Privacy Policy

SALAMANDER HOSPITALITY PRIVACY POLICY

Last updated: February 12, 2024

Table of Contents

1. Overview and Scope
2. Information We Collect
3. Use of Information
4. Sharing of Information
5. Your Choices
6. Cookies and Tracking
7. External Links and Features
8. Children
9. Security
10. Changes to this Policy
11. Contact
12. Additional Information for EEA and UK Residents

1.  Overview and Scope

This Privacy Policy (“Policy”) applies to Salamander Hospitality, LLC, and its affiliates (“Salamander Hospitality”, “we”, “us”, “our”).

In this Policy, we describe the information, including personal information, that we collect about you, and our use and disclosure of that information. This Policy applies to information that we collect about you from the following sources:

• Online: through our websites, mobile versions of our website, and our mobile applications (collectively, our “Sites”).
• Offline:  when you interact with us (e.g., such as by contacting our call center, posting to our social media pages, and as described below).
• At a Property that We Manage: We manage hotel properties as listed in the footer of our website. This Policy applies to the information that you provide to any property that we manage, such as when you make a reservation to stay at one of our properties, whether you make that reservation in person or online, and any other actions with the particular property.

In this Policy, we refer to the actions that we provide as our “Services.” Please note that depending upon your relationship with us and your interaction with a property that we manage, there may be circumstances in which the use of your personal information is subject to an additional policy (e.g., if you enter a property-specific promotion)., your information may be governed by this Policy as well as a policy pertaining to the property’s use of your information. 

For users in the United States: Use of our Services and any dispute over privacy is subject to this Policy and our Terms of Use, available at https://www.hotelbennett.com/terms including its applicable terms governing limitations on damages and the resolution of disputes.

We may offer promotions or co-branded offerings; in some circumstances, those data collections will be governed by an additional or different privacy policy. If you have any questions about the treatment of your personal information, please contact us at [email protected].

2. Information We Collect

We collect information, including personal information, about you from a variety of sources, including, information that we collect directly from users of our Services (for example, visitors to our Sites, guests at properties that we manage, and persons who otherwise contact us); information that we collect from other persons; and information that we collect automatically when you use our Services.

Information That We Collect Directly From You: We collect identifying information, financial information, demographic information, purchase history, and other information described below. The type of information, including personal information, that we collect from you depends on your interaction with us. We collect information from you when you take the following actions:

• Make a Reservation/Purchase/Stay at One of Our Managed Properties:  We manage certain hotel properties (listed at the bottom of our Sites). If you make a reservation or complete a transaction at one of these properties, we will receive your contact information, payment information, including guest credit and debit card number or other payment information, information regarding your reservation, information about your intended stay, and any other information that you choose to provide to us (this may include information about hobbies, dining reservations, activities in which you participate at the property). Please note that we may retain information about you even if you cancel your reservation.
• Sign Up for Email Marketing From Salamander Hospitality: We collect your name and email address if you sign up to request email advertising from us. When you join our email marketing list, we may send communications to you about any of the properties that we manage. If we cease managing a specific property, please note that Salamander Hospitality – not the property – maintains the email contact list. Please note that the properties that we manage also may maintain their own email marketing lists. If you sign up with a specific property to receive email about that property, your email will be added to the specific property database as well as to our corporate database. Please see information below regarding opting out of email either from the specific property or from Salamander Hospitality.
• Posts to our Services or Our Social Media Pages: You may post, or grant us permission to post, photos, reviews, ideas, or other content to our Services, as indicated, and on our social media pages. Regarding social media, a platform’s privacy policy may also govern collection of personal information.
• Contact Customer Service: We collect information about you when you contact our customer service department, whether by phone, mail, or email. This includes your name, contact number, and scope of your inquiry. Calls to our call center may be recorded for quality assurance and training purposes; we will obtain your consent (which may be inferred) where required by law. We do not typically associate these recordings with the personal information we collect about you.
• Participate in Promotions, Marketing, and Surveys: We may offer promotions and other marketing materials. Additional policies may govern such promotions. We may also provide users with surveys to better understand our customers, which may request contact information as well as household information (e.g., income, age, marital status, members of household, etc.).

