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Privacy Policy

Updated On 11/26/2024

PRIVACY NOTICE

Version 4.0

Last Updated: 1st December 2024

Our Commitment to Data Privacy

Your privacy is important to Freehand Hostel Manager LLC, its affiliates and partners (“Freehand,” “we,” “us,” “our”). To better protect your privacy, we are providing information explaining our information practices. This Privacy Policy (“this Policy”) 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 Policy, please contact legal@thefreehand.com. You do not need to take any action as a result of this Policy, 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 Policy 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 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 Policy covers:

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 policy 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:

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

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

2. HOW WE OBTAIN YOUR PERSONAL INFORMATION

Personal Information is collected in a variety of ways:

“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:

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 Mac), 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:

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

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 and to protect Freehand and our guests as detailed below. In some instances, we will request that you provide Personal Information or Other Data to us directly. If you do not provide the data that we request, 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 the following 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:

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:

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:

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:

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:

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

Right to Non-Discrimination

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

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 Policy, please contact legal@thefreehand.com.

Alternatively, you may wish to write to:

Freehand Hostel Manager LLC

Freehand New York

23 Lexington Avenue

New York, NY 10010

Changes to this Policy and Your Personal Information

This Policy is regularly reviewed and was last updated on 1st October 2024. 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.