Privacy Policy

1. Introduction

We, Urgo Hotels Canada, are a hotel management company that independently operates over 18 hotels across Canada. Our portfolio includes both independent properties and hotels affiliated with chains. The chain-affiliated hotels bear the following banners: Hilton Worldwide, Marriott International. This Privacy Policy, in accordance with provincial and federal regulations (where applicable), generally applies to any personal information collected by Urgo Hotels Canada about all individuals who are not employees of Urgo Hotels Canada and who access our hotel premises (‘guests’) and our websites, to job applicants at Urgo Hotels Canada and to any other individuals with whom Urgo Hotels Canada conducts business, such as customer representatives and business partners.

We make reasonable efforts to explain why and how we collect, use and disclose personal information. We obtain their consent when necessary and process their personal information for purposes that a reasonable person would consider acceptable under the circumstances.

The Privacy Policy is a statement of principles, guidelines and practices governing the protection of personal information, how this information is used and/or disclosed and the choices you can make regarding how your information is collected by Urgo Hotels Canada through the channels described below:

  • Our corporate website (www.urgohotels.ca), including the Wi-Fi network login page of the establishment from which you can access this Privacy Policy;
  • The social media page under our authority/management on various platforms, including LinkedIn, from which you can access this Privacy Policy;
  • Communications with clients through other channels, such as fax, chat, or instant messaging services.

2. Information

Definition of Non-Identifiable Information: Personal information that is anonymized and/or aggregated and cannot be associated with an identifiable individual is not considered personal information. Urgo Hotels Canada reserves the right to conduct statistical analysis using the information and/or personal data collected, including data collected from individuals entering its establishments or through its websites, the Wi-Fi network, anonymously and/or aggregated, in order to understand user interests, improve its services and measure interest in and usage of its websites. Urgo Hotels Canada reserves the right to provide third parties with analysis based on this anonymized and/or aggregated data.

Definition of Personal Information: : As used in this Privacy Policy, personal information refers to any information about an identifiable individual.

We may also use personal information to verify the identity of individuals who contact us by telephone, electronically, or otherwise, for internal training and quality assurance purposes, to manage our operations and ensure the effectiveness, reliability and security of our systems and networks and to ensure the safety of our guests and hotels.

Furthermore, we may collect and use, to the extent permitted by law, personal information from our guests to understand their interests and needs in order to provide them with personalized products, recommendations and services.

Specifically, Urgo Hotels Canada collects and uses personal information as follows:

I. Information Collected From or About You.  In many cases, we collect personal information directly from you when you visit our establishments, make a reservation at one of our hotels, use our services, file a complaint, submit an application, contact us in person or through our websites and use them to connect to the Wi-Fi network. This is so you will know on which occasions we collect this information. We may also receive personal information about you from our franchisors when you make your reservation directly with them, from third parties when you make your reservation through them, from our customers, such as your employer or any other third party through which your stay in our hotels is managed or organized (for example, if you attend a conference held by a professional association), but at any time, with your prior consent and/or as allowed by law, orally or in writing, before or at the time of collection, unless the purpose of this collection is obvious and you voluntarily provide your information.

  • Visitors. We may collect information such as your name, contact details, email address, payment information, gender identity, date and place of birth, home address, telephone number, preferred language of communication, employers’ contact details, travel itinerary, previous stays, stay preferences and other similar information related to your reservation or more generally, your stay at the hotel, only where managed and maintained by hotel staff. In the case of amenities managed by third parties, we recommend reviewing the Privacy Policy of those third parties, if applicable. Generally, we collect this personal information to provide you with our products and services or the information you have requested, or to communicate with you to answer your questions. 
  • Customers, Suppliers and Other Business Partners. We may collect the name, address, phone numbers (office, mobile) and email addresses of our customers, suppliers, or business partners. We collect this personal information to assess and select suppliers and other business partners, process orders, handle payments, establish and maintain responsible business relationships, provide uninterrupted service and manage risks.
  • Employees of Urgo Hotels Canada. We may collect the name, address, phone numbers (home, mobile), email addresses, social insurance number and personal information obtained as part of a reference and background check (such as employment history, credit records and criminal records) of employees. The signature of reference requests will be obtained in advance. We collect this information to prevent identity theft and to ensure that we can communicate with our employees. 
  • Job Applications. We may collect the information you provided to Urgo Hotels Canada in your resume for recruitment purposes and other standard human resources purposes. For example, we may send you information about new job openings within Urgo Hotels Canada as well as other professional advancement resources. We may also collect personal information as part of reference and background checks (such as employment history, credit records and criminal records). The signature of reference requests will be obtained in advance.

