HILTON GLOBAL PRIVACY STATEMENT

Last Updated: May 10, 2023

NOTICE RELATING TO THE COVID-19 PANDEMIC

For the purposes of (1) protecting the health and safety of you and team members at Hilton properties, and (2) complying with legal requirements, some Hilton properties may take your temperature when you arrive at the property and/or during your stay. If a property is conducting temperature checks of guests, the property will make available to you a privacy notice about the temperature checks. The notice will include details such as what personal information is being collected, the legal basis for the collection of such information, the purpose for which the information will be used, and how long the information will be retained. For more information on Hilton’s commitment to you during the COVID-19 pandemic, pleaseclick here.

INTRODUCTION

Hilton’s mission is to be the most hospitable company in the world. We’re passionate about delivering exceptional guest experiences, and we look forward to welcoming you to our hotels so we can share the light and warmth of hospitality with you.

We pledge to deliver the highest level of customer service, which includes respecting your privacy and protecting your personal information. In this privacy statement (“Statement”), we provide you with details about how we collect, use, and disclose your personal information.

This Statement applies to Hilton Worldwide Holdings Inc., its subsidiaries, and all of the hotels within the Hilton Portfolio of Brands (collectively, “Hilton,” “we,” or “us”). Our Portfolio of Brands includes Waldorf Astoria Hotels & Resorts, LXR Hotels & Resorts, Conrad Hotels & Resorts, Canopy by Hilton, Signia by Hilton, Hilton Hotels & Resorts, Curio Collection by Hilton, DoubleTree by Hilton, Tapestry Collection by Hilton, Embassy Suites by Hilton, Tempo by Hilton, Motto by Hilton, Hilton Garden Inn, Hampton by Hilton, Tru by Hilton, Homewood Suites by Hilton, and Home2 Suites by Hilton.

By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement.

Please note that this Statement does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, companies that organize or offer packaged travel arrangements, marketing partners, or certain corporate customers.

¹ Hilton Domestic Operating Company Inc. is the Hilton entity that is the data controller for all guest data and operates, among other things, Hilton’s marketing activities. Hilton Reservations Worldwide, L.L.C., which is a subsidiary of Hilton Domestic Operating Company Inc., processes the data you provide when making a reservation at a Hilton property and is a data controller for that information. Hilton Honors Worldwide LLC, which is a subsidiary of Hilton Domestic Operating Company Inc., operates the Hilton Honors loyalty program and is a data controller for that program. Hilton Domestic Operating Company Inc. is a subsidiary of Hilton Worldwide Holdings Inc.

The Hilton Portfolio of Brands includes managed hotels and franchised hotels. A list of entities that operate managed hotels in the European Economic Area, the United Kingdom, Switzerland, and the Asia Pacific region can be found here. In addition to Hilton Domestic Operating Company Inc., these entities also are data controllers for guest data. Franchised hotels are operated by entities that are separate from Hilton. To determine the entity that operates a franchised hotel, please contact that hotel. In addition to Hilton Domestic Operating Company Inc., those entities also are data controllers for guest data.
HGV operates timeshare and fractional resorts. HGV is a third-party partner whose privacy statement is available at https://www.hiltongrandvacations.com/en/privacy-policy.html.

COLLECTION OF PERSONAL INFORMATION – GENERALLY

The chart below summarizes the categories of personal information we have collected in the past 12 months, the sources for those categories of personal information, the business or commercial purposes for which the information was collected, the categories of third parties with whom the information may have been shared, as permitted by law, and whether the information was sold to a third party for a business or commercial purpose within the past 12 months.

