Privacy Policy

Effective Date March 6, 2024

These websites are provided by Hospitality Services, Inc. d/b/a Coyle Hospitality Group (Coyle) for several different purposes in addition to promotion, including (i) provision of Coyle’s services to clients and (ii) management of evaluators and their work product.

By visiting these websites, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree please do not use or access our services. This Privacy Policy describes the information we collect about you and what may happen to that information. By accepting the Privacy Policy, you expressly consent to our use and disclosure of your personally identifiable information as described in this Privacy Policy.

If you choose to use Coyle’s services, we may require you to provide certain Personal Information.

For the purposes of our policy, we use the following definition:

“Personal Information” (PI) is any information that can be used to uniquely identify, contact, or locate a single person or that can be used with other sources to identify an individual. This includes but is not limited to: name, address, Phone number, E-mail address, race, nationality, ethnicity, origin, religious or political beliefs, age, gender, family status, etc.

The subject-matter of the collection, processing and/or use of personal data covers various categories of data, such as:

• Personal master data
• Contact details (names, e-mail addresses, addresses, phone numbers,)
• Demographic and profile details
• Contract master data (contractual relationship)
• Performance metrics and history
• Customer history
• Billing and Payment data (tax ID numbers, bank account numbers)
• Media files and information from media files
• Results from mystery shopping, mystery calling, mystery mailing and other marketing, service evaluation, market research and data collection and reporting projects

This information is collected for the purpose of market research and facilitation of customer experience evaluations.

The personal data processed concern various categories of data subjects, such as:

• Customers/Clients
• Employees
• Suppliers
• Contacts
• Independent contractors, such as mystery shoppers/callers/mailers/market researchers etc. and the subjects of such projects

Where possible, we indicate which information is required and which information is optional. You always have the option to not provide information by choosing not to use a particular service or feature.

We use your information to improve your experience using the Coyle website and to facilitate our services for our clients. We use information in the file we maintain about you, and other information we obtain from your current and past activities on the site, to resolve disputes, troubleshoot problems and enforce our User Agreement.

Coyle complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Coyle has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  [INSERT your organization name] has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Coyle is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission (FTC).

Coyle may use third-party vendors to provide support in the delivery of our services and payments. We may also use third-party vendors for data verification and anti-fraud purposes. A list of these companies is available upon request. The vendors used include:  validation support (editors), scheduling services, credit card processing, professional services such as accounting, financial and legal, data processing and email. The vendors are collecting PI as defined by this policy and including contact details (names, e-mail addresses, addresses, phone numbers), demographic and profile details, customer history, billing and payment data (tax ID numbers, bank account numbers), media files and their information, and market research/mystery shopping data.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request limiting the use and disclosure of your personal information, please submit a written request to privacy@coylehospitality.com.

The following information describes the principles that Coyle (including “the Company”, “we”, or “us”) follows while managing your Personal Information (“PI”):

• Notice – If we collect any PI from you directly, we will inform you of the purpose for which we collect and use Personal Information. The company must have the agreement of the individual for any disclosure or use of PI for a purpose other than for which it was originally collected. Prior to disclosing PI to non-agent third parties, the individual will be notified and presented with a choice and means (an “opt out” option) for limiting the disclosure of the PI. An exception is government and law enforcing agencies in cases where we are required by law to provide such information, including without notice.
• Choice – We will provide the opportunity to choose (i.e.: to opt out) whether the individual’s PI may be disclosed to non-agent third parties or be used for a purpose other than for which it was originally collected. This is accomplished using the means provided in the notice, or by contacting us directly at info@coylehospitality.com or by using the contact information provided below.
• Accountability for Onward Transfer – We will ensure that any agent third party to which PI may be disclosed subscribes to the same principles for managing PI and agrees in writing to provide an adequate level of privacy protection. Coyle’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. Coyle remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Data Privacy Framework Principles, unless Coyle proves that it is not responsible for the event giving rise to the damage. Also note that we may be required to disclose an individual’s personal data in response to a lawful request by governmental authorities including to meet national security and law enforcement requirements.
• Security – We will take reasonable steps to protect PI from loss, misuse and unauthorized access, disclosure, alteration, and destruction. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure PI from loss, misuse, unauthorized access or disclosure, alteration, or destruction. We cannot guarantee the security of PI on or transmitted via the Internet.
• Relevance – We shall collect only as much PI as needed in order to conduct specific, identified activities related to our business.
• Retention – We shall keep individuals’ PI only as long as needed for the purposes for which it was originally collected, or as permitted by law.
• Data Integrity and Purpose Limitation – We shall only process PI in a way that is compatible with, and relevant to, the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, we shall take reasonable steps to ensure that PI is accurate, complete, current, and reliable for its intended use.
• Access – Pursuant to the Data Privacy Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you, except where the burden or expense of providing such access would be disproportionate to the risks of the privacy of the specific individual in the case in question, or where the rights of persons other than the specific individual would be violated. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the Data Privacy Frameworks, should direct their query to privacy@coylehospitality.com. Individuals wishing to access their PII may do so by logging on to the website where they registered. End users who wish to access the personal data that Coyle hosts on behalf of our company clients, or to make choices concerning their data, are invited to contact the company client directly. If requested to remove data, we will respond within a reasonable timeframe.
• Recourse, Enforcement and Liability – We use a self-assessment approach to assure compliance with this Privacy Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, accessible, and in conformity with its principles. We encourage interested persons to raise any concerns using the contact information provided, and we will investigate and attempt to resolve any complaints or disputes regarding use and disclosure of PI in accordance with our principles outlined above. To ask questions about our privacy policy, or to make a complaint, contact us at:

  Coyle Hospitality Group
  244 Madison Ave #369
  New York, NY 10016
  info@coylehospitality.com
  +1(212-629-2083)

If individuals have any questions or complaints concerning our processing of personal data on behalf of our company clients, they are invited to contact the company client directly, or they may contact us at info@coylehospitality.com. In compliance with the Data Privacy Framework Principles, Coyle commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Data Privacy Frameworks. European Union, United Kingdom, and Swiss individuals with DPF inquiries or complaints should first contact Coyle by email at privacy@coylehospitality.com

Coyle has further committed to refer unresolved privacy complaints under the Data Privacy Framework Principles to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf