PRIVACY CENTER

DATA COVERED BY THIS MAINLAND CHINA PRIVACY STATEMENT

This Mainland China Privacy Statement describes the privacy practices of the Marriott Group for Data that we collect:

• through websites operated by us from which you are accessing this Mainland China Privacy Statement, including Marriott.com.cn and other websites owned or controlled by the Marriott Group (collectively, our Websites);
• through the software applications made available by us for use on or through computers and mobile devices (collectively, our Apps);
• through our social media pages that we control from which you are accessing this Mainland China Privacy Statement (collectively, our Social Media Pages);
• through email messages that we send you that link to this Mainland China Privacy Statement and through your communications with us online or in person;
• from third parties including Authorized Licensees, Owners and Franchisees, etc. and Other Sources, including public databases, marketing partners and other third parties; and
• when you visit or stay as a customer at one of our properties, or at homes and villas offered on the Homes and Villas by Marriott International platform (Homes and Villas), or through other offline interactions (collectively, Property Visits and Offline Interactions).

Collectively, we refer to our Websites, our Apps and our Social Media Pages, as our “Online Services” and, together with the Property Visits and Offline Interactions, our “Services.”

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THE PERSONAL DATA WE COLLECT

At touchpoints throughout your customer journey, we collect Personal Data in accordance with law, and to serve you better. Personal Data is information that may identify you as an individual or relate to you as an identified individual. We may collect and process the following types of Personal Data about you:

• Name
• Gender
• Country/Region
• City
• Postal code
• Address
• Telephone number
• Email address
• Fax
• Payment information (including credit and debit card number, other payment information, etc.)
• Language preference
• Date and place of birth
• Nationality, passport, visa or other government-issued identification information
• Important dates: birthdays, anniversaries and special occasions
• Membership or loyalty program information (including co-branded payment cards, travel partner program affiliations)
• Employment information (including occupation, employer, position) (for business related bookings)
• Travel itinerary, tour group, or activity information
• Accommodation information
• Transaction and consumption records
• Special service and amenity requests
• Social media account ID and other information publicly available, or information made available by linking your social media and loyalty accounts

In more limited circumstances, we may also collect:

• Information about family members and companions (including names and ages of children, etc.);
• Biometric information; and
• Images, video and audio data via: (a) security cameras located in public areas, including hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel

We may also collect information about your Preferences that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information that we learn about you during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and specific dietary, health restrictions or personal needs to ensure your wellbeing. We may also collect your “Personal Preferences,” that may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us, and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship to you and your marital status.

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Mainland China Privacy Statement.

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HOW AND WHERE WE COLLECT YOUR DATA

This Mainland China Privacy Statement describes the privacy practices of the Marriott Group for Personal Data and Other Data that we collect through the following:

