What is Personal Information?
The term "Personal Information" refers to any information that can be used to identify you as an individual. It can include, among other things, your name, address, age, gender, personal financial history and social insurance or social security number.
I. Why is Personal Information collected?
1. Provide Superior Customer Service to our Clients
Personal Information is collected to assist us in making your reservation and providing the services you request at any of our properties, to ensure we meet your needs while you are with us and/or to allow us to contact you in relation to matters that arise from your time with us.
By keeping certain event-related Personal Information on file, such as information regarding client history and itemized spending, clients of The Hub have the ability to confirm prior transactions and reconcile statements or invoices.
2. Keep Our Clients Informed
We may use the Personal Information you provide to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you. In order to do this, your information may be shared with a third party, including a customer relationship management company and/or a marketing and communications company. These companies are under contract with The Hub and are contractually required to protect all client information to which they have access.
If you do not wish to receive information from The Hub you may indicate your wishes on your contract or send an e-mail to: email@example.com
3. Marketing Research
Finally, we may wish to contact Clients to conduct surveys or focus groups to receive your views of our properties and service delivery. Such information may be collected by a third party under contract with us and they will be contractually required to protect your Personal Information as explained below.
Occasionally we will combine information from a number of Clients to better understand trends and Client expectations. When this occurs, all identifiers are removed and the aggregate information cannot be linked to any specific Clients.
II. How is Personal Information Collected?
1. Our Web Site
A. Initially Upon Contact With Our Web Site
When you visit our web site, you are initially given a "cookie", and your computer is assigned an ID number. A cookie is a commonly used device that tracks an individual user's preferences, and is capable of enhancing your visit to the site. Cookies allow us to provide a customized experience without the visitor having to remind us of his or her preferences each time she or he visits our site. Our cookies do not contain any personally identifying information. The Hub cookies also do not follow visitors when traveling on the Internet after leaving The Hub's web site.
Once you have visited our web site and accepted our cookie, your ID number is automatically assigned to your computer whenever you visit our web site. Despite the fact that you remain anonymous until you enter Personal Information in the web site, the ID number allows us to log your session, so that we may better assist you should you need some individualized service or support. Once you enter Personal Information on the web site, we associate your ID number with your contact information so we can recognize you on a future visit. We also use it to keep track of information that appears to be of particular interest to you.
B. While Browsing Our Web Site
While in the process of browsing our web site, you also provide us with information that does not reveal your personal identity - what type of meeting you are seeking information about, for example. We use this aggregated, anonymous data mainly for editorial purposes, but we do not connect it to any Personal Information, such as your name or address.
While you explore our web site for the information that interests you, you may wish to put in a specific "Information Request" about one of our properties, or you may wish to participate in one of our on-line surveys or promotions. To respond to this request or to participate in our various programs, we may ask you for Personal Information, such as your name, zip/postal code, e-mail address, and phone number.
If you wish, you may also submit your e-mail address in order to be placed on a subscription list or to receive other information. You will be placed on these lists only when you indicate your desire to be included. In deciding whether or not to join such lists, please note that they are only used for internal purposes - we do not sell or rent our lists to anyone. In the event you choose to join one of our lists, you may ask to be removed from the list at any time. Visitors will always have the ability to accept or decline any form of communication from The Hub.
C. Making a Purchase or Deposit on Our Web Site
When making a purchase on the site you will be asked to complete a form that includes your contact information and payment information. The form is secure (see below). When the form is complete, your credit card number will be verified using a checking sequence, and once this is confirmed we authorize payment for the amount shown on your order form. Once your transaction is confirmed you will see a 'Thank You' screen, and if you requested an e-mail confirmation it will be sent within a few moments. Again, due to the personal nature of the information you give when making a purchase through our web site, the form is secure, such that your credit card number is protected with the most sophisticated encryption technology available and is transmitted on a private network. Purchasing transactions are assisted by third party processors who are required by contract with us to protect the privacy of your Personal Information.
We retain a log file of transactions at our web site, excluding your credit card number, connected to your ID number. We will then use that information to assist in any inquiries about your transaction. We also occasionally combine information from a number of web visitors in a way that does not identify any user, in order to identify user patterns.
2. During Your Meeting or Event at Our Properties
During your meeting or event, we record your spending to properly assemble your folio, which sets out your rates and other expenses billed to your meeting. We also record this information to comply with financial reporting requirements, including those imposed by our auditors and government regulators. We may also collect certain information as required by local laws. Information particular to your meeting may also be stored (i.e. health issues, payment difficulties, special requests, service issues). This meeting-specific information is stored in the management system at the particular property and is combined with information from previous visits that you have made to that property. Certain information regarding your service preferences may be made available to other The Hub properties through The Hub's client history database. You may advise the Property if you do not want personal preferences shared.
