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ARLO HOTELS

PRIVACY POLICY

Part 1 (HHL 6-2-21)

PLEASE READ CAREFULLY BEFORE USING THIS SERVICE.

This Privacy Policy applies to your interactions with Quadrum Hospitality Group LLC and with any of its respective subsidiary companies (respectively referred to as “we”, “us” “our” or the “Company” in this policy) whose websites you access, including those of Arlo Hotels at www.arlohotels.com (the “Websites”) and your access to and use of our applications, and connected products and services (“Services”). This Privacy Policy explains our information collection practices, such as the types of information we collect and how we may use that information.

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY.

END USERS FROM OUTSIDE THE US ARE ENCOURAGED TO READ MORE

OVERVIEW

This initial summary of our Privacy Policy highlights some important points regarding collection and sharing of your information and third parties who may set cookies and collect information through the Services. Please review our full Privacy Policy below before using the Services.

1. USE OF INFORMATION.

We primarily use the information we collect through the Services in connection with your use of the Services and to communicate with you regarding news, special offers and other information.

2. SHARING OF INFORMATION.

We may share the information we collect through the Services with our vendors and third-party business and marketing partners, including companies who sponsor and offer sweepstakes, contests and similar promotions through the Services. We may also share information about you for legal and business reasons. If you are a California Resident, you may request additional information by contacting our Privacy Officer at the address listed below.

3. THIRD PARTIES COLLECTING INFORMATION THROUGH THE SERVICES.

The Services may contain content served by third parties, including videos and advertisements, and we work with third-party service providers to serve advertisements on the Services and elsewhere online. In connection with providing content and services, third parties may collect certain information about you and your visits to this or other web sites and we may receive information regarding the use of the Services and the effectiveness of our advertisements. These advertising networks, advertisers, ad agencies, analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your online browsing activities. Please contact our Privacy Officer at the address below for additional information, including regarding certain opt-out choices available to you.

INFORMATION COLLECTION

INFORMATION COLLECTION, REGISTRATION AND OTHER INFORMATION YOU PROVIDE

The Services may collect “Personal Information” (information that identifies you as a specific individual, such as your full name or e-mail address and demographic or other information (such as your ZIP or postal code and information about your interests and preferences). If we combine demographic or similar information with the Personal Information we collect, we will treat it as Personal Information under this Privacy Policy.

INFORMATION THIRD PARTIES PROVIDE ABOUT YOU

We may receive information about you from third parties. We may combine this information in our database and we may use it to offer you products or services, or for similar purposes. We also may supplement the information we collect with outside records from third parties. If we combine the information we receive from others with information we collect through the Services, we will apply this Privacy Policy to the combined information.

SOCIAL MEDIA/INTEGRATION WITH THIRD-PARTY PLATFORMS

The Services may permit you to interact with a third-party site or service, such as enabling you to “like” us on another site or “share” content from the Services with other sites (a “Social Networking Service”). If you choose to “like” or “share” content or to otherwise post information from or via the Services to a Social Networking Service, that information may be publicly displayed, and the third-party may have access to certain information about you and your use of the Services. Similarly, if you interact with us through a Social Networking Service, we may have access to information about you (for example, if you “like” or “follow” our page on a third-party site). Please note that if you mention or comment about us or the Services in your post to a third-party platform, the third-party platform may allow us to publish your post on the Services.

INFORMATION WE COLLECT AUTOMATICALLY

We and our third-party service providers (including analytics providers, advertising companies and third-party content providers), may automatically collect certain “Usage Information” whenever you visit or interact with the Services. “Usage Information” typically includes the browser and operating system you may be using, the URL or advertisement that referred you to the Services (if applicable), the search terms you entered into a search engine that lead you to the Services (if applicable), all of the areas within the Services that you visit, and the time of day you used the Services, among other information relating to your use of the Services. We may use Usage Information for a variety of purposes, including analyzing and improving the Services and products, to provide special offers, and to select appropriate content to display to you.