Information We Collect About You From Other Persons: We collect information about you from other persons as follows:

• Guests: We may collect information about you if another guest books a reservation or makes a purchase for you or on your behalf.
• Persons Making Reservations on Your Behalf: This includes employers, conference group managers, travel agents and other guests (e.g., other members of your household).
• Our Other Properties and Affiliates: We may collect information about you from our affiliates and from the properties that we manage (e.g., if a guest books a stay in-person at a hotel, rather than online or over the phone, that property will provide their booking information to us).
• Your Friends: We may collect information about you if your friends purchase a gift or product for you.
• Social Media: If you post information on our social media pages, we collect the information that you post. We also may obtain information about you through your social media pages that you have made public if you mention us in a post. If so, the platform’s privacy policy may also govern collection of personal information. We do not typically associate your social media information with the personal information we collect about you.
• Non-Affiliated Providers: We may obtain information about prospective customers from a non-affiliated source, such as data analytics firms and marketing and social media providers, for purposes of reaching new customers, where permitted by applicable law. We may also purchase demographic information from non-affiliated sources.
• Service Providers: We collect information about you from entities who provide services or perform functions on our behalf. For example, we may collect demographic information and viewing history from data analytics providers, internet service providers, and social media platforms. Please also see below regarding information we collect automatically.

Information We Collect Automatically: We automatically collect information about you when you use our Services (usage information). We collect this information from our service providers and vendors, which may include operating systems and platforms, internet service providers, data analytics providers, and social media providers. The type of information that we collect varies depending on the settings of your web browser or device, but it may include the pages you view on our Sites; the date and time you access our Sites; how long you use our Services; the type of web browser you are using (for example, Firefox or Chrome); the type of device you are using (for example, whether you are using a mobile device); and your Internet Protocol address; device ID; your location information (collected, e.g., through our analytics providers such as Google or directly through our Sites; see the section below titled Cookies and Tracking). We do not typically associate this information with the personal information that we collect about you.

The foregoing information may be required to enter into a contract with you (such as to reserve a room) or provide services (such as resort services) at your request, and failure to provide any information may result in our inability to provide requested services or products.

3. Use of Information

We use your information, including personal information, for the following purposes:

• Transactional Purposes: to provide our services to you, such as to facilitate your hotel reservation; to establish and update your account; and for other transactional purposes.
• Customer Service/Communications: to provide you with a personalized experience on our Sites; for technical support to answer your inquiries; to provide details about upcoming events, our properties, or other services that we think may be of interest to you.
• Marketing/Advertising: for marketing purposes, including to provide you with special offers, promotions, news, and newsletters; to contact you about offers we think may interest you, including promotions/events offered by the hotels that we manage; to administer contests, promotions, and other offers; and for other marketing, advertising, and promotional purposes. Our communications may include information about our management company and any property that we manage. Our marketing communications with you may include communications via postal mail, email, and social media. We, and our service providers, also use your information to determine the success of our advertising campaigns, regardless of the marketing and advertising channel.
• Administration: for administrative purposes, including to manage our inventory; to help us better understand how our customers access and use our Sites, including the pages viewed, ad impressions clicked, or other Site activity; to maintain security and operability of our Sites (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this Policy, our Terms of Service, and other policies.
• Research and Development/Analytics: for research and development purposes, including to improve our Services, products, and customer experience; to understand what parts of our Sites are most popular or to improve upon our Sites; to understand demographics of users who visit our Sites and stay at our properties; and for other research and analytical purposes.
• Legal compliance: to comply with applicable legal or regulatory obligations, including to respond to a subpoena, warrant, court order, or other legal process; to cooperate with an investigation or request, whether formal or informal, from law enforcement or other governmental authority.
• Protection of us and others: where we believe it is necessary to protect us and others, including, without limitation to detect, prevent, and respond to fraud, security incidents, potential threats to the safety or legal rights of any person or entity, violations of our Terms of Use, or other issues where we believe it is appropriate to protect us and others.
• Auditing, Reporting, and Other Internal Operations: To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security, financial controls, risk, and compliance with legal obligations; our general business, accounting, record-keeping, and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
• Business Transfers and Transactions. To plan and carry out acquisitions, mergers, business transactions such as an investment or financing, transfers of some or all of our assets or the assets of one of our corporate relatives to another legal entity, bankruptcy proceedings, sale of a business or a similar transfer of assets.

4. Sharing of Information

We share your information with the following entities:

• Corporate Relatives. We may share your information with any current or future parent company, affiliate, subsidiary or division.
• Service Providers. We share your information with our service providers or others who perform functions on our behalf. For example, we share your information with service providers who host our Sites, coordinate mailings, analyze aggregate information about our customers, assist us in detecting and deterring fraud, security incidents, or other unlawful activity, and for other business purposes as described above in how we use your information. We also permit service providers to collect information about you online through cookies and other tracking tools; please see the Cookies and Tracking and Analytics Providers/Advertisers sections below.
• Hotels We Manage. We manage certain hotel properties (listed at the bottom of our website). We will provide your information to the particular property at which you are making a reservation. Please see the particular hotel’s website privacy notice for information about how that property will use your information. 
• Carefully Selected Partners. If you choose to enter a joint promotion, then we will share your contact information (and other information that you provide to us in connection with that promotion) with the other party. The promotions may be subject to an additional or different privacy policy.
• Site Users. We may share your information with other users of our Sites. For example, if you post a review, pictures, or other content on our Sites, the contents of your post (including any pictures that you post) as well as other information, such as your username, may be available to all visitors to our Sites.
• Analytics Providers/Advertisers. As set forth above, we share information with analytics providers and advertisers to assist us in implementing and evaluating relevant advertising. Often the information that we share is collected from you through cookies and other tracking technologies on our Sites. We also may disclose certain information (such as your email address) to data analytics firms and marketing and social media providers, which may use it to target advertising to you. See the section entitled Your Choices, Opt Out of Interest-Based Advertising below.

We may also share your information in the following ways:

• Business Transfers and Transactions. We may share your information with another entity if we or any of our current or future corporate relatives are acquired by or merged with another legal entity, in connection with a business transaction (such as an investment or financing), if we transfer some or all of our assets or the assets of one of our corporate relatives to another legal entity, as part of a bankruptcy proceeding, or as part of a sale of a business or a similar transfer of assets.
• In Response to Legal Process. We share your information to law enforcement, regulators, and other persons when we believe it is appropriate to comply with the law or a regulatory requirement; to comply with governmental, administrative, or judicial process or other similar requirement or order, such as a subpoena or court order; to cooperate with law enforcement or other governmental investigations (without necessarily requiring the law enforcement or government agency requesting the information to formally serve us with a subpoena); or in connection with litigation in which we are involved. We also reserve the right to report to appropriate law enforcement or governmental agencies any activities that we believe are in violation of applicable laws, rules, or regulations without providing notice.
• To Protect Us and Others. We share your information where we believe it is necessary to prevent or investigate a possible crime, such as fraud or identity theft; to enforce a contract; to protect the legal rights, Site, or safety of you, us, our corporate relatives, and their respective employees, clients, partners, agents, other users, or the public in general; to enforce our [Terms of Use] or this Policy; and to monitor and remediate security issues.
• Aggregate and De-Identified Information. We may disclose aggregate and de-identified information about our customers for marketing, advertising, research, or other purposes.
• Other Disclosures. We may disclose your information in other ways not described above when we either provide you with notice, obtain your consent, or are otherwise permitted by applicable law.

5. Your Choices

You have certain choices regarding the personal information we collect about you. For example, you may:

