Privacy Policy

This website www.sportstravelhospitality.com/indian-wells/ (“Site”) is operated by Volume Services, Inc. an affiliate of STH Group (“STH”, “we”, “us”, “our”). We are committed to respecting your privacy and protecting your personal information. In support of our commitment, we developed this privacy policy (“Privacy Policy”) together with our Cookie Policy, in order to be transparent about how we collect, use, disclose and safeguard your (and/or the members of your group/traveling party’s) personal information submitted by you at our Site as well as any other media form, media channel (including, without limitation, email, mobile website, mobile application, or call center, related or connected thereto our Site, regardless of whether they directly display or link to this Privacy Policy (individually, a “connected service”, and collectively, “connected services”).

This Privacy Policy applies to the following:

All connected services relating to STH, including all information collected through our connected services.
Information collected by us (or on our behalf) but excluding instances where your information is collected under a different Privacy Policy or notice made available to you at the time your information is collected.
Information shared with us by third parties for our own use, as well as publicly available information collected by us.

The collection, use, and disclosure (collectively, “processing”) of information described in this Privacy Policy is controlled by STH. Please read this Privacy Policy carefully before using the Site or submitting any personal information as it contains important information including, but not limited to, on personal information we collect about you, what we do with your personal information and who your personal information will be shared with. If you have any questions or concerns about this Privacy Policy or our practices with regards to the information processed under this notice, please contact us using the contact information and methods provided under How To Contact Us below. By using the Site, you are accepting the practices described in this Privacy Policy. These practices may be changed from time to time, but any changes will be posted to our Site and we will take the appropriate steps to inform you consistently of the significance of the changes, and in accordance with applicable law. As it deems necessary, STH reserves the right to amend or make revisions to this Privacy Policy at any time and for any reason in its sole discretion You can see the date the policy was last updated by looking at the “Last updated” date shown at the end of this Privacy Policy document. You are encouraged to review the Privacy Policy whenever you visit the Site to make sure that you understand how any personal information you provide will be used. Your continued use of our services (including without limitation using our Site or submitting any personal information) after any changes to the Privacy Policy constitutes your consent to said changes.

Note: The privacy practices set forth in this Privacy Policy are for this Site only. If you link to or utilize other websites, you must review the privacy policies posted at those sites.

WHO WE ARE

1.1 Volume Services, Inc. d/b/a Sodexo Live!, a Delaware corporation with its principal place of business at One Independence Pointe, Suite 305, Greenville, South Carolina 06902. Volume Services, Inc. is a Sodexo Live! operating company which forms part of Sodexo.

1.2 The data controller is the organization which you interact with in relation to the personal information that you submit or that we collect from you via the Site.

1.3 We’ve set out details about when we share personal information between our group companies in the section titled “Disclosure of your Information”. To find out more about us visit our website https://uk.sodexo.com/home.html and search under the other locations tab.

1.4 STH is the organization responsible for the collection and processing of personal information collected through or in relation to this Site. However, Your information may also be shared with a) Sports Travel and Hospitality Limited (“STHL”) a Sodexo Live! operating company who has been granted the authority to work with STH as a separate data controller to STH for purposes related to the administration, management, servicing and fulfilment of your tickets and packages and facilitating your attendance at the 2026 BNP Paribas Open in Indian Wells, California, as well as to obtain a better understanding of overall fan engagement, understanding performance of their websites, activities and activations related to the 2026 BNP Paribas Open. You can view the STHL Privacy Policy here.

1.5 Your information may also be shared with STHL in relation to marketing opt-in data only, in circumstances where you have agreed to receive marketing communications directly from STHL. In such circumstances, your information will be processed in accordance with STHL’s Privacy Policy.

INFORMATION THAT WE COLLECT FROM YOU

ALL PERSONAL INFORMATION THAT YOU PROVIDE TO US MUST BE TRUE, COMPLETE AND ACCURATE, AND YOU MUST NOTIFY US OF ANY CHANGES TO SUCH PERSONAL INFORMATION.

We will collect and process the following personal information about you:

2.1 Personal information you give us. This is personal information about you which you give us by filling in forms on the Site or by corresponding with us by phone, email or otherwise. For instance, if you submit your information on the Contact Us or Sign Up page of the Site, you will be asked to provide certain personal information about yourself including your name and contact details and we will collect and keep this information. Also, if you choose to subscribe to our newsletters and updates you may provide your contact information and information about your preferences.