In addition, we automatically collect your internet protocol (IP) address, mobile device identifier or other unique identifier (“Device Identifier”) for any computer, mobile phone or tablet, or other device you may use to access the Services. A Device Identifier is a number that is automatically assigned or connected to the device you use to access a Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the geographic location of the device used to access a Service. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

COOKIES AND SIMILAR TECHNOLOGIES

The Services may include the following tracking technologies, and similar technologies, and which may be set and controlled by us or by our third-party providers:

Cookies: A cookie is a data file placed on your computer or other device when you visit the Services or otherwise access our online content. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences, tracking your visits to our web pages, and facilitating your check-out and purchases. We employ Adobe Flash cookies in certain situations where we use Flash to provide content such as video clips or animation. We do not use Flash cookies to serve interest-based advertising. For more information about Flash and the privacy choices Adobe offers, visit www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html . If you choose to disable cookies or to adjust your Flash privacy settings, some features of the Services may not function properly.

Web Beacons: Web beacons are small graphic images or other web programming code that may be found within the Services and our communications with you. Web beacons are used to recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, and to count whether an e-mail we sent was opened. Web beacons may be used to collect certain Personal Information (for example, the email address associated with an email message).

Embedded Scripts: An Embedded Script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device for use when you connect to the Services.

HOW WE USE INFORMATION ABOUT YOU

We may use information about you, including Personal Information and Usage Information, to:

  • provide and charge for hotel accommodation and other goods and services;
  • provide you with a better or more personalized level of service, including information and services from a third-party (such as additional guest services at our venues, local attractions and transportation options);
  • respond to requests for information and services, including services from a third-party (such as restaurants or transportation providers);
  • fulfill contractual obligations to you, anyone involved in the process of making your travel arrangements (e.g. travel agents, group travel organizers or your employer) and vendors (e.g. credit card companies, airline operators and third-party loyalty programs);
  • conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions and for other internal business;
  • provide for the safety and security of staff, guests and other visitors;
  • administer general record keeping;
  • meet legal and regulatory requirements;
  • test and evaluate new products and services; and
  • process credit applications.
  • process a transaction, including your registration with the Services and verifying information you provide is active and valid;
  • allow you to participate in features we offer or to provide related customer services (for example, to respond to your questions, complaints or comments);
  • tailor content, recommendations and offers we display to you on the Services and elsewhere online;
  • send you information regarding us or information from us relating to a third-party, including our parent or affiliated companies;
  • contact you with regard to your use of the Services including, in our discretion, changes to our policies; and
  • as described in this Privacy Policy and for purposes disclosed at the time you provide your information or otherwise with your consent.

INFORMATION SHARING

We do not sell your personal information. We may, however, share non-Personal Information, such as aggregate user statistics, demographic information and Usage Information with third parties, including advertisers, content providers, and analytics providers, in our discretion and for a variety of purposes. We also may share the information we have collected about you, including Personal Information, as described in this Privacy Policy, including the following.

Third-party Marketing Partners: We may share the Personal Information we collect through the Services with our subsidiaries and affiliates, and with third-party business and marketing partners, including companies who sponsor and offer sweepstakes, contests and similar promotions through the Services. Those third parties may reach out to you for their own marketing purposes. California Residents: for information on how to request additional information about third parties with whom we share Personal Information for their marketing purposes, see please contact our Privacy Officer as described below.

Sweepstakes, Contests and Promotions. We may work with third parties that sponsor or offer sweepstakes, contests, and other promotions. By participating in a promotion, you are agreeing to the terms, conditions or official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing us and the sponsor(s) of the promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing. If you choose to enter a promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.

Third Parties Providing Services on Our Behalf. We may provide third parties with access to user information, including Personal Information, in order for them to perform certain services on behalf of us or you, such as fulfilling and processing contest entries, tracking analytics, sending communications on our behalf or performing other administrative services.

Administrative and Legal Reasons. We may also transfer and disclose user information, including Personal Information, to third parties: (i) in the event we are required to respond to subpoenas or other legal process or if in our opinion such disclosure is required by law; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Terms and Conditions or other policies applicable to the Services or to protect the personal safety, rights, property or security of the Services or any individual. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion.