• Request to Modify Content You Have Posted. You may request to modify content that you have posted to our Sites (including our social media sites) by emailing us at [email protected] and specifying the content (such as comments or reviews) that you would like modified or deleted. In some cases, we may not be able to remove your content. If this is the case, we will let you know if we are unable to do so and why. Even if we are able to anonymize or make your content or information no longer visible, there is no way to ensure complete or comprehensive removal of your content from the Internet because other persons may have archives of our web pages. We therefore cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy.
• Opt Out of Promotional Email Communications. You may opt out of promotional emails by clicking on the unsubscribe link in the email, or by emailing us at [email protected], and explaining the email that you would like to unsubscribe from. Please note that opting out of an email from a particular hotel will opt you out of our entire database; the reverse also is true:  if you opt-out of receiving emails from Salamander Hospitality, we also will opt you out of receiving emails from the individual properties.
• Opt Out of Interest-Based Advertising. We use service providers such as Google's AdSense and AdWords to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our Site or elsewhere (“Interest-Based Ads”). Any advertisements served by Google, Inc., and affiliated companies may be controlled using cookies. These cookies allow Google to display ads based on your visits to this Site. Any tracking done by Google through cookies and other mechanisms is subject to Google's own privacy policies. You may decide to disable Google cookies by clicking on: https://myadcenter.google.com/. You can visit My Ad Center to manage the Google ads you see and opt out of Interest-Based Ads delivered by Google. You also may opt out of receiving Interest-Based Ads from many non-affiliated ad networks, such as those provided by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding Interest-Based Ads by NAI members and DAA members, including how to opt out of Interest-Based Ads provided by NAI and DAA members, please visit their respective websites: optout.networkadvertising.org and optout.aboutads.info. Please note that opting out of participating ad networks does not mean that you will not see any advertisements; you will continue to receive advertisements on other websites and from companies that do not participate in the above programs. Even if you opt out of interest-based ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search. Certain of our Sites also may use Facebook advertising, including Facebook Custom Audience. As set forth above and in the Cookies and Tracking section below, we may disclose certain information (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audiences click here) so that we can better target ads and content to you and others with similar interests on non-affiliated websites or media (“Custom Audiences”). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other entities display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described in this paragraph.

Please note that even if you opt out of receiving marketing communications from us, we may still send you communications about your account or any products or services you have purchased from us and we will still respond to your inquiries and requests for information.

6. Cookies and Tracking

We and our service providers use cookies and other mechanisms to track information about your use of our Services. We do not typically associate this information with the personal information that we collect about you nor do we attempt to identify you as a natural person through this information.

• Cookies. We or our service providers may use cookies to track visitor activity on our Sites. A cookie is a text file that a website transfers to your device for record-keeping purposes. We or our service providers may use cookies to track user activities on our Services, such as the web pages you view and time you spend on our Sites. The help section on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable cookies may not be able to browse certain areas of the Services.
• Pixel Tags. Pixel tags (also known as clear GIFs or web beacons) are tiny graphics with a unique identifier, similar in functionality to cookies, which are embedded invisibly on web pages. We or our service providers may use pixel tags, in connection with our Services to perform functions like tracking the activities of visitors to our Services, helping us manage content, and compiling statistics about usage of our Services. We or our service providers may also use pixel tags in emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
• Cross-Device Tracking. We and our service providers may use the information we collect from users within our Services and on other non-affiliated websites and services to help us and other entities identify other devices used (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Services.
• Customer Lists. Subject to applicable law, we and our service providers may disclose certain customer list information (such as name, email address and other contact information, which in most cases is hashed when it is shared) with data analytics firms and marketing and social media providers to target ads and content to a site or app user and others with similar interests. In some cases, these entities may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns.
• Embedded Scripts. We may use embedded scripts, which is code designed to collect information about how visitors interact with a website, such as the website which linked them to one of our Sites.
• Analytics. We use service providers, such as Google Analytics, to evaluate the use of our Sites. We or our service providers use automated devices and applications to evaluate use of Services. We use these tools to help us improve our services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as pixel tags or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review Google’s privacy policy at https://policies.google.com/technologies/partner-sites. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
• Do Not Track. Our Services do not respond to Do Not Track signals. You may disable certain tracking as discussed in this section (e.g., by disabling cookies).

7. External Links and Features

Our Sites (and apps) contain links to other entities’ websites and applications. Any access to and use of such website and applications are not governed by this Policy. Instead, your use of these websites or applications is governed by their own privacy policies, and not this Policy. We are not responsible for the information practices of such websites or applications: please read the relevant entity’s privacy policies for more information.

8. Children

Our Services are for general audiences and are not targeted to persons under the age of eighteen (18) years of age. We do not knowingly collect any personal information from persons under 18, and we will delete any personal information collected that we later know to be from such a person. If you believe someone under 18 has disclosed personal information to us, please contact us at [email protected] and specify the customer and information you believe to be from such person.