We have collected the following categories of personal information in the past 12 months:	We have obtained this personal information from the following sources:	We collected this personal information for the following business or commercial purposes:	We have shared this personal information with the following categories of third parties:	This information was sold to a third party within the past 12 months
Name	Directly from consumers themselves From third party partners such as credit card providers From demographics companies	Fulfill guest reservations Send guests communications relating to their reservations Administer membership and activity in the Hilton Honors loyalty program Provide customer service and support Verify identity Send marketing communications via email, direct mail, and social media Perform analytics in order to provide guests with personalized offers and content Perform analytics to improve business operations Determine guests’ eligibility for special or promotional rates Process payments, including sonducting strong customer authentication (SCA) when required by law Process transactions with partners Administer contests and sweepstakes Share that data with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Detect and prevent fraud	Service providers who perform tasks on behalf of Hilton Hilton Grand Vacations, Hilton’s third-party partner Journera, a platform for creating seamless travel experiences Payment card issuers and payment processors Employers pursuant to corporate agreements, employee consent, and as permitted by law Entities that have arranged a special rate plan with Hilton and/or organized an event and/or room block with Hilton The third-party booking platform or travel agent through which a guest made a reservation Government agencies pursuant to legal requirements in some countries	Yes
Telephone	Directly from consumers themselves From third parties such as travel booking platforms and credit card providers From demographics companies	Fulfill guest reservations Send guests communications relating to their reservations Provide customer service and support Verify identity Send marketing communications via SMS Process transactions with partners Share that data with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Authenticate mobile account Sending service-related SMS communications Detect and prevent fraud Engage in sales activity for group bookings, meetings, and events	Service providers who perform tasks on behalf of Hilton Hilton Grand Vacations Journera Employers pursuant to corporate agreements, employee consent, and as permitted by law The third-party travel booking platform or travel agent through which a guest made a reservation	Yes
Email address	Directly from consumers themselves From third parties such as travel booking platforms and credit card providers From demographics companies	Fulfill guest reservations Send guests communications relating to their reservations Administer membership and activity in the Hilton Honors loyalty program Provide customer service and support Verify identity Send marketing communications via email Process transactions with partners Administer contests and sweepstakes Share that data with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Authenticate mobile account Detect and prevent fraud Engage in sales activity for group bookings, meetings, and events	Service providers who perform tasks on behalf of Hilton Hilton Grand Vacations Journera Employers pursuant to corporate agreements, employee consent, and as permitted by law The third-party travel booking platform or travel agent through which a guest made a reservation	Yes
Home address	Directly from consumers themselves From third parties such as travel booking platforms and credit card providers From demographics companies	Fulfill guest reservations Administer membership and activity in the Hilton Honor loyalty program Provide customer service and support Verify identity Send marketing communications via direct mail Perform analytics to provide guests with personalized offers and content Perform analytics to imporve business operations Process payments, including conducting SCA when required by law Process transactions with partners Administer contests and sweepstakes Share that data with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Detect and prevent fraud Engage in sales activity for group bookings, meetings, and events	Service providers who perform tasks on behalf of Hilton Hilton Grand Vacations Journera Payment card issuers and payment processors Employers pursuant to corporate agreements, employee consent, and as permitted by law The third-party travel booking platform or travel agent through which a guest made a reservation	Yes
Nationality	Directly from consumers themselves	Comply with applicable laws that require us to collect this information in some jurisdictions	Government agencies pursuant to legal requirements in some countries	No
Date of birth	Directly from consumers themselves	Comply with applicable laws that require us to collect this information in some jurisdictions	Government agencies pursuant to legal requirements in some countries	No
Gender	Directly from consumers themselves	Comply with applicable laws that require us to collect this information in some jurisdictions	Government agencies pursuant to legal requirements in some countries	No
Payment card information	Directly from consumers themselves The third-party travel booking platform or travel agent through which a consumer made a reservation	Process payments, including conducting SCA when required by law Detect and prevent fraud	Payment card issuers and payment processors	No
Hilton Honors number	Directly from Hilton Honors members themselves	Fulfill guest reservations Send guests communications relating to their reservations Administer membership and activity in the Hilton Honors loyalty program Provide customer service and support Verify account Send marketing communications via email, direct mail, and social media Perform analytics in order to provide guests with personalized offers and content Perform analytics to improve business operations Determine guests’ eligibility for special or promotional rates Process payments Process transactions with partners Administer contests and sweepstakes Share that data with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Detect and prevent fraud	Service providers who perform tasks on behalf of Hilton Hilton Grand Vacations Journera Employers pursuant to corporate agreements, employee consent, and as permitted by law	Yes
WeChat ID	Directly from consumers themselves	Enable guests to log into Hilton Honors account	We do not share customers’ WeChat ID with third parties	No
Passport information	Directly from consumers themselves	Pursuant to laws that require the collection of such data	Government agencies pursuant to legal requirements in some countries	No
Preferred language	Directly from consumers themselves, including from browser and computer settings	Better serve our guests	We do not share customers’ preferred language with third parties.	No
Room preference	Directly from consumers themselves	Better serve our guests	We do not share customers’ room preferences with third parties.	No
Room selection and assignment	Guests can select their rooms on the Hilton Honors app and Hilton assigns rooms	Better serve our guests	We do not share customers’ room assignments with third parties.	No
Arrival Time	Directly from consumers themselves	Better serve our guests	We do not share customers’ arrival times with third parties.	No
Additional guest names	Directly from consumers themselves	Fulfill reservations	Journera	Yes
Corporate travel planner contact information (name, title, company, business phone, email and address)	Directly from the corporate contacts themselves	Fulfill and manage corporate travel reservations Provide customer service and support Send marketing communications via email, direct mail, and social media	Employers pursuant to corporate agreements, employee consent, and as permitted by law	No
Business contact data for members of the media and social media influencers	From a third-party communications service provider	Contact members of the media and social media influencers in their business capacity	We do not share business contact data for members of the media and social media influencers with third parties	No
Corporate number and name	Directly from consumers themselves	Fulfill reservations Determine guests’ eligibility for special or promotional rates	Employers pursuant to corporate agreements, employee consent, and as permitted by law Hilton Grand Vacations Journera	Yes
Travel agent number and name	Directly from consumers themselves From travel agents	Properly attribute reservations to travel agents	Hilton Grand Vacations Journera	Yes
Airline partner number and name	Directly from consumers themselves	Properly attribute points to consumers who participate in airline loyalty programs	The respective airlines Hilton Grand Vacations Journera	Yes
Vehicle information	Directly from consumers themselves From license plate recognition technology From video capabilities	Enable guests to park at our properties Ensure safety and security	We do not share vehicle information with any third parties.	No
Images or footage captured by closed circuit television (CCTV)	Directly from cameras located on and around the property	Protect guests, employees and visitors to properties Comply with applicable laws that require us to collect this information in some jurisdictions	During the COVID-19 pandemic, we may share CCTV footage from a property with a college or university if that college or university is using rooms at the property for student housing	No
Promotional images or footage captured by on-property photographers	Directly from cameras utilized on the property	Internal and external promotions and communications	We share promotional images with third parties that facilitate promotions.	No
Internet or other electronic network activity information, including information regarding a customer’s interaction with Hilton websites, applications, or advertisements	Directly from consumers themselves via cookies, server logs, web beacons, tags, pixels, and other similar technologies	Perform analytics in order to provide guests with personalized offers and content Perform analytics to improve business operations Marketing Share that data with advertising networks who serve personalized advertisements Detect and prevent fraud	Advertising networks Analytics providers for our websites and mobile applications	Yes Note: If in the Hilton Honors iOS App you ask the App not to track you across other companies’ apps and websites, Hilton will honor that request. Please note that you may still receive emails about properties you searched for either directly within the Hilton Honors App, or on Hilton.com. You may also receive emails related to Hilton-American Express Co-Branded Credit Cards; those emails are not sent based oniOS tracking.
IP addresses	Directly from consumers as a result of their browsing activity on the internet	Perform analytics in order to provide guests with personalized offers and content Perform analytics to improve business operations Share that data with advertising networks who serve personalized advertisements Detect and prevent fraud	Advertising networks Analytics providers for our websites and mobile applications	No
Session IDs	Directly from consumers as a result of their browsing activity on the internet	Perform analytics in order to provide guests with personalized offers and content Marketing Perform analytics to improve business operations Share that data with advertising networks who serve personalized advertisements Detect and prevent fraud	Advertising networks Analytics providers for our websites and mobile applications	Yes
Booking engine	Directly from consumers as a result of their browsing activity on the internet	Show you targeted advertisements on media Support marketing efforts Provide customer service Perform analytics to improve business operations	Advertising networks Analytics providers for our websites and mobile applications	Yes
Streaming service usage (including service used, hours of use, launch method, and log-out method)	Directly from consumer as a result of their logging into a streaming service through Connected Room functionality	Evaluate the usage of different streaming services	We do not share streaming service usage with third parties	No
Whether you have a Hilton and American Express Co-Branded Credit Card	From American Express	Provide you with benefits associated with your co-branded card Show you targeted advertisements on media Support marketing efforts Provide customer service Perform analytics to improve business operations	Advertising networks Analytics providers for our websites and mobile applications Hilton Honors affiliated partners	No
Whether your Hilton and Amazon accounts are linked	From Amazon	Facilitate use of Honors points as part of Amazon’s Shop with Points program Show you targeted advertisements on media Support marketing efforts Provide customer service Perform analytics to improve business operations	Advertising networks Analytics providers for our websites and mobile applications	No
Whether your Hilton and Lyft accounts are linked	From Lyft	Show you targeted advertisements on media Support marketing efforts Provide customer service Perform analytics to improve business operations	Advertising networks Analytics providers for our websites and mobile applications Hilton Honors affiliated partners	No
Geolocation information	Directly from consumers as a result of their browsing activity on the internet and use of the Hilton Honors app	Perform analytics in order to provide guests with personalized offers and content Marketing Share that data with advertising networks who serve personalized advertisements Detect and prevent fraud	Advertising networks Analytics providers for our websites and mobile applications	No
Device information (including MAC address)	Directly from consumers as a result of their browsing activity on the internet, scanning of QR codes on property, and use of the Hilton Honors app	Perform analytics to provide guests with personalized offers and content Marketing Share that data with advertising networks who serve personalized advertisements Detect and prevent fraud	Advertising networks Analytics providers for our websites and mobile applications	Yes
Social media information; publicly available online information (including through social media platforms)	Directly from consumers themselves Indirectly from consumers by reviewing publicly available information on their social media channels From publicly available online sources	Perform analytics in order to provide guests with personalized offers and content Respond to service concerns in order to better serve our guests Provide a more personalized welcome and stay experience	We do not share social media information with any third parties.	No
Demographics data	From third-party companies that provide demographics data.	Perform analytics in order to provide guests with personalized offers and content Link with customer information that Hilton already has on file	We do not share demographics data with any third parties.	No
Your usability preferences regarding our website (such as your email preferences, your MyWay preferences, and your opt-out preferences)	Directly from consumers themselves	Better serve our guests	We do not share your usability preference data with any third parties.	No
Description of an incident that occurs at a Hilton property or involves a Hilton employee, including incidents related to safety, security, violation of law, violation of applicable policy, or violation of contractual obligation	Directly from consumers themselves Directly from Hilton employees Directly from law enforcement	Respond to safety & security concerns Better serve our guests Comply with legal or contractual obligations	Law enforcement Employers pursuant to corporate agreements, employee consent, and as permitted by law Entities that have arranged a special rate plan with Hilton and/or organized an event and/or room block with Hilton The management and/or owners of a franchise property if the incident relates to that property Others as required by law	No
Description of a complaint that you make to us, including your free form textual feedback if you are a Hilton Honors member	Directly from consumers themselves	Better serve our guests	The management and/or owners of a franchise property if your complaint relates to that property.	No
Customer ratings and survey responses	Directly from consumers themselves	Troubleshoot and resolve website issues Improve customer experience	We do not share your customer ratings and survey responses with any third parties.	No
Free form textual feedback	Directly from consumers themselves	Troubleshoot and resolve website issues Improve customer experience	We do not share your feedback with any third parties.	No

