Concerning Crowne Plaza franchises, what is the definition of "Eligible Participant Personal Data" that AT&T collects, holds, or uses?

According to Crowne Plaza's 2025 Franchise Disclosure Document, "Eligible Participant Personal Data" is defined as information that identifies an individual that the Crowne Plaza franchisee directly or indirectly makes accessible to AT&T. This data is then collected, held, or used by AT&T in the course of providing services to the Crowne Plaza franchisee.

In simpler terms, this refers to any personal information of customers, employees, or agents of the Crowne Plaza franchise that is shared with AT&T, whether intentionally or unintentionally, and that AT&T then uses to provide its services. This could include names, contact information, or any other data that could identify an individual.

It is important for a prospective Crowne Plaza franchisee to understand this definition because they are responsible for obtaining consent from and giving notice to their users, employees, and agents regarding the collection and use of their information by both the franchisee and AT&T. The franchisee must also ensure they have the legal authority to make this data accessible to AT&T. This highlights the importance of data privacy and compliance with relevant regulations when operating a Crowne Plaza franchise.