2.2 We use cookies and similar technologies on our connected services that automatically receive and track certain data about how you and other visitors interact with our connected services, preferences expressed and chosen settings. PLEASE SEE OUR COOKIE POLICY TO LEARN MORE ABOUT OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES, THE TYPES OF DATA COLLECTED THROUGH THESE TECHNOLOGIES, AND YOUR CHOICES REGARDING THEIR USE ON OUR ONLINE SERVICES.

2.3 Personal information we receive from other sources. We may obtain your personal information from other sources. For instance, if you have submitted personal information to any of our group companies, we may obtain information about you from them and combine it with personal information that you submit via this Site. We may also work with third parties such as payment service providers, credit reference agencies, list brokers and advertising networks and we may receive your personal information from them and combine it with personal information that you provide to us. We also use a variety of publicly available third party sources (such as Linked In) and general information researched on the internet in order to carry out basic research to enable us to reach out to businesses who we think will be interested in our Site and services. We will only collect corporate contact details (such as business email addresses) when carrying out such research.

2.4 Combining information we collect from other sources with your personal information. Where permitted by law, we may combine the personal information you provide to us through our connected services with information we collect through other connected services, information collected offline, and information provided to us by third parties. Where permitted by law and feasible, we may also combine your personal information with data collected automatically through your use of our connected services, in which case we will treat any information that is combined or associated with your personal information as personal information for as long as it can reasonably be linked with your personal information. We use this consolidated information to improve our connected services and product and service offerings, enhance our marketing and research activities, communicate information to you, and for any other legitimate purpose described in this Privacy Policy.

2.5 Guests’ personal information. Where you submit personal information to us about another person, such as personal information about your guests for a product that you have purchased, you must only do so where you have their consent. We will use that information in accordance with this Privacy Policy.

2.6 “Special categories” of particularly sensitive personal information require higher levels of protection. Special categories of data include, but are not limited to, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We need to have further justification for collecting, storing and using this type of personal information. We have in place appropriate safeguards which we are required by law to maintain when processing such data.

We will process the following special categories of personal information, on the basis of your explicit written consent:

dietary requirement/food allergies; and
special access/assistance you may require.
USE OF PERSONAL INFORMATION

3.1 Personal information you give to us. We will use this information:

to provide you with the information, products and services you have requested from us;
to carry out our obligations arising from any contracts entered into between you and us;
to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
if you are a business contact, to provide you with information about our goods and services which we think will be of interest and relevance to you;
to manage our relationship with you or your business;
to receive and issue payments;
to enforce our terms, conditions and policies;
to respond to legal requests and comply with applicable laws;
to notify you about changes to our services;
to develop and carry out marketing activities (see marketing section below for more information);
to study how our customers use products and services from us and other organizations;
to develop and manage our brands, products and services;
to manage how we work with other companies that provide services to us and our customers;
to detect, investigate, report, and seek to prevent fraud and other crimes;
to obey laws and regulations that apply to us;
to request feedback, respond to complaints and seek to resolve them;
to exercise our rights set out in agreements or contracts; and
to run our business in an efficient and proper way.

3.2 Personal information we collect about you. We may use the personal information that we collect about you for some or all of the following purposes:

to administer the Site and the operation of our business;
to facilitate account creation and logon process and administer user accounts;
to supplement account profiles and sharing;
to protect our connected services and maintain safety and security;
to administer events when you elect to participate in events;
to make improvements to the Site so we can present it in the best possible manner for you;
as part of our efforts to maintain the safety and security of the Site;
to make suggestions and recommendations to users of our Site about products or services that may interest them;
for the purposes identified in our Cookie Policy.

3.3 Personal information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

3.4 Marketing. When you sign up to receive STH news and information or use the Site, we will use your personal information to create a profile based on the information we hold about you. This is necessary for the purposes of our legitimate interests in ensuring we have accurate information about you. We create a profile for you based on your preferences in order to provide you with the best experience and to send you personalized marketing communications and newsletters. This is necessary for the purposes of our legitimate interests in ensuring that we provide you a personalized experience and provide you with the most relevant products.

