Privacy Agreement 

Hilton

 

 

Applicant Privacy Notice

 

Last Updated: June 2023

 

Hilton Worldwide Holdings Inc. and its direct and indirect subsidiaries ("Hilton", "we", "our" or "us") value the trust of individuals submitting job applications on the Hilton Careers Site ("you" or "Applicant") and are committed to the responsible management, use and protection of personal information. This Applicant Privacy Notice (this "Notice") applies to all the information collected by Hilton to facilitate your job application and includes your use of our Careers Site. This Notice explains how Hilton processes the personal information that we collect through the job application process ("personal information"). Please note that this Notice applies only to Hilton's processing of your personal information on the Careers Site and if you are applying for a Hilton corporate position, or a position at a property that is managed by Hilton. 

You may be applying for a position at a franchised property in which case, the franchised property will process your personal data in accordance with its own policies and procedures, which may be provided to you via a separate privacy policy.

 

Personal information submitted to other Hilton web sites will be used in accordance with our Global Privacy Statement.

 

The Careers Site is operated by Hilton, 7930 Jones Branch Drive, McLean, Virginia, USA 22102, in order to support the recruitment functions of Hilton and Hilton properties. The Careers Site is not intended for distribution or use in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.

 

Where local laws impose greater obligations or restrictions on the use of personal information, or require additional information to be provided to you, this Notice may be supplemented by local policies or procedures that are specific to a particular region, country or entity. In particular, Appendix A to this Notice includes additional information applicable to Applicants residing in countries that have enacted privacy laws giving certain additional rights to residents of those countries. These countries include, but are not limited to, those in the European Economic Area, the United Kingdom and Switzerland (collectively, the "EEA"), Argentina, Australia, Brazil, Canada, China, Israel, Japan, Kenya, Nigeria, and Turkey. Where additional consent, consultation or other rights exist under local laws, Hilton's processing of personal information will be subject to the exercise of those rights.

For applicants who are residents of California, please see Appendix B for additional information regarding how we collect and use your personal information in accordance with the California Consumer Privacy Act. 

 

In some locations around the world, Hilton manages hotel properties on behalf of a third party owner. At many of those properties, the Hotel owner (and not Hilton) is the actual employer, and Hilton performs recruiting and hiring functions on behalf of the owner. You understand and agree that, by applying through this site, you may be applying for a position with a company other than Hilton, where Hilton is serving as the recruiter, but will not be your employer of record.

 

If you accept a position with Hilton or the Hotel owner, you will be considered a Hilton "Team Member" and a separate notice will govern our use of your personal information.

 

Some positions listed on the Hilton Careers Site are for positions with a franchised property. For these positions, the franchise management company or property owner (and not Hilton) is the actual employer. By providing access to the Hilton Careers site, Hilton does not perform or exercise any direction, oversight or control over any recruiting or hiring functions on behalf of franchisees and allows access to its Careers Site for applicants of these franchise entities as an optional resource only. You understand and agree that, by applying through this site, you may be applying for a position with a franchised property (not Hilton) and Hilton will not be your employer of record.

 

 

Your Acknowledgement

 

Please read this Notice carefully and indicate your acknowledgment and acceptance of our collection, retention, use, transfer and disclosure of personal information as described in this Notice by clicking the "I Accept" button at the end of this Notice.

 

Your personal information may be transferred to countries outside your home country, including countries where data protection laws may differ from those of your home country.

 

Hilton maintains safeguards designed to protect your personal information. Please see Appendix A for additional information.

 

 

Information We Collect

 

Hilton may collect personal information in connection with your submitting to apply or searching for a position on the Hilton Careers Site. This includes information you provide as well as passive information collection, where permitted by applicable law.

 

Information You Provide

• Log-in and password, for users of the Careers Site;
• Information on how you found out about the job;
• Identifiers and contact Information including names and addresses, telephone numbers, mobile telephone numbers, email addresses, dates of birth, Social Security numbers, driver's license or state identification numbers, bank account information, and other similar contact information and identifiers);
• Professional and employment-related information including:
  • data submitted with employment applications including employment history and experience, employment recommendations or references, employment preferences, willingness to relocate, willingness to travel, desired salary, CV, résumé, cover letter, etc.;
  • background check and criminal history;
  • work authorization;
  • fitness for duty data and reports;
• Education information including education history such as education level, school, major, certifications held, etc.
• Protected classification information including characteristics of protected classifications under applicable state or federal law by your self-identification (such as Age range, Gender, Religion, Disabled, Ethnic Group).
• Internet or other electronic network activity information including all activity on the Hilton Careers Site or Hilton information systems, such as search history on the Careers Site.
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information. This category includes, for example, information collected from cameras, and similar devices.

