Privacy Policy

Updated On 02/09/2023

PRIVACY NOTICE

Last Updated: 1st December 2022

Our Commitment to Data Privacy

Your privacy is important to George Super TopCo LLC, its affiliates and partners (“Freehand,” “us,” “we,” “our”). To better protect your privacy, we are providing information explaining our information practices. This Privacy Notice describes how we gather and use information for visitors of this website and guests at our hotels.

If you have any questions regarding our use of your Personal Information, or this Privacy Notice, please contact legal@thefreehand.com. You do not need to take any action as a result of this Privacy Notice, but if you reside in California, you may have certain rights as described below in the section headed “Special Information for California Consumers”.

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Information about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. 

This website is not intended for children and we do not knowingly collect, solicit or sell data relating to children.

This Privacy Notice covers:

     1. The Personal Information we collect about you

     2. How we obtain your Personal Information and Other Data

     3. How we use your Personal Information and Other Data

     4. Disclosure of Personal Information and Other Data

     5. How we keep your Personal Information secure

     6. How long we retain your Personal Information

     7. Your rights

     8. Special Information for California Consumers

     9. How to contact us

Third Party Sites and Links

Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their processing of your Personal Information. When you leave our website, we encourage you to read the privacy notice of every website you visit.

1. THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

“Personal Information” are data that identify you as an individual or relate to an identifiable individual. Freehand collects the following categories of Personal Information from you:

• Personal identifiers
• Categories of personal information related to California Customer Records statute (Cal. Civ. Code § 1798.80);
• Commercial information;
• Audio, electronic and visual information;
• Internet or other electronic network activity information;
• Geolocation Data; and
• Protected classification information.

Freehand also collects the following specific types of Personal Information, when providing you with our products and services:

• Name
• Gender
• Postal address
• Telephone number
• Email address
• Credit and debit card number or other payment data
• Financial Information in limited circumstances such as residential services
• Language preference
• Date and place of birth
• Nationality, passport, visa or other government-issued identification data
• Important dates, such as birthdays, anniversaries and special occasions
• Travel itinerary, tour group or activity data
• Prior guest stays, interactions, goods and services purchased, special service and amenity requests
• Dietary requirements, disability and medical data
• Geolocation information
• Social media account ID, profile photo and other data publicly available

We will also collect the following types of Personal Information for the following purposes: 

• Images and video and audio data via security cameras located in public areas, such as hallways and lobbies, in our properties
• Guest preferences and personalised data such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us, or which we learn about during your visit

2. HOW WE OBTAIN YOUR PERSONAL INFORMATION

Personal Information is collected in a variety of ways:

• Online Services. Personal Information is collected through online services either directly or through an affiliate booking website
• Reservation Process
• Check out process for electronic folio receipts
• Purchase goods or services through the website or ecommerce website
• Communication via email
• Connect or post to social media related to the properties
• Participate in a survey, contest or promotional offer
• Property Visits. Personal Information is collected when guests visit our properties or use on-property services and outlets.
• Restaurants
• Concierge services
• Health clubs
• Spas
• Offline Interactions. Personal Information is collected when individuals attend promotional events that we host or in which we participate, or when you provide your Personal Information to facilitate an event
• Reservations and Customer Service Centers. Personal Information is collected when you make a reservation over the phone, communicate with us by email or contact customer services. These communications may be recorded for the purposes of quality assurance and training
• Other Sources. Personal Information is also collected from other sources, such as public databases, joint marketing partners, data analytics vendors and other third parties
• Internet-Connected Devices. Personal Details may also be collected from internet-connected devices available in our properties. For example, a smart assistant device may be available for your use and to tailor your accommodations and experience

“Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveals your specific identity or relates to an individual, we will treat Other Data as Personal Information. Other Data includes:

• Browser and device data
• App usage data
• Data collected through cookies, pixel tags and other technologies
• Demographic data and other data provided by you
• Aggregated data

We Collect Other Data in a Variety of Ways

We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that our Online Services function properly.

Cookies

We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize. See the Cookie List on your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions.

What is a Cookie?

A cookie is a text file that contains small amounts of data downloaded to your device when you visit a web site. A cookie is sent back to the web site on each subsequent visit or to another web site that recognizes that cookie. Cookies enable a website to recognize your computer, mobile, or other device. As with most other websites, we place cookies on your device to understand more about your visit and help us enhance your experience. You can find more information about cookies at: www.allaboutcookies.org.

Cookies on this Site

We will use Cookies to:

• Remember your username and password for future visits so that log-in is easier and faster;
• Remember your language and other preferences;
• Ensure you obtain all requested information;
• Provide a safe and secure service for online transactions;
• Measure how many people use the Site, and how they use it, so that we may keep it running quickly and efficiently; and
• Help us and others deliver communications and content to you that are relevant and responsive to your interests and location.

There are four different categories of cookies used on our Sites: 

• cookies that are strictly necessary;
• cookies that record functionality requests; 
• cookies that assist with the performance of our Sites; and 
• advertising cookies. 

