Where are the privacy and data protection terms stated for Additional Required Services for Even Hotels?
Even_Hotels Franchise · 2025 FDDAnswer from 2025 FDD Document
The Parties will comply with the privacy and data protection terms set forth on Attachment 2 (Privacy and Data Protection Terms), attached hereto and incorporated herein.
- 5.5 Hotel's Security Obligations.
Hotel will implement and maintain commercially reasonable and industrystandard measures, safeguards, and other controls to prevent a breach of or unauthorised access to the PMS Solution.
Source: Item 23 — RECEIPTS (FDD pages 99–438)
What This Means (2025 FDD)
According to Even Hotels' 2025 Franchise Disclosure Document, the privacy and data protection terms related to additional required services are detailed in Attachment 2, titled "Privacy and Data Protection Terms." Several sections within Item 23 refer to this attachment, indicating its importance in understanding data handling practices.
Specifically, Section 5.4 of Item 23 states that all parties involved must comply with the privacy and data protection terms outlined in Attachment 2. This attachment is incorporated into the agreement, making it a legally binding component. Furthermore, sections discussing PMS (Property Management System) Data usage by both HotelKey and IHG also reference Attachment 2, emphasizing that the data handling practices must adhere to the terms specified therein.
Attachment 2 defines key terms such as "Personal Data," "Excluded Personal Data," and "Privacy Laws," providing a framework for understanding the scope and limitations of data processing activities. It also clarifies the roles of different parties, such as IHG and the hotel, as either Controllers or Processors of personal data, which determines their respective responsibilities under privacy laws.
Therefore, a prospective Even Hotels franchisee should carefully review Attachment 2 to fully understand their obligations and rights regarding data privacy and protection, especially in relation to any additional services they might utilize. This includes understanding how HotelKey, as a data processor, handles personal data and the measures in place to comply with privacy laws.