BUTLER BENCHMARKING PRIVACY POLICY

1. Introduction

Butler Benchmarking (“we,” “our,” or “us”) is committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy explains what information we collect, how we use it, with whom we share it, and what rights you have in relation to it.

Butler Benchmarking is headquartered at 260 Adelaide Street East, P.O. Box 82, Toronto, Ontario, M5A 1N1, Canada. We operate a global platform serving hotel properties and butler teams worldwide. As such, this policy is designed to meet the requirements of applicable Canadian privacy legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), as well as the European Union’s General Data Protection Regulation (GDPR) where applicable.

By using our platform or services, you agree to the collection and use of information as described in this policy. If you do not agree, please discontinue use of our services.

2. Information We Collect

We collect only the information necessary to provide and improve our services. This includes:

Account and Registration Information

  • Your name
  • Hotel or company name
  • Email address
  • Job title or role
  • Butler team details (names, roles, and department structure)
  • Platform Usage Information
  • Test and quiz responses and scores
  • Dashboard activity and usage data
  • IP address and browser type
  • Pages visited and time spent on the platform

Communications

  • Emails and messages sent to us, including support enquiries
  • Survey responses or feedback you choose to provide

We do not collect sensitive personal information such as financial account details, government identification numbers, or health data.

3. How We Use the Information

The table below summarises the personal data we collect, the purpose for which we use it, and the legal basis on which we rely.

Data Collected Purpose Legal Basis
Name, email, hotel details Account registration and authentication Contract — necessary to provide the service
Butler team details and test results Delivering benchmarking reports and dashboard data Contract — necessary to provide the service
Usage and analytics data Improving platform performance and user experience Legitimate interests
Email address Service communications, updates, and support Contract / Legitimate interests
Email address Marketing communications (where opted in) Consent
All data Compliance with legal obligations Legal obligation

If you are in the European Union or European Economic Area, we rely on the legal bases described above under the GDPR (Article 6). You may withdraw consent at any time where consent is the stated basis, without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, contact us at info@butlerbenchmarking.com.

4. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve the platform. Cookies are small data files stored on your device that help us recognise you between sessions and understand how the platform is used.

We use the following categories of cookies:

  • Essential cookies — required for the platform to function. These cannot be disabled.
  • Analytics cookies — help us understand how users navigate the platform so we can improve it. These are only set with your consent.
  • Preference cookies — remember your settings and personalisation choices.

You can manage or disable non-essential cookies through your browser settings or via our cookie consent tool when you first visit the platform. Please note that disabling essential cookies may impact your ability to use certain features.

5. How We Share Your Information

We do not sell your personal information. We do not share your information with third parties for their own marketing purposes. We may share your information only in the following limited circumstances:

  • Service providers — trusted third-party vendors who assist in operating our platform (such as cloud hosting and email delivery providers). These parties are contractually bound to protect your data and may only use it as directed by us.
  • Within your hotel group — brand standard testing results are shared exclusively within your hotel’s corporate group, as directed by the hotel admin.
  • Legal requirements — where required to comply with applicable law, regulation, legal process, or enforceable governmental request, or to protect the rights, property, or safety of Butler Benchmarking, our users, or others.
  • Business transfers — if Butler Benchmarking is acquired by or merged with another company, we will notify you in advance and give you the opportunity to object before your personal information is transferred or becomes subject to a different privacy policy.

6. International Data Transfers

Butler Benchmarking is based in Canada. If you are accessing our platform from outside Canada — including from the European Union — your information may be transferred to and processed in Canada or other countries where our service providers operate.

Canada has been recognised by the European Commission as providing an adequate level of data protection for commercial organisations subject to PIPEDA. Where we transfer data to countries that do not have an adequacy decision, we implement appropriate safeguards, such as Standard Contractual Clauses, to protect your information.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you with our services. If you close your account, we will delete or anonymise your personal information within 90 days, unless we are required to retain it longer to comply with a legal obligation, resolve a dispute, or enforce our agreements.

Anonymized and aggregated benchmarking data — which cannot be linked back to any individual or hotel — may be retained indefinitely for industry reporting purposes.

8. Your Rights

Depending on your location, you may have the following rights in relation to your personal information:

  • Right of access — the right to request a copy of the personal information we hold about you.
  • Right to correction — the right to request that we correct any inaccurate or incomplete information.
  • Right to deletion — the right to request that we delete your personal information, subject to certain exceptions.
  • Right to restrict processing — the right to ask us to limit how we use your data in certain circumstances.
  • Right to data portability — the right to receive your data in a structured, commonly used, machine-readable format (GDPR only).
  • Right to object — the right to object to processing based on legitimate interests or for direct marketing purposes.
  • Right to withdraw consent — where processing is based on consent, the right to withdraw that consent at any time.
  • Right to lodge a complaint — the right to file a complaint with your national data protection authority. In Canada, this is the Office of the Privacy Commissioner of Canada. In the EU, this is your local supervisory authority.

To exercise any of these rights, please contact us at info@butlerbenchmarking.com. We will respond within 30 days. We may ask you to verify your identity before processing your request.

9. Data Security

We take the security of your personal information seriously. We implement appropriate technical and organisational measures to protect your data against unauthorised access, loss, destruction, or alteration. These measures include encrypted data transmission, secure server infrastructure, and access controls limiting who within our organisation can view personal data.

While we take every reasonable precaution, no method of transmission over the internet or electronic storage is completely secure. In the event of a data breach that poses a risk of significant harm to individuals, we will notify affected users and the Office of the Privacy Commissioner of Canada as required by law.

10. Children’s Privacy

Our platform is not directed at individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected such information, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify you by email to the address associated with your account and update the “Last Updated” date at the top of this document. We encourage you to review this policy periodically.

Your continued use of our platform following notification of changes constitutes your acceptance of the updated policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Privacy Officer:

Butler Benchmarking — Privacy Officer

C/O Charles MacPherson Associates Inc.

260 Adelaide Street East,

Toronto, Ontario, M5A 1N1, Canada

Email: info@butlerbenchmarking.com

If you are in the European Union and are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.