For Atwell Suites, what duty is HotelKey's Subprocessors subject to regarding Personal Data?
Atwell_Suites Franchise · 2025 FDDAnswer from 2025 FDD Document
- HotelKey's Subprocessors that process Personal Data on HotelKey's behalf shall be subject to a duty of confidentiality and have a written agreement that requires them to meet their obligations under the Privacy Laws and that is materially at least as protective as this Attachment.
Source: Item 23 — Receipts (FDD pages 99–486)
What This Means (2025 FDD)
According to the 2025 Atwell Suites Franchise Disclosure Document, HotelKey's Subprocessors, when processing Personal Data on HotelKey's behalf, must adhere to specific confidentiality and data protection obligations. These Subprocessors are subject to a duty of confidentiality.
Furthermore, HotelKey is required to have a written agreement with its Subprocessors. This agreement must stipulate that the Subprocessors meet their obligations under the Privacy Laws. The agreement's terms must be materially at least as protective as the terms outlined in Attachment 2 of the Atwell Suites agreement with HotelKey.
This means that any third-party companies HotelKey uses to process personal data related to Atwell Suites hotels must maintain the same level of data protection and privacy as HotelKey itself. This requirement aims to ensure that sensitive information is handled securely and in compliance with applicable privacy regulations, regardless of whether it is processed directly by HotelKey or by its Subprocessors.