1. In General
2. Personal Data We Collect
We collect and process Personal Data, which may include the following:
Your personal identification information, as would typically be included on your driver’s license, passport or other identification that you present at the time you check-in to a Triumph Hotel, including your: name and/or any alias or pseudonym you provide to us at check-in, residential address(es), mailing address(es), telephone and cell phone number(s), electronic mail (“email”) address(es), gender or gender identity, date of birth, country of citizenship, and your image(s). Upon registering with Triumph or a Triumph Hotel, or a Triumph Loyalty Program security question answers, your contact details including, and photos.
Your credit or debit card number, and related information with respect to your payments to us, which we process in compliance with the Payment Card Industry (“PCI”) Security Standards and PCI Data Security Standard (“PCI DSS”) established by the PCI Security Standards Council.3 .
Information about your hotel stay, such as your arrival time, travel companions, departure time, room and amenity preferences, package selection, and any special assistance you request at the hotel.
Information concerning your use of the Triumph membership program, including your name, and email address. Triumph Hotels may collect additional personal data from you with respect to guest programs operated by individual hotels which are part of the Triumph group, such as your name, email address, physical address, room and amenity preferences.
(e) Information about your communications with Triumph Hotels
A copy or record of any communications you have with Triumph Hotels, including any communications you have with Triumph Hotels staff or personnel before, during or after your stay in one of our hotels, or in connection with other services or products we offer. This includes communications with us to get assistance with a problem or issue you are having with our products or services and includes communications you have with Triumph staff in-person, over the phone, or electronically via electronic mail, through one of our websites, or by messaging or communicating to us through social media or other electronic means.
(f) Information about your social media postings and press coverage
If you post on social media any comments or reviews about a Triumph Hotel, Triumph Hotels may keep a record of such comments or postings and social media profile. Press coverage includes TV or radio interviews, newspaper or magazine articles, and records Triumph maintains regarding a customer’s appearance in a documentary film, or appearance on a reality TV show.
Your personal data in connection with any of our contests that you decide to enter. We run such contests periodically, and if you decide to enter one of our contests, we may keep records regarding your contest entry, and any prize you may have won, which in addition to your photographs or images of our customers.
If you are traveling and staying in a Triumph Hotel on business, we may collect certain information about your company, organization or governmental entity, including information that typically appears on a business card or that is published on an organization’s website, such as the name of the organization, your business address and other contact information at the organization, your title or role at the organization, and any other information that may be included on an invoice or provided in connection with the booking of your business-related stay at one of our hotels.
3. How we collect Personal Data
3.1 We collect Personal Data from you directly or thru third parties including: (a) TAs (which include corporate travel managers) and other persons that make bookings or otherwise interact with us on your behalf when booking a stay at one of our hotels; (b) outside reservation services; (c) OTA’s and providers of other online travel-related services; (d) marketing and advertising data analytics providers; (e) Triumph Loyalty Program service providers; (f) organizations which conduct credit and fraud checks; and (g) providers of websites, apps and social media providers that advertise or refer you to our services.
3.2 Please note that We collect information about your traveling companions and other members of your party who utilize our services.
4. Why we collect and process your Personal Data:
- To communicate with you in connection with booking your hotel stay and assist in making travel arrangements;
- To communicate with you regarding issues that may arise regarding your hotel booking and other communications related to our services;
- to deliver to you the services and options included with any travel package you purchased in connection with your hotel booking;
- to provide or facilitate any special assistance you may have requested in connection with your hotel booking;
- To personalize the services, we provide to you in connection with your current and future hotel bookings, such as using information about your room and amenities preferences to provide you a more comfortable stay.;
- For customer support purposes such as responding to your inquiries and requests and any issues you may have;
- To provide you with marketing communications, as explained in more detail in section  below;
- To operate our Triumph Loyalty Programs;
- To conduct our periodic contests in which our guests have the opportunity to participate;
- To comply with requirements under applicable international, federal, state and local laws and regulations, including: verification of your identity, verifying and processing your card payment or other payment method, screening against fraud and illegitimate bookings, detecting criminal or unlawful activities, ensuring the safety of our hotel staff and guests, enforcing or protecting our legal rights or the legal rights of our customers or contractors, and compliance with any court order or judicial mandate
- To improve our service to you; and
- For necessary administrative purposes, including for accounting, billing and audit purposes, and for insurance claims handling.
Please note that -- although you may request that we stop storing and/or processing certain of your Personal Data as described below -- when booking a stay at one of our hotels, we do require that you provide to us certain Personal Data, such as payment and contact information. If you do not provide the required Personal Data to us in connection with your stay, we may be unable to provide you with our services.
