In the context of the Even Hotels franchise agreement, what is the meaning of 'Eligible Participant Personal Data'?
Even_Hotels Franchise · 2025 FDDAnswer from 2025 FDD Document
This Managed Fortinet Participation Agreement ("Participation Agreement"), effective as of [INSERT DATE] ("Effective Date"), is entered into by and between AT&T Corp. ("AT&T") and [INSERT OWNER'S LEGAL ENTITY NAME] d/b/a [INSERT NAME OF HOTEL] located at [INSERT ADDRESS OF HOTEL] (the "Eligible Participant"). This Participation Agreement is entered into pursuant to the certain Master Agreement Ref. No. 101513UA dated 11/26/2003, as maybe amended, (the "Customer Agreement") between AT&T and IHG ("Customer").
Source: Item 23 — RECEIPTS (FDD pages 99–438)
What This Means (2025 FDD)
Based on the 2025 Even Hotels Franchise Disclosure Document, the term 'Eligible Participant Personal Data' is not explicitly defined within the provided Item 23 excerpts. However, there is a reference to an 'Eligible Participant' in the context of a Managed Fortinet Participation Agreement between AT&T and the hotel owner. This agreement allows the Eligible Participant (the hotel) to purchase certain services under a Customer Agreement between AT&T and IHG.
Given the absence of a direct definition, it's reasonable to infer that 'Eligible Participant Personal Data' would refer to the personal data collected or processed by the 'Eligible Participant' (i.e., the Even Hotels franchisee) in the course of their participation in the aforementioned AT&T agreement. This could include data necessary for AT&T to provide services to the hotel, such as contact information for hotel staff or data related to the hotel's network configuration. The FDD excerpts do define related terms such as "Personal Data", "Excluded Personal Data", "Hotel Personal Data", "IHG Personal Data", and "Licensee Personal Data", which provide context for understanding how personal data is generally handled within the Even Hotels system.
To fully understand the scope and implications of 'Eligible Participant Personal Data', a prospective Even Hotels franchisee should seek clarification from the franchisor regarding the specific types of personal data involved, how that data is used and protected under the AT&T agreement, and what obligations the franchisee has in relation to that data. Understanding the data flow and security measures associated with this agreement is crucial for ensuring compliance with privacy laws and protecting guest information.