If you have given us your consent to send you marketing communications (including by email, text, SMS, social media, on-screen message/push notification) or if we are permitted by law to send such communications without obtaining your consent, we use the information that you have provided to us or which we have collected about you (for instance from publicly available third party sources such as Linked In and general information researched on the internet) for sending you personalized marketing messages about our products or services, events, and promotions for the 2026 BNP Paribas Open as well as other STH products, services events or promotions.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION

4.1 We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:

Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.
Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a leading sports travel and hospitality provider offering premium spectator experiences at global sporting events, provided in each case that this is done in a legitimate way which does not unduly affect your privacy and other rights. For example, we will rely on this legal basis when we market to corporate contacts and when we conduct certain market analysis to understand our customers in sufficient detail so we can create new services and improve the profile of our business.
Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a product or service from us and we need to use your contact details and payment information in order to process your order.
Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
DISCLOSURE OF YOUR PERSONAL INFORMATION

We may disclose your personal information to third parties, as set out below, and in accordance with your local data protection laws.

The security and confidentiality of your personal information is of great importance to us. This is why we restrict access to your personal information only to members of our staff and only to the extent strictly necessary to process your orders or to provide the requested services. We ensure that persons authorized to process your personal information have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

We will not disclose your personal information to any unauthorized third parties. We may, however, share your personal information with entities within the Sodexo Group and with authorized service providers whom we may call upon for the purpose of providing our services. We may also disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 2006. This information is not routinely shared. It may be shared for the provision of joint services, for example IT support and shared systems, Legal advice, debt recovery or HR support. It may also be shared for statistical analysis.

Your personal information will be used by us and those third parties for the purposes set out above in the “Use of Personal Information” section.

Your personal information may be disclosed to the following types of third parties:

5.1 We may share your information with sports rights holders. Because this Site offers travel and hospitality products delivered by us and third party partners to various sporting events, we may be required to share your personal information with the third party provider, event organizer or venue operator of the event you have purchased in relation to.

5.2 Your personal data may also be shared with selected IT providers, such as third party cloud platform providers, in order to administer the purposes set out above.

5.3 We may also, in the usual course of our business and for the purposes of the processing, share your personal information with personnel of:

our related entities and brands;
travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;
a prospective purchaser, in connection with a merger, acquisition, reorganization or sale of Volume Services, Inc. or any of our subsidiaries, business lines, related bodies corporate and franchisees, or of assets of Volume Services, Inc. or any such subsidiaries, business lines, or related bodies corporate and franchisees;
a person making your travel or hospitality booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a family member, friend or work colleague);
your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes;
a person who can verify to us that they have a relationship with you (e.g. a family member) where you are not contactable, the person correctly answers our required security questions and the request is, in our opinion, in your interest (for example, where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);
as required or authorized by applicable law, and to comply with our legal obligations;
customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
government agencies and public authorities, to comply with a valid and authorized request, including a court order or other valid legal process;
various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
other third parties selected by us including:
1. suppliers and sub-contractors whom disclosure is necessary for the performance of any contract we enter into with them or you (this may include payment service providers, service contractors, and marketing fulfilment partners) or any other data processor who undertakes any data processing on our behalf;
2. analytics and search engine providers that assist us in the improvement and optimization of our site; and

credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

5.4 We may also disclose your personal information within marketing and/or advertising materials. You agree that we may send marketing or advertising materials to you via email or mail, including but not limited to, newsletters, blog updates, travel developments, etc. If you do not wish to receive marketing materials from us or any company we are affiliated with, please Contact Us and submit a request to remove your personal information from our marketing list. Any personal information shared with our affiliates (including, without limitation, our host agency, if applicable) will be protected by and subject to this Privacy Policy as well as the privacy policies of our affiliates. We also may share your information with other third-party suppliers who provide services for your booking(s) and their privacy policies apply to the information they receive from us.

5.5 We may also disclose your personal information:

to third parties in order to enforce or apply the Sites terms of use or our terms and conditions of supply;
to advertisers, advertising networks and other third parties chosen by us; or
to third parties in order to protect the rights, property, or safety of STH, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5.6 Other than as expressly set out in this Privacy Policy or as otherwise required or permitted by law, we will not share, sell or distribute any of the personal information you provide to us without your consent.

INTERNATIONAL TRANSFERS

We may disclose your personal information to certain overseas recipients, as set out below, which we will do in accordance with your local data protection laws.

It is possible that information will be transferred to an overseas recipient (other than any of our overseas related entities) located in a jurisdiction where you will not be able to seek redress under your local data protection laws and that does not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by your local data protection laws, we will not be liable for how these overseas recipients handle, store and process your personal information. By providing your personal information to us for the purpose of booking and otherwise arranging travel/hospitality related products and services for you, you consent to our disclosure of your personal information to these overseas recipients for that purpose.

Where such a transfer occurs, we will take steps which are reasonably necessary to ensure that appropriate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this Privacy Policy.

6.1 Our overseas related entities

STH is part of Sodexo Live! an international group of companies. Your personal information may be disclosed to our overseas related entities in connection with facilitation of your travel/hospitality booking and/or to enable the performance of administrative, advisory and technical services, including the storage and processing of such information. We have also implemented appropriate safeguards to ensure an adequate level of protection of your Personal data, even if the Personal data is processed by another Sodexo entity that did not collect your Personal data originally.

Sodexo has implemented the Sodexo’s Binding Corporate Rules (BCRs) within Sodexo Group. Therefore, even if the third countries in which Sodexo entities operate are located outside of the European Economic Area, your Personal data is protected in the same way that they would have been by any entity located within the European Economic Area.

6.2 Travel service providers located overseas

In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas travel service providers. We deal with many different travel service providers all over the world, so the location of a travel service provider relevant to your personal information will depend on the travel services being provided. The relevant travel service providers will in most cases receive your personal information in the country in which they will provide the services to you or in which their business or management is based.

6.3 Our third party service providers located overseas

We may also disclose your personal information to third parties located overseas for the purpose of performing services for us, including the storage and processing of such information. Generally, we will only disclose your personal information to these overseas recipients in connection with facilitation of your travel/hospitality booking and/or to enable the performance of administrative and technical services by them on our behalf.

We deal with many different service providers all over the world, so it is not possible for us to set out in this policy all of the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please email DataProtection.UKandIE@sodexo.com.

STORING PERSONAL INFORMATION

7.1 We collect personal information from wherever users are situated, but our Site servers are situated in France. The personal information that we collect will therefore be transferred to France from any other country in which you may be located and will be subject to the European Privacy Regulations (as defined below) rather than the laws of the country in which you are resident.

7.2 We implement appropriate technological and operational security measures to protect your information which is in our control against any unauthorized access or unlawful use. Unfortunately, information transmitted via the internet cannot be completely secure and so we cannot guarantee the security of your data transmitted to our site. Any transmission of data to us via the internet is at your own risk.

7.3 Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Please check these policies before you submit any personal information to these websites.

7.4 We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us. If we have not been in contact with you for 6 years, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements), then your account may be classed as dormant or your personal information may be deleted in line with our data retention policy. We will email to remind you before deletion so please check your inbox regularly to see if we have sent you any emails about this.

STORAGE LIMITATION AND ACCURACY

8.1 We will keep Personal Data that is processed accurate and, where necessary, up to date.

8.2 We will store your Personal data only for as long as necessary to fulfil the purposes for which it was collected and processed. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply.

8.3 To determine the retention period of your Personal data, we take into consideration several criteria such as:

The purpose for which we hold your Personal data (e.g., when you purchase products on our Sites, we keep your Personal data for the duration of our contractual relationship).
Our legal and regulatory obligations in relation to that Personal data (e.g. accounting reporting obligations).
Whether you are an active user of our services, you continue to receive marketing communications, or you regularly browse or purchase off our Sites or whether you do not open our emails or visit our Sites; For instance, if you have agreed to receive marketing communications, we keep your Personal data until you: (i) unsubscribe from receiving marketing communications (ii) request we delete your Personal data, or (iii) after a period of inactivity (i.e. where you have not interacted with us for a period of time). This period is defined in accordance with local regulations and guidance.
Any specific requests from you in relation to the deletion of your Personal data or account.
Any statutory limitation periods allowing us to manage our own rights, for example the defense of any legal claims in case of litigation; and
Any local regulations or guidance (e.g., regarding cookies).