5. Who we share your Personal Data with
In certain circumstances, we disclose your Personal Data to third parties, as described below:
5.1 Our service providers who process personal data on Triumph’s behalf for the purposes described in section 4. We will permit our third-party service providers, marketing consultants, including agents, contractors to use your Personal Data on our behalf for the purposes set out in section 4. Examples of such third parties include operators of our IT systems and outside reservation agents. We may also disclose your personal data to third parties in order to meet any personal requests you may have with respect to your room or amenities such as special dietary requests or the like.
5.2 Other hotels, travel operator’s TAs and OTAs if required to facilitate and administer any travel package you have purchased that includes such third parties, you have purchased through such a third party.
5.3 Our third-party partners, for marketing purposes
We may disclose your Personal Data to third parties so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, contests, sweepstakes, market research, customer surveys and data analytics to help us improve and tailor our marketing activities, products and services. Subject to us having obtained appropriate consent from you, we may also disclose your Personal Data to our third-party marketing partners in order that they may market their products and services to you.
5.5 Our corporate or government clients
For employees or other persons travelling or obtaining products or services in relation to one of our corporate or government clients, we may disclose your travel details and information concerning your use of our service to our corporate or government clients in accordance with any agreement we may have with such government or corporate clients.
5.6 Government and regulatory bodies and other individuals, bodies and organizations
We will disclose your personal data as may be required by law to any government or regulatory organization that has the legal right to obtain your information or for reasons involving the safety and security of our guests and staff.
6.1 We may use Personal Data for marketing and promotional purposes, including (i) for sending or showing you updates on latest news, offers and promotions in connection with our services (ii) for sending or showing you joint marketing offers about our hotel offers and packages, loyalty programs, contests and sweepstakes; or (iii) for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to any of our websites.
6.2 We may also use Personal Data to analyze our customers’ preferences and market trends and derive insights, which we may use to tailor the types of services and offers that we present to you. This may involve us combining Personal Data that we hold about your use of our services with information that we have collected about your web usage. We may also combine information that we have collected about you with information that we have collected about our other customers in order to derive these insights and establish market trends. We may provide this and other information to contracted third party marketing and promotional analytics providers to enhance our marketing and promotional activities and to better inform you and our other customers about our services and offers.
6.3 We may send you marketing materials and promotions to you by post, telephone, or electronic means (such as by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to opt-out of receiving such marketing materials, at the time we send you any such materials.
6.4 You may also opt out by contacting us as set out in paragraph 8 below.
6.5 Please note that if you choose to unsubscribe or opt out of marketing communication, we will still send you communications about your travel with us and any other services that we provide to you.
7. Transmission, storage and security of your Personal Data
7.1 IT Security
Although there is no way to remove all risk of a data breach involving your Personal Data, we comply with all computer and information technology (“IT”) security requirements mandated under applicable US law and the GDPR, including commercially reasonable physical, electronic and procedural safeguards to protect your Personal Data.
7.2 Exporting your Personal Data
Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.
7.3 Retention period
We will keep your Personal Data for no longer than is necessary for the purpose(s) for which it was collected, based on our relevant and necessary business needs or any other permitted purpose.
8. Your rights and contacting us
8.1 General rights
You have the right to access and review your Personal Data collected and processed by us. Please note that we may charge a reasonable fee for the processing of any such request to access and review your Personal Data stored by us. You also have the right to notify us regarding any inaccuracies in your Personal Data stored by us that you would like us to correct.
8.2 Right to opt out of direct marketing
You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal Data for direct marketing purposes by:
(a) following the “unsubscribe” instructions contained in the relevant communications; or
(b) emailing or contacting us at email@example.com
8.3 Right to “be forgotten”
You have the right to have your data erased where the personal data is no longer necessary in relation to the purposes for which it was collected. We may nevertheless retain Personal Data which is necessary for compliance with legal obligations or for the establishment, exercise or defense of legal claims. You can exercise the right at any time after we have collected and used your Personal Data by requesting via email firstname.lastname@example.org
8.4 Updating information
We will take reasonable steps to try and ensure that your Personal Data is accurate. To help us do this, please notify us of any changes to your Personal Data.
8.5 Contacting us
1633 Broadway, 46th Flr
New York, NY 10019
9. Links to Other Sites
The Triumph websites contain links to other sites that are operated by third party companies with different privacy practices. You should remain alert when you leave our site and read the privacy statements of other websites. We have no control over Personal Data that you submit to or receive from these third parties.
1 Which include the following hotel properties located in New York City as of June 1, 2018: Hotel Belleclaire, Hotel Edison, The Evelyn, The Frederick Hotel, The Iroquois, and the Washington Jefferson Hotel.
2 REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).