What are the Even Hotels franchisee's obligations regarding user consent and notification related to data collection and use by both the franchisee and AT&T?

According to Even Hotels' 2025 Franchise Disclosure Document, franchisees are responsible for obtaining consent from and providing notice to their users, employees, and agents regarding the collection and use of their information by both the franchisee and AT&T in connection with the services provided. This means that franchisees must ensure they have the appropriate legal authority to collect and share personal data with AT&T.

This obligation highlights the importance of data privacy compliance for Even Hotels franchisees. They must understand and adhere to all applicable privacy laws and regulations. This includes informing individuals about the types of data collected, how it will be used, and with whom it will be shared. Franchisees should implement clear and transparent privacy policies and procedures to ensure they meet these requirements.

Furthermore, franchisees should be aware that AT&T also has its own responsibilities regarding data protection. AT&T is required to protect personal data in accordance with applicable data protection laws and regulations. However, if a franchisee has concerns about AT&T's access to certain data, they are advised to encrypt the data to make it unintelligible to AT&T. This adds an extra layer of security and control over sensitive information.

In practice, this means that Even Hotels franchisees need to proactively manage data privacy and security. They should consult with legal counsel to ensure their data collection and usage practices comply with all applicable laws. They should also train their employees on data privacy policies and procedures. By taking these steps, franchisees can protect themselves from potential legal and reputational risks associated with data breaches or privacy violations.