GUESTBOOK REWARDS, INC.
GUESTBOOK REWARDS, INC.
Additional California Privacy Disclosures
Last Updated: March 22, 2021
These Additional California Privacy Disclosures ("Disclosures") supplement the information contained in our Privacy Policy by providing additional information about how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the "CCPA"). Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these Disclosures and all other terms defined in the CCPA and not otherwise defined in these Disclosures have the same meaning when used in these Disclosures. If there is any conflict between these Disclosures and our Privacy Policy with respect to California residents, these Disclosures control.
When we use the term "personal information" in these Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
Personal Information Disclosures
In the last 12 months, we have collected the following categories of personal information, disclosed them for a business purpose, and sold or shared certain of them as described in the Sales and Sharing of Personal Information section below:
Collection, Disclosure, Sale, and Sharing of Personal Information
Category of Personal Information
Collected
Disclosed for Business Purpose
Sold or Shared
Identifiers, including relating to data used to identify you, such as full name, email(s), address, birthdate (month and day), and phone number,. We may also collect your travel companions’ names.
Yes — name and e-mail address only, and only with your opt-in consent
Protected Classification Characteristics, including age.
No
Commercial Information, including account history relating to your hotel reservations, your rewards information including cash back, points and other rewards earned/redeemed, earning/redemption statements, rewards status, rewards expiration dates, rewards earning cap status, and transaction identifiers used to connect your transactions to you to provide the associated benefits and rewards, your profile information relating to your bookings, purchases, and interests, and feedback and ratings you provide relating to our services, products, and rewards.
No
Internet/Network Information, such as device information, logs and analytics data.
Yes — shared for cross-context behavioral advertising
Geolocation Data, includingyour general geographic location and precise geolocation when you grant usaccess through your device settings.
Yes — general geographic location shared for cross-context behavioral advertising
Sensory Information, including recordings of phone calls between you and us, where permitted by law.
No
Profession/Employment Information, including the business or organization you represent, your title with that business or organization and information relating to your role with the business or organization.
No
Other Personal Information, including communication preferences, customer service and communications history, personal information you permit us to see when interacting with us through social media, and personal information you provide us in relation to a question, request, inquiry, survey, contest or promotion.
No
Inferences, including our predictions about your interests and preferences and related Service Profile Information.
No
Sources of Personal Information
The CCPA treats certain categories of personal information as "sensitive personal information." We may collect precise geolocation data from your mobile device where your device settings permit it, and account log-in credentials where you access your account or connect a third-party log-in service. We use this information only to provide the Service you request, to secure our systems and prevent fraud, and for other purposes for which the CCPA does not require us to offer a right to limit. We do not sell or share sensitive personal information, and we do not use or disclose it to infer characteristics about you.
Sales and Sharing of Personal Information
We utilize third-party providers to engage in online analytics and advertising involving the collection of personal information, including Identifiers, Internet/Network Information, and general, non-precise Geolocation Data, directly from your browser or device through cookies or related technologies when you visit or interact with our online services or otherwise engage with us online. We use these third-party providers to analyze and optimize our online services, provide more relevant content and ads to users of our online services and other third parties, and perform other services related to analytics or advertising consistent with these Disclosures and our Privacy Policy. These third-party businesses may use the information they collect directly from you for their own purposes in accordance with their own privacy notices, which may include using this information for services provided to other third parties, including other parties operating in advertising networks. These practices constitute "sharing" for cross-context behavioral advertising under the CCPA, and you may opt out of them at any time as described under Submitting Requests below.
Marketing by the property where you enrolled. If you gave your express opt-in consent at the time you enrolled in the Service at a Participating Property, we disclose your name and e-mail address to that property so that it can send you its own marketing communications. Because that property may then use that information for its own purposes, we treat this disclosure as a "sale" under the CCPA. We make it only where you have given that consent, and you may withdraw it at any time by following the instructions set out in the Your Choices About Your Information section of our Privacy Policy.
Other than as described in this section, we do not sell or share personal information. We do not sell or share the personal information of consumers we know to be under 16 years of age.
Sources of Personal Information
As described in the How We Collect and Use Information section of our Privacy Policy we collect personal information directly from you when you provide it to us, automatically when you visit our websites and other online services, and from service providers and other third parties. For representatives of our clients, vendors, service providers and other third parties, we also collect personal information directly from you and from the entity you represent.
Purposes for Collecting Personal Information
We collect personal information about you for the purposes described in the How We Collect and Use Information section of our Privacy Policy. For representatives of our clients, vendors, service providers and other third parties, we also collect your personal information to maintain an ongoing relationship between us and the entity you represent and to contact you in connection with our relationship with the entity you represent.
Recipients of Personal Information
As described in the How We Share Your Information section of our Privacy Policy, we disclose or otherwise make available personal information within The Guestbook group of companies and with a variety of third parties, including service providers and contractors who perform services on our behalf. We may also sell your personal information to Participating Properties and share it with the analytics and advertising providers described above. For representatives of our clients, vendors, service providers and other third parties, we also disclose your personal information to the entity you represent.
Your Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
Right to Know
The right to request any or all of the following personal information we have collected and disclosed about you:
• The specific pieces of personal information we have collected about you;
• The categories and specific pieces of personal information we have collected about you;
• The categories of sources of the personal information we have collected about you;
• The categories of personal information we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
• The categories of personal information we have sold or shared about you (if any), and the categories of third parties to whom this information was sold or shared; and
• The business or commercial purposes for collecting or, if applicable, selling or sharing personal information.