• Marriott Group. We collect Personal Data and Other Data from other companies within the Marriott Group for the purposes described in this Mainland China Privacy Statement, including providing and personalizing the Services, communicating with you, facilitating the loyalty programs and to accomplish our business purposes, etc.
• Owners, Franchisees & Joint Ventures. We collect Personal Data and Other Data from Owners of Marriott Group branded properties that we manage, from Franchisees of Marriott Group branded properties that are independently owned and operated under a franchise agreement with us, and from Joint Venture Partners. Owners and Franchisees are independent from the Marriott Group. Franchisees include their third party operators and management companies.
• Homes and Villas Property Management Companies. We collect Personal Data and Other Data from companies and their service providers who manage Homes and Villas properties, your booking of Homes and Villas, and provide additional support to you during your stay at Homes and Villas (“Homes and Villas Property Management Companies”). Homes and Villas Property Management Companies are independent from the Marriott Group.
• Authorized Licensees. We collect Personal Data and Other Data from companies when we enter into a license or similar agreement to sell goods and services under a Marriott Group brand (“Authorized Licensees”). Examples of Authorized Licensees include our time share partner, Marriott Vacations Worldwide Corporation, Cruise Yacht Optco Ltd. d/b/a The Ritz-Carlton Yacht Collection, developers of Marriott Group branded real estate, and co-branded credit card partners. Authorized Licensees are independent from the Marriott Group.
• On-Property and/or Travel Providers. We may collect your Personal Data and Other Data from spa, restaurant, health club, concierge, and other outlets at our properties.
• Linked Accounts. We collect Personal Data and Other Data when you use your loyalty program number or Online Services login to receive or register for certain third party services. These companies include businesses such as airlines and rental car providers, and restaurant reservation and car services partners. Additionally, your social media account provider allows you to connect your social media account to your Online Services account or log into your Online Services account from your social media account. When you enroll in those services, we disclose your Personal Data and Other Data to those third parties. If you do not want us to collect your Personal Data and Other Data in this way, do not provide your loyalty program number to third parties, do not use your Online Services login to register for third-party promotions and do not connect your Online Services account with accounts on third-party services.
• Promotional Activity. We collect Personal Data and other Data from with third parties who may provide promotions to you, such Data and Other as sweepstakes, contests, or other offers.
• eFolio Program. If you are an employee of a company that participates in the Marriott Group eFolio Program and book your room using a company corporate code or pay for your expenses using a corporate credit card, we may collect Personal Data and Other Data related to your stay or employment. This Mainland China Privacy Statement does not apply to the handling of your Personal Data by your employer, credit card company or bank, and we are not responsible for their practices.
• Other Sources & Service Providers. We collect Personal Data and Other Data from various third parties, such as public databases, joint marketing partners and online travel agencies (OTAs).
• Online Services. We collect Personal Data and Other Data when you interact with our Online Services, by performing such actions as, but not limited to, browsing, making a reservation, purchasing goods and services from our Websites or Apps, communicating with us or otherwise connecting with us or posting to social media pages, or signing up for a newsletter or participating in a survey, contest or promotional offer.
• Customer Care Centers. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax, or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance and training.
• Internet-Connected Devices. We collect Personal Data and Other Data from internet-connected devices available in our properties. For example, when you connect a device to the hotel’s internet, or when a smart home assistant may be available for your use to tailor your accommodations and experience.

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HOW AND WHEN WE SHARE YOUR DATA

Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data and Other Data with the following third parties as necessary for fulfilling the purposes stated in this Mainland China Privacy Statement.

• Marriott Group entities. We disclose Personal Data and Other Data to other companies within the Marriott Group for the purposes described in this Mainland China Privacy Statement, including providing and personalizing the Services, communicating with you, facilitating the loyalty programs, and accomplishing our business purposes. For example, we may share your name, contact details, travel itinerary and other information with your selected hotel in order to fulfill and complete your requested reservation and stay.
  
  
• Franchisees. We disclose Personal Data and Other Data to Franchisees of Marriott Group branded properties for the purposes described in this Mainland China Privacy Statement. Franchisees have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data handlers for the following processing: Franchisees and their third-party operators and management companies manage and coordinate your stay at hotels that they operate so they may use your Personal Data shared by us, including your name, contact details, and travel itinerary, etc. for that purpose. Franchisees may also use your Personal Data for complying with their own legal obligations, including maintaining books & records and other compliance obligations.
  
  
• Owners: We disclose Personal Data and Other Data to Owners of Marriott Group branded properties for the purposes described in this Mainland China Privacy Statement. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data handlers for the following processing: Owners may use your Personal Data shared by us, such as your name and accommodation information, for complying with their own legal obligations, including maintaining books & records and other compliance obligations.
  
  
• Homes and Villas Property Management Companies. We disclose Personal Data and Other Data, such as your name and membership or loyalty program information to Homes and Villas Property Management Companies and their service providers for the purposes described in this Mainland China Privacy Statement, including providing, facilitating and personalizing the Services requested by you, facilitating the loyalty programs, and performing their own marketing where permitted by law, etc.
  
  
• Authorized Licensees. We may disclose Personal Data and Other Data to our Authorized Licensees, including Marriott Vacations Worldwide, Ritz-Carlton Yacht Collection, Marriott Group branded real estate, and co-branded credit cards from banks, for the purposes described in this Mainland China Privacy Statement, such as providing the Services requested by you, fulfilling your requests and providing their own marketing to the extent permitted by law. This sharing enables you, among other things, to purchase Marriott branded goods and services, including time share properties and Marriott Group branded real estate.

◦ Select Authorized Licensees. As defined in the Marriott Bonvoy Communication Preferences, Select Authorized Licensees mean Marriott Vacations Worldwide Corporation, international co-branded credit cards, and joint venture partners.