Controls For Do-Not-Track Features

Our connected services do not respond to “do not track” requests or signals at this time. Certain web browsers may allow you to enable a “do not track” option that sends signals to the websites you visit indicating that you do not want your online activities tracked. Right now, there is no industry standard for how companies should respond to “do not track” signals, although one may be adopted in the future. If we do so in the future, we will modify this Privacy Policy accordingly. In addition, more information about “do not track” is contained in our Cookie Policy.

YOUR PRIVACY RIGHTS
EUROPEAN PRIVACY RIGHTS

We are committed to ensuring protection of your rights under applicable laws. If you reside in Europe or your personal information is otherwise covered by the European Union’s General Data Protection Regulation (GDPR) or U.K. Data Protection Act (collectively, “European Privacy Regulations”), the following additional information and rights apply to you with respect to STH’s collection, use, and disclosure of personal information. For purposes of this section, “personal information” means any information that identifies an individual or for which there is a reasonable basis to believe the information can be used to identify an individual. “Personal information” does not include publicly available information or information that is deidentified or in the aggregate.

Controller | European Representative

The processing of personal information collected by STH is governed by this Privacy Policy, and STH is the “controller” of such information. To contact us concerning our processing of your personal information, please email DataProtection.UKandIE@sodexo.com.

Your European Privacy Rights

In addition to the rights previously described herein, you have various additional rights with respect to the collection, use, transfer, and processing of your personal information, as described below. We reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified by STH or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please submit your request to STH. You have the right to obtain confirmation as to whether or not your personal information is being processed by STH. Where we are processing your personal information, you have the right to access the data and to obtain certain information about the processing of such data. You will find below a summary of these different rights:

Right of access

You can request access to your personal information. You may also request rectification of inaccurate personal information, or to have incomplete personal information completed.

You can request any available information as to the source of the personal information, and you may also request a copy of your personal information being processed by us.

Right to be forgotten

Your right to be forgotten entitles you to request the erasure of your personal information in cases where:

the data is no longer necessary in relation for the purposes of its collection or processing;
you choose to withdraw your consent;
you object to the processing by automated means using technical specifications;
your personal information has been unlawfully processed;
there is a legal obligation to erase your personal information; or
erasure is required to ensure compliance with applicable laws.

Right to restriction of processing

You may request the restriction of processing in the cases where:

you contest the accuracy of the personal information;
we no longer need the personal information, for the purposes of the processing; or
you have objected to processing for legitimate reasons.

Right to data portability

You can request, where applicable, the portability of your personal information that you have provided to us, in a structured, commonly used, and machine-readable format you have the right to transmit this data to another controller without hindrance from us where:

the processing of your personal information is based on consent or on a contract; and
the processing is carried out by automated means.

You can also request to transmit directly your personal information to a third party of your choice (where technically feasible).

Right to object to processing for the purposes of direct marketing

You may object (including the right to “opt-out”) to the processing of your personal information (notably to profiling or to marketing communications). When we process your personal information on the basis of your consent, you can withdraw your consent at any time.

Right not to be subject to automated decisions

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Right to lodge a complaint to the competent Supervisory Authority

If you have a privacy-related complaint against us, you may make your complaint by email to DataProtection.UKandIE@sodexo.com. If you are unsatisfied with our response, you may then seek further recourse by contacting the competent supervisory authority or the competent court. You can notably contact the relevant supervisory authority, the Information Commissioner’s Office (the “ICO”, www.ico.org.uk) for the United Kingdom or the the National Commission on Informatics and Liberty, commonly known as CNIL (Commission Nationale de l’Informatique et des Libertés) in France.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please conduct us using the contact details below.

We may need to request specific information from you to help us confirm your identity and to enable you to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

UNITED STATES PRIVACY RIGHTS

Important Information Regarding Minors

Our connected services are intended for general audiences. We are in compliance with the requirements of the Federal Trade Commission’s Children’s Online Privacy Protection Act (COPPA), and as such we do not knowingly collect any personal information from children under the age of 13 through our connected services, except after obtaining verifiable parental consent or as otherwise permitted under applicable law.

