What is 'IHG Marketing Data' in the context of an Even Hotels franchise?
Even_Hotels Franchise · 2025 FDDAnswer from 2025 FDD Document
"IHG Marketing Data" means Personal Data in respect of any member of IHG's or its Affiliates' marketing or loyalty rewards program.
"Licensee Personal Data" means any Personal Data (excluding any IHG Marketing Data) that is held and processed locally at the Hotel by Licensee for which Licensee is an independent controller, Licensee employee Personal Data for which Licensee is the sole controller, and Excluded Personal Data for which Licensee is the sole controller, including (i) data contained in the Hotel's property management system and (ii) Personal Data relating to Hotel employees. For the avoidance of any doubt, Licensee Personal Data does not include IHG Marketing Data.
With respect to IHG Marketing Data, Licensee will act as IHG's processor and is prohibited from (x) "selling" or "sharing" it (as defined by Data Privacy Laws), (y) processing it for any purposes other than as expressly permitted by IHG, including any commercial purposes, or outside of
Source: Item 23 — RECEIPTS (FDD pages 99–438)
What This Means (2025 FDD)
According to Even Hotels' 2025 Franchise Disclosure Document, IHG Marketing Data refers to personal data concerning members of IHG's or its affiliates' marketing or loyalty rewards programs. This data is crucial for IHG to effectively manage and operate its loyalty programs, such as IHG One Rewards, and to conduct targeted marketing activities.
For an Even Hotels franchisee, understanding the role and restrictions around IHG Marketing Data is essential. The franchisee acts as IHG's processor for this data and is strictly prohibited from selling or sharing it, or processing it for any purposes other than those expressly permitted by IHG. This includes restrictions on using the data for commercial purposes or outside the specific uses designated by IHG.
The franchisee's responsibilities include adhering to data privacy laws and IHG's data protection requirements. Upon termination of the franchise agreement, the franchisee must remove all IHG Marketing Data from their systems, or IHG has the right to remove it at the franchisee's expense. This ensures that IHG maintains control over its marketing data and that franchisees do not misuse it for their own purposes, which could potentially conflict with IHG's marketing strategies or violate data privacy regulations.