• On-Property and/or Travel Providers. We may share your Data such as your Preferences and Personal Preferences with spa, restaurant, health club, concierge and other outlets at our properties to provide you with services requested by you, and their own marketing to the extent permitted by law. We may also share your Data with Travel Partners such as with Disney Destinations, LLC and Walt Disney Travel Company when you stay at one of our properties affiliated with Walt Disney World®. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars and vacation packages.
  
  
• Linked Accounts. We partner with certain third parties that allow you to enroll in their services. For example, certain companies allow you to use your loyalty program number or Online Services login to receive or register for their services. These companies include businesses such as airlines, rental car providers, and restaurant reservation and car services partners. Additionally, your social media account provider allows you to connect your social media account to your Online Services account or log into your Online Services account from your social media account. When you enroll in those services, we may disclose your Personal Data and Other Data such as your name, membership or loyalty program information (including co-branded payment cards, travel partner program affiliations), and social media account information, to those third parties. If you do not want us to share your Personal Data or Other Data in this way, do not provide your loyalty program number to third parties, do not use your Online Services login to register for third-party promotions and do not connect your Online Services account with accounts on third-party services. Data shared in this way will be governed by the third party’s privacy policy and not this Mainland China Privacy Statement.
  
  
• Promotional Activity. We partner with third parties who may provide promotions to you, including sweepstakes, contests, or other offers. With your consent or where permitted by law, we may disclose your Personal Data and Other Data including your name, contact details, membership or loyalty program information (including co-branded payment cards, travel partner program affiliations), etc. to those third parties.
  
  
• eFolio Program. If you are an employee of a company that participates in the Marriott Group eFolio Program and book your room using a company corporate code or pay for your expenses using a corporate credit card, an extract of your folio detailing the goods and services provided to you may be sent to your company and to the credit card company. This Mainland China Privacy Statement does not apply to the handling of your Personal Data by your employer, credit card company or bank, and we are not responsible for their practices.
  
  
• Service Providers. We disclose Personal Data and Other Data to third party service providers including, for example, companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing, and other services. For example, we may share your name and payment card information with service providers that are involved in processing your payment for a requested reservation and stay.

Other Uses, Transfer and Disclosures:

Except as described below and to the extent permitted by applicable law, we will not transfer or disclose your Personal Data to third parties.

• We may transfer your Personal Data to third parties if you have consented to such transfer.
  
  
• We may transfer your Personal Data to third parties if such transfer is necessary in connection with merger, acquisition, bankruptcy, or liquidation proceedings. We will require the third party to which your Personal Data is transferred to either continue protecting and processing your data in accordance with this Mainland China Privacy Statement, or to seek fresh consent from you to process your Personal Data.
  
  
• We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country or region of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country or region of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations, such as in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Marriott Group business, assets or stock (including any bankruptcy or similar proceedings); (f) to protect the rights, privacy, safety or property of the Marriott Group, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law.

Details of Third-Party Software Development Kits (SDKs) in the Online Services:

Our Online Services may include third-party SDKs, which may collect and use your data (including your Android ID and other device information), in order to provide you with various features of the Online Services and ensure the normal operation of the Online Services. Details of such third-party SDKs, including information about their collection and use of data and their respective privacy statements, are disclosed in the list below. We will update this list from time to time as the use of third-party SDKs in our Online Services may change.