II. Automatically Collected Information. In some cases, we may automatically collect information that may not necessarily identify you as an individual. For example, we may collect the following types of information:

  • Door Locking Systems. For security purposes, we may collect information through our door locking system. These details may be disclosed under certain circumstances.
  • Browser, Device, Behaviour and Technical Information. When you visit our websites and use our Wi-Fi network, we may collect technical information through electronic means such as cookies. These may include information about your visit or use, such as your device/computer’s IP address and the browser you used to access our websites or Wi-Fi network, your operating system, screen resolution, location, browser language settings, referral site, search keywords (if you accessed our sites from a search engine), number of pages viewed, as well as information you entered and ads you viewed. We may also collect information such as your gender identity, age group and interests, but this information is always aggregated and not associated with any identifiable individual. We use this information to measure and monitor traffic on our websites and to improve the efficiency of our websites or the guest experience. In addition, we may use the personal information collected from our guests to ascertain their interests and understand the evolving needs in order to enhance our products and services and develop new ones, as well as to assess possible enhancements or other modifications to the functionalities of our websites. You can limit the type of information we collect, use or disclose about you, when you visit and/or use our websites or when you connect to our Wi-Fi network.
    • Google Analytics: We use Google Analytics, a service that allows us to see information about users’ online activities, including, but not limited to, pages viewed, the source and time spent on our websites and/or mobile application. This information is anonymized and displayed as numbers, meaning they cannot be linked to individuals. You can prevent our use of Google Analytics by visiting the Google Analytics Opt-out Page.
    • Google Ads, Formerly Known as Google AdWords: We use Google Ads to reach new potential clients or existing clients. Remarketing through Google Ads is also used to advertise Urgo Hotels Canada on the internet and to advertise on third-party websites (including Google) to people who have already visited our websites. The Google Ads remarketing feature displays ads to you based on parts of our websites that you have visited by placing a cookie on your web browser. This may mean that we advertise to visitors who have not completed a task on our site, or advertise on the Google search results page, or on a site in the Google Display Network. This cookie does not in any way identify you or grant access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on our websites, so they can show you ads related to that page. If you do not wish to participate in our Google Ads remarketing activities, you can disable this feature by visiting the Google Ads Preferences Manager.
  • Geolocation Data. When you use our Wi-Fi network or internet-connected devices in our establishments, we or our third-party providers may collect location data, as well as any other personal information clearly indicated on the devices themselves.
  • Social Media. If you interact with us through a social media platform (LinkedIn), through which you authorize us to collect information about you (including personal information) such as details about your friends/connections. 

3. Communications

You may receive the following types of electronic communications from Urgo Hotels Canada:

  • Commercial Electronic Messages. You may receive commercial electronic messages if we have your consent to send them:

Please contact us for more information on how you can unsubscribe from receiving these commercial electronic messages.

4. Your Consent

In general, by interacting and/or doing business with us, or by providing us with information in the course of using services at Urgo Hotels Canada, visiting, interacting with and/or using our websites and/or using our Wi-Fi network, you consent to the collection, use and disclosure of personal information as outlined in this Privacy Policy.

Exceptions to the Requirement for Consent. In certain circumstances, your personal information may be collected, used, or disclosed without your consent. Here are examples of these exceptional circumstances:

  • When it is clearly in the individual’s interest and consent cannot be obtained in a timely manner, for example, in case of emergency, when the life, health, or safety of the individual is threatened, or when legal, medical, or security reasons make obtaining consent impossible or difficult.
  • When information is collected, used, or disclosed to detect or prevent a breach of an agreement, fraud, or any other illegal activity and obtaining consent could hinder the purpose of collecting the information.
  • To comply with a subpoena, warrant, or any other court order, requests received from law enforcement authorities, or as otherwise required or permitted by law or any competent regulatory body.

Please contact our privacy officer for more information on how Urgo Hotels Canada may disclose your personal information.

5. Right to Withdraw Consent

Consent can be withdrawn at any time, subject to legal or contractual restrictions and reasonable notice. However, without this consent, Urgo Hotels Canada may, in some cases, limit the services it can provide to you and/or may not be able to establish a business relationship, maintain that relationship and/or interact with you. You can also withdraw your consent in the following ways:

  • Marketing by Mail, Telemarketing and Quality Control Communications. You can decide that you prefer for us not to use your personal information to promote other or new products and/or services that may interest you and that we do not share your information with our franchisors and that you refuse us to contact you by mail or telephone for marketing purposes or by email or telephone for quality control. If this is the case, you can inform us by contacting our privacy officer directly.
  • Choices Offered Regarding Cookies: When you visit or use our websites, you can always block the use of cookies by adjusting your browser settings accordingly. The “Help” function in most browsers explains how to prevent your browser from accepting new cookies, how to be notified when a new cookie is placed, or how to disable cookies entirely. If you choose to withhold or subsequently block cookies, you may not be able to access the content of our websites, either in whole or in part. In addition, you can disable or delete similar data used by browser add-ons by changing the add-on’s settings or by visiting the developer’s website. Our websites use the following types of cookies for the purposes stated above:
TYPE OF COOKIES PURPOSE
Essential cookies These cookies are essential to providing you with the services offered on our websites and to enable you to use some of their features. Without these cookies, the services you have requested cannot be provided to you; we use these cookies only to provide you with these services.
Functionality Cookies
These cookies enable our websites to remember choices you make when you use our sites. These cookies are meant to provide you with a more personalized experience and save you from having to select your preferences every time you visit a website.
Cookies for Analysis and Performance
These cookies are used to collect information about traffic on our websites and how users use them. The information collected may include the number of visitors to our websites, the websites that referred them to ours, the pages they visited on our websites, the time they visited our websites, whether they have visited them before and other similar information. We use this information to operate our websites more efficiently, gather general demographic information and monitor activity levels on our websites.
Targeted and Advertising Cookies
These cookies track your browsing habits to enable us to present ads that are more likely to interest you. These cookies use information about your browsing history to group you with other users who have similar interests to yours. Based on this information and with our permission, third-party advertisers may place cookies to enable them to show you ads that we believe may match your interests when you visit third-party websites.
Social Media Cookies
These cookies are used when you share information using a share button on social media platforms or a Like button on our websites, when you link your account to them, or when you engage with our content on or through a social media site like Facebook, Twitter, Instagram, or others. The social network will record what you have done.