In addition, we may retain the content of any document (including letters, comment cards, electronic documents such as e-mails and other similar forms of communication) that you send us before, during or following your meeting. This information may be shared with employees of the property but will not be shared with any third party.
III. How do we store Personal Information?
1. At the Property
Each property goes to great measures to ensure that all Personal Information is kept in a secure location, be it a database or filing cabinet. Furthermore, we take steps to ensure that only designated individuals have access to this information.
2. In Our Client Reservation System
In order to serve you better we also store certain client information in our Client Reservation system ("CLIENTres"). CLIENTres is a secure customer database stored on a dedicated server located in a data center in Portsmouth, New Hampshire.
The stored information includes client name, address, phone numbers and credit card number. We may also store certain information regarding your service preferences. When you make a reservation at another property, this information is sent to that property.
We also store other transaction information in CLIENTres, including the number of meetings you have had at properties managed by The Hub. This information may be available to another property in order to serve you better.
3. In Our Marketing Database
The Hub maintains a database of Client information which is used for marketing, promotion and research purposes. Any information sent provides a clear notice of how to discontinue receiving promotional materials.
IV. Security, Protection, Exchange and Admin of Information
1. What information is not secure?
Your online interaction with us is protected from eavesdropping using encryption technology based on the browser you use. In order to ensure your privacy and the protection of information you choose to share with us, we allow only encrypted communications from all of our web forms.
It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the Contact Us section of our web site).
2. What information may be exchanged between properties?
Information is shared between certified data privacy personnel at individual properties in certain limited circumstances, particularly where health or safety concerns have arisen in the past. Preference information may also be shared to enhance your property experience.
Further, if a client does not pay the outstanding account on time, or acts in an unlawful manner in regards to payment obligations, this information may be shared among accounting personnel at The Hub properties.
3. What Personal Information may be provided to third parties?
We will only share Personal Information about you outside The Hub without your consent, where: (a) it is required or authorized by law (for example, in response to a legal subpoena); (b) it is required to provide you with services you have requested in which case you will be considered to have implied your consent (i.e. car rental); (c) if your meeting has been paid for by a third party we will provide billing information to the paying party; (d) if you have failed to pay amounts owed.
If The Hub suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency.
4. How do I access or revise my Personal Information?
We understand that you may like to know what Personal Information we hold about you. We are happy to assist you with your request. To protect your Personal Information, however, we require that you prove your identity to us at the time your request is made. Please contact a manager at any facility to discuss this need.
When you make a request in person, we will require you to produce some form of photo identification such as a passport or a driver's license and you will be asked to sign a request form.
Where you make a request by other means, we require the request be made in writing via fax or letter including a copy of a government issued identification and signature. We also require home and business addresses and phone numbers so we can check them with our files and satisfy ourselves as to your identity.
The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Information.
The Hub reserves the right to decline access to your Personal Information under certain circumstances. If your Personal Information will not be disclosed, you will be provided with the reasons for this non-disclosure.
If at any time you wish to update or access your Personal Information, you can do so by contacting our Corporate Client Historian:
- via e-mail at firstname.lastname@example.org
- via fax at 215-561-8093
- via letter -Attention: President
The Hub, LLC
30 S. 17th ST., Ste. 1410
Philadelphia, PA 19103
How long is my Personal Information retained?
Your Personal Information will be stored for the period of time required by law in the jurisdiction of any property holding the information. It may be stored indefinitely by The Hub as long as there is a business purpose for doing so. From time to time we may delete your Personal Information if you have not had a meeting or event with us in a number of years.
How will I know if there are changes to this Policy?
How Is Personal Information affected by business transfers?
The Hub also manages properties on behalf of third party owners. Client information required for the business transaction between the client and the property may be shared with the owner, but all other Personal Information is considered to be proprietary to The Hub, and is not shared with owners. If we cease to manage a particular property, all Personal Information remains with The Hub. Client information that is historically shared with the owner is retained by the owner.
5. Protection of Children
The Hub website is not designed for children; nevertheless, The Hub takes special care to protect the safety and privacy of young people who may venture into the website. We do not specifically collect information from or about children and believe that children should get their parents' consent before giving out any personal information. Should a child whom we know to be under 13 send personal information to us, we will delete that information from our servers. We encourage parents or guardians to participate in their child's experience in cyberspace and to supervise the child so that he or she views only age-appropriate content available on the Web. The Hub also recommends that parents utilize Web filtering technology to supervise their children's access to the Web.
To whom do I direct questions or concerns regarding this policy?
The Hub, LLC
30 S. 17th St., Ste. 1410
Philadelphia, PA 19103