Name of Third Party	Name of Third-Party SDK	Types of Data Collected	Relevant Purposes and Functions	Third Party’s Privacy Statement
Appdome, Inc.	AppDome	device information (accelerometer sensor information)	Protect Apps and users from hackers, fraud, malware and cheats	https://www.appdome.com/legal/privacy-policy/
Tencent computer system Co. Ltd.	TPNS SDK	device location (brand, model, OS type, system language, name, mode, type) network information (carrier name) application information	Push notifications to mobile devices	https://privacy.qq.com/document/preview/8565a4a2d26e480187ed86b0cc81d727 (in Chinese)
Huawei Software Technology Co.Ltd	Huawei push SDK	device information (type, model) application information system information	Push notifications to Huawei mobile devices	https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides/sdk-data-security-0000001050042177 (in Chinese)
Beijing Xiaomi Mobile Software Co. Ltd.	Xiaomi push SDK	device information (IMEI number, MAC address, Android ID, serial number) application information system information	Push notifications to Xiaomi mobile devices	https://dev.mi.com/console/doc/detail?pId=1193
Accertify Inc.	Accertify SDK	device information (IDFV) payment card information	Payment card fraud and risk prevention	https://www.accertify.com/client-privacy/
Adobe Inc.	Adobe SDK	device information (Android ID, resolution, name, mode, type, GUID, IDFA) network information (carrier name) geographic location information	Analytics A/B Testing Push notifications	https://www.adobe.com/privacy.html
Apptentive Inc.	Apptentive SDK	device information (MAC address, type, operating system) network information (carrier name)	App ratings Pop-up, Notifications, Surveys	https://www.apptentive.com/privacy/
Assa Abloy AB	Assa Abloy SDK	device information (Android ID)	Mobile Key to open hotel room doors at properties	https://www.assaabloy.com/group/en/privacy-center/privacy-notice
Beijing Baidu Netcom Science and Technology Co., Ltd.	Baidu Maps SDK	device information (including accelerometer, Android ID, MAC address, IDFV, OS type, MEID, name, mode, type)	Provide map service to users to locate the hotels	https://privacy.baidu.com/ (in Chinese)
Bazaarvoice, Inc.	BazaarVoice (SDK)	device information (mode, name, type)	Hotel ratings and reviews display	https://www.bazaarvoice.com/legal/privacy-policy/
Alphabet Inc.	Google AdMob	device information (mode, name, type)	Hotel ratings and reviews display	https://policies.google.com/privacy?hl=en
Branch Metrics Inc.	Branch.io SDK	device information (name, mode, type, Android ID, CPU architecture) network information (IP address, carrier name) geographic location information	Intelligent Deeplinking	https://branch.io/policies/privacy-policy/
Embrace Mobile Inc.	Embrace SDK	device information (IDFV, model, OS version, disk used, resolution, name, mode, type, CPU architecture) network information (carrier name) geographic location information	App crash and usage analytics	https://embrace.io/docs/privacy-policy/
Glassbox Ltd.	Glassbox SDK	device information network information	Session recording for customer engagement centers	https://www.glassbox.com/privacy-policy/
F5 Inc.	Shape Security SDK	device location (Android ID, IDFV, IP address, AAID) geographic location information	API call monitoring and blocking	https://www.f5.com/company/policies/privacy-notice
Medallia Inc.	Medallia SDK	membership information (rewards level type, rewards number) device information (OS Version, SDK Version, App Version, OS Type, Device ID, Device Model-Brand, App ID, System Language)	User feedback submission	https://www.medallia.com/privacy-policy/

Except for the Accertify SDK which is only embedded in the Android version of the App, other third-party SDKs are used in both the Android and iOS versions of the App.

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YOUR DATA, YOUR CHOICES: YOUR PRIVACY PREFERENCES & RIGHTS

At Marriott, we believe that you should have choices with respect to your Data. We provide you with the options, information and choices below to express your preferences: what and how much you share with us and when and how you hear from us.

Communications and Preferences

• To change how and how often we or our partners communicate with you, please sign into your loyalty account profile and select Communication Preferences.
• You can also use the unsubscribe link at the bottom of any of our communications.
• If you no longer wish to receive marketing-related emails, you may opt out by visiting our unsubscribe page or by following the instructions in any such email you receive from us.
• In addition, you can opt out from marketing-related emails by sending a letter to: Marriott Guest Services, Level 3/F, HNA, 8 LinHe Zhong Road, TianHe District, GuangZhou 510610, China.
• NOTE: Even if you choose to opt out of marketing-related emails, we will continue to send you transactional messages, such as information about your reservations or stays, including confirmation and pre-arrival emails, or account security updates.
• If you want to adjust your Stay Preferences, log into your loyalty account and choose Room and Stay Preferences.
• NOTE: Our Android Bonvoy App does not display personalized recommendations or targeted notifications within the Bonvoy App.

Cookies and Other Data

For information on your choices related to Cookies and Other Data, please see the Section on Manage Cookie Preferences, above.

How You Can Exercise Your Personal Data Rights

If you would like to exercise your right to access, obtain a copy of, port, correct, complete, delete, restrict, or obtain information or explanations relating to the processing of your Personal Data that you have previously provided to us (to the extent these rights are provided to you by law), please visit our Individual Rights Portal and complete this form. If you have any questions about the form or our process, feel free to contact us at privacy@marriott.com. If you would like to de-register your account, you can do so by contacting us as indicated in the “Contact Us Section below.