Hilton does not knowingly collect, disclose, or sell personal information of minors under the age of 16 without permission from a minor’s parent or guardian. When searching for hotel reservations on a Hilton website or on the Hilton Honors app, you may be asked to provide the ages of any minor guests staying in the room. Hilton collects this information for the purpose of determining room rates where applicable, such as at an all-inclusive property.

French residents: as disclosed in this Statement, we may collect your phone number to fulfill guest reservations, send guests communications relating to their reservations, provide customer service and support, verify identity, send marketing communications via SMS, process transactions with partners, share data with Hilton Grand Vacations and Journera, authenticate mobile accounts, send service-related SMS communications, detect and prevent fraud, and engage in sales activities for group bookings. We will not use your phone number for telemarketing. Nonetheless, if you would like to register on the list of opposition to telephone canvassing, you may do so at www.bloctel.gouv.fr.

COLLECTION OF PERSONAL INFORMATION – NOTICE AT POINT OF COLLECTION

Browsing Hilton Websites

When you browse a Hilton website, we collect the following categories of personal information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Internet or other electronic network activity information, including information regarding your interaction with Hilton websites, applications, or advertisements	Show you targeted advertisements on marketing efforts including media, email, and chat (e.g., if you searched for Hilton properties in New York City, then when you visit a non-Hilton website, we may show you an ad for a Hilton property in New York City) Optimize our websites and mobile apps Perform analytics to improve business operations
IP address	Show you targeted advertisements on media Optimize our websites and mobile apps Perform analytics to improve business operations
Session ID	Show you targeted advertisements on media Optimize our websites and mobile apps Perform analytics to improve business operations
Booking engine	Show you targeted advertisements on media Support marketing efforts Provide customer service Perform analytics to improve business operations
Whether your Hilton and Lyft accounts are linked	Show you targeted advertisements on media Support marketing efforts Provide customer service Perform analytics to improve business operations

If you are a Hilton Honors member and you log into your account during your browsing session, then we collect the following information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Internet or other electronic network activity information, including information regarding your interaction with Hilton websites, applications, or advertisements	Show you targeted advertisements on marketing efforts including media, email, and chat (e.g., if you searched for Hilton properties in New York City, then when you visit a non-Hilton website, we may show you an ad for a Hilton property in New York City) Optimize our websites and mobile apps Perform analytics to improve business operations
IP address	Show you targeted advertisements on media Optimize our websites and mobile apps Perform analytics to improve business operations
Session ID	Show you targeted advertisements on media Optimize our websites and mobile apps Perform analytics to improve business operations
Customer ratings and survey responses	Troubleshoot and resolve website issues Improve customer experience
Free form textual feedback	Troubleshoot and resolve website issues Improve customer experience
IP address	Show you targeted advertisements on media Optimize our websites and mobile apps Troubleshoot and resolve website issues Perform analytics to improve business operations
Hilton Honors number	Support marketing efforts Provide customer service Troubleshoot and resolve website issues
Hilton Honors tier	Support marketing efforts Provide customer service Troubleshoot and resolve website issues

Making a Reservation

When you make a reservation at a Hilton property, we collect the following categories of personal information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Name	Look up and verify your reservation Fulfill your reservation Send you communications relating to your reservation Send you marketing communications via email and direct mail Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Determine your eligibility for special or promotional rates Process payments Process transactions with partners Share this information with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Optimize our websites and mobile apps Detect and prevent fraud
Additional names	Fulfill your reservation
Hilton Honors number	Look up and verify your Hilton Honors account and reservation Administer your membership in Hilton Honors
Phone number	Send you text messages relating to any services you may need during your stay Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Process transactions with partners Share this information with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Detect and prevent fraud
Address	Fulfill your reservation Send you communications relating to your reservation Send you marketing communications Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Process payments Process transactions with partners Share this information with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Detect and prevent fraud
Address type (home/work)	Perform analytics in order to provide you with personalized offers and content
Email address	Look up and verify your Hilton Honors account and reservation Associate your reservation with your Hilton Honors account Send you communications relating to your reservation Send you marketing communications Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Determine your eligibility for special or promotional rates Process transactions with partners Share this information with Hilton Grand Vacations and Journera Detect and prevent fraud
Preferred language	Provide you with a superior guest experience Send you communications relating to your reservation Send you marketing communications Perform analytics in order to provide you with personalized offers and content Share this information with Hilton Grand Vacations and Journera
Payment card information	Process payments Detect and prevent fraud
Room preference	Fulfill your reservation Personalize your experience Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations
Corporate name and number	Fulfill your reservation Determine your eligibility for special or promotional rates
Travel agent name and number	Fulfill your reservation Determine your eligibility for special or promotional rates Calculate commissions
Airline partner name and number	Credit points to you if you participate in an airline loyalty program

Enrolling in Hilton Honors

When you enroll in Hilton Honors, we collect the following categories of personal information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Name	Administer your membership in the Hilton Honors loyalty program Verify your Hilton Honors account Send you communications relating to Hilton Honors Send you marketing communications Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Determine your eligibility for special or promotional rates Process payments Process transactions with Hilton Honors affiliated partners (such as Points.com and Lyft) Share this information with Hilton Grand Vacations, Hilton’s third-party partner, and Journera, a platform for creating seamless travel experiences Detect and prevent fraud
Phone number	Administer your membership in the Hilton Honors loyalty program Verify your Hilton Honors account Send you text messages relating to any services you may need during your stays at Hilton properties Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Process transactions with partners Share this information with Hilton Grand Vacations and Journera Detect and prevent fraud
Addresses	Administer your membership in the Hilton Honors loyalty program Verify your Hilton Honors account Send you communications relating to Hilton Honors Send you marketing communications Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Determine your eligibility for special or promotional rates Process transactions with partners Detect and prevent fraud
Email addresses	Administer your membership in the Hilton Honors loyalty program Verify your Hilton Honors account Send you communications relating to Hilton Honors Send you marketing communications Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations Determine your eligibility for special or promotional rates Process transactions with partners Detect and prevent fraud
Preferred language	Provide you with a superior guest experience Send you communications relating to Hilton Honors Send you marketing communications
Payment card information	Process payments
Room preference	Fulfill your reservations Perform analytics in order to provide you with personalized offers and content Perform analytics to improve business operations
Corporate name and number	Fulfill your reservation Determine your eligibility for special or promotional rates
Travel agent name and number	Fulfill your reservation Determine your eligibility for special or promotional rates Calculate commissions
Airline partner name and number	Credit points to you if you participate in an airline loyalty program
My Way preferences	Provide you with a superior guest experience
Email subscription preferences	Send you the communications you would like to receive
Opt-out preferences	Send you the communications you would like to receive

Checking In at a Hilton Property

When you check in at a Hilton property, we may collect the following categories of personal information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Name	Verify your reservation
Payment card information	Receive payment for your reservation
Additional guest names	Fulfill your reservation
Passport information	Comply with applicable laws that require us to collect this information in some jurisdictions
Address	Comply with applicable laws that require us to collect this information in some jurisdictions
Nationality	Comply with applicable laws that require us to collect this information in some jurisdictions
Date of birth	Comply with applicable laws that require us to collect this information in some jurisdictions
Gender	Comply with applicable laws that require us to collect this information in some jurisdictions
Hilton Honors number	Look up and verify your Hilton Honors account and reservation Administer your membership in Hilton Honors
Frequent flyer number	To facilitate the award of loyalty points
Email address	Send folios after the completion of a stay

E-Check In

When you check in using e-check in, we collect the following categories of personal information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Payment card information	Receive payment for your reservation
Room selection and assignment	Fulfill your reservation
Arrival time	Fulfill your reservation Personalize your experience Customer service

Digital Key

When you use Digital Key, we collect the following categories of personal information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Payment card information	Receive payment for your reservation
Room selection and assignment	Fulfill your reservation
Arrival time	Fulfill your reservation
Precise geo-location information	Enable you to access your guest room and hotel facilities Fulfill Digital Key sharing requests

Guest Assistance

When you contact Guest Assistance, we collect the following categories of personal information about you, which are used for the following purposes:

We collect the following categories of personal information…	We collect this information in order to…
Name	Verify your identity Search our records for information about your past stays and membership in the Hilton Honors loyalty program Provide service recovery
Address	Verify your identity
Phone number	Verify your identity
Description of complaint or inquiry	Respond to your complaint Perform analytics to improve business operations

ANALYTICS AND INTEREST-BASED ADVERTISEMENTS

We partner with certain third-party service providers to collect information to engage in analytics, auditing, research, and reporting. These third parties may use server logs, web beacons, tags, pixels, and similar technologies, and they may set and access cookies on your computer or other device.

In particular, we use Yahoo Analytics to help us understand how our customers use our websites. Read more about how Yahoo uses your Personal Information and opt out of the use of cookies in web browsers by Yahoo Analytics.

We also use FullStory. The FullStory analytics service uses heat mapping and records mouse movements, clicks, scrolls, and keystrokes during your use of our site. This information helps us identify and address technical issues and understand usage of our Services, which we use to improve the Services for you. You can opt-out of our use of FullStory.

We also partner with third parties to provide advertising services that are targeted based on your online activities across websites, mobile apps, and devices over time (commonly referred to as “interest-based advertising”). Our advertising partners may collect information about your activities on our Services on your current device and combine it with information about your activities on other websites, mobile apps, and devices. They may collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Facebook cookies or Google’s Advertising ID), cross-device linking, and similar technologies. For example, our advertising partners may use the fact that you visited our website to target advertising to you on other websites and mobile apps on your current device or on other devices you use. They may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices. You can opt out of interest-based advertising in web browsers and mobile apps on your current browser or device by following the instructions below.

For more information about interest-based advertising and cross-device linking, please visit the Network Advertising Initiative (“NAI”) website and the Digital Advertising Alliance (“DAA”) website. We adhere to the DAA’s interest-based advertising principles by providing you enhanced notice, transparency, and control of our digital marketing practices as stated at http://www.aboutads.info/principles/. You may opt out of interest-based advertising and cross-device linking in web browsers and mobile apps on your current browser or device by following the instructions below.

Web Browser Opt-Out. To opt out in web browsers, please visit http://optout.aboutads.info/ andhttp://optout.networkadvertising.org. To help preserve the choices that you make in the DAA’s WebChoices page, you can install the DAA’s “Protect My Choices” extension that is available at http://www.aboutads.info/PMC.
Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the advertising preferences on your mobile device (for example, in iOS, visit Settings > Privacy > Advertising > Limit Ad Tracking, and in Android, visit Settings > Google > Ads > Opt out of interest-based ads). You can also opt out for companies that participate in the Digital Advertising Alliance’s AppChoices tool by downloading the app and following the instructions. For more information about opting out on mobile devices, please see here.

Please note that the opt-outs described above will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile advertising identifiers, change browsers (including upgrading certain browsers), or use a different device, any opt-out cookie or tool may no longer work, and you will need to opt out again. We do not respond to Do Not Track signals at this time.

