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
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. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Coyle has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.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.
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. We may be liable for the appropriate transfer of personal data to agent third parties. 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 – We acknowledge the right of EU and Swiss individuals to access their personal data that is collected under the Privacy Shield and will allow an individual access to his or her PI. We will allow the individual to correct, amend, or delete inaccurate information, 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. 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.
- 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 EU-US and Swiss-US Privacy Shield Principles, Coyle commits to promptly resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Coyle at the address above.
Coyle has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield 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 Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Rev. 9-28-2023
