Consent may have been obtained from the hotel company that originally collected the information.

Whenever applicable, LodgIQ will offer individuals the opportunity to choose, by opting out, if Personal Information will (1) be disclosed to a third party or (2) be used for a purpose other than the purpose for which it was originally collected or subsequently authorized. For all and any Sensitive Information, LodgIQ will provide opportunity to consent, by opting in, to the disclosure of the information for any other purposes different from the purpose of original collection.

Onward Transfers

Before disclosing Personal Information to any third party, LodgIQ ensures that any third party for which Personal Information may be disclosed, subscribes to the Principles or are subject to laws providing the same level of privacy protection as is required by the Principles, and agree in writing to provide an adequate level of privacy protection.

LodgIQ may share personal information with third parties, for example:

Other Service Providers: LodgIQ may use outside organizations to perform specialized services such as Sales, Marketing or information technology services. During such instances, only needed information to perform those services will be provided and it is ensured that these service providers are bound contractually to protect the privacy and security of information and limit the use of personal information to the service being provided.

Governmental or Other Authorities: If ordered by a court of law or for other legal reasons, such as to comply with a legal process such as a search warrant, subpoena or court order, to protect the company’s rights and property, LodgIQ may have to disclose personal information to the government or other legal or regulatory institution. In some cases, disclosure may be without notice.

Any Successor Entity: In the case of any significant transaction or event such as a sale, merger, amalgamation, financing, re-organization, liquidation, or insolvency, other parties to the transaction and their professional advisors may need to have access to LodgIQ databases as part of the due diligence process. In this event, LodgIQ would only provide such access under terms of a strict confidentiality agreement. Upon completion of the transaction or event, your personal information would be transferred to the successor-in-interest company to be used for the purposes for which it was collected.

Information Security
LodgIQ has implemented physical, electronic and administrative measures to protect personal information from error, loss or unauthorized access. For example, LodgIQ uses strong as passwords, strict firewalls rules and Secure Socket Layers, to secure the Personal Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. In addition, LodgIQ employees and any third parties are contractually bound to protect the confidentiality of personal information and access is restricted to those with a need to know the information to carry out the identified purpose. Although LodgIQ use technical safeguards, it is impossible to guarantee the security of Personal Information on or transmitted via the Internet.

Information Integrity
LodgIQ processes Personal Information only in a way which is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, LodgIQ takes reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Information Access
One may access their Personal Information and request corrections, amendments or deletions of inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to their privacy or where the rights of other persons would be violated. One may do this by sending a request to the contact information provided below.

Enforcement
LodgIQ continuously self-assesses practices to assure compliance with this stated Privacy Policy and periodically verifies that the policy is updated and provides comprehensive coverage for the information, prominently displayed, implemented and accessible and in conformity with the Principles. LodgIQ encourages interested persons to raise any concerns using the contact information provided and will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles.

Contact Information
Questions or comments regarding Privacy Policy or data collection and processing practices can be mailed:
LodgIQ
85 Broad Street, 18th Floor
New York, NY 10004

Or emailed to:
privacy@lodgiq.com