Hilton may also collect the following information from applicants in the United Kingdom and Ireland and other EEA jurisdictions, as well as Canada:

• Right to Work Document Type;
• For Visa/Work Permits, the type of such permit;
• Related to a Right to Work Document or Permit: Document Number, Country of Issue, Place of Issue, Issue Date, Expiration Date.

We do not require, but you may voluntarily choose to provide, other relevant information as part of your application. Please do not submit the following sensitive information unless we specifically request that you provide such information so that we may comply with our legal obligations and/or internal policies relating to diversity and anti-discrimination: sexual orientation, race, ethnic origin, religion, political and religious beliefs, disability, marital status, creed, nationality, national origin, color and/or age.

 

By voluntarily submitting information about your racial or ethnic origin; physical or mental health or condition; job evaluations or educational records; commission (or alleged commission) of an offence or related proceedings; political opinions or beliefs; religious beliefs; sex life; membership in a trade union or political party, you expressly authorize Hilton to receive and process such information for the purpose of processing your application.

 

Any information you submit must be true, complete, and not misleading and you must have the lawful right to provide it. If not, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been hired.

 

If you intend to provide us with details of a reference or any other third party as part of your CV/resume, it is your responsibility to obtain consent from that third party prior to providing his/her personal information to us.

 

The provision of personal information, including on the Careers Site, is voluntary. Please note however that the failure to provide sufficient information may result in you being unable to be considered for employment.

 

Passive Information Collection: Cookies and Similar Technology

 

We and our service providers may use "cookies" and similar technologies on the Careers Site. Cookies are data that a web server transfers to an individual's computer for record keeping purposes. We use cookies and other technologies to better serve you with more tailored information and facilitate your ongoing access to and use of our Careers Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. However, if you decline session management cookies from Taleo (the third-party that hosts the Careers Site), the Careers Site may not function properly for you.

 

If you are a resident of certain countries, we are required to obtain your consent before placing certain cookies or similar technology on your computer. We will separately prompt you for this consent before we attempt to place a cookie or similar technology on your computer.

 

 

Legal Bases, Use, and Disclosure of Personal Information

 

The information that you submit on the Careers Site will be stored in the United States (and in the relevant jurisdiction(s) if the job relates to one of our franchise companies or affiliated entities outside of the United States). As a reminder, you may be applying for a position at a franchised property in which case, the franchised property will process your personal data in accordance with its own policies and procedures, which may be provided to you via a separate privacy policy.

 

The following information may be collected, used, transferred and disclosed by employees, consultants and/or service providers of Hilton around the world for Hilton's global recruitment functions and for related management and planning purposes, including, as permitted by local law, to:

• Maintain personnel records and record retention requirements.
• Prevent unauthorized access to or use of the Hilton's property, including Hilton's information systems, electronic devices, network, and data.
• Investigate complaints, grievances, and suspected violations of Hilton policy.
• Design, implement, and promote Hilton's diversity and inclusion programs.
• Improve safety of our facilities for employees, customers and the public with regard to use of Hilton property and equipment.
• Confirm eligibility for employment and related checks regarding fitness for duty.
• Conduct background checks if you are offered a job.
• Comply with applicable state and federal health, labor, employment, benefits, workers compensation, disability, equal employment opportunity, workplace safety, and related laws, guidance, or recommendations.
• Send surveys to collect feedback on your recruiting experience.
• Conduct video interviews, including storing the interview.

Personal information about you will be added to Hilton's international candidate database and may be used for the purposes of considering whether your profile is suitable for other job vacancies at Hilton. If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. The processing of your personal information for these purposes is based on your consent. If you become a Team Member, any personal information that you submit may become part of your Team Member file and may be used for other employment/work-related purposes and otherwise in accordance with the Hilton Team Member Privacy Notice.

 

To the extent any use is inconsistent with or outside of the contemplated uses in this Notice, we will communicate it to you at the time of use.

 

Personal information about you will be reviewed by Hilton Team Members or agents who have a business need to access such personal information and may include recruiters, human resources personnel, technical services personnel and managers or their designees.