 

6. Communication of Personal Information

Your personal information will not be sold or transferred to unaffiliated third parties without your consent unless permitted by law or as follows:

  • Affiliated Companies and Franchisors. Urgo Hotels Canada may share with its franchisees information relating to stays or payments and observations about service preferences. Subject to Section 5, Right to Withdraw Consent in this Privacy Policy, Urgo Hotels Canada may also, at any time, disclose personal information to its affiliated partners and franchisors for purposes related to marketing the services offered by Urgo Hotels Canada, in accordance with applicable privacy laws.
  • Third-Party Service Providers. We may hire third-party service providers (which may be affiliated companies) or use their services to provide services on our behalf. We provide them with a limited amount of information necessary for them to provide the required services. They are prohibited from using this information for any other purpose than facilitating and performing the services for which they have been hired.
  • As Permitted or Required by Law. From time to time, Urgo Hotels Canada may disclose your personal information if such disclosure is necessary for the establishment, exercise, or defence of legal claims, as part of the administration of its loss-prevention program, or as permitted by law, for example if Urgo Hotels Canada is required to disclose personal information in response to a law, regulation, court order, subpoena, valid request, search warrant, government investigation, other valid legal requests or investigation, or if it is reasonably necessary to protect the rights, property and safety of others and Urgo Hotels Canada. Urgo Hotels Canada may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of our rights recognized by law.
  • Commercial Transaction. We may disclose personal information to a third party as part of a merger, acquisition, or business consolidation, the sale of a portion of our business, business units, or assets, or any other fundamental change to the business, in any form. However, in the event the transaction is completed, your personal information will continue to be protected by applicable privacy laws. If the transaction is not completed, we require the other party to neither use nor disclose your personal information in any way and to completely delete such information.
  • Candidates. If you fill out and submit a job application (including the online form on our websites), you consent to the information contained in that job application being disclosed to the Urgo Hotels Canada staff.

7. Security

We use reasonable security measures to protect your personal information against unauthorized access. We have implemented security measures that include administrative, technical and physical controls designed to protect your personal information. For example, we use industry-standard encryption technology to secure sensitive personal information when it is collected and transmitted over the internet, as well as firewalls, website monitoring software and intrusion detection systems. In the event of a security incident involving any of your personal information collected and stored by Urgo Hotels Canada as outlined in our Privacy Policy, we may contact you via email, letter, phone, or any other secure means of communication.

The internet has security and privacy limitations beyond the control of Urgo Hotels Canada. Unfortunately, no data transmission or storage system can be considered completely secure. Please inform our privacy officer immediately if you have reason to believe that your interaction with us is no longer secure.

8. Retention of Personal Information

We have personal information retention processes in place to ensure that your personal information is not kept longer than is reasonably necessary for the purposes outlined in this Privacy Policy or to otherwise fulfill our legal obligations.

9. Locations, Storage and Cross-Border Transfer

Your personal information is stored in secure locations and on servers managed by Urgo Hotels Canada. Notwithstanding the above, Urgo Hotels Canada and third-party services may process or store your personal information outside of Canada. In accordance with the laws of these countries, in certain circumstances, your personal information may be accessible to law enforcement, regulatory authorities, or other foreign entities. Please contact us as indicated below for more information about our practices and policies regarding the use of foreign service providers.

10. children

We recognize the importance of protecting children’s privacy. Children cannot make reservations at our hotels or stay there without their parents’ consent. Our websites are not intended for or directed at children under the age of thirteen (13). If you are under thirteen (13) years of age, please do not use our websites. If you are over thirteen (13) years of age but have not reached the age of majority where you reside, you should only use our websites with the guidance and permission of a parent or legal guardian. Urgo Hotels Canada does not voluntarily or knowingly collect any personal information from children under the age of thirteen (13) without obtaining parental consent.

11. Role of the Privacy Officer

The Urgo Hotels Canada Privacy Officer and the general managers of hotels managed by Urgo Hotels Canada are responsible for ensuring compliance with this policy, as well as provincial and federal regulations.
Please direct any questions, complaints or concerns regarding this Privacy Policy, or the privacy practices of Urgo Hotels Canada regarding the manner in which we collect, use and disclose your personal information, in writing to the person responsible for protecting your privacy: [email protected]