CHANGING AND ACCESSING YOUR PERSONAL INFORMATION

If you are a Hilton Honors member, you may review and update the information you provided to us at the time of enrollment at any time by signing in to your Hilton Honors account.You may also make changes to your information by contacting Hilton Reservations and Customer Care by completing a support form. If you are located in the United States or Canada, you can call customer care toll free by dialing + 1-888-4HONORS (888-446-6677). Customers located outside of the United States and Canada can review a list of customer care phone numbers here.

You may be able to request that we inform you about the personal information we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your personal information. We will make all required updates and changes within the time specified by applicable law and as required by law. When permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. Such requests may be submitted by accessing the Data Subject Rights Requests Portal at datarights.hilton.comor in writing to [email protected] or Hilton Data Protection Officer, 7930 Jones Branch Drive, McLean, VA 22102, USA.

In addition, in some circumstances you may request that we cease sharing personal information about you with our business partners or that Hilton cease using personal information about you by contacting us using the email or mailing address above.

CALIFORNIA CONSUMERS’ RIGHTS

The Right to Know, The Right to Delete, and the Right to Opt-Out of the Sale of Personal Information

The California Consumer Privacy Act (“CCPA”) affords California consumers (1) the right to know what personal information we collect, use, disclose, and/or sell; (2) the right to request that we delete their personal information; and (3) the right to request that we no longer sell their personal information.

If you would like information about the personal information that we collect, disclose, and/or sell about you, or if you would like to make a request for us to delete or to stop selling your personal information, please visit our website at datarights.hilton.com or click the “Personal Data Requests” link at the bottom of any Hilton website to submit your request. You also may call our toll-free telephone number: (800) 413-7470, email the Data Protection Office (“DPO”) at[email protected], send a letter to the Data Protection Office at 7930 Jones Branch Drive, McLean, Virginia, USA 22102, or complete a paper form available from the front desk at any of our hotels. In addition to these methods, California consumers may request that we no longer sell their personal information by completing a personal data request form.

When the DPO receives your request, the DPO will first verify your identity. If you are a Hilton Honors member, the DPO will verify your identify by asking you to provide your name, Hilton Honors account number, and the email address and phone number associated with your Hilton Honors account. If you are not a Hilton Honors member, the DPO will verify your identity by asking you to provide your name, the confirmation number from one of your stays at a Hilton property, and the email address associated with that stay. Once the DPO has verified your identity, the DPO will promptly fulfill your request.

If you would like, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent, please submit an order issued by a court, a document submitted by a barred attorney, or a formal certified document issued by an official governmental agency.

If you would like to opt out of the sale of your personal information, you may do so by clicking on the banner that appears on any Hilton website when you access that site from an IP address that relates to California or by visiting our website at datarights.hilton.com or click the “Personal Data Requests” link at the bottom of any Hilton website to submit your request. Please note that when you opt out of cookies, tags, and pixels, that opt out only pertains to the device and the browser that you are using when you opt out. If you wish to opt out for other devices or browsers, you must opt out again when you are using those devices or browsers.

Sensitive Personal Information

We limit the use of your personal information to that use which is necessary to perform reasonably expected services or as required by law.

Direct Marketing Disclosure

California consumers also may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following addresses: [email protected] or [email protected], send a letter to the Data Protection Office at 7930 Jones Branch Drive, McLean, Virginia, USA 22102. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

The Right to Non-Discrimination

The CCPA prohibits a business from treating a consumer differently because the consumer exercised a right conferred on him/her by the CCPA. We welcome you to exercise your rights under the CCPA, and we will not discriminate against you for doing so.

Financial Incentive Notice

Hilton does not offer a financial incentive for the collection, sale, or deletion of personal information. As detailed in this Statement, Hilton primarily collects personal data from guests in order to fulfill guest reservations and from Honors members in order to operate the Hilton Honors loyalty program. Hilton also collects personal data for marketing and other purposes as permitted by applicable law.

As set forth in the Hilton Honors Terms and Conditions, Hilton Honors members have the ability to accumulate points and access discounted rates. The ability to accumulate points and to access discounted rates is not directly related to the value provided to the business of members’ data.

Removal of Content

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected]. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

NEVADA CONSUMERS’ RIGHTS

The Right to Opt-Out of the Sale of Personal Information

If you are a Nevada resident, you may request that we stop selling certain categories of personal information that we collect. To submit a request please visit our website at datarights.hilton.comor click the “Personal Data Requests” link at the bottom of any Hilton website to submit your request. You also may call our toll-free telephone number: (800) 413-7470, email the Data Protection Office (“DPO”) at[email protected], send a letter to the Data Protection Office at 7930 Jones Branch Drive, McLean, Virginia, USA 22102, or complete a paper form available from the front desk at any of our hotels. When the DPO receives your request, the DPO will first verify your identity. If you are a Hilton Honors member, the DPO will verify your identify by asking you to provide your name, Hilton Honors account number, and the email address and phone number associated with your Hilton Honors account. If you are not a Hilton Honors member, the DPO will verify your identity by asking you to provide your name, the confirmation number from one of your stays at a Hilton property, and the email address associated with that stay. Once the DPO has verified your identity, the DPO will promptly fulfill your request.

HOW WE PROTECT PERSONAL INFORMATION

We take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration, or destruction, and (ii) keep personal information accurate and up-to-date as appropriate.

Hilton employs a robust team of dedicated information security professionals who are responsible for managing Hilton’s security program. This team is responsible for, among many other things, monitoring our systems for potential intrusions, responding to potential incidents, supporting property-level information security, regularly reviewing and updating the security controls Hilton uses to protect data, and providing training on Hilton’s information security program.

Hilton maintains a payment card industry (“PCI”) compliance program and an Information Technology compliance program. This compliance program generates audit reports concerning the adequacy and effectiveness of Hilton’s Technology internal controls, including a PCI Attestation of Compliance signed by an external PCI Qualified Security Assessor and a SSAE16/SOC1 report addressing the Technology general controls over systems that support certain accounting and financial reporting.

We require third parties with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information.

We will never ask you to send us confidential personal information or payment card information via email or text message.

In the event of a security incident, Hilton will notify regulators and/or consumers as required by applicable laws and regulations.

DISCLOSURE PURSUANT TO LEGAL OBLIGATIONS OR TO PROTECT THE SAFETY AND SECURITY OF PEOPLE AND PROPERTY

Hilton will disclose personal information as required by law. Examples of such disclosures include when countries require Hilton to collect personal data about visitors to properties in that country, when a law enforcement agency serves a valid subpoena on Hilton, and when a civil litigant serves a lawful discovery request on Hilton. Hilton may elect to share personal information with law enforcement, employers, those who host events with Hilton, or others as necessary to protect the safety and security of people and property, to pursue available remedies or limit the damages that we may sustain, and to respond to an emergency.

MARKETING COMMUNICATIONS – CHOICES

We want to make you aware of the fantastic products we offer! To do so, we may send you communications via email, text message, push notifications, in-app alerts, direct mail, and social media.

