Steele Rewards

About Us/General Information

This Privacy Policy Statement shall cover our privacy practices for all Steele Rewards (SR) services related to the Steele Rewards affiliate

While certain areas of this website may be accessed and viewed by members of the public, not all visitors to this website may have access to the entire SR network. The SR network is available for use only by persons or entities that join SR as either a "Property" or "Hotel" (Referred to as "Hotel") or a "Publisher."

Only persons or entities that operate websites through which they conduct a business are eligible to become Hotel. Publishers must be corporations or other legal entities or adults (at least of the legal age to be able to enter into contracts in the jurisdiction in which they reside) that also manage or operate websites which they use to conduct a business or generate revenues. In order to become an SR Hotel or Publisher, a person or entity must apply for membership and have the application accepted by SR, which includes accepting certain contractual terms.

Information Collected from Visitors to this Website

We gather standard information that accompanies Internet transmissions (e.g. IP Address), which in some jurisdictions may be considered personally-identifiable information. Other than this information, we do not gather personally-identifiable information about or from visitors to or users of this website solely as a result of such visits or usage, other than from (i) people requesting to be contacted with more information about SR offerings, (ii) persons or entities whom we allow to join SR as an Hotel and (iii) persons or entities whom we allow to join SR as a Publisher pursuant. We use the personally identifiable information submitted with inquiries about SR offerings to respond to those inquiries.

Our servers log the standard information that accompanies Internet transmissions, like the date and time of a visit, browser type, IP address, domain names, access dates and times, referring website addresses and operating system. Third parties uses web tracking technology such as, but not limited to, cookies, JavaScript and/or other kinds of Web beacons. We have no control over this third party's tracking devices. We receive only aggregated, non-personally-identifiable information generated by this tracking technology. SR may store cookies on a visitor's computer in order to manage a visitor's session on our site. By accessing our site, you agree that SR may place cookies on your computer and a third party may use web tracking technology, in each case, as described above. You may opt-out of receiving cookies by adjusting your web browser settings to reject cookies. If you reject cookies, you may not be able to take full advantage of all of the features of our site, including "signing in" to password-protected areas. A detailed summary of cookies can be found below under "Data about Customers of Hotels and Publishers."

The SR is membership-based, and members must enter into a legal contract with SR in order to join and use the SR affiliate network. Each of our contracts with Hotels and Publishers contains terms that set forth the obligations of SR with respect to the use and disclosure of the information that we gather from our Hotels and Publishers. Hotels and Publishers should refer to those terms and not to this Privacy Policy.

We use a "template" form of contract to enroll Hotels. That template changes from time to time and is accessible only by Hotels or prospective Hotels. We do not publish our template Hotel Agreement on this website. We do provide the template to prospective Hotels with whom we are interested in pursuing a business relationship with us. Each such prospective Hotel is encouraged, and has the opportunity, to review the template and any incorporated policies, including the terms that define the respective obligations of SR and the Hotel regarding use and disclosure of confidential information and privacy. SR's rights and obligations with respect to the disclosure and use of the information we gather about any Hotel are governed by the Hotel Agreement that the Hotel and we sign.

Prospective Hotels are required to submit certain personally identifiable information (e.g. Company name, phone and email address) on our websites in ordered to be contacted in connection with one or more of our advertising services. If we do not enter into an agreement with such Prospective Hotels, then we may (but have no obligation to) retain the information that the applicant provided on our website. Retention of such information may be restricted under applicable laws, and we will delete information in accordance with these laws. We will not disclose this information to third parties except, as follows:

  • We may disclose this information with our corporate affiliates in response to your election to be contacted for one or more our various advertising services.
  • We may disclose it to government agencies or officials or other third parties if we believe such disclosure to be required or compelled under applicable law or regulations or legal process.
  • We may disclose it to government agencies or officials upon their request, even if not compelled by a subpoena or other legal process, and without any duty on our part to independently confirm that such agencies or officials are legally entitled to such disclosure.
  • In the event that SR sells or transfers ownership, operation or control the SR, its corporate affiliates or otherwise engages any subcontractor or agent to operate the SR or provide any service related to SR. SR reserves the right to transfer or disclose all or any part of its data to the buyer, subcontractor or agent. In the case of a disclosure to a subcontractor or agent to perform services on our behalf, such contractors and agents may have access to your information, but only to perform services for us.
  • In the event that SR is acquired by or merged with a third party entity, or in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected as part of such merger, acquisition, sale, reorganization or other change of control.

