Is Hotel Data considered Confidential Information of the Crowne Plaza hotel?
Crowne_Plaza Franchise · 2025 FDDAnswer from 2025 FDD Document
Hotel Data, constitutes Confidential Information of Hotel, may only be used, stored, or copied by FreedomPay (a) for assisting in completing a card transaction, (b) for fraud control services, (c) as otherwise permitted by Hotel, (d) as otherwise permitted by IHG, or (e) to perform FreedomPay's obligations under this Participation Agreement.
When reporting its total count of transactions processed for all customers FreedomPay may include in such total the transactions processed under this Participation Agreement as long as the data so included is limited to Hotel Aggregated Data..
Hotel hereby further authorizes FreedomPay's use of Hotel Aggregated Data to improve the Solution and as expressly provided in this Participation Agreement. "Hotel Aggregated Data" means data collected or generated by FreedomPay as a result of FreedomPay providing Services that meets each of the following requirements: (a) Hotel's transactions cannot be identified or associated with Hotel directly or indirectly; (b) no personally identifiable data is included; and (c) no individual can be identified, contacted, or marketed to, directly or indirectly, from such data.
Return of Hotel Data; License to Use Hotel Data.
Upon termination, Hotel may request, but subject to PCI DSS rules and all applicable laws (including statutes of limitation), and FreedomPay shall: (a) promptly provide to Hotel, in the format and on the media reasonably requested by Hotel, a copy of all or any part of the Hotel Data; (b) promptly return to Hotel, in the format and on the media reasonably requested by Hotel, all or any part of the Hotel Data that has exceeded established retention policies; and (c) erase or destroy all or any part of the Hotel Data in FreedomPay's or FreedomPay agents' possession that has exceeded established retention policies, and certify in writing to the Hotel that it and each of its Affiliates has performed the foregoing, in each case to the extent so requested by Hotel.
Any archival tapes containing Hotel Data shall be used by Supplier and Supplier Agents solely for back-up purposes.
Hotel hereby grants FreedomPay a perpetual, nonexclusive license to store, copy and use Hotel Data to the extent necessary to perform its obligations under this Participation Agreement and comply with applicable law and to use and disclose Hotel Aggregated Data for FreedomPay's business purposes.
Source: Item 23 — Receipts (FDD pages 100–424)
What This Means (2025 FDD)
According to the 2025 Crowne Plaza Franchise Disclosure Document, Hotel Data is considered Confidential Information of the Hotel. However, the hotel may only use, store, or copy the data under certain conditions. These conditions include assisting in completing a card transaction, for fraud control services, as otherwise permitted by the Hotel or IHG, or to perform FreedomPay's obligations under the Participation Agreement.
FreedomPay may include transactions processed under the Participation Agreement when reporting its total count of transactions processed for all customers, as long as the data included is limited to Hotel Aggregated Data. Hotel Aggregated Data means data collected or generated by FreedomPay as a result of FreedomPay providing services that meets certain requirements. These requirements are that the Hotel's transactions cannot be identified or associated with the Hotel directly or indirectly, no personally identifiable data is included, and no individual can be identified, contacted, or marketed to, directly or indirectly, from such data.
Upon termination, the Crowne Plaza hotel may request a copy of all or any part of the Hotel Data, subject to PCI DSS rules and all applicable laws. FreedomPay must promptly provide the data in the format requested by the hotel, return any Hotel Data that has exceeded established retention policies, and erase or destroy all Hotel Data in their possession that has exceeded established retention policies. FreedomPay must also certify in writing that they and their affiliates have performed these actions. Crowne Plaza grants FreedomPay a perpetual, nonexclusive license to store, copy, and use Hotel Data to the extent necessary to perform its obligations under the Participation Agreement and comply with applicable law, and to use and disclose Hotel Aggregated Data for FreedomPay's business purposes.