If you are a Hilton Honors member, you may change the communications you receive from us by logging on to your online account and managing your subscriptions; by writing to us (and including your email address) at Hilton Data Protection Officer, 7930 Jones Branch Drive, McLean, VA 22102, USA; or by emailing us at[email protected].

If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in any email you receive from us or by clicking this link: https://secure.hilton.com/en/hhonors/optout/unsubscribe.jhtml?listid=0, by writing to us (and including your email address) at Hilton Data Protection Officer, 7930 Jones Branch Drive, McLean, VA 22102, USA, or by emailing us at [email protected]. Opt-out requests can take up to ten business days to be effective.

To opt out of text messages, tell the hotel front desk that you do not want to receive text messages from the hotel or reply “STOP” to the message you received.

You may control whether our mobile apps send you push notifications by changing your notification settings on your mobile device. If we engage in sending you in-app messages, we will allow control for those in our apps’ settings.

Provisions Applicable to Korean Data Subjects.
Domestic Representative for Information and Communication Services
Local Representative. You may contact our representative in Korea by email or mail to handle questions and complaints in connection with the processing of your personal data if you are in Korea.

Brad Jeong
[email protected]
10 Gukjegeumyuong-ro Yeouido, Seoul, 07326, South Korea

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

As a global company, we endeavor to provide you with the same level of service that you have come to expect at Hilton whether you are in San Francisco, London or Tokyo. To provide this service, you acknowledge that we may share your personal information among members of the Hilton Portfolio of Brands, our service providers, and other third parties, which may be located in countries outside of your own. When you stay at a Hilton property outside the United States, the data controller for that property transfers the personal information relating to your reservation to Hilton in the United States pursuant to data transfer agreements when required by applicable laws or regulations. The data controller may also maintain a local copy of your personal information when so required by applicable laws or regulations. Although the data protection laws of various countries may differ from those in your own country, we will take appropriate steps to ensure that your personal information is handled as described in this Statement and in accordance with the law.

DATA RETENTION PERIODS

We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

CHANGES TO THIS STATEMENT

We may modify this Statement from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site. You can tell when this Statement was last updated by looking at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.

CONTACT INFORMATION FOR QUESTIONS OR CONCERNS

If you have any questions or concerns, please contact us by sending an email to[email protected], by sending a letter to Hilton Data Protection Officer, 7930 Jones Branch Drive, McLean, VA 22102, or by calling our toll-free number: (800) 413-7470.

This Statement was most recently updated on March 29, 2022.

APPENDIX A
ADDITIONAL PRIVACY PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
INFORMATION OF RESIDENTS OF CERTAIN COUNTRIES AND US STATES

This Appendix provides additional information for individuals residing in countries and U.S. states that have enacted privacy laws giving certain additional rights to residents of those jurisdictions. These countries include, but are not limited to, those in the European Economic Area (EEA), the United Kingdom and Switzerland, as well as Australia, Brazil, China, Israel, Japan, Nigeria and Turkey. This Appendix outlines certain additional information that Hilton is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws. This Appendix will control to the extent it conflicts with any provision in the main body of this Statement.

Controller: Find more information on the Hilton entities that process your personal information, please click here.

Data Protection Officer: Hilton’s Data Protection Officer may be contacted by email at [email protected], or at the following address:

Attn: Data Protection Officer 7930 Jones Branch DriveMcLean, VA 22102 USA

Purposes and Legal Basis for ProcessingHilton processes your personal information for the purposes set forth in the Section titled Collection of Personal Information – Generally and the Section titled Collection of Personal Information – Notice at Point of Collection of the main body of this Statement.

The legal bases for Hilton’s processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent.

The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:

Hilton Honors Participation: We process the personal information obtained in connection with your participation in the Hilton Honors program on the basis of our contractual relationship with you and in furtherance of our business interests, including to personalize your use of our services and applications, to communicate news and promotional items, and to deliver personalized advertising and content.

Surveys: Completion of surveys is voluntary – we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.

On-property Collection: When you make a reservation and when you stay at one of our hotel properties, we process your name, address, contact information, along with the details of your stay (arrival and departure day and time, vehicle information and information regarding others traveling or staying with you), on the basis of our contractual relationship with you. We also process such data for our business interests, including for marketing, service improvements, administration of our e-Folio program, and analytics and service personalization, as described in the sections referenced above of our Global Privacy Statement.

We collect certain additional personal information during registration/check-in at our properties (such as national ID or passport information), as necessary to comply with our legal obligations.

We use closed circuit television and other security measures at our properties that may capture or record images of guests and visitors in public areas, as well as information related to your location while on our properties (via keycards and other technologies) for the protection of our staff, guests and visitors to our properties.

We process personal information in connection with on-property services (such as concierge services, health clubs, spas, activities, child care services, equipment rental, and our Digital Key functionality), in order to provide the services to you and for our business interests including for marketing, service improvements, administration of our e-Folio program, and analytics and service personalization, as described in the sections referenced above of our Global Privacy Statement.

Event Profiles: We process the personal information obtained in connection with your event on the basis of our contractual relationship with you and for our business interests, including for marketing, service improvements, and analytics and service personalization, as described in the sections referenced above of our Global Privacy Statement.

Social Media: Participation in Hilton-sponsored social media activities and offerings is voluntary – we process information obtained from social media participation on the basis of your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization, as described in the sections referenced above of our Global Privacy Statement.

Promotions and Sweepstakes: Participation in sweepstakes, contests and other promotional offerings is voluntary – we process the information obtained from such participation based on your consent and as necessary to administer the offering. We also use certain data for our business purposes, including for marketing, service improvements, administration of our e-Folio program, and analytics and service personalization, as described in the sections referenced above of our Global Privacy Statement.

Direct Marketing: We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at [email protected] or by following the unsubscribe instructions in the marketing message, or by logging in to your Hilton Honors account and updating your communication preferences.

Franchise and Ownership Opportunities: We process this information on the basis of our contractual relationship with you and for our related business interests, including maintaining and promoting the Hilton brand and facilitating direct communication between properties within the Hilton Portfolio of Brands.

WMBE Suppliers: Participation in Hilton’s Supplier Diversity Program is voluntary – we process this information based on your consent and for our related business interests, including maintaining and enhancing our diversity program.

Retention: We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.

Data Subject Rights: Residents of the EEA have the following rights:

Access, Correction and Erasure Requests: You have the right to:

ask us to confirm whether we are processing your personal information receive information on how your data is processed
obtain a copy of your personal information
request that we update or correct your personal information
request that we delete personal information in certain circumstances

Right to Object to Processing: You have the right to request that Hilton cease processing of your personal information:

for marketing activities, including profiling for statistical purposes
where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim

Right to Restrict Processing: You have the right to request that Hilton limit the processing of your personal information:

while Hilton is evaluating or in the process of responding to a request by you to update or correct your personal information where such processing is unlawful and you do not want Hilton to delete your data
where Hilton no longer requires such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim
where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.

Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

Submitting Requests: your requests may be submitted by accessing the Data Subject Rights Request Portal or in writing to [email protected], or the Hilton Data Protection Officer, 7930 Jones Branch Drive, McLean, VA 22102, USA. You may also update your personal information as provided in Section 12 (Changing and Accessing Your Personal Information) of the main body of this Global Privacy Statement.

We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.

If you have concerns about our data practices or the exercise of your rights, you may either contact Hilton at [email protected] or the supervisory authority in the Member State of your residence.

Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails, or contacting [email protected]. For any other activities for which you have previously consented, you may contact [email protected] to withdraw such consent.

Segmentation (also referred to as profiling) and Automated Decision Making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behavior, or demographics.

With your consent, we make automated decisions, meaning without human interference, using segmentation and/or your specific personal information to offer you certain benefits based on your characteristics (such as discounted room rates or other special offers based on your geography, behavior, or demographics). For example, if you travel frequently during the week to hotels in France, we may send you special offers for Hilton hotels in France.

International Data Transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection. In particular, we transfer your personal information to the United States.

We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions, and where required, we have implemented data transfer agreements, such as the European Commission standard contractual clauses or other such safeguards for such purposes. To obtain a copy of theses clauses or additional information on transfers, you may send your request to [email protected].

APPENDIX B
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
INFORMATION OF DATA SUBJECTS IN TURKEY

For data subjects in Turkey, this Appendix outlines certain additional information that Hilton is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws. This Appendix will control to the extent it conflicts with any provision in the main body of this Statement.

Data Controller. Hilton Domestic Operating Company Inc. is the Hilton entity for all guest data and Hilton’s marketing activities, whereas Hilton Reservations Worldwide, L.L.C. processes the data you provide when making a reservation at a Hilton property and is a data controller for that information. Hilton Honors Worldwide LLC operates the Hilton Honors loyalty program and is a data controller for that program.

Your personal data may be processed by other Hilton entities in Turkey who act as a data controller based on the Hilton property you stay at. In such cases, the relevant Hilton entity will act as the data controller for your personal data, who will provide you with a separate privacy notice, where necessary.

Data Controller Representative. You may contact our data controller representative in Turkey by email or mail to handle questions and complaints in connection with the processing of your personal data if you are in Turkey.

Esin Attorney Partnership
[email protected]
Akatlar Mah. Ebulula Mardin Cad. Gül Sok. No. 2

Legal bases for the processing your personal data. Hilton relies on the following legal bases while processing your personal data for the purposes indicated in the Global Privacy Statement in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data (“Data Protection Law”):

processing of your personal data is necessary provided that it is directly related to the conclusion or fulfilment of the contract between you and Hilton;
processing is mandatory for Hilton to be able to comply with our legal obligations;
processing is mandatory for Hilton’s legitimate interests, provided that it does not violate your fundamental rights and freedoms; or
your explicit consent. (Please note that we rely on your explicit consent only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above.)

Your rights. You have the rights under Article 11 of the Data Protection Law and may exercise your rights by contacting us at: [email protected] or Data Protection Officer, Hilton, 7930 Jones Branch Drive, McLean, VA 221102, USA.

The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.

Amendments. The following sections of the Global Privacy Statement do not apply to individuals in Turkey: The following sentence at the second paragraph: By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement.

The following sentence in the International Personal Data Transfers section: To provide this service, you acknowledge that we may share your personal information among members of the Hilton Portfolio of Brands, our service providers, and other third parties, which may be located in countries outside of your own.

Language. This Statement is available in English and Turkish. If there is any inconsistency or different interpretation between the English and Turkish versions, the Turkish text shall prevail.

International Data Transfers. Hilton is required to transfer your personal data to its affiliates outside of Türkiye, which includes Hilton Domestic Operating Company Inc., Hilton Reservations Worldwide LLC, and Hilton Honors Worldwide LLC, all resident in the United States, as well as their in-country suppliers, in order to complete reservations, process Hilton Honors memberships and conduct promotion activities through its website, whose servers are located abroad. Without your consent, Hilton is unable to provide you with its services through this website. Therefore, we ask for your consent when you access this website for the cross-border transfer of your data.

This consent practice is only temporary, and Hilton is working on effecting an undertaking letter, which is one of the alternative legal mechanisms for cross-border data transfers. Accordingly, the consent practice will be terminated once the undertaking letter is prepared and approved by the Personal Data Protection Authority.

APPENDIX C
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL
INFORMATION OF CHINA RESIDENTS OR CITIZENS

1. Introduction

For individuals who resident in the People’s Republic of China (for the purposes of this Privacy Statement, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan) (“China”) or citizens of the People’s Republic of China, we understand that privacy is important to you. Therefore, in this Appendix, we provide you with an introduction to how Hilton collects, uses, discloses, and otherwise processes your personal information (including sensitive personal information, where applicable) that we receive or collect from you. Please read this Statement carefully before using any of Hilton’s services or products.

This Appendix does not replace the main body of this Statement, but supplements the main body of this Statement, and should be read together with the main body. In the event of any conflict or inconsistency between this Appendix and the main body of this statement, this Appendix shall prevail.

“Personal Information” shall have the same meaning as defined in the Personal Information Protection Law of the People’s Republic of China (as revised from time to time). Such information can be recorded electronically or in other ways and can identify the identity or reflect the activity of a specific natural person alone or in combination with other information, including sensitive personal information. “Personal Information” or “Information” used in the main text of this Statement and in this Appendix also includes Sensitive Personal Information (where applicable). “Sensitive Information” shall have the same meaning as defined in the Personal Information Protection Law of the People’ Republic of China (as revised from time to time). The Sensitive Personal Information involved in this Statement includespassport or ID card information, payment card information, accommodation information (such as arrival time), web browsing records, and precise positioning information. You agree that the sensitive personal information will be processed in accordance with the purposes and methods set forth in this Statement.

2. Collection and Use of Personal Information

Regarding the following issues, please refer to Section 2 (Collection of Personal Information – Generally) and Section 3 (Collection of Personal Information – Notice at Point of Collection).

The types of personal information that we collect from you (including sensitive personal information, which include the information that may applicable as set out in Section 3 – “Collection of Personal Information – Notice at Point of Collection”)
How we collect and use your personal information, the purposes for which we use it, and how we share or disclose your personal information.

Hilton will not knowingly collect or disclose personal information from minors under the age of 16. When we collect personal information from an individual under the age of 16, we need to obtain consent from his/her parent or guardian and we will process such information in accordance with the safeguards set out in applicable laws and regulations.