IF YOU ARE NOT OLD ENOUGH TO FORM LEGALLY BINDING OBLIGATIONS IN YOUR APPLICABLE JURISDICTION, PLEASE TALK TO YOUR PARENTS OR GUARDIANS BEFORE USING OUR ONLINE SERVICES OR PROVIDING YOUR NAME OR OTHER PERSONAL INFORMATION TO STH. YOU CANNOT SUBMIT INFORMATION TO OUR ONLINE SERVICES WITHOUT YOUR PARENT’S OR GUARDIAN’S PERMISSION. If the parent or guardian of a child believes that their child has provided us with personal information without permission, the parent or guardian should contact us using the details provided under How To Contact Us below to request access to the information and deletion of such information where required. For more information regarding protecting children’s privacy online visit https://www.ftc.gov/business-guidance/privacy-security/childrens-privacy.

Change in Preference and Opting Out of Email Marketing

We are in compliance with the GDPR along with the email marketing service we use to collect your data. In addition, we comply with the U.S. Federal CAN-SPAM Act of 2003 and do not spam or send misleading information. Should you wish to no longer receive communication from us, you have the option of unsubscribing by clicking “unsubscribe” in the bottom of the email we send to you or by contacting us using the details provided under How To Contact Us below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. As for third party websites, please contact them directly to unsubscribe and/or opt out from their communications.

State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information.

CALIFORNIA RESIDENTS

If you are a California resident, the following additional information and rights apply to you subject to the California Consumer Privacy Act (CCPA) with respect to STH’s collection, use, and disclosure of personal information about you. For purposes of this section, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household. “Personal information” does not include publicly available information or information that is deidentified or in the aggregate.

Collection, Use, and Disclosure of Personal Information

Categories of Personal Information Collected

STH has collected the following categories of personal information about California consumers in the preceding 12 months:

Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account name, Social Security Number, driver’s license number or state identification card number, passport number, or other similar identifiers.
Other identifiers or consumer information, such as physical characteristics or description, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications under California or federal law, such as race, color, sex, age (40 and older), religion, national origin, disability, citizenship status, genetic information, marital status, sexual orientation and identity, political affiliations or activities, military or veteran status, medical condition, or status as a victim of domestic violence, assault, or stalking.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Geolocation data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

STH uses these categories of personal information for the purposes described under How We Use Your Information above.

Categories of Personal Information Disclosed for Business Purposes

STH has disclosed for a business purpose the following categories of personal information about California consumers in the preceding 12 months:

Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, account name, Social Security Number, driver’s license number or state identification card number, passport number, or other similar identifiers.
Other identifiers or consumer information, such as physical characteristics or description, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications under California or federal law, such as race, color, sex, age (40 and older), religion, national origin, disability, citizenship status, genetic information, marital status, sexual orientation and identity, political affiliations or activities, military or veteran status, medical condition, or status as a victim of domestic violence, assault, or stalking.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Geolocation data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

“Business purposes” include the use of personal information as reasonably necessary and proportionate for operational purposes, such as performing services on our behalf (e.g., maintaining or servicing accounts, providing customer service, processing orders, verifying member information, processing payments, or providing marketing or analytic services), auditing related to a current interaction with you and concurrent transactions, detecting and protecting against security incidents, debugging to identify and repair errors, conducting research, and undertaking activities to verify or maintain the quality or safety of our products and services.

Categories of Personal Information Sold

STH has not sold personal information about California consumers in the preceding 12 months.

Your Privacy Rights Under California Law

In addition to the Personal Information rights described above, California residents also have the rights described below.

Right to Notice and Access

You have the right to request that STH disclose additional information regarding our collection and use of your personal information, including the following:

The categories of personal information we have collected about you.
The categories of sources from which personal information is collected.
The purpose for collecting or selling personal information.
The categories of third parties with whom we share personal information.

In addition, you have the right to request access to the specific pieces of personal information we have collected about you. To request this additional information or to access your personal information, please submit a request to STH using one of the methods described under How to Exercise Your California Privacy Rights below.

Right to Deletion of Personal Information

You have the right to request that STH delete any personal information about you which we have collected from you. To request deletion of your personal information, please submit your request to STH using one of the methods described under How to Exercise Your California Privacy Rights below. Please be aware that such a request does not ensure complete or comprehensive deletion of your personal information and that there may be circumstances in which the law does not require or allow deletion even if requested.