Right to Deletion
The right to request the deletion of personal information we have collected from you, subject to certain exceptions.
Right to Correction
The right to request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes for which we process it.
Right to Opt Out of Sale or Sharing
The right to direct us not to sell or share personal information we have collected about you to third parties.
Right to Limit Use and Disclosure of Sensitive Personal Information
The right to direct us to limit the use and disclosure of sensitive personal information to those uses permitted by the CCPA. As described above, we do not currently use or disclose sensitive personal information for purposes that would give rise to this right, but you may contact us at any time using the methods below.
Right to Non-Discrimination
The right to be free from discrimination for exercising any of the rights described above.
The right to non-discrimination does not prohibit us from offering you certain financial incentives that may result in different prices, rates or quality levels of products or services. Our rewards program is a financial incentive, and we describe it under Notice of Financial Incentive below. In addition, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may not be able to provide our products and services to individuals who exercise these rights, or to otherwise engage with such individuals going forward.
In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.
Submitting Requests
To Exercise Your Right to Know, Right to Deletion, or Right to Correction
To submit a request to exercise your right to know, right to deletion, or right to correction, please submit a request by emailing us at contact@theguestbook.com or by submitting a request via our California Consumer Rights Request Form. You may also delete your account within your Profile settings
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your membership, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email, address, member number, product website name, and/or date of last interaction with customer service.
To Exercise Your Right to Opt Out
To opt out of the sale or sharing of your personal information, use the "Do Not Sell or Share My Personal Information" link in the footer of our website, or e-mail us at contact@theguestbook.com. You do not need to create an account to opt out, and we will not require you to verify your identity before honoring the request.
When you opt out, we will stop disclosing your name and e-mail address to the Participating Property at which you enrolled, and we will notify any property to which we previously disclosed that information with your consent.
Please see Online Advertising in the Your Choices About Your Information section of our Privacy Policy for more information about the choices and opt-out options you may have in relation to those practices.
Opt-Out Preference Signals
We recognize and honor opt-out preference signals, including the Global Privacy Control (GPC), as valid requests to opt out of the sale and sharing of personal information sent from the browser or device on which the signal is enabled. If you are logged in to your account when we receive the signal, we will apply the opt-out to your account as well.
Authorized Agents
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these Disclosures where we can verify the authorized agent’s authority to act on your behalf by:
1. For requests to know, correct, or delete personal information:
a. receiving a power of attorney valid under the laws of California from you or your authorized agent; or
b. receiving sufficient evidence to show that you have:
i. provided the authorized agent signed permission to act on your behalf;
ii. verified your own identity directly with us pursuant to the instructions set forth in these Disclosures; and
iii. directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
2. For requests to opt-out of personal information "sales" or "sharing": receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
Notice of Financial Incentive — The Guestbook Rewards Program
The Guestbook rewards program is a financial incentive under the CCPA, because we provide Rewards to members who enroll in the Service and give us the personal information described below. We offer it to encourage participation in the Service; we have designed it to be reasonably related to the value your personal information provides to us, and participation is entirely voluntary.
Summary of the incentive: Members earn a Reward on a qualifying stay at a Participating Property. The Reward is calculated on Eligible Charges at the rate we publish at the time of booking, which is subject to change. Rewards have no cash value until redeemed, and the redemption options available from time to time, together with any earning cap and expiration rules, are set out in our Terms of Use.
Categories of personal information implicated: To participate, you enroll in the Service and provide the identifiers and commercial information described in the table above — principally your name, e-mail address, and the reservation and stay information needed to calculate and pay your Reward.
How to opt in: Enroll through our website, through a Participating Property’s booking path, or with a Participating Property directly. Enrolling is how you opt in.
Right to withdraw: You may withdraw from the program at any time by deleting your account through My Account or by e-mailing us at contact@theguestbook.com. Withdrawing ends your ability to earn further Rewards.
Good-faith estimate of the value of your personal information and the method of calculation: We value the personal information of a member at the redemption value of the Rewards that member earns, because the Rewards we issue are the expense we incur to obtain and maintain that information. We calculate that value using the expense-related method permitted by section 7081 of the CCPA regulations: for each member, our estimate of the value of that member’s personal information is the total redemption value of the Rewards credited to that member over the preceding twelve (12) months. We apply the Reward rate published at the time of each qualifying booking, so the estimate reflects what that member actually earned rather than an average. This estimate is required by the CCPA and does not give Rewards a cash value; Rewards are redeemable only as described in our Terms of Use.
The difference in the price or service offered to members and non-members is reasonably related to the value of the personal information we receive, because the incentive we pay is measured by, and limited to, that same value.
California "Shine the Light"
California's "Shine the Light" law (Civil Code Section 1798.83) provides certain rights to California residents that have an established business relationship with us regarding the disclosure of certain types of personal information to third parties for their direct marketing purposes. It is company policy that we do not disclose personal information to third parties for their direct marketing purposes if a consumer has exercised their right to opt out. To opt out of having your personal information disclosed to third parties for their direct marketing purposes, e-mail us at contact@theguestbook.com with "Shine the Light" in the subject line. We will respond within thirty (30) days.
Updates to These Disclosures
We will update these Disclosures from time to time. When we make changes to these Disclosures, we will change the "Last Updated" date. If we make material changes to these Disclosures, we will notify you by prominent posting at the beginning of these Disclosures or our Privacy Policy.
Contact Us
If you have questions about these Disclosures or our privacy practices, contact us at contact@theguestbook.com.