 

We may share personal information about you with selected service providers or consultants acting on our behalf, such as third parties assisting Hilton with the operation of the Careers Site (including (a) Taleo (with its primary place of business at 4140 Dublin Boulevard, Suite 400, Dublin, CA 94568 USA), which is the Applicant Tracking System and hosts job openings for the Careers Site, (b) Phenom (with its primary place of business at 300 Brookside Ave., Building 18, Suite 200, Ambler, PA 19022), which hosts the Careers Site and talent relationship and content management system, and (c) SHL (with its primary place of business at 1 Atwell Place, Thames Ditton, Surrey, KT7 ONE UK), which conducts job- specific candidate assessments). Those third parties are required by contract to use appropriate measures to protect the confidentiality and security of personal information.

 

Hilton also may disclose personal information about you in order to:

 

1. Protect the legal rights, privacy, safety or property of Hilton or its Team Members, agents, contractors, customers or the public;

2. Protect the safety and security of visitors to our web sites or other properties;

3. Protect against fraud or other illegal activity or for risk management purposes;

4. Respond to inquiries or requests from legal authorities;

5. Permit Hilton to pursue available remedies or limit the damages that we may sustain;

6. Enforce our website Terms of Service;

7. Respond to an emergency;

8. Comply with the law or legal process;

9. Effect a license, sale or transfer of a business or assets (including in connection with any bankruptcy or similar proceedings); or

10. Manage acquisitions, mergers and re-organizations.

 

 

Data Retention

 

We are required to retain information relating to candidates applying for jobs within the United States. We will retain your personal information for three years, or a longer time if required or allowable by applicable law, during which time we or a franchise company or affiliate may contact you regarding open positions. Personal Information of candidates applying for jobs in other parts of the world will be retained in accordance with local law. If there is no activity in relation to the personal information, Hilton may remove it from its database, subject to Hilton's data retention obligations and policies and any applicable legal or regulatory obligations or for the period of time permitted by local laws, for the purpose of considering whether your skills are suitable for other opportunities.

 

Note that Hilton may delete personal information about you at any time (including your CV/resume), without any reason. Therefore, please retain your own copy of the personal information provided to us.

Access, Correction and Deletion

 

If you choose to register on the Careers Site, you may access, review, and change some of the personal information collected about you and stored on the Careers Site by logging into the Careers Site and choosing to update your account information. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you already have submitted for consideration for a specific position, please resubmit your application to update personal information about you that is associated with that job application. We encourage you to promptly update your personal information if it changes or is inaccurate. Upon your request, we will deactivate or remove your personal information from our active databases, although some information may be retained as permitted or required by law.

 

If you have any questions or concerns about how we otherwise process personal information please contact us at the e-mail link below.

 

 

DataProtectionOffice@hilton.com

 

You may access, modify or object to the use of personal information as permitted by applicable local law. Applicants who would like to review, update, or request that we delete their personal information should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA. Please note, however, that certain personal information may be exempt from access, correction or deletion rights pursuant to applicable data protection laws. 

If you are a resident of a country that grants you certain rights with respect to your personal information (such as EEA residents), you may have other rights with respect to your personal information, which are explained in Appendix A.

 

 

Career Site Security

 

We take reasonable precautions to safeguard the personal information transmitted between visitors and the Careers Site and the personal information stored on our servers. Unfortunately, no method of transmitting or storing data can be guaranteed to be 100% secure. Do not send sensitive information via email. It is your sole responsibility to use the appropriate level of care whenever communicating with us.

 

If you have reason to believe that your interaction with us is no longer secure (for example, you feel that the security of any account you might have with us has been compromised), you should immediately notify us of the problem by contacting us at the link below.

 

 

ISC@hilton.com

 

 

Hilton hereby disclaims, as far as permitted by law, any liability for itself and its affiliated companies and contractors for any of your information sent to our Careers Site that is lost, misused, illegally accessed, disclosed, altered or destroyed or not integrally or timely delivered to our Careers Site.

 

 

Links to other websites

 

The Careers Site may contain links to other websites. The operators of those other websites may collect information about you, through cookies or other technologies. If you link to another website, you will leave the Careers Site and this Notice will not apply to your use of and activity on those other sites.

 

If you provide personal information through or on any other site, your transaction will occur on that website (not the Hilton Careers Site) and the personal information you provide will be collected by, and controlled by, the privacy policy of that website operator.