Right to Transparency Regarding Disclosure or Sale of Personal Information

You have the right to request that STH disclose additional information regarding the disclosure or sale of your personal information, including the following:

The categories of personal information that STH disclosed about you for a business purpose.
The categories of personal information that STH sold about you and the categories of third parties to whom the personal information was sold (by category or categories of personal information for each third party to whom the personal information was sold).

In addition, you have the right to request information regarding the disclosure of your personal information by STH to third parties for the third parties’ direct marketing purposes.

To request additional information regarding the disclosure and sale of your personal information (as applicable), or to opt-out of the disclosure of your personal information to third parties for their direct marketing purposes, please submit your request to STH by using one of the methods described under How to Exercise Your California Privacy Rights below.

Right to Opt-Out of the Sale or Sharing of Personal Information

STH generally does not sell your personal information, and only shares your personal information with necessary suppliers and vendors in connection with the travel products and services being provided to you. If STH sells your personal information to third parties, you can opt-out of the sale of your personal information at any time by submitting a request to STH using one of the methods described under Do Not Sell or Share My Personal Information below.

Do Not Sell or Share My Personal Information

You have the right to opt-out of the sale or sharing of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling or sharing your personal information. To exercise your right to opt-out, please contact us via phone or email provided above.

Rights of Children

Notwithstanding anything else contained in this Privacy Policy, STH will not sell the personal information of individuals if STH has actual knowledge that the individual is less than 16 years of age, unless the individual, in the case of individuals between 13 and 16 years of age, or the individual’s parent or guardian, in the case of individuals who are less than 13 years of age, has affirmatively authorized the sale of the individua’s personal information (the “right to opt-in”).

Right to Removal of Content Posted Publicly by Minors

If you are a California resident under the age of 18, and a registered user of any connected services where this Privacy Policy is posted, you may request and obtain removal of content or information you have publicly posted. To make such a request, please use one of the methods described under How to Exercise Your California Privacy Rights below and include a detailed description of the specific content or information to be removed. 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.

Right Not to Be Subject to Discrimination

STH will not and cannot discriminate against you for exercising any of your rights described above, such as by denying you goods or services or by providing you with a different level of goods or services. However, we can charge a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to you by your personal information. In addition, we may offer financial incentives, including payments to you as compensation, for the collection, sale, or non-deletion of your personal information. If we offer you any such financial incentives, we will first notify you of the applicable incentives and will only include you into a financial incentive program with your prior opt-in consent (which may be revoked by you at any time).

How to Exercise Your California Privacy Rights

California Civil Code Section 1798.83 permits users who are California residents to request and obtain from us information about certain personal information we disclose to third parties for their direct marketing purposes in the preceding calendar year. To exercise any of your California privacy rights described above—including to request additional information regarding our collection and use of your personal information, to request access to your personal information, to request that we delete your personal information, to request additional information regarding the disclosure and sale of your personal information, or to opt-out of the disclosure of your personal information to third parties for their direct marketing purposes—please submit your request to STH using one of the methods provided under Contact Us above.

COLORADO, CONNECTICUT, VIRGINIA and UTAH RESIDENTS

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to: (i) confirm whether we process their personal information; (ii) access and delete certain personal information; (iii) data portability; and (iv) opt-out of personal data processing for targeted advertising and sales. In addition, Colorado, Connecticut, and Virginia also provide their state residents with rights to: (i) correct inaccuracies in their personal information, taking into account the information’s nature processing purpose; and (ii) opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. For more information regarding Colorado, Connecticut, Virginia and Utah privacy rights, please submit your request to STH using the method provided under Contact Us below.

JURISDICTION SPECIFIC RIGHTS

In some regions and jurisdictions (such as California and other U.S. states), you may have certain additional rights under applicable data protection laws. To the extent that relevant jurisdictions grant additional privacy rights to individuals, these rights are described separately under the applicable Supplemental Information and Rights sections included with and incorporated in, this Privacy Policy below.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to make changes to the Privacy Policy from time to time. Any material changes to our Privacy Policy will be posted to the Site and, where appropriate, through e-mail notification.

CONTACT US

If you have any requests concerning personal information or any other queries about this Privacy Policy please contact us by sending an email to DataProtection.UKandIE@sodexo.com.

Indian Wells Privacy Policy

PRIVACY POLICY

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