> Employee Privacy Policy

> Notice of Privacy Rights to California Residents

Last Updated: January 8, 2024 

Your privacy is important to Eat.Drink.Sleep. and its affiliates, including Tower23 Hotel, Rambler Motel, Heat Hotel, Padre Hotel and Bellanca Hotel (“EDS”, “we”, “our”, “us”, “Hotel”, “Property”). This Privacy Policy describes how and why EDS collects, uses and/or shares personal information about you and your choices and options about the way your information is handled, including how you can update, manage, export and/or delete your information. We use your personal information in order to fulfill our commitment to providing an unparalleled guest service experience in connection with all your interactions with us. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather. 

This Privacy Policy applies to personal information regarding guests and the other individuals with whom we do business or who visit us and to the use of that personal information in any form – whether oral, electronic, or written. We collect information that you voluntarily provide in order for us to provide services, process reservations, and provide customer care. We may also use this information for other business purposes, such as to better understand our guests or make appropriate marketing offers. This Privacy Policy has been adopted by us and the separate and distinct legal entities that manage, operate and/or own our hotels, including but not limited to, EDS. We may occasionally update this Privacy Policy, but we will always update it at least once a year. If we make significant changes to this Privacy Policy, we will notify you by revising the date at the top of this Privacy Policy and such changes will become effective upon publication on our websites. We may also provide you with additional notice, such as an email notification. 

The term “personal information” in this Privacy Policy refers to information that does or is capable of identifying you as an individual. The types of personal information that we process (which may vary by jurisdiction based on applicable law) include: 

  • Contact Information: your first and last name, gender, shipping address, email address, phone number, personal and/or work contact details, business title, date of birth image, nationality, and passport and visa information; 
  • Guest Stay Information:  hotels where you have stayed, dates of arrival and departure, goods and services utilized, special requests made by you, and observations about your service preferences;  
  • Other Guest Stay Information: any information necessary to fulfill special requests (e.g. health conditions that require specific accommodation or services); 
  • Other Identifying Information: social media user names, IP address, commerce ID, order ID passwords and other security information for authentication and access; 
  • Preference Information: preferences including information about the types of events and products you prefer, including information, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites; 
  • Commercial Information: information collected while at a Hotel through the use of television systems, internet systems (including wireless networks that collect data about your computer, smart or mobile device), card key and other security and technology systems, including video data via security cameras we use at some locations; 
  • Internet or Other Electronic Activity: information related to your browsing history, product or service purchases, communications with customer care teams, browser type and version, time zone settings, geolocation information about where you might be, operating system and version and other information about how you navigate within our services and which elements of our services you use the most; 
  • Other Commercial Information: contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g. travel agents or meeting and event planners); 
  • Employment Information: employment status or history, including your professional information, identifiers and educational information. 
    Financial/Payment Information: name, card type and issuer, card numbers, expiration dates, CVV code, and/or billing contact information; 
  • Inferences: inferences drawn from the categories described herein in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude; and 
  • Sensitive Personal Information: in certain circumstances, we collect sensitive personal information, including precise geolocation data indicated by your mobile device or computer, passport and visa information, driver’s license, state identification card or your account log-in in combination with any security access code or password. 


You have the choice to decline to provide the requested information. However, declining to provide certain information may impact the services that we can provide you. For instance, Hotel cannot make a reservation without a name. 


We collect personal information directly from you, as well as from third parties, including: 

  • Making Reservations: When you make a reservation we will request your name, address, phone number, email address information along with other information to assist with your reservation and stay such as credit card number, date of arrival/departure, and room preferences. 
  • Requests for Information: When you request additional information related to our services or properties, we may request your name and contact information such as a street address, phone number, and email address.  
  • Email Offers Sign-Up: If you are interested in receiving special offers via email, we require that you provide your first name and email address. You may also provide additional information such as your city of residence, birthday, or interests, to help us tailor our special offers. 
  • Request for Proposal: Meetings, Events and Weddings: If you are interested in obtaining more information about meeting and event planning, we may request your name and contact information such as street address, phone number, and email address. 
  • Contacting Us by Email with Questions or Comments: When you send us an email from one of our sites, we may retain information such as the content, your email address, our response, and the text of any follow-up questions you may have. We may use this information, for example, to measure how effectively we address customer concerns online, to personalize your experience, and to continuously improve our service to you. 
  • Property Visits: Personal data is collected when guests use on-property services, such as concierge services, restaurants and spa services.  
    Connect or post to social media accounts connected to the property. 
  • Third Parties: We collect your personal information from third parties, such as social media sites, vendors and business partners. We may collect your identifying information such as your name, email, age, gender, and location, in accordance with the third parties’ terms of use and privacy policies. We may also receive demographic information about you from third party data sources to make sour service and marketing efforts more efficient and personalized for you. We may also receive legal information from third parties such as fraud checks or issues raised about your transactions, payment card refusals, suspected crimes, complaints or claims. 
  • Cookies and similar technology:  

