Terms Unconditional

Consumer Apps · Travel/Loyalty · Regulatory action + Private litigation + Data breach

Marriott (Bonvoy)

Headline

Marriott's combined litigation — the 2018 breach, a separate 2020 breach, resort-fee deception, and biometric employee timekeeping violations…

Marriott's combined litigation — the 2018 breach, a separate 2020 breach, resort-fee deception, and biometric employee timekeeping violations — includes data breaches that the FTC says affected more than 344 million customers worldwide. The FTC's related order — which carries no monetary penalty and requires Marriott to let US customers request deletion of data tied to their Bonvoy account — is a SEPARATE settlement from the $52 million Marriott paid; that money went to a 49-state-plus-DC Attorney General coalition (District of Columbia among them) over the same breaches, not to the FTC. Both the deletion right and the $52 million exist only because of these settlements, not because Marriott offered either voluntarily. Separately, the Fourth Circuit in June 2025 decertified the consumer classes based on a class-action waiver in Starwood's loyalty-program contract, illustrating how hard it can be for guests to litigate collectively, regardless of how large the underlying breach was.

  • SeveritySeverity 5 of 5. Marriott's combined litigation — the 2018 breach, a separate 2020 breach, resort-fee deception, and biometric employee timekeeping violations…
  • Evidence tierUnassigned
  • Claims confirmed5 of 13 claims confirmed against a primary source
  • Last verified2026-08-06

Primary source. www.ftc.gov/legal-library/browse/cases-proceedings/192-3022-marriott-international-inc-starwood-hotels-resorts-worldwide-llc-matter — Verified - primary source confirmed.

Last verified 94 days agoverified 94 days ago0180 days
Freshness. Last verified 94 days ago (2026-08-06); stale after 180 days.

Terms

Arbitration

Class-action lawyers specifically 'questioned an arbitration clause in Marriott's free internet monitoring program' offered to breach-affected customers — i.e., the very remediation program Marriott offered to breach victims may itself have contained an arbitration clause limiting those victims' ability to sue over the breach that prompted the offer in the first place. A federal appeals court (Aug 2023) specifically VACATED an earlier class-certification win and sent the case back for further consideration of a class-action waiver signed by hotel guests; after the district court reinstated the classes (Nov 2023), the Fourth Circuit on June 3, 2025 held the waiver valid and enforceable and decertified the classes — showing how a contractual class-action waiver ultimately defeated class treatment in this litigation years after the breach.

Data sharing

ONE OF THE LARGEST DATA BREACHES IN THIS ENTIRE AUDIT: the 2018 Starwood breach (discovered after Marriott's acquisition of Starwood) exposed approximately 339 MILLION guest account records worldwide (per the FTC), including ~5.25 million UNENCRYPTED passport numbers and 20.3 million encrypted passport numbers — the breach reportedly went undiscovered for more than 4 YEARS after it began. A second, separate breach hit another 5.2 million guests in 2020. Marriott paid $52 MILLION to settle with a coalition of 50 state and DC Attorneys General (Oct 2024; the settlement also requires an independent third-party assessment of Marriott's information security program every two years for 20 years) and was separately fined approximately GBP 18 million (reported as roughly $24 million) by the UK Information Commissioner's Office under GDPR over the Starwood breach. The consumer class action has seesawed: the Maryland MDL court certified state-specific classes; in 2023 the Fourth Circuit (78 F.4th 677) held the court erred by not considering a class-action waiver in Starwood's loyalty-program (SPG) contracts and remanded; the district court reinstated the classes on Nov. 29, 2023; and on June 3, 2025 the Fourth Circuit (Maldini v. Marriott Int'l, No. 24-1064) reversed again, holding the waiver valid and enforceable and decertifying the classes. SEPARATELY, Marriott has faced resort-fee litigation (it settled the Pennsylvania AG's drip-pricing suit in Nov 2021 by agreeing to show total prices including mandatory fees, without admitting wrongdoing) and a reported Illinois BIPA lawsuit over fingerprint-based EMPLOYEE timekeeping systems; current status of private resort-fee and BIPA suits not verified as of Oct 2026.

Fees and billing

Resort-fee litigation has alleged Marriott advertised room prices that left out mandatory resort fees; Marriott settled the Pennsylvania AG's suit in Nov 2021 by agreeing to display all-in prices (no admission of wrongdoing), and a June 2023 Los Angeles County suit challenged a separate per-night surcharge. Current status of private suits not verified as of Oct 2026.

Contacts

Privacy contact. Not recorded.

Legal notice. PUBLIC COMPANY (MAR). Service route: c/o General Counsel / Corporate Secretary, Bethesda, Maryland — the corporate address on the SEC Form 10-K cover page is the official address of record. Confirm the exact street address on the current 10-K at sec.gov/edgar, and check the state-of-incorporation registered agent (usually Delaware; most large filers use The Corporation Trust Company or Corporation Service Company) via the Secretary of State business-entity search. A registered agent MUST accept service, which is why it is the reliable channel when a company publishes no privacy address.

Mailing address. Not recorded.

No published channel
Paper trail: none. No published channel.

Evidence

ClaimKindSupportSources
1. Marriott's litigation includes a 2018 breach.factunsupported1 (0 confirmed)
2. Marriott's litigation includes a separate 2020 breach.factunsupported1 (1 confirmed)
3. Marriott's litigation includes resort-fee deception claims.factunsupportednone recorded
4. Marriott's litigation includes biometric employee timekeeping violations.factunsupportednone recorded
5. Marriott's combined litigation has touched over 500 million people worldwide.factunsupported1 (0 confirmed)
6. The FTC issued an order against Marriott settling data-security charges.factsupportednone recorded
7. The FTC order carries no monetary penalty.factunsupported1 (1 confirmed)
8. The FTC order requires Marriott to let US customers request deletion of data tied to their Bonvoy account.factunsupported1 (1 confirmed)
9. Marriott paid $52 million to a 49-state-plus-DC Attorney General coalition over the same breaches.factunsupported1 (1 confirmed)
10. The FTC order is a separate settlement from the $52 million payment.factunsupported1 (1 confirmed)
11. The deletion right and the $52 million exist only because of settlements, not voluntary action.characterizationn/anone recorded
12. Multiple federal courts dismissed versions of the data-breach class actions for lack of standing.factunsupported1 (0 confirmed)
13. This illustrates how hard it is for an individual guest to get their case heard.characterizationn/anone recorded

5 of 13 claims have a confirmed source of their own.

Sources

SourceClaimTierStatusQuote
regulator · 2024-10-09
www.ftc.gov/news-events/news/press-releases/2024/10/ftc-takes-action-against-marriott-starwood-over-multiple-data-breaches
Claim 1UnassignedcorrectedNo quote recorded.
Quote basis: not recorded.
court · 2021-03-03Claim 2Unassignedconfirmed“a data breach of Defendant Marriott that occurred in early 2020”
Quote basis: not recorded.
noneClaim 5Unassignednot foundNo quote recorded.
Quote basis: not recorded.
regulator · 2024-10-09
www.ftc.gov/news-events/news/press-releases/2024/10/ftc-takes-action-against-marriott-starwood-over-multiple-data-breaches
Claim 7Unassignedconfirmed“does not have legal authority to obtain civil penalties in this case”
Quote basis: not recorded.
regulator · 2024-10-09
www.ftc.gov/news-events/news/press-releases/2024/10/ftc-takes-action-against-marriott-starwood-over-multiple-data-breaches
Claim 8UnassignedconfirmedNo quote recorded.
Quote basis: not recorded.
regulator · 2024-10-09
www.ftc.gov/news-events/news/press-releases/2024/10/ftc-takes-action-against-marriott-starwood-over-multiple-data-breaches
Claim 9UnassignedconfirmedNo quote recorded.
Quote basis: not recorded.
regulator · 2024-10-09
www.ftc.gov/news-events/news/press-releases/2024/10/ftc-takes-action-against-marriott-starwood-over-multiple-data-breaches
Claim 10Unassignedconfirmed“The FTC and the states worked in parallel on the investigation.”
Quote basis: not recorded.
court · 2021-03-03Claim 12Unassignedcorrected“Plaintiffs’ claims are dismissed for lack of standing”
Quote basis: not recorded.

Source vault

Link status: Candidate - not yet fetched

DocumentLast fetchPDF
Privacy policy
marriott.com/en-us/privacy-statement.mi
Not fetched yetNO (HTML only)
Terms of service
marriott.com/en-us/terms-of-use.mi
Not fetched yetNO (HTML only)
Website
marriott.com
Not fetched yet—
Primary source
https://www.ftc.gov/legal-library/browse/cases-proceedings/192-3022-marriott-international-inc-starwood-hotels-resorts-worldwide-llc-matter
Verification: Verified - primary source confirmed
Not fetched yet—

Enforcement

No enforcement actions are linked to this row.

State statute

Headquarters on file: Maryland. Provisions of MODPA on file:

ProvisionTypeSource
Applicability Threshold — Low Thresholds (10k/35k)
Md. Code Com. Law § 14-4602
thresholdsource
Right to Access
Md. Code Com. Law § 14-4605(b)(1)-(2)
hardsource
Right to Correction
Md. Code Com. Law § 14-4605(b)(3)
hardsource
Right to Deletion
Md. Code Com. Law § 14-4605(b)(4)
hardsource
Right to Data Portability
Md. Code Com. Law § 14-4605(b)(5)
hardsource
Right to List of Categories of Third Parties
Md. Code Com. Law § 14-4605(b)(6)
hardsource
Right to Opt Out of Sale, Targeted Advertising, and Profiling
Md. Code Com. Law § 14-4605(b)(7)
hardsource
Right to Appeal Denied Request
Md. Code Com. Law § 14-4605(e)(3), (f)
hardsource
Sensitive Data — Flat Ban on Sale; Consent Required to Process
Md. Code Com. Law § 14-4607(a)(1)-(2)
hardsource
Minor Protections — Flat Ban on Sale and Targeted Advertising for Known Minors Under 18
Md. Code Com. Law § 14-4607(a)(4)-(5)
hardsource
Strict Data Minimization — Reasonably Necessary AND Proportionate
Md. Code Com. Law § 14-4607(b)(1)(i)
hardsource
Privacy Notice Requirements
Md. Code Com. Law § 14-4607(d)
hardsource
Universal Opt-Out Mechanism Required at Effective Date
Md. Code Com. Law § 14-4607(f)(3)(ii); § 14-4606(a)(2)
hardsource
Processor Contract Requirements
Md. Code Com. Law § 14-4608
hardsource
Enforcement — AG; 60-Day Cure
Md. Code Com. Law §§ 14-4613, 14-4614
hardsource