9. Security

We have taken steps to help protect the information we collect from you, including personal information, from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. Please note that we cannot guarantee the security of any information we have collected from you, including personal information, and your use of our Services indicates understanding and acceptance of this risk.

We encourage all users to take steps to protect their accounts by, among other things, choosing a strong password that nobody else knows or can easily guess and keeping log-in and password information private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on any account via unauthorized password activity.

10. Changes to this Policy

This Policy will be updated from time to time. Changes will go into effect when posted. If we make any changes to this Policy that materially affect our practices regarding our use of the information that we previously collected, we will endeavor to provide users with notice, such as by posting prominent notice on our Sites. We will post any updated Policy to our Sites.

11. Contact

For any questions or concerns regarding this Policy or our privacy practices, please contact us using the information provided below:

Email: [email protected]
Phone: 540-687-3710

12. Additional Information for EEA and UK Residents

The controller of your personal information is Salamander Hospitality, LLC. 100 West Washington Street, Middleburg, VA 20118.

Your Rights

We would like to make sure you are fully aware of your data protection rights under the EEA and UK General Data Protection Regulations (“GDPR”) or other applicable data protection law. EEA and UK residents are entitled to the following, subject to specific conditions and limitations as set out in GDPR:

• The right to access: You have the right to request that we provide additional information about the processing of your personal information, and copies of your personal information.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request we complete the information you believe is incomplete.
• The right to erasure: You have the right to request that we erase your personal information, such as where you have withdrawn your consent, where you object to processing based on legitimate interests due to your particular situation and we have no overriding legitimate grounds (see below), or where your personal information is unlawfully processed.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal information so that it is merely stored and not otherwise processed, under certain conditions such as:
  • you contest the accuracy of the personal information (we will restrict processing until we have taken sufficient steps to correct or verify its accuracy);
  • the processing is unlawful but you do not want us to erase the personal information;
  • we no longer need your personal information for the purposes of the processing, but you require such personal information for the establishment, exercise or defense of legal claims; or
  • you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

Where your personal information is subject to restriction, we will only process it with your consent or for the establishment, exercise, or defense of legal claims.

·       The right to object to processing based on legitimate interest: Where we are relying upon our legitimate interests to process personal information, you have the right to object to that processing based on grounds related to your particular situation. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal information for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a legal basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis. ·       The right to object to processing for direct marketing purposes: You have the right to object at any time to processing of your personal information for direct marketing, including profiling related to direct marketing.

• The right to data portability: Where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal information is processed by automated means, you have the right to request that we transfer the information that we have collected to another organization where this is technically feasible, or directly to you.
• Right to withdraw consent: In the event your personal information is processed on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• You also have the right to lodge a complaint with the supervisory authority, in particular the authority in the place of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal information infringes applicable law.

If you would like to exercise any of these rights (other than your right to lodge a complaint, for which you can directly contact the data protection supervisory authority), please contact us at our email: [email protected], or write to us at: 100 West Washington Street, Middleburg, VA 20118.

Our UK representative is Stavros Antonis, and may be contacted at [email protected]. Our EEA representative is Stavros Antonis, and may be contacted at [email protected].

International Data Transfers

By choosing to interact with us, your personal information will be transferred to us where we operate, which is the United States, a country with data protection laws that are not as protective as those of the EEA or UK. [In order to protect your information, we abide by the data importer obligations set forth in European Commission-approved Standard Contractual Clauses and their UK equivalent. You may obtain a copy of these by contacting us as indicated here.] [In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.]

Retention of Your Information

Our general approach is to only retain personal information for as long as is required to satisfy the purpose for which it was collected by us or provided by you, including for the duration of the applicable statute of limitations. For example, we retain records in order to resolve queries or disputes regarding our Services, or bring or defend claims which we think may arise from time to time during the relevant statute of limitations. In certain cases, legal or regulatory obligations require us to retain specific records for a set period of time, including following the termination of any contract with you or your employer (e.g., under applicable tax law). 