 

Links on the Careers Site to other websites are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site. We encourage you to read the legal notice posted on those sites, including their privacy policies. We have no responsibility or liability for your visits to, or the data collection or use practices of, other sites.

 

 

Law Applicable to Job Application

 

The Careers Site allows you to benefit from Hilton's centralized global recruitment function, while applying for jobs worldwide. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the U.S. and will be subject to U.S. laws. However, if we share your personal information with a Hilton entity located in another country in its capacity as a potential employer (or acting as recruiter for a Hotel owner), the Hilton entity will handle your personal information in accordance with this Notice. Franchisee entities may handle your information pursuant to a separate privacy notice they may provide to you. Any hiring or other employment-related decisions will be made by the hiring entity in accordance with the laws of the country where the job will be located. Please see Appendix A for additional information on International Data Transfers.

 

 

About Children

 

The Careers Site is not intended for minors under the age of 15 or the lawful age of employment (whichever is greater) in any country in which we operate.

 

 

Changes to the Notice

 

We reserve the right to amend this Notice at any time without advance notice in order to address future developments of Hilton, the Careers Site or changes in industry or legal trends. We will post the revised Notice on the Careers Site or announce the change on the home page of the Careers Site. You can determine when the Notice was revised by referring to the "Last Updated" legend on the top of this Notice. Any changes will become effective upon the posting of the revised Notice on the Careers Site. By continuing to use the Careers Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Notice, in whole or part, you can choose to not continue to use the Careers Site.

 

 

Additional Privacy Provisions for Applicants from Certain Countries

 

Please see Appendix A for additional provisions that pertain to you if you are a resident of a country that has enacted a privacy law granting additional rights to residents of that country.

 

 

APPENDIX A

 

ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF APPLICANTS FROM COUNTRIES WITH PRIVACY LAWS GRANTING ADDITIONAL RIGHTS TO INDIVIDUALS

 

 

For applicants from countries that have enacted privacy laws granting additional rights to individuals, this Appendix outlines certain additional information that Hilton is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws.

 

Hilton Controller:

 

Hilton Domestic Operating Company Inc. is the data controller with respect to your personal information and can be contacted by email at DataProtectionOffice@Hilton.com or at the following address:

 

Hilton Data Protection Officer

7930 Jones Branch Drive

McLean, Virginia 22102 USA

 

Purposes and Legal Basis for Processing

 

Hilton processes your personal information for the purpose of either recruiting and evaluating candidates for employment, or to allow franchisee entities to access your personal information if you are applying for a position at a franchised property. Hilton processes your information pursuant to its legitimate business interests and, in some cases, based on your consent.

 

Data Subject Rights

 

Access, Correction and Erasure Requests: Applicants who would like to review, update, or request that we delete their personal information should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA. Please note, however, that certain personal information may be exempt from access, correction or deletion rights pursuant to applicable data protection laws.

 

Restriction Requests: Applicants who would like to request that Hilton cease processing of certain personal information should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA.

 

Please note, however, that certain personal information may be exempt from such requests pursuant to applicable data protection laws.

Data Portability Requests: Applicants who would like to request a copy of certain of their personal information, or request that such personal information be transmitted to a third party, should go to the Data Subject Rights Portal or should send a request in writing to DataProtectionOffice@Hilton.com or Hilton Data Protection Office, 7930 Jones Branch Drive, McLean, VA 22102, USA. Please note, however, that data portability rights apply only in limited circumstances and to limited data sets.

 

Disclosures of your Information: In order to administer and manage the job application process, and to otherwise perform the activities set forth in this Notice, your information will be shared with other Hilton personnel, such as personnel responsible for hiring determinations, members of the human resources team, as well as other employees and individuals within Hilton involved in the recruitment and selection process. Hilton will provide franchisee entities with access to your information if you are applying for a job with a franchise property.

 

Your information will be shared with various third party service providers engaged by Hilton to support its recruitment efforts for its corporate offices and owned and managed properties. These third parties include:

• human resources services, performance management and talent management
• back office IT systems suppliers and providers

We will also share information with legal and regulatory authorities and our accountants, auditors, lawyers and other outside professional advisors.