Each purpose is outlined below.

Strictly Necessary Cookies

These cookies are required to allow you to navigate a Site and utilize its various features, such as accessing secure areas of the Site. Services that you have requested, such as making a hotel reservation online, could not be provided without these cookies. These cookies do not collect information that could be used for advertising purposes.

Functional Cookies

These cookies allow a Site to collect information about your choices, such as your region or preferred language. This allows the Site to personalize content for you. These cookies can also be used to store login information and to remember the changes you have made to the font, text size, and other customizable features on the Site. Although the information collected by these cookies does not personally identify you, these cookies may be able to identify you when combined with other data, because they track certain ISP information for your settings. They do not gather information about you that could be used for advertising or tracking where you have been on the Internet.

Performance Cookies

These cookies gather information about how you use this Site to ensure efficient operation of

the Site’s functions. For example, they may collect information regarding whether you encountered problems or errors from one of the pages or which pages you visit most often. These cookies do not directly collect information that personally identifies you. When you provide information that identifies you, we may use these cookies to provide relevant information on the Site, based on your activities and information you have provided on the Site.

Targeting Cookies

These cookies collect information regarding your browsing habits. They are usually placed by third party advertising networks, such as those owned by Google, Facebook or other third parties. They remember when you visit this Site and share this information with other organizations, including advertisers. They do this to tailor online advertisements to you or your interests. Although these cookies can track your visits to sites on the Internet, the cookies themselves do not usually personally identify you.

How to Manage Cookies

You can restrict or block cookies that are set by the Site (or any other site on the Internet) by adjusting your browser settings, or you can click here. You may visit www.allaboutcookies.org to obtain more information regarding cookies and how to adjust the cookie settings on various browsers. This site explains how to delete cookies from your computer.

Please be aware that restricting cookies may restrict the functionality of the Site.

Pixel Tags and Other Similar Technologies

We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.

Your IP Address

We collect your IP address; a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.

Aggregated Data

We may aggregate data that we have collected, and this aggregated data will not

personally identify you or any other user.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use Personal Information and Other Data to provide you with Services, to develop new offerings andto protect Freehand and our guests as detailed below. In some instances, we will request that youprovide Personal Information or Other Data to us directly. If you do not provide the data that werequest, or prohibit us from collecting such data, we may not be able to provide the requested Services.We will let you know if this is ever the case. 

We use Personal Information and Other Data for thefollowing business purposes, under the following lawful bases:

	Purpose	Activity	Lawful Basis
1.	To facilitate reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with meetings and events and to provide you with other information about the area and the property at which you are scheduled to visit.	When you register to use our services or facilities, we collect your personal contact details, payment information, passport details and any other information required to facilitate the purposes stated.	Performance of Contract
2.	To support our electronic receipt program.	When you provide an email address when making a reservation, we use that email address to send you a copy of your bill. If you make a reservation for another person using your email address, that person's bill will be emailed to you, as well.	Legitimate Interest
3.	To personalize the Services according to your Personal Preferences.	We use Personal Information and Other Data to personalize the Services and improve your experiences, including when you contact our reservations center, visit one of our properties or use the Online Services. We do this to customize your experience according to your Personal Preferences and present offers tailored to your Personal Preferences.	Legitimate Interest
4.	To communicate with you about goods and services according to your Personal Preferences.	We use Personal Information and Other Data to send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys.	Consent
5.	To offer sweepstakes, activities, events and promotions.	We use Personal Information and Other Data to allow you to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities have additional rules and may contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully.	Consent
6.	For business administration, to uphold the law and to maintain the safety and security of our guests, employees and property.	We use Personal Information and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed-circuit television, card keys and other security systems).	Legitimate Interest Legal Obligation
7.	To continually develop the products and services we provide.	We use Personal Information and Other Data for developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.	Legitimate Interest

4. DISCLOSURE OF PERSONAL INFORMATION AND OTHER DATA

Our goal is to provide you with the highest level of hospitality and services, and to do so, we share the following categories of Personal Information:

• Personal Identifiers;
• Categories of personal information related to California Customer Records statute (Cal. Civ.Code § 1798.80);
• Commercial information;
• Audio, electronic and visual information;
• Geolocation Data; and
• Special categories of personal information.

