This analysis describes what Hilton's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The protection is contingent on an intra-group agreement that may—but does not always—apply, meaning coverage is not guaranteed for every transfer within the Hilton Group.
Interpretive note: The excerpt uses 'may be covered,' indicating the intra-group agreement does not automatically apply to all intra-group transfers. The full scope of when and where it applies is not established by this excerpt alone.
Your personal information shared within the Hilton Group of Companies may be protected by a contractual obligation requiring adequate and consistent protection, but such coverage is not assured in every instance.
How other platforms handle this
Whenever we transfer personal data internationally, we use tools and transfer agreements to: make sure the data transfer complies with applicable law; and help to give your data the same level of protection as it has in the EU...
we also transfer personal information to all other countries in which Adobe or its affiliates, providers, and partners operate. We carry out these transfers in compliance with applicable laws – for example, by putting data transfer agreements in place...
Australia, Brazil, Canada, Europe, India, Japan, Singapore, Taiwan, United States
"transfers within the Hilton Group of Companies may be covered by an agreement entered into by members of Hilton (an intra-group agreement) which contractually obliges each member to ensure that your information receives an adequate and consistent level of protection...Excerpt from Hilton's Privacy Statement
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The protection is contingent on an intra-group agreement that may—but does not always—apply, meaning coverage is not guaranteed for every transfer within the Hilton Group.
Your personal information shared within the Hilton Group of Companies may be protected by a contractual obligation requiring adequate and consistent protection, but such coverage is not assured in every instance.
ConductAtlas has identified this type of provision across 287 platforms. See the full comparison.
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