“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...”
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.
The updated privacy statement now explicitly discloses that Hilton collects and may share Gender, Telephone, Arrival Time, Departure Date, and Spending Amount with third parties. These data categories were not previously listed in the disclosed collection practices. The statement continues to state that Hilton will not knowingly collect or disclose personal information from minors under the age of 14.
View change record →The updated policy expands disclosure of how Hilton properties use SMS and WhatsApp to contact guests during their stay. Properties may send welcome messages upon arrival, mid-stay reminders about the messaging service, and respond to guest requests via SMS or WhatsApp. The policy specifies that short code opt-in data will not be shared with third parties for their marketing purposes, and guests can opt out by replying STOP to any message. The policy also now explicitly discloses collection of WeChat account identifiers for linking Hilton Honors accounts to partner accounts. CCTV retention has been extended from 30 to 31 days. You can opt out of SMS or WhatsApp messages by replying STOP, or contact the hotel front desk to decline text messages.
View change record →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
Any information you provide through use of the Sites may be stored and processed, transferred between, and accessed from the United States and other countries which may not guarantee the same level of protection of Personal Information as the one in which you reside.
Whenever we transfer your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all measures that are reasonably necessary to ensure the existence of adequate safeguards...
All transfers of information to service providers are covered by appropriate data agreements and, in the case of cross-border data transfers, legal mechanisms for doing so.
"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
ConductAtlas detected a major restructuring of Meta’s privacy policy that removed detailed consumer rights disclosures and relocated them to separate documents.
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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 280 platforms. See the full comparison.
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