We will use your personal information with your consent or as otherwise required or permitted by applicable law. If we want to use your personal information for other purposes, we will obtain your further consent. We will explain when it is necessary for you to provide your personal information, and the result if you provide.

3. Disclosure and Sharing of Personal Information

With your consent, we may share your personal information for the purposes described in this Statement with members of the members of Hilton worldwide brand portfolio, our service providers, and other third parties as follows:

Hilton Worldwide Holdings Inc. and its subsidiaries, and members of the Hilton brand portfolio, including franchised and managed hotels,
Service providers providing services on Hilton’s behalf,
Payment card providers and processors,
Employers specified in the company agreements,
Advertising networks and analytics providers for Hilton’s website and mobile applications.

To provide and optimize our services, third-party SDKs are embedded in our applications (including WeChat Mini Programs). The following lists the names of the third-party SDKs we currently embed, the types of personal information collected, and the purpose of collection and use. If you have questions about the collection of your personal information by the third parties through the SDKs, please refer to the privacy policies of such third parties.

Name of the SDK	Provider of the SDK	Purposes of the SDK	Application where the SDK is embedded	Types of personal information collected by the SDK	Link to the privacy policy of the SDK
Alipay “App Payment” SDK	Alipay (China) Network Technology Co., Ltd.	Payment	iOS, Android	Common device information (IMEI/IMSI, SIM card serial number/MAC address, android id (only for Android devices)), network information	https://opendocs.alipay.com/open/01g6qm
WeChat Pay	Tencent	Payment	iOS, Android, WeChat Mini-Program	WeChat User OpenId	https://weixin.qq.com/cgi-bin/readtemplate?t=weixin_business_pay
Adobe Analytics SDK for WeChat Mini-Program	Adobe	User clicks and usage records	WeChat Mini-Program	Location information, device information, version of operating system	https://aep-sdks.gitbook.io/docs/resources/adobe-experience-platform-mini-programs-sdk
Adobe Analytics SDK	Adobe	User clicks and usage records	iOS, Android	Location information, device information, version of operating system	https://www.adobe.com/cn/privacy/policy.html
Baidu Maps SDK	Baidu	Displaying hotels nearby on the map	Android	Location information (domestic users)	https://lbsyun.baidu.com/index.php?title=open/law
Google Maps SDK	Google	Displaying hotels nearby on the map	Android	Location information (domestic users)	https://developers.google.cn/maps/faq?hl=zh-cn#tos_logging
Workspace one	VMWare	Recording app crashes and error messages	iOS, Android	Device information, version of operating system	https://www.vmware.com/cn/help/privacy/products-and-services-notice.html

Despite the above situations, we may disclose personal information to third parties to: comply with applicable laws or effective legal procedures; respond to enquiries of the governments or requests of the public and/or the government authorities; protect rights, privacy, security or property of Hilton, site visitors, guests, employees or the public; pursue or exercise our rights; or respond to emergencies.

4. Mobile and Location Services

We may collect your personal information if you download and use our mobile applications or use other digital platforms such as our WeChat Mini-Programs. We will obtain your consent and collect, use, disclose and otherwise process this information in accordance with this Statement. If you allow us to access the location information on your device to provide you with our application features and services, such information may include geolocation information. We also collect information device information, such as your phone brand, model, operating system, operating system version, to direct you to the appropriate APP store to download our mobile apps.

You can prevent or limit the collection of this information by changing the settings in the Hilton Honors APP or by changing the settings in your device.

5. Analytics and Interest-based Advertisements

We also cooperate with third parties to serve targeted advertising based on your online activities across different websites, mobile applications, and devices over time. Our advertising partners may collect information about your activities related to our services on your current device and combine it with information about your activities on other websites, mobile applications, and devices. They may collect this information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs, cross-device linking and similar technologies. This may include your personal information.

You can opt out interest-based advertising and cross-device linking in the current browser or the web browsers and mobile apps on your device. We do not currently respond to “do not track” signals. For more information, please see Section 4 (Analytics and Interest-Based Advertising) in the main body of this Statement, as well as the Statement Regarding Cookies and Other Technologies.

6. Changing and Accessing Your Personal Information, and Deregistration of Accounts

You have the right to access, correct and/or (in certain circumstances) delete your personal information, withdraw consent to our processing of your personal information, deregister your membership account (if any), object to the use of your personal information in automated decision making and make complaints about how we process your personal information. You may have other rights under other applicable laws. Please see the contact information in Section 11 below, or Section 5 (Changing and Accessing Your Personal Information) in the main text of this Statement, to learn how to contact us. We seek to handle these requests within the legally required period in accordance with the applicable laws. Particularly, we will respond to your request to deregister within 15 days of our receipt of the request, unless there are extenuating circumstances, in which we will inform you of the anticipated timeline if we expect our response to take longer than 15 days. Please note that if you request to deregister your membership account, you will no longer be able to enjoy any membership benefits from the date of deregistration. After you deregistered your membership account, your personal information will be deleted or anonymized unless the applicable laws require us to retain this information.

7. How We Protect Personal Information

We take reasonable steps to: (i) protect personal information from unauthorized access, disclosure, alteration, or destruction, and (ii) keep personal information appropriately accurate and current by using appropriate technical and organizational measures. For more information, please see Section 6 (How We Protect Personal Information) in the main body of this Statement.

We are not responsible for the collection, use, disclosure, or otherwise processing of personal information by our third-party websites or applications. Please read the privacy policies and terms of use of these websites and applications. This applies to: (1) in-hotel internet services we may offer; (2) third-party websites and applications to which the links in our websites and mobile applications may direct; and (3) third-party digital messaging applications or platforms which we use to communication with you.

8. International Transfers of Personal Information

With your express consent, we may transfer your personal information (including your sensitive personal information, if applicable) outside of China, including United States, Europe, and other jurisdictions where we, our service providers and other relevant third parties conduct business.We will take appropriate steps to protect the integrity and confidentiality of your information and to ensure that your personal information is processed in accordance with the main body of this Statement and in accordance with the applicable laws.

9. Data Retention Period

We will retain personal information about you for as long as necessary to complete the purpose for which it was collected, or as required or permitted by the laws. We will destroy your personal information in accordance with our retention and records management procedures. For more information, please see Section 10 (Data Retention Period) in the main body of this Statement.

10. Changes to This Statement

If we make material changes to this Statement, we will publish these changes. For more information, please see Section 11 (Changes to Statement Content) in the main body of this Statement. If required by the local laws, we will notify you and/or seek your consent.

11. Contact Information for Questions or Concerns

You can contact us if you have any questions, requests, or complaints regarding the protection of personal information. You can contact our global privacy team at [email protected], or, if you would like to get in touch with the contact in China, please contact: [email protected].