Business Transfers. We may share Personal Information with our parent, and with our subsidiaries and affiliated entities primarily for business and operational purposes. We reserve the right to disclose and transfer all information related to the Site, including Personal Information: (i) to a subsequent owner, co-owner or operator of the Sites or one of our databases; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of our ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process.

THIRD-PARTY AD NETWORKS, ANALYTICS PROVIDERS AND SIMILAR THIRD PARTIES

The Services may contain content served by third parties, including videos and advertisements, and we may work with vendors (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Services, to serve our advertisements through the Services and elsewhere online, and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. In connection with serving content and providing analytics and advertisement services, third parties may collect certain information about you and your visits to the Services or other web sites. These third parties may set and access their own tracking technologies (including cookies and web beacons) and may otherwise collect or have access to your Device Identifier and information about your visits to and activity on the Services, as well as other web sites or online services. Some of these third parties may collect Personal Information over time when you visit the Service or other websites and services.

Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. We may share Device Identifier and Usage Information about visitors with third-party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit https://www.networkadvertising.org/managing/opt_out.asp which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or https://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while online.

THIRD-PARTY CONTENT AND OUR CONTENT FOUND OUTSIDE OF THE SERVICES

The Services may contain links to third-party web sites that we do not control. For example, the Services may provide links to third-party sites through which you can purchase merchandise, products or services or which link to a product or service offered by a third-party. The Services may also contain certain third-party applications, such as email, web browser toolbars, wallpapers or other downloads or software applications. These third parties may collect Site Usage Information through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services.

SECURITY

We take commercially reasonable security measures to protect the Personal Information submitted to us, both during transmission and once we receive it, including encryption of Personal Information transmitted over the Internet.

However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee the security of any information you submit and you do so at your own initiative and risk.

CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the following rights:

  • Right to Know. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) the categories of sources from which the personal information was collected, (3) the business purpose for which we use this information, and (4) the categories of third parties with whom we share or have shared your personal information in the last 12 months;
  • Right to Access. The right to request, up to 2 times in a 12-month period, that we provide you access to or disclose to you, free of charge, the specific pieces of personal information we have collected about you in the last 12 months;
  • Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions;
  • Right to Opt Out. The right to opt-out of the sale of your personal information to third parties;

You also have the right to designate an authorized agent to submit one of the above requests on your behalf. You will not be discriminated against in receiving different or less favorable pricing, service or financial incentive for exercising any of the above rights.

How to submit a request
You can submit any of the these consumer requests by any of the 2 options below:

  • Submit an online request via our privacy request form
  • Call our privacy toll-free line at 1-833-589-8229.

How we will verify that it is really you submitting the request
When you submit a Right to Know, Right to Access, or Right to Delete consumer request through one of the methods provided above, we will ask you to provide some information in order to verify your identity and respond to your request. We will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us. For example, if your sole interaction with us was as a website visitor, then in order to verify your identify, we will need to ask you to provide your name, email, phone number, IP address, device ID, browser ID, and/or cookie ID.

How to authorize an agent to act on your behalf
You can authorize someone else as an Authorized Agent who can submit a consumer request on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized Power of Attorney or (b) provide other written authorization that we can then verify. When we receive a consumer request submitted on your behalf by an Authorized Agent, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your Authorized Agent.

Responding to your Right to Know, Right to Access, and Right to Delete requests
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days or 90 days total from the date we receive your request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Other California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. However, Woodside Hotel Group does not share your personal information with our affiliates or third parties for their use in marketing to you.

Children under the age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.

Questions about this policy
If you have any questions about this Privacy Policy, you should contact us by phone at 1-833-589-8229 or via email at Privacy@ArloHotels.com.

Changes
From time to time we may modify and/or update this Privacy Policy and so we encourage you to check back on a regular basis to determine if any changes have been made.
California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us one time per calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

CONTACT US

If you have questions or comments about this privacy policy, you can contact us at
Quadrum Hospitality Group LLC
261 5th Avenue, Suite 1802
New York, NY 10016
Attn: Privacy Officer
Or e-mail: Privacy@ArloHotels.com

(Last updated June 2, 2021)