Information about Hotels
In order to join the SR network as a Publisher, a person or entity has to apply for membership by completing an "online" application on this website. The online application requires personally identifiable information about the applicant. The application form may be viewed by clicking on the Publisher registration page of this website. Besides the information that we gather by means of the online application, we may obtain a great deal of personally-identifiable information about a Publisher through a variety of online or offline means. That information includes the Publisher's contact information, Taxpayer Identification Number (which may be an individual's Social Security Number), VAT registration numbers or other foreign tax identification numbers (for the SR operated outside of the U.S.), as well as information about the business conducted by the Publisher on its website related to the use of SR, including information about the online marketing strategies and plans and the kinds and volumes of transactions conducted through SR generally and with specific Hotels. We may use third party vendors to authenticate and/or supplement the information a Publisher applicant submits.

The Publisher Agreement that we enter into with that Publisher governs SR's rights and obligations with respect to the disclosure and use of the information we gather about any Publisher. Usually, that Publisher Agreement is an "online" form that, as a condition to joining SR, we require each Publisher to accept by clicking on a button on the Publisher registration page of our website used for SR. In a few special cases, the Publisher Agreement may be a paper document that is manually signed and physically delivered. We post on the Publisher registration pages of this website our "template" form of contract by which we enroll Publishers. That template changes from time to time and may incorporate policies that we also publish on this website. Each prospective Publisher is encouraged, and has the opportunity, to review the template and any incorporated network policies, including their terms that define the respective obligations of SR and the Publisher regarding use and disclosure of confidential information and privacy.

All applications for membership as a Publisher are subject to SR's acceptance. If we do not accept an application, then we may (but have no obligation to) retain the information that the applicant provided in the online application. Retention of such information may be restricted under applicable laws, and we will delete information in accordance with these laws. We will not disclose this information to third parties except as follows:

  • We may disclose it to government agencies or officials or other third parties if we believe such disclosure to be required or compelled under applicable law or regulations or legal process.
  • We may disclose it to government agencies or officials upon their request, even if not compelled by a subpoena or other legal process, and without any duty on our part to independently confirm that such agencies or officials are legally entitled to such disclosure.
  • In the event that SR sells or transfers ownership, operation or control of any or all of SR, its corporate affiliates or otherwise engages any subcontractor or agent to operate SR or provide any service related to SR. SR reserves the right to transfer or disclose all or any part of its data to the buyer, subcontractor or agent. In the case of a disclosure to a subcontractor or agent to perform services on our behalf, such contractors and agents may have access to your information, but only to perform services for SR.
  • In the event that SR is acquired by or merged with a third party entity, or in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected as part of such merger, acquisition, sale, reorganization or other change of control.

If we accept an application for membership in SR as a Publisher, we do retain the information that the applicant provided in the online application. We may also obtain other information about our Publishers during the course of their usage of our networks, including, but not limited to, information about the volumes of business they conduct through SR with Hotels or others. We may, but are not obligated to, retain the information that we obtain about any Publisher after that Publisher leaves SR.

We may use and disclose the information we have or acquire about any Publisher as provided in the Publisher Agreement, which such Publisher enters into with SR. The template form of Publisher Agreement gives SR broad discretion in using and sharing the information that Publishers provide to us, including the right to furnish any or all of that information to Hotels or other third parties. SR is not responsible or liable for any use or disclosure by any Hotel or other third party of information about any Publisher that we furnish.

Some of the services we offer allow a Publisher to enter into a direct business relationship with a Hotel. For example, if an Hotel engages us to manage its affiliate marketing program through SR, the Hotel will have the ability to make a general offer to all Publishers in SR, and Publishers will have the ability to apply directly to the Hotel's affiliate marketing program. In order to participate in that Hotel's affiliate marketing program, each Publisher must separately apply to join that program and then must be accepted into that program by the relevant Hotel. A Hotel may require a Publisher applying to or participating in its program to provide information directly to the Hotel. Any Hotel's use of Publisher data, however obtained, is governed by that Hotel's own contract, if any, with that Publisher and by its own privacy policies, if any. SR is not responsible or liable for any use or disclosure of any such information by the Hotel or any third party. If the Hotel provides SR with any data about any Publisher, then that Hotel is solely responsible for ensuring that its provision to us is consistent with that Hotel's own privacy policy, own contract with such Publisher, applicable legal requirements of other obligations or commitments of such Hotel to such Publisher. To the maximum extent permitted by applicable law, SR expressly disclaims any obligation or liability to any Publisher with regard to any use, storage, processing or disclosure of any data about that Publisher that SR obtains from any Hotel or any third party.

Data about Customers of Hotels and Publishers
In providing our affiliate marketing, search management and related services, SR does not deal directly with the customers of Hotels or Publishers. We enable Hotels and Publishers to create links between their own websites. A visitor who clicks on a Hotel's banner or other promotion on a Publisher's website is redirected, through our website, to the Hotel's website, where he or she may make a reservation, purchase a product or service or engage in another transaction or activity that entitles the Publisher to compensation from the Hotel. As a result of such redirection through our website, our technology automatically records the IP (Internet Protocol) address of the browser used. In addition, during such redirection, we may place one or more "cookies" on the hard drive of the visitor's computer through his or her Web browser.

Cookies are alphanumeric identifiers that enable the systems used by the website operator who places the cookie to recognize the visitor's browser. In connection with certain features of our services to Hotels, we use cookies in order to determine whether and when a "cookied" Web browser is used to return to the Hotel's site after a prior visit. The cookies we currently use permit us to determine when a browser is used to make repeat visits or click-throughs to a website and to determine whether the same browser has accessed more than one site on SR, but do not permit us to determine the identity of any user of that browser or gather any other personally-identifiable information about that user, such as postal address, email address, phone number, social security number or any credit card number. To learn more about cookies, click these links:
www.iab-performance-marketing-explained.net
http://www.allaboutcookies.org
For Microsoft Internet Explorer: http://www.microsoft.com/infor/cookies.htm
For Mozilla Firefox: http://support.mozilla.com/en-USkb/Options+window
Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

In order to provide reports to a Hotel and the Publishers, if applicable to the service offering, we need basic data about the kinds and volumes of Web user activities that occur as a result of the links created through SR, but we do not need data that identifies or permits the identification of any customers or website visitors of an Hotel or Publisher. Other than IP Address, we do not intentionally obtain any personally-identifiable data about any of such customers or visitors through our technology or services, unless the Hotel or a Publisher elects to furnish it to us or authorizes us to obtain that data and to the extent that IP Address is used or disclosed, our rights and obligations with regard to that information is defined by our contract with the particular Hotel or Publisher. We use IP Address for fraud/verification purposes (not for targeting purposes) or to extract non-exact geographical information; such information may be shared with Hotels for reporting purposes and to give our Hotels more information about the performance of their advertising campaigns. We do not, through this Privacy Policy or otherwise, make any promise or undertake any obligation directly to any user of any Hotel's or Publisher's website with regard to any use or disclosure of information that a user furnishes directly to any Hotel or Publisher. Each Hotel and Publisher is solely responsible for establishing its own privacy policy, communicating that policy to the users of its website and ensuring that any access to, processing, storage and use by SR, in accordance with the applicable Hotel Agreement or Publisher Agreement, of any data about those users are consistent with that Hotel's or Publisher's own privacy policy, applicable legal requirements, other obligations or commitments to such users. To the maximum extent permitted by applicable law, SR expressly disclaims any obligation or liability to any user of any Hotel's or Publisher's website of any nature, including with regard to any data about that user that SR obtains, processes, stores, uses or discloses.

Security
We have implemented reasonable security measures in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. These include firewalls, data encryption redundancy and intrusion detection. Our employees are made aware of and are accountable for compliance with these procedures. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure. As a result, although we strive to protect your information, we cannot ensure or warrant the security of your information against any possible loss or unauthorized access.

Changes to Our Privacy Policy
SR reserves the right to change or replace this Privacy Policy at any time and from time to time. Any changes or replacement will be noted through indications on this Privacy Policy.

Change in Control
In the event that SR sells or transfers ownership, operation or control of the company or SR is acquired by or merged with a third party entity, or in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected as part of such merger, acquisition, sale, reorganization or other change of control. You agree that SR may provide to such entity information that is related to that part of our business that was sold to or merged with the other entity without obtaining your further consent. Any entity acquiring assets comprising or consisting of your information shall agree to handle such information in accordance with the terms of this Privacy Policy. In this event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy.

Questions and Comments about Our Privacy Policy/Removal or Correction of Information

Persons already enrolled as a Hotel in SR who have questions or comments about this Privacy Policy or the relevant provisions of their Hotel Agreements should contact their Concierge. Prospective Hotels should contact SR by email at info@steelerewards.com to discuss any such questions or comments.

Existing or prospective Publishers and others who have questions or comments about this Privacy Policy may contact us by email at info@steelerewards.com.

Consumers with questions about our privacy practices or who wish to have their personally identifiable data corrected or removed may contact us by email at info@steelerewards.com.

Contact Information
Our postal address is:
Steele Rewards
250 West 27th Street
New York, NY 10001

Safe Harbor
SR complies with the U.S.-EU Safe Harbor Framework and U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal identifiable information from European Union member countries and Switzerland. Our privacy practices are consistent with the European Union Data Protection Directive and the U.S. Department of Commerce Safe-Harbor Program Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the company's certification, please visit http://www.export.gov/safeharbor/.