Legal Bases for Processing Your Personal Information

All processing (i.e. use) of your personal information is justified by a condition (called “legal basis”) for processing. Processing will be justified on one of the following bases:

• Contract Performance: the processing is necessary to perform a contract with you or take steps to enter into a contract at your request, such as providing requested services;
• Compliance with Law: the processing is necessary for us to comply with a relevant EEA or UK legal obligation, such as accounting for our sales of products;
• Legitimate Interests: the processing is in our legitimate interests, subject to your interests and fundamental rights; or
• Consent: you have consented to the processing, for those situations where we may rely on your consent to justify our processing of your personal information.

We use your personal information for the following purposes, relying on the following legal bases:

• Transactional Purposes: to provide our services to you, such as to facilitate your hotel reservation; to establish and update your account; for technical support to answer your inquiries; and for other transactional purposes. The legal basis for this processing is Contract Performance.
• Customer Communications: to provide you with a personalized experience on our Sites; to provide details about upcoming events, our properties, or other services that we think may be of interest to you. The legal basis for this processing is our Legitimate Interests in improving your experience on our Sites and promoting our activities, in order to increase your engagement and our sales.
• Marketing/Advertising: for marketing purposes, including to provide you with special offers, promotions, news, and newsletters; to contact you about offers we think may interest you, including promotions/events offered by the hotels that we manage; to administer contests, promotions, and other offers; and for other marketing, advertising, and promotional purposes. Our communications may include information about our management company and any property that we manage. Our marketing communications with you may include communications via postal mail, email, and social media. We, and our service providers, also use your information to determine the success of our advertising campaigns, regardless of the marketing and advertising channel. The legal basis for this processing is your consent, where we have obtained and rely on your consent to market to you. If we have not obtained your consent, our legal basis is our Legitimate Interests in improving your experience on our Sites and promoting our activities, in order to increase your engagement and our sales.
• Administration: for administrative purposes, including to manage our inventory; to help us better understand how our customers access and use our Sites, including the pages viewed, ad impressions clicked, or other Site activity; to maintain security and operability of our Sites (including for debugging purposes); to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this Policy, our Terms of Service, and other policies. The legal basis for this processing is our Legitimate Interests in operating our Sites and Services efficiently, and in protecting our reputation, sales, rights and business prospects.
• Research and Development/Analytics: for research and development purposes, including to improve our Services, products, and customer experience; to understand what parts of our Sites are most popular or to improve upon our Sites; to understand demographics of users who visit our Sites and stay at our properties; and for other research and analytical purposes. The legal basis for this processing is our Legitimate Interests in improving our Sites and Services in order to increase our sales.
• Legal compliance: to comply with applicable legal or regulatory obligations, including to respond to a subpoena, warrant, court order, or other legal process; to cooperate with an investigation or request, whether formal or informal, from law enforcement or other governmental authority. The legal basis for this processing is our Legitimate Interests in complying with our legal obligations in order to protect our reputation and avoid the costs of non-compliance.
• Protection of us and others: where we believe it is necessary to protect us and others, including, without limitation to detect, prevent, and respond to fraud, security incidents, potential threats to the safety or legal rights of any person or entity, violations of our Terms of Use, or other issues where we believe it is appropriate to protect us and others. The legal basis for this processing is our Legitimate Interests in protecting our reputation and business activities.
• Auditing and Reporting: To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security, financial controls, risk, and compliance with legal obligations. The legal basis for this processing is our Legitimate Interests in complying with our legal obligations in order to protect our reputation and avoid the costs of non-compliance.
• Other Internal Operations: For general business, accounting, record-keeping, and legal functions, and to maintain appropriate business records and enforce company policies and procedures. The legal basis for this processing is our Legitimate Interests in operating our business efficiently, and in protecting our reputation, sales, rights and business prospects.
• Business Transfers and Transactions. To plan and carry out acquisitions, mergers, business transactions such as an investment or financing, transfers of some or all of our assets or the assets of one of our corporate relatives to another legal entity, bankruptcy proceedings, sale of a business or a similar transfer of assets. The legal basis for this processing is our Legitimate Interests in maximizing operational efficiencies and the interests of our stakeholders.