For your protection, we only fulfill requests for the Personal Data associated with the email address and/or loyalty account number that you identify in your request, and we may need to verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.

Marriott acknowledges and respects our customers’ privacy and we will respond to your request as soon as reasonably practicable and in any event, within fifteen (15) working days.

If you have given us consent in relation to particular action or activities, you can withdraw your consent at any time by contacting us as indicated in the “Contact Us” Section below.

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OTHER IMPORTANT PROVISIONS

Non-Marriott Group Entities

This Mainland China Privacy Statement does not address, and we are not responsible for the privacy, data, or other practices of any entities outside of the Marriott Group, including Franchisees, Owners, Homes and Villas Property Management Companies, Authorized Licensees, or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We generally have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data.

In addition, we are not responsible for the data collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to other organizations through our Apps or our social media pages.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Data, to prevent and/or detect and respond to unauthorized access, public disclosure, use, modification, damage or loss of data. During data collection, transmission, storage, processing, exchange and destruction, we take appropriate encryption, backup, access control and other measures to protect data security, so that relevant data is available, complete and auditable. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.

Retention

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Mainland China Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services)
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
• Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations)

Sensitive Personal Data

We only collect Sensitive Personal Data which may be necessary to perform reasonably expected services or as required by law. We ask that you not send and/or disclose to us on or through the Services any Sensitive Personal Data (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, information on other judicial or administrative proceedings, or other information that may lead to discrimination or serious harm to personal and property safety in the event of leakage or unauthorized use). Please note our disclosures relating to the processing of Sensitive Personal Data, which have been underlined and marked with bold font in this Mainland China Privacy Statement.

Use of Services by Minors

The Services are not intended for children, and we do not knowingly solicit or collect personal data from children under the age of fourteen (14) without parental consent. We request that they not provide Personal Data through the Services.

Cross-border Data Transfers

The Marriott Group is a global organization and provides a global service. Transferring data internationally is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer Personal Data and Other Data collected in connection with the Services, to entities in countries or regions outside the People’s Republic of China. This includes transfers to entities in the Marriott Group for the purposes described in this Mainland China Privacy Statement. By making a reservation, visiting or staying at a Marriott branded property or using any Marriott Group branded service, you understand that we transfer your Personal Data globally.

In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries or regions may be entitled to access your Personal Data. We will handle such access requests in compliance with applicable laws.

Updates to This Mainland China Privacy Statement

The “Last Updated and Effective” legend at the top of this page indicates when this Mainland China Privacy Statement was last revised and became effective. If you would like to review the version of the Mainland China Privacy Statement that was effective immediately prior to this revision, please contact us at privacy@marriott.com.

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CONTACT US

If you have any questions about this Mainland China Privacy Statement, please contact us at privacy@marriott.com.

If you live in the People’s Republic of China, the data handler responsible for your Personal Data is Shanghai Gingerroot Hotel Management Co., Ltd. with an address of:

Unit 2902 Office Tower, Raffles City
268 Xizang Middle Road
Huangpu District, Shanghai
China

Additional Information

DATA HANDLER

The Marriott Group acts as an independent data handler in relation to our owners and franchisees, who have a limited right to use the Data we collect as described below:

Owners: As the hotel you are booked to stay in may not be owned by the Marriott Group, we disclose Data to owners of Marriott Group branded properties for the purposes described in this Mainland China Privacy Statement. Owners have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data handlers in order to comply with their own legal obligations, including maintaining books & records and other compliance obligations.

Franchisees: In addition, some Marriott-branded hotels are owned and operated under a franchise agreement with the Marriott Group. As such, we disclose Data to franchisees of Marriott Group branded properties for the purposes described in this Mainland China Privacy Statement. Franchisees have a limited right to use certain Personal Data for their own purposes and therefore qualify as independent data handlers for the purposes of managing and coordinating your stay at hotels, and for complying with their own legal obligations, including maintaining books & records and other compliance obligations.

You can also:

• Contact our data protection officer responsible for your country or region via MarriottDPO@marriott.com. In your email, please indicate the country or region from which you are contacting us.
• Lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs.

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