Cookies and Similar Technology: 

We use cookie technology on our websites to allow us to evaluate and improve the functionality of our websites. Cookies by themselves cannot be used to reveal your identity. They identify your browser, but not you, to our servers when you visit our websites. For example, we may collect information such as your browser type, operating system type or mobile device model, viewed webpages, links that are clicked, IP address, mobile device identifier or other unique identifier, websites visited before coming to our website, the amount of time you spend viewing or using our website, the number of times you return or other click-stream or site usage. Visitors to the sites who accept cookies may be presented with targeted messages, offers and ads on the site and via email that we believe would be of value, based on observed preferences. If you have registered as a member of the sites and accept cookies, we can tailor your use to your personal preferences, and it is easier and faster to take advantage of the site’s benefits. If you have submitted your email address, you may receive targeted messages we believe you will find of value. Remember, you may request to be removed from your email subscription lists. An unsubscribe link is included in all promotional emails.  
Your Choice to Accept or Deny Cookies: 

If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. Keep in mind that your choice to accept or deny a cookie is different from your choice to accept/deny email messages and disabling cookies may disable some features of the website. 

We may derive personal information or draw inferences about you based on the other types of personal information we collect. We may infer from your location based on your IP address or otherwise that you may be interested in staying at a certain type of hotel based on your browsing behavior or history. 

We do not sell personal information to third parties and have not done so in the previous 12 months. However, where disclosure of personal information is necessary to satisfy the purpose, or a directly related purpose, for which the personal information was collected, we may share personal information with the following:  

Owners: We disclose personal information and other information to Owners of our hotels.  
Business Partners: We disclose personal information with select business partners who provide goods, services and offers to enhance your stay or that we believe are of interest to you. For example, if you purchase a package that includes transportation and accommodations, we may disclose your information to the transportation provider.  

Service Providers: We disclose personal information to third-party service providers, including vendors, consultants, and contractors who access personal information to carry out work or services on our behalf and improve the products or services they provide to us. Examples of service providers include email delivery services and website hosting services, cloud storage providers, research partners, attorneys, accountants and other professional service providers, insurance and financing partners, restaurant/spa partners, shipping and delivery, payment processing, fraud prevention customer service, analytics, marketing and advertising, among others. We rely on service providers to help us deliver products and services, such as providing services in connection with our websites including reservations or communicating news and delivering promotional materials via email and direct mail, processing credit card transactions, and administering surveys. 

We will use personal information to comply with applicable laws, legal process, enforce terms and conditions among other reasons we believe to be necessary and appropriate. We will also share your personal information with your consent or at your direction. 

Subject to applicable laws, we may collect, use and disclose relevant portions of your personal information so that we can operate effectively and provide you with the best experience. We also use the information we collect for the following purposes: 

  • Provide, maintain, improve and charge for hotel accommodations and other goods and services; 
  • Provide you with a better or more personalized level of service, including information and services from a third party (such as local attractions and transportation options); 
  • Respond to comments, questions and requests for information and services, including services from a third party (such as restaurants or transportation providers); 
  • Administer the Hotel frequent guest program; 
  • Process your orders, payments and account adjustments and initiate, render, bill and collect payments for our products and services; 
  • Fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organizers or your employer) and vendors (e.g. credit card companies and third party loyalty programs); 
  • Conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions, including communicating to you about products, services, offers, promotions and events. You can manage these communications per the below Your Choices section; 
  • Provide for the safety and security of staff, guests and other visitors, including protecting against and preventing security incidents and illegal or unauthorized activities, investigate complaints and claims and provide other security protections such as identity verification; 
    Administer general record keeping; 
  • Meet legal and regulatory requirements, including cooperating with law enforcement and protecting the rights (including free speech), interests, safety or property of Hotel or our customers, service providers and other third parties; 
  • Manage your online account(s) and send you technical notices, updates, security alerts and support and administrative messages; 
  • Personalize your experience and provide advertisements, content or features that may match your profile and interests , including monitoring and analyzing trends, usage and activities; 
  • Test and evaluate new products and services and process credit applications (for example in the context of setting up a credit line for a corporate account); and 
  • Carry out any other purpose directly related to the purpose readily apparent to you or described to you at the time the personal information was originally collected. 


To the extent permissible by applicable law, we will retain your personal information for such period as necessary to satisfy or to fulfill the following: 

  • The purpose for which that personal information was provided; 
  • A specific legal or regulatory requirement. For example, we mat retain certain transaction details and communications until the time limit for claims arising from the transaction has expired; 
  • An identifiable and ongoing business need, including tax or record-keeping purposes; and 
  • A requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings. 
  • When we destroy your personal information, we do so in a way that prevents the information from being restored or reconstructed. 


