Is a Delta Hotels By Marriott franchisee allowed to sell Guest Personal Data?
Delta_Hotels_By_Marriott Franchise · 2025 FDDAnswer from 2025 FDD Document
Franchisee will collect, use, handle, and share Guest Personal Data only for purposes of operating the Hotel and only in accordance with this Agreement, Applicable Law, and the Standards.
Without limiting the foregoing, Franchisee will comply with all Standards relating to the use of Guest Personal Data for direct marketing to customers and will not sell any Guest Personal Data.
Franchisee will ensure that (i) all Hotel personnel with access to Guest Personal Data complete any training required by the Standards, and (ii) Franchisee complies with the Standards relating to revoking or disabling any such Person's access to Guest Personal Data upon termination of employment or service.
Source: Item 23 — RECEIPTS (FDD pages 134–251)
What This Means (2025 FDD)
According to the 2025 Delta Hotels By Marriott Franchise Disclosure Document, a franchisee is explicitly prohibited from selling any Guest Personal Data. While both the franchisee and franchisor act as independent controllers of Guest Personal Data and are permitted to share this data during the term of the agreement, this sharing is strictly limited to the operation of the hotel and must comply with all applicable laws and standards.
Delta Hotels By Marriott franchisees are obligated to collect, use, handle, and share Guest Personal Data solely for the purpose of operating the hotel. This data handling must align with the franchise agreement, relevant laws, and established standards. Furthermore, franchisees must adhere to all standards concerning the use of Guest Personal Data for direct marketing purposes.
To ensure compliance, Delta Hotels By Marriott franchisees must ensure that all hotel personnel with access to Guest Personal Data complete the necessary training as required by the established standards. Franchisees are also responsible for complying with standards related to revoking or disabling access to Guest Personal Data for personnel whose employment or service has been terminated. This stringent control over Guest Personal Data underscores the importance Delta Hotels By Marriott places on data protection and privacy.