The business purposes for which we disclose these categories of personal information and the third parties with whom we share it are described in detail below:

	Purpose	Third-Party Recipients
1.	We disclose Personal Information and Other Data to Owners of Freehand-branded properties and other companies in the Freehand and Generator brand of companies for the purposes described in this Privacy Statement, such as providing and offering products and services to Freehand.	Owners and Franchisees
2	We disclose Personal Information and Other Data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables restaurant, health club, concierge and other outlets at our properties to provide you with services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars and vacation packages.	Strategic Business Partners
3.	We disclose Personal Information and Other Data to third-party affiliates, vendors and service providers for the purposes described in this Privacy Statement and to support Freehand’s operations. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfilment, billing, information technology and related infrastructure provision, customer services, email delivery, marketing, auditing and other services.	Service Providers
4.	We may disclose or transfer your Personal Information and Other Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Freehand business, assets or stock (including any bankruptcy or similar proceedings).	Corporate Restructure Entities
5.	We may disclose your Personal Information to the employers of guests who used a corporate credit card for purchases.	Employers of Guests
6.	We may disclose your Personal Information to any event organizers participating in planning events with / on behalf of Freehand.	Event Organizers
7.	We may disclose your Personal Information to legal and regulatory authorities, our professional advisors (such as lawyers, accountants, auditors, etc.), or law enforcement agencies to support Freehand’s operations and comply with legal and contractual obligations.	Government Authorities and Professional Advisors

Other Uses and Disclosures

We will use and disclose Personal Information as we believe to be necessary or appropriate:

• to comply with applicable law and contractual obligations, including laws outside your country of residence; 
• to comply with legal process;
• to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements;
• to enforce our terms and conditions;
• to protect our operations;
• to protect the rights, privacy, safety or property of Freehand, you or others; and
• to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Information (such as combining your name with your location). If we do, we will treat the combined data as Personal Information for so long as it is combined.

We do not sell, and in the past 12 months have not sold, your personal information.

5. HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

We use appropriate organizational, technical and administrative measures to protect Personal

Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section on the website.

6. HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We will only retain your Personal Information for as long as is necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount,

nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, along with the applicable legal requirements.

In some circumstances we may anonymize your Personal Information (so that it can no longer be

associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. For further information on how long we retain your Personal Information, please contact legal@thefreehand.com.

7. YOUR RIGHTS

You are provided with certain rights in relation to the processing of your personal data, including to:

• Request access to personal data about you (a “data subject access request”). This enables you to receive a copy of the personal data we hold about you, and to check that we are processing it lawfully;
• Request rectification, correction, or updating to any of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
• Request personal data provided by you to be transferred in machine-readable format (“data portability”);
• Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below);
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g., if you want us to establish its accuracy or the reason for processing it); and
• Object to the processing of your personal data in certain circumstances. This right may apply where the processing of your personal data is based on our legitimate interests.

Some of these rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation, laws, and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us atlegal@thefreehand.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

In addition to the above, please note that you have the right to make a complaint at any time to the relevant data protection supervisory authority if you are concerned about the way in which we are handling your personal data.

Please allow up to thirty (30) days for a response, from the day of your request submission.

8. SPECIAL INFORMATION FOR CALIFORNIA CONSUMERS

California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us through one of the methods listed under the “How to contact us” section. 

California Consumer Privacy Act (CCPA) Consumer Rights

If you are a resident of California, the CCPA grants you the following specific rights regarding your personal information. To exercise the rights, you must submit a verified consumer request. We will deliver a response to you within 45 days of receiving the verifiable consumer request.

Right to Know

You have the right to submit a verifiable consumer request, that we disclose the following to you in a readily useable format covering the 12-month period preceding your request:

• The categories of personal information we have collected about you
• The categories of sources of the personal information we have collected about you
• The business or commercial purpose(s) for collecting personal information
• The categories of third parties with whom we share personal information
• The specific pieces of personal information we have collected about you
• The categories of personal information we have disclosed for a business purpose
• Verifiable consumer requests to know may be submitted through one of the following methods:
• Send an email to legal@thefreehand.com entitled “CCPA Request”; or
• Submit a consumer request at the front desk of any Freehand Hotel location.

A consumer may submit a request to know and receive a response twice within a 12-month period.

Right to Request Deletion

You have the right to request that we delete any personal information that we have collectedfrom you. However, we are not required to comply with a request to delete, if it is necessary forus to retain the personal information to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq);
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with legal obligations; or 
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Verifiable consumer requests to delete may be submitted through one of the following methods:

• Send an email to legal@thefreehand.com entitled “CCPA Request”; or
• Submit a consumer request at the front desk of any Freehand Hotel location.

Right to Non-Discrimination

You have the right to be free from discrimination when you exercise your consumer rights under the CCPA, including by:

• Denying you goods or services;
• Charging you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Providing you a different level of quality of goods or services; or
• Suggesting that you may receive a different rate for goods or services or a different level or quality of goods or services.

We may, however, offer you financial incentives for the collection, sale or deletion of your personal information. We may also offer you a different price, rate, level or quality of goods or services if that difference is reasonably related to the value provided to us by your data.

9. HOW TO CONTACT US

If you have any questions regarding our use of your Personal Information, or this Privacy Notice, please contact legal@thefreehand.com.

Alternatively, you may wish to write to: 

George Super TopCo LLC

c/o Generator Chicago

19 East Ohio St., Chicago, IL 60611

Changes to this Privacy Notice and Your Personal Information

This Privacy Notice is regularly reviewed and was last updated on 1st December 2022. It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes during your relationship with us.