 

We also share information with third parties:

• if, in good faith, we believe that the disclosure is required to comply with a judicial proceeding, court order, subpoena, warrant or legal process, and such disclosure is in compliance with local law;
• in the event of a merger or acquisition, asset sale, a transfer of some or all of Hilton's business, or other related transaction; and
• when we believe in good faith that disclosure is required by law or to protect the safety of our employees, the public or Hilton property.

International Data Transfers

 

We reserve the right to transfer your personal information to, or process your personal information in, countries that have not been found to provide adequate protection of data pursuant to a country-specific law. In particular, we collect and store the personal information you provide via the Careers Site in the United States.

 

We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions, and where required, we have implemented data transfer agreements, such as the European Commission controller-to- controller standard contractual clauses or other similar safeguards, for such purposes. To obtain a copy of theses clauses or additional information on transfers, you may send your request to privacy@hilton.com.

 

 

Complaints

You have the right to lodge a complaint regarding the processing of your personal information with us at privacy@hilton.com or with the supervisory authority in the Member State of your residence or place of work if you believe that the processing of your personal information infringes applicable local laws.

 

Privacy Notice Changes

This Notice may be changed from time to time. You can determine when this Notice was last revised by referring to the "Last Updated" legend at the top of this Notice. Any changes to this Notice will become effective upon our posting of the revised Notice on the Careers Site.

  APPENDIX B

CALIFORNIA CONSUMER PRIVACY ACT NOTICE AT COLLECTION 

CALIFORNIA APPLICANTS

Last Updated: June 2023

This Appendix B applies solely to individuals who are residents of the State of California as required under the California Consumer Privacy Act, as amended (“CCPA”). The other provisions of the Applicant Privacy Notice continue to apply, as applicable, except as modified in this Appendix B. 

 

This Notice at Collection (“Notice”) describes the categories of Personal Information that Hilton Worldwide Holdings Inc., Hilton Domestic Operating Company Inc., Hilton Worldwide Manage Limited, any other company owned in whole or in part by Hilton Worldwide Holdings Inc., and any Hilton-owned, leased, and/or managed hotel (“Hilton” or “Company”) may collect from California residents and the purposes for which such information may be collected and used. It also provides information concerning the Company’s record retention practices and rights you may have under the CCPA. Any terms defined within the CCPA have the same meaning when utilized within this Appendix B.

Categories of Personal Information Collected

Identifiers and Contact information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signatures, account names, dates of birth, bank account information, log-in and password for Careers site, and other similar contact information and identifiers. 

Protected Classification Information. This category includes characteristics of protected classifications under California or federal law.

Internet or Other Electronic Network Activity Information. This category includes, without limitation: 

• all activity on the Company’s information systems, such as email communications, stored documents and emails, usernames and passwords

• all activity on communications systems, including phone calls, call logs, voice mails, text messages, etc.

Geolocation Data

Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information. This category includes, for example, information collected from cameras, and similar devices.

Professional and Employment-Related Information. This category includes, without limitation, where permitted by law, data submitted with employment applications, employment history, employment recommendations, etc.

Education Information. This category includes, without limitation, education history.

Sensitive Personal Information. This category includes sensitive information such as:

• Social Security, driver’s license, state identification card, or passport number

• financial account information 

• racial or ethnic origin

• content of mail, email, and text messages (unless the Company is the intended recipient of the communication)

• biometric information for the purpose of uniquely identifying an individual

• health information

• information concerning sex life or sexual orientation

Inferences Drawn from the Personal Information in the Categories Above.  This category includes engaging in human capital analytics, including, without limitation, identifying correlations between certain characteristics and job success.

Purposes Personal Information, Including Sensitive Personal Information, Is Used

• Collecting and processing employment applications, including confirming eligibility for employment, background and related checks, drug tests, references, onboarding, and related recruiting efforts; evaluating an individual’s appropriateness for a particular position.

• Retaining your information for consideration with respect to future job vacancies with Hilton.

• Providing access to the Careers site. 

• Maintaining records and satisfying record retention requirements.

• Communicating with applicants about a current application, future job opportunities or current and past employment.

• Submitting relevant information to prospective employers (e.g., third party hotel owners for whom Hilton manages properties; franchisees, etc.)

• Complying with applicable state and federal health, labor, employment, disability, equal employment opportunity, workplace safety, and related laws, guidance, or recommendations.

• Preventing unauthorized access to, use, or disclosure of the Company’s property, including information systems and network. 

• Investigating complaints, grievances, and suspected violations of Company policy.

• Designing, implementing, and promoting the Company’s diversity and inclusion programs.

• Facilitating the efficient and secure use of the Company’s information systems; ensuring compliance with the Company information systems policies and procedures. 

• Improving safety of applicants, employees, customers and the public with regard to use of Company property and equipment.

• Improving efficiency.

• Protecting the legal rights, privacy, safety or property of Company or its employees, agents, contractors, customers or the public.

• Protecting against fraud or other illegal activity or for risk management purposes.

• Investigating, responding to and managing legal claims against the Company and/or its personnel, including civil discovery in litigation.

• Facilitating other business administrative functions and strategic activities, such as risk management, information technology and communications, financial management and reporting, workforce and succession planning, merger and acquisition activities, and maintenance of licenses, permits and authorization applicable to Company operations.

• Sending surveys to collect feedback on your recruiting experience.

• Conducting and storing video interviews.

 

Categories of Personal Information

______________________________________________________________________

Identifiers and Contact information – such as name, postal address, email address, phone number, account name, date of birth, Social Security number, driver’s license number, photograph, passport number, unique personal identifier, online identifier, Internet Protocol address or other similar identifiers

 

NOTE: The information in this category may include the following elements of Sensitive Personal Information: Social Security number, driver’s license number, state identification card number, and/or passport number. 

Categories of Third Parties to Whom Disclosed

Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.

Affiliates, business partners, third party hotel owners for whom we manage properties, franchisees and other entities for whom we perform recruiting and hiring functions or list positions. 

Third parties that perform services on our behalf. For example, we may disclose information to certain service providers including professional services providers; information technology providers; background check vendors; applicant tracking, talent relationship and content management vendors; and data storage companies. We might also authorize our service providers to collect personal information on our behalf such as information you provide in response to a survey.

Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

Governmental entities, legal service providers.

______________________________________________________________________

Protected Classification Information – such as citizenship, ethnic background, gender, or other similar identifiers

NOTE: The information in this category may include the following elements of Sensitive Personal Information: racial, ethnic, or national origin. 

Categories of Third Parties to Whom Disclosed

Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.

Affiliates, business partners, third party hotel owners for whom we manage properties, franchisees and other entities for whom we perform recruiting and hiring functions or list positions. 

Third parties that perform services on our behalf. For example, we may disclose information to certain service providers including professional services providers; information technology providers; background check vendors; applicant tracking, talent relationship and content management vendors; and data storage companies. We might also authorize our service providers to collect personal information on our behalf such as information you provide in response to a survey.

Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

Governmental entities, legal service providers.

______________________________________________________________________

Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement

NOTE: The information in this category may include the following elements of Sensitive Personal Information: the contents of mail, email, or text messages, to which the business was not the intended recipient.

Categories of Third Parties to Whom Disclosed

Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.

Affiliates, business partners, third party hotel owners for whom we manage properties, franchisees and other entities for whom we perform recruiting and hiring functions or list positions. 

Third parties that perform services on our behalf. For example, we may disclose information to certain service providers including professional services providers; information technology providers; background check vendors; applicant tracking, talent relationship and content management vendors; and data storage companies. We might also authorize our service providers to collect personal information on our behalf.

Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

Governmental entities, legal service providers.

______________________________________________________________________

Professional, or employment related information, including veteran status or other similar identifiers 

NOTE: The information in this category may include the following elements of Sensitive Personal Information: union membership. 

Categories of Third Parties to Whom Disclosed

Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.

  

Affiliates, business partners, third party hotel owners for whom we manage properties, franchisees and other entities for whom we perform recruiting and hiring functions or list positions. 

Third parties that perform services on our behalf. For example, we may disclose information to certain service providers including professional services providers; information technology providers; background check vendors; applicant tracking, talent relationship and content management vendors; and data storage companies. We might also authorize our service providers to collect personal information on our behalf such as information you provide in response to a survey.

Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

 

Governmental entities, legal service providers.

______________________________________________________________________

Education information

Categories of Third Parties to Whom Disclosed

Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.

  

Affiliates, business partners, third party hotel owners for whom we manage properties, franchisees and other entities for whom we perform recruiting and hiring functions or list positions. 

Third parties that perform services on our behalf. For example, we may disclose information to certain service providers including professional services providers; information technology providers; background check vendors; applicant tracking, talent relationship and content management vendors; and data storage companies. We might also authorize our service providers to collect personal information on our behalf such as information you provide in response to a survey.

Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

Governmental entities, legal service providers.

______________________________________________________________________

Inferences drawn from personal information – such as individual profiles, preferences, characteristics, behaviors or other similar identifiers

NOTE: The information in this category may include the following elements of Sensitive Personal Information: racial or ethnic origin, religious or philosophical beliefs, union membership, health information. 

Categories of Third Parties to Whom Disclosed

Third parties as directed by you. We may disclose your personal information to the third parties to whom you direct.

  

Affiliates, business partners, third party hotel owners for whom we manage properties, franchisees and other entities for whom we perform recruiting and hiring functions or list positions. 

Third parties that perform services on our behalf. For example, we may disclose information to certain service providers including professional services providers; information technology providers; background check vendors; applicant tracking, talent relationship and content management vendors; and data storage companies. We might also authorize our service providers to collect personal information on our behalf such as information you provide in response to a survey.

Successors to all or portions of our business. If all or part of our business is sold, we may disclose personal information in preparation for or as part of that transaction.

Governmental entities, legal service providers.

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The Company may add to the categories of Personal Information it collects and the purposes for which it uses Personal Information. In that case, the Company will inform you. 

We do not sell or share, as those terms are defined under the CCPA, the above categories of Personal Information. 

We do not use or disclose your Sensitive Personal Information for purposes that, with limited exceptions, are not necessary for the application or recruitment related purpose for which we collect it or as reasonably expected by an average individual in this context or for other permitted purposes under the CCPA or as authorized by regulation. 

Retention. We retain your Personal Information for as long as is necessary for the recruitment process, assess and or process your application for employment, consider you for future positions, etc. and in accordance with the Company’s data retention schedule.  

We may retain your Personal Information for longer if it is necessary to comply with our legal or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, address other legitimate business needs, or as permitted or required by applicable law. 

We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you.  

To determine the appropriate retention period for your Personal Information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements. Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.  

Individual Rights Requests. Individuals who are residents of the State of California have certain individual rights, which are outlined below. 

Right To Know About Personal Information Collected or Disclosed. As a California resident, you have the right to request additional information, beyond that disclosed above, regarding the following, to the extent applicable:

• the categories of Personal Information the Company collected about you 

• the categories of sources from which that Personal Information was collected

• the business or commercial purposes for which that information was collected, sold, or shared 

• the categories of third parties to whom the information was disclosed

• the specific pieces of Personal Information collected

Upon receipt of a verifiable request to know (see below), and as required by applicable law, we will provide a response to such request. 

Right To Request Deletion of Your Personal Information. You have the right to request that we delete the Personal Information we collected or maintain about you. Once we receive your request, we will let you know what, if any, Personal Information we can delete from our records, and will direct any service providers and contractors to whom we disclosed your Personal Information to also delete your Personal Information from their records.

There may be circumstances where we cannot delete your Personal Information or direct service providers or contractors to delete your Personal Information from their records.  Such instances include, without limitation, when the information at issue is maintained: (a) to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information, or (b) to comply with a legal obligation.  

Upon receipt of a verifiable request to delete (see below), and as required by applicable law, we will provide a response to such requests.

Right to Request Correction. You have the right to request that the Company correct any inaccurate Personal Information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable request to correct (see below), and as required by the CCPA, we will provide a response to such requests.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate or retaliate against you for exercising any of the rights described above. 

Submitting CCPA Rights Requests. To submit a California Consumer Rights request, please visit our website at datarights.hilton.com or click the “Personal Data Requests” link at the bottom of any Hilton website to submit your request. You also may call our toll-free telephone number: (800) 413-7470, email the Data Protection Office (“DPO”) at DataProtectionOffice@hilton.com. We reserve the right to only respond to verifiable consumer requests to know, delete, or correct.  

What to submit. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a CA resident. In general, we may ask you to provide identifying information that we already maintain about you. In either event, we will try to avoid asking you for sensitive Personal Information to verify your identity. We may not be able to respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  However, making a verifiable consumer request does not require you to create an account with us.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the Personal Information we collect from an individual to determine a verifiable request for any other purpose, except as required or permitted by law. 

Our response. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.

Spouses, Dependents, and Associates. If you have knowledge that the Company collected Personal Information related to your spouse or dependent, please share a copy of this notice with all such individuals. 

Changes to this Notice. We reserve the right to amend this Notice.