RSC MANAGEMENT SERVICES PRIVACY STATEMENT
Last Updated: April 23, 2018
This privacy statement (“Statement”) applies to Pasta Resources Inc. (“we” or “us”), its subsidiaries, including:
and www.tarrylodge.com (each an “RSC MANAGEMENT SERVICES Website”).
At RSC MANAGEMENT SERVICES, we strive to deliver outstanding products, services, and experiences around the world. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, when you visit one of our restaurants, or from other sources. While this Statement broadly describes the practices we have adopted across RSC MANAGEMENT SERVICES, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require affirmative consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements. If you are a resident of the European Economic Area (EEA), please see the section “European Visitors” of this Statement regarding RSC MANAGEMENT SERVICES’s use of your personal information.
In general, by using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement. In some situation, applicable laws may require specific methods for soliciting consent, in such we will follow the applicable laws.
Please note that this Statement does not apply to our processing of personal information on behalf of and subject to other data controllers such as other booking websites (e.g., OpenTable.com, Groupon.com, etc), marketing partners, or corporate customers.
This Statement includes the following sections:
- Personal Information We Collect
- Use of Personal Information Collected About You
- Personal Information We Share
- Automated Collections
- Sensitive Information
- Personal Information From Children
- Links to Third-Party Websites and Services
- Protecting Personal Information
- International Transfers of Personal Information
- Changing and Accessing Your Personal Information
- Retaining Personal Information
- Choices – Marketing Communications
- Statement Modifications
- Contact Us
- European Visitors
PERSONAL INFORMATION WE COLLECT
We collect personal information at every touch point or guest interaction, and in conducting every aspect of our business, we may collect personal information. This personal information may include: your name, mailing address, billing address, email address, phone number, information related to your reservation, visit to a property; participation in a membership program; participation in a contest, sweepstakes, or marketing program (even if you do not visit at one of our restaurants); information related to the purchase and receipt of products or services; personal dining preferences; dates of special occasions; payment information, such as your payment card number and other card information, as well as authentication information and other billing and account details associated with mobile billing; marketing and communication preferences; information about vehicles you may bring onto our properties; reviews and opinions about our products and services; groups with which you are associated for visits at restaurants; information provided on membership and account applications; and other types of information that you choose to provide to us or that we may obtain about you.
We may also collect information related to conversations, including recording or monitoring customer service calls for quality assurance and training purposes, and other communications such as in-app messages and SMS.
In addition, we collect other personal information in certain cases, such as:
- Surveys: We may request demographic data or other personal information in customer surveys.
- Event Profiles: If you plan an event with us, we collect meeting and event specifications, the date of the event, number of guests, and, for corporate events, information on your organization (name, annual budget, and number of sponsored events per year). We also collect information about the guests that are a part of your group or event. If you visit us as part of a group, we may have personal information about you provided to us by the group and may market to you as a result of your visit with a group or attendance at an event in accordance with your preferences as permitted by law. If you visit us as part of an event, we may share personal information about you with the event planners, as permitted by law. If you are an event planner we may also share information about your event with third-party service providers who may market event services to you as permitted by law.
- Social Media: If you choose to participate in RSC MANAGEMENT SERVICES-sponsored social media activities or offerings, we may collect certain information from your social media account consistent with your settings within the social media service, such as locations, activities, interests, photos, status updates and friend list. We may also allow you to enter into contests to provide photos, such as of your visit with us, which you may share with your connections on social media for votes, shared offers or other promotions.
- Recommending a Friend: From time to time, we may offer products or services that allow you to send an electronic postcard or otherwise share a message with a friend, whether via the Internet, a stand-alone kiosk or mobile device. If you choose to use this feature, we will ask you for the recipient’s name and email address, along with the text of any message you choose to include. By using this feature, you represent that you are entitled to use and provide us with the recipient’s name and email address for this purpose.
- Franchise and Ownership Opportunities: If you are interested in obtaining more information about franchise or ownership opportunities, we may collect information about you in order to assess your suitability to become a franchisee or owner. We may combine the information you provide to us with information we obtain from third parties, such as credit reporting agencies and public records databases. We use this information to conduct due diligence on potential franchisees and owners.
In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from Other Information we collect.
USE OF PERSONAL INFORMATION COLLECTED ABOUT YOU
We use your personal information in a number of ways, including to provide and personalize the services you request and expect from RSC MANAGEMENT SERVICES, to offer you the expected level of hospitality throughout our restaurants, conduct direct marketing and sales promotions and as set forth below in more detail. We will collect your consent prior to processing your data where required by applicable law.
We may collect certain data, including your name, address, payment information, and, in certain countries, travel document information, in order to process your reservation.
- Service Administration: We use your personal information to administer programs in which you participate, including providing you with access to your account information, such as rewards status and offers for which you are eligible; to fulfil services that are part of such program; to enable direct communication between you and us; and to facilitate collections.
- Meeting and Event Planning: We may use your personal information to provide you with information about meeting and event planning.
- Marketing and Communications: Where permitted we may use your personal information to provide or offer you newsletters, promotions and featured specials, as well as other marketing messages in accordance with any communications preferences you have expressed. We use your information to provide in-visit messaging, account alerts, and reservation confirmations; to send you marketing messages; and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means (including on-property messaging, such as your in-room television). With your consent, we also use user-generated content (such as photos) from social media services to deliver display advertising or on our website and apps.
- Transactions: We may collect information from your payment card, which can be appended to personal information and used by RSC MANAGEMENT SERVICES. or its business partners to recognize what type of card you have. We may also partner with third parties to learn whether a visitor to our site has a cash-back offer associated with their payment card and to deliver the visitor advertising and information that explains how to take advantage of that offer through a visit at a restaurant of RSC MANAGEMENT SERVICES.
- Service Improvements: We may use your personal information to improve PASTA RESOURCES INC.’s services and to ensure that our site, products, and services are of interest to you. We also use your personal information to provide you with the expected level of dining experience throughout our properties.
- Data Correctness, Analytics and Personalization: We may aggregate your personal information with data from third-party sources for purposes of keeping information up to date and analytics. We also rely on information from third parties in order to provide better, more personalized service. For example, if you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal and social, or share and use it as described elsewhere in this Statement.
PERSONAL INFORMATION WE SHARE
In order to offer you the expected level of dining experience and to provide you with the best level of service, we may share your personal information among members of the RSC MANAGEMENT SERVICES, our service providers, and other third parties as set forth in detail below:
- RSC MANAGEMENT SERVICES, Including Franchised Restaurants, Managed Restaurants, Timeshare and Fractional Resorts: We may share personal information within the RSC MANAGEMENT SERVICES, as well as with owners and operators of franchised restaurants, owners of restaurants that we manage but do not own. In addition, when we cease managing a restaurant that we do not own or end a franchise relationship, we may provide the restaurant’s owner with certain information about past or future guests of that restaurant.
- Electronic Billing: If you receive an invoice by email, a summary detailing the goods and services provided to you during your visit will be shared with the payment card provider and, if you participate in a corporate billing program and use a corporate payment card, the payment card provider may share that summary with your employer. Additionally, if you participate in a special rate plan, we may share lists of RSC MANAGEMENT SERVICES membership numbers that used the plan with the entity that provided the special rate plan to you. The privacy policies of your employer, the relevant payment card provider and card issuer apply once we have transferred your information.
- Group Events or Meetings: If you visit RSC MANAGEMENT SERVICES as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
- Business Partners: We may partner with other companies to provide you with products, services, or offers based upon your experiences at our properties and may share your information with our business partners accordingly. We may also work with third parties to allow us and our partners to deliver advertisements to our shared customers. Our partners may be able to provide more relevant offers to you based upon information that we share about your experiences at our properties, as well as information in your RSC MANAGEMENT SERVICES profile. We may share a hashed version of your email address with third parties using available security measures that may match it with their own hashed versions of email addresses so that they can send online and email advertisements to you on our behalf.
- Co-Sponsors of Promotions: We co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, and we provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.
- Service Providers: We rely on third parties to provide services and products on our behalf and may share your personal information with them as appropriate. Generally, our service providers are contractually obligated to protect your personal information and may not otherwise use or share your personal information, except as may be required by law. However, our fraud detection service providers may use, but not share, your personal information for fraud detection purposes. We may use service providers to communicate news and deliver promotional and transactional materials to you on our behalf, including personalized online and mobile advertising in accordance with your preferences and applicable law. RSC MANAGEMENT SERVICES will only work with parties that offer a method to opt-out of such advertising. We may also share information with service providers to allow you to create itineraries by selecting sites, activities, and restaurants from lists that we have personalized for you based on your preferences and third-party data.
- Business Transactions: As we develop our business, we might sell, buy, restructure or reorganize businesses or assets, or cease being the manager or franchisor of a restaurant that is currently part of our portfolio. In such circumstances, RSC MANAGEMENT SERVICES may transfer, sell or assign information collected, including, without limitation, Other Information (described below) and personal information, to one or more affiliated or unaffiliated third parties in connection with these business transactions. To the extent that local laws require it, we will provide notice of our intent to transfer personal data to a third party for this purpose, and explain how you can object to such transfer.
- Telemarketing: If you visit at one of our restaurants, we may share your telephone number among the RSC MANAGEMENT SERVICES for purposes of telemarketing in accordance with your preferences and applicable law. We may also receive your telephone number from our partners or from other sources, which we may use for telemarketing purposes.
- Other: In addition, RSC MANAGEMENT SERVICES may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of RSC MANAGEMENT SERVICES, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites’ terms and conditions, and (vii) respond to an emergency.
When you visit the websites operated by RSC MANAGEMENT SERVICES, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on this site, dates and times of visits to this site and other usage statistics. A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and is used to transmit information collected through cookies back to a web server. Through these automated collection methods, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website. As the visitor clicks through the website, a record of the action may be collected and stored. We link certain data elements we have collected through automated means, such as your browser information, with other information we have obtained about you to let us know, for example, whether you have opened an email we sent to you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of this site. To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.
The providers of third-party apps, tools, widgets and plug-ins on this site, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. Subject to applicable law, RSC MANAGEMENT SERVICES is not responsible for these providers’ information practices.
The term “sensitive information” refers to information related to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life, or sexual orientation, genetic information, criminal background, and any biometric data used for the purpose of unique identification. In some jurisdictions, mobile phone numbers, location data, and information contained on identity documents also are considered sensitive information.
We do not generally collect sensitive information unless it is volunteered by you or unless we are required to do so pursuant to applicable laws or regulations. We may use health data provided by you to serve you better and meet your particular diet needs.
PERSONAL INFORMATION FROM CHILDREN
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.
LINKS TO THIRD-PARTY WEBSITES AND SERVICES
PROTECTING PERSONAL INFORMATION
RSC MANAGEMENT SERVICES will take reasonable measures to: (i) protect personal information from unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date as appropriate. RSC MANAGEMENT SERVICES employs a robust internal team of dedicated information security professionals who are responsible for creating, updating and managing RSC MANAGEMENT SERVICES’s security program.
We also seek to require our affiliates and service providers with whom we share personal information to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use reasonable technological measures to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.
For your own privacy protection, please do not send payment card numbers or any other confidential personal information to us via email.
We will not contact you by mobile/text messaging or email to ask for your confidential personal information or payment card details. We will only ask for payment card details by telephone when you are booking a reservation or promotional package.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We may share your personal information among members of the RSC MANAGEMENT SERVICES, our service providers, and other third parties, which may be located in countries outside of your own. When you visit at an RSC MANAGEMENT SERVICES property outside the United States, the data controller for that property transfers the personal information relating to your reservation to RSC MANAGEMENT SERVICES in the United States pursuant to data transfer agreements when required by applicable laws or regulations. The data controller may also maintain a local copy of your personal information when so required by applicable laws or regulations. Although the data protection laws of various countries may differ from those in your own country, we will take appropriate steps to ensure that your personal information is handled as described in this Statement and in accordance with the law.
CHANGING AND ACCESSING YOUR PERSONAL INFORMATION
To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, withdraw your consent for certain data processing activity and/or request that we update, correct, delete, and/or stop processing your personal information. We will make all required updates and changes within the time specified by applicable law and as required by law. When permitted by law, we may charge an appropriate fee to cover the costs of responding to the request. Such requests may be submitted to firstname.lastname@example.org.
In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that RSC MANAGEMENT SERVICES. cease using personal information about you by contacting us using the email or mailing address above. We will seek to honor those requests consistently with applicable law.
RETAINING PERSONAL INFORMATION
We retain personal information about you for the period necessary to fulfill the purposes outlined in this Statement, unless a longer retention period is required or permitted by applicable law. We retain personal information collected in order to fulfill guest reservations for seven years after the visit is completed. We retain other personal information for shorter periods of time if possible and if permitted by law.
We will destroy your personal information as early as practicable and in a way that the information may not be restored or reconstructed.
If printed on paper, the personal information will be destroyed in a secure manner, such as by cross-shredding or incinerating the paper documents or otherwise and, if saved in electronic form, the personal information will be destroyed by technical means to ensure the information may not be restored or reconstructed at a later time.
CHOICES – MARKETING COMMUNICATIONS
If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you in accordance with any preferences you have expressed, and with your consent where required, about our products and services or invite you to events via email, online advertising, social media, WeChat, WhatsApp, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, our customer service call center, and other means (including on-property messaging, such as your in-room television).
If you prefer not to receive email marketing materials from us, you may opt-out at any time by sending a request to email@example.com.
To opt out of text messages, tell the restaurant front desk that you do not want to receive text messages from the restaurant or reply “STOP” to the message you received.
We may modify this Statement from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site, and if you have registered for any of your products or services, will may also inform you though a communications channel that you have provided. You can tell when this Statement was last updated by looking at the link and at the date at the top of the Statement. Any changes to our Statement will become effective upon posting of the revised Statement on the site. Use of the site, any of our products and services, and/or providing consent to the updated Statement following such changes constitutes your acceptance of the revised Statement then in effect.
If you have any questions about this Statement or how RSC MANAGEMENT SERVICES processes your personal information, or if you wish to either provide a compliment or a complaint, please contact us
RSC MANAGEMENT SERVICES
45 E. 20th Street, 3rd Floor
New York, NY 10003
Attention: Missy Adriazola
By telephone: (212) 397-2471
By email: firstname.lastname@example.org
For individuals residing in the EEA, this section outlines certain additional information that PASTA RESOURCES INC. is obligated to provide to you, as well as certain rights you have, pursuant to General Data Protection Regulation (GDPR). This section will control to the extent it conflicts with any provision in the main body of this Statement.
The legal bases for PASTA RESOURCES INC.’s processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent.
The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:
- Surveys: Completion of surveys is voluntary – we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.
- Event Profiles: We process the personal information obtained in connection with your event on the basis of our contractual relationship with you and for our business interests, including for marketing, service improvements, and analytics and service personalization.
- Social Media: Participation in PASTA RESOURCES INC.-sponsored social media activities and offerings is voluntary – we process information obtained from social media participation on the basis of your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization.
- Promotions and Sweepstakes: Participation in sweepstakes, contests and other promotional offerings is voluntary – we process the information obtained from such participation based on your consent and as necessary to administer the offering. We also use certain data for our business purposes, including for marketing, service improvements, administration of our e-Folio program, and analytics and service personalization.
- Direct Marketing: We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at email@example.com or by following the unsubscribe instructions in the marketing message.
- Franchise and Ownership Opportunities: We process this information on the basis of our contractual relationship with you and for our related business interests, including maintaining and promoting the PASTA RESOURCES INC. brand and facilitating direct communication between properties within the PASTA RESOURCES INC. Hospitality Group.
Retention: We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.
Data Subject Rights: Residents of the EEA have the following rights:
Access, Correction and Erasure Requests: You have the right to:
- ask us to confirm whether we are processing your personal information
- receive information on how your data is processed
- obtain a copy of your personal information
- request that we update or correct your personal information
- request that we delete personal information in certain circumstances
Right to Object to Processing: You have the right to request that PASTA RESOURCES INC. cease processing of your personal information:
- for marketing activities, including profiling
- for statistical purposes
- where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim
Right to Restrict Processing: You have the right to request that PASTA RESOURCES INC. limit the processing of your personal information:
- while PASTA RESOURCES INC. is evaluating or in the process of responding to a request by you to update or correct your personal information
- where such processing is unlawful and you do not want PASTA RESOURCES INC. to delete your data
- where PASTA RESOURCES INC. no longer requires such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim
- where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.
Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account).
Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
Submitting Requests: your requests may be submitted
PASTA RESOURCES INC. Hospitality Group 45 E. 20th Street, 3rd Floor
New York, NY 10003
Attention: Kate Greenberg
By telephone: (212) 397-2471
By email: firstname.lastname@example.org
We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.
International Data Transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection. In particular, we transfer your personal information to the United States.