We do not knowingly collect the personal information from children who are under the age of 16 without prior consent from such child’s parent or guardian. We do not have actual knowledge about selling or sharing personal information of consumers under the age of 16. 


If you decide to make an online reservation at the Site, you will be linked to a reservation interface and a third party booking engine (“Booking Engine”). While it appears to be part of our site, the Booking Engine is in fact provided by a third party (“Booking Engine Vendor”) and is governed by its own, separate privacy practices. We understand that security remains the primary concern of online consumers and we have chosen the Booking Engine Vendor after carefully reviewing the vendor’s privacy and security policies carefully. The Booking Engine Vendor and all information sent to this site is in a Secured Socket Layer (SSL), is encrypted, protecting against disclosure to third parties. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. 


To prevent loss, destruction, unauthorized access or alteration, to maintain data accuracy, and to ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. However, we cannot guarantee that security of all communications with or information submitted to our websites. We would like our Site visitors to feel confident about using the Site to plan and purchase their accommodations, so Hotel is committed to protecting the information we collect. Hotel has implemented a security program with its web design and maintenance firm to keep information that is stored in our systems protected from unauthorized access. 

Our websites may contain links to other websites that are operated by third parties. We are not responsible for the privacy practices of these third parties and do not have control over the content of the linked websites or how they deal with your personal information. You should review the privacy policy for such third party websites to understand how your personal information may be used by them. 

Promotional Communications: You may opt out of receiving promotional communications from us at any time. We only send you communications that we believe you would want to receive in order to keep you informed of events offered or arranged by us or third parties. We will not use your personal information for such purposes unless we have received your consent. You can opt out of receiving promotional communications from us at any time by either following the instructions provided in those communications.  

If you reside in California, you also have specific rights pursuant to the California Consumer Privacy Act (and as amended via the California Privacy Rights Act), which is governed by Civil Code section 1798.100, et seq. You have the right to know what personal information we collect, use, share, disclose and/or sell, the right to request that we delete personal information collected from you (with some exceptions), the right to opt out of the sale or sharing of personal information, the right to correct inaccurate personal information, and the right to limit the use and disclosure of sensitive personal information. As is the case for all consumers regardless of residency, we will not discriminate against you for exercising any of these rights. 

California residents can exercise these access, deletion and/or correction rights by making a verifiable consumer request by clicking here or by calling +1 (866) I-OPT-OUT or +1 (866) 467-8688, Service Code 1791. You may make a verifiable consumer request no more than two times within a 12-month period. The verifiable consumer request must: 

Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information. Such verification process will involve you confirming at least three pieces of personal information we have collected about you.  For example, your telephone number, email address or mailing address; and 

Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. 
We will take reasonable steps to verify your identity prior to responding to your request. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record-keeping purposes, to maintain an active account and/or to process transactions and facilitate consumer requests. California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent and ensure the agent has the necessary information to complete the verification process. When required, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time, which will be communicated to you within 45 days from your request. 

If you reside in California, pursuant to Civil Code section 1798.83, you also have the right to ask us one time each calendar year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please communicate to us using the email here or by calling +1 (866) I-OPT-OUT or +1 (866) 467-8688, Service Code 1790. 

Effective January 1, 2023, we are required under the California Consumer Privacy Act to disclose the categories and usages of personal information that our HR Department will be collecting and maintaining as to our employees. Accordingly, disclosure is made that the following employee personal information is collected and used by us:   

Categories of Documents:   
• Pre-hire documents such as this application form   
• I-9 documentation;   
• Resumes;   
• Job applications;   
• Education verification;   
• Employment verification;   
• References;   
• Job descriptions;   
• Job offers;   
• Employment agency or temporary agency agreements;   
• New employee orientation;   
• Background checks;   
• Drug tests;   
• Job interview notes;   
• Performance and evaluation reports;   
• Promotions and assignments;   
• Acknowledgment of receipt of Employee Handbooks and other company policies;   
• Warnings and discipline;   
• Counseling;   
• Training and certificates;   
• Timesheets;   
• Direct deposit information;   
• An employee’s personnel file   
How the Documents are Used:   

We retain the personal information described in the above categories for the following purposes:   
• To process payroll, including withholdings and taxes;   
• To comply with state and federal law requiring employers to maintain certain records;   
• To administer and maintain group health insurance benefits and retirement plans;   
• To monitor and manage employee performance of job duties;   
• Immigration and authorization to work documents;   
• To administer and process workers compensation claims;   
• To administer disciplinary warnings and termination;   
• To implement and monitor PTO, leaves of absence, vacation, and other benefits;   
• To comply with FMLA and ADA requirements;   
• To maintain performance review and counseling records;   
• To monitor compliance with various training regimen;   
If you have any questions on the subject, please contact the HR Department at: