PRIVACY POLICY

Geronimo Hospitality Group Privacy Policy

As part of our commitment to providing best-in-class service to our guests, Geronimo Hospitality Group has created this policy to describe our policies regarding our collection of information from our guests (“you” or “your”), our use of such information, and our privacy practices with respect to information collected by us. We strongly urge you to review this policy completely and carefully, so that you may make informed decisions regarding your personal information.

This privacy policy applies to information collected by Geronimo Hospitality Group, its subsidiaries, licensees, and affiliated companies (collectively, “we”, “our”, or “us”) through your (i) use of our website(s), our mobile applications, social media pages controlled by us, or other third party services made available for guest use at our hotel, restaurant, fitness and club properties (collectively, the “Services”), (ii) participation in our “Groupies” loyalty program; (iii) participation in any sweepstakes, promotion, or survey offered by us, and (iv) disclosure of personal information to us through any other means.

Please be aware that we are based in the United States and do not have any operations in any country other than the U.S., including, without limitation, any country in the European Union. We welcome guests from all countries to stay at our hotels and to visit our restaurants; however, we do not directly market to or offer services to any non-U.S. residents.

While your acceptance of this policy is voluntary, your continued use and/or participation in any of the foregoing constitute your acceptance of this policy and any other applicable terms.

What Data Do We Collect?

A. Reservations and Memberships.

When you make a reservation to stay at one of our hotels or to eat at one of our restaurants, or when you join one of our fitness centers or clubs, you will be required to provide certain personal data, such as your name, address, phone number, and email address. We collect this data due to contractual necessity, as it is necessary in order for us to complete your reservation or activate your membership. If you choose to not provide your personal data when making a reservation or becoming a member, we may be limited in our ability to complete your transaction and provide you with other services. We will retain your personal data for the period necessary to fulfill the purposes outlined in this section, unless a longer retention period is required or permitted by law.

When you make a hotel reservation, we receive personal data from a variety of third party sources with whom we partner. These sources include, but are not limited to, the booking engines we use to take reservations, which may provide information directly to us; online travel agents, such as Expedia; third party wholesalers to whom we make limited rooms available for sale; and through the global distribution system used by certain travel industry service providers, such as travel agencies.

B. Use of Services.

You may generally use the Services without disclosing personally identifiable information. However, use of certain aspects of the Services may require you to submit personally identifiable information.

When you use the Services, we automatically collect data on your usage of the Services and your online behavior, including previous websites you visited, your computer’s web browser, operating system, and IP address, and how you navigate and interact with the Services. We collect this information on an anonymous basis.

We may also collect additional information from you, depending on how you engage with us. For example, if you participate in our “Groupies” loyalty program, you will be asked to provide information such as your name, email address, birthday, and phone number. We may collect information from you if you communicate with us through email or participate in online surveys. These services may require you to provide your email address, your name, and comments.

You may voluntarily sign up on the Services to participate in surveys, contests, or sweepstakes, or to receive promotions and other marketing material from us. The information collected may include your name, email address, zip code, and birthday and anniversary information.

Additionally, the Services offer you the opportunity to place requests for future services or services during your stay at one of our properties, such as making a restaurant reservation, booking conference rooms or ballrooms, or requesting room service. Information collected from you when you place requests for services through the Services includes your name, phone number, and email, and information about the service requested. We may also need information regarding your room number. If shared by you, we may also collect data relating to your likes and dislikes about our services and specific dietary, health restrictions, or personal needs to ensure your wellbeing.

C. Limitations.

Please be aware that the technical limitations of certain third party services we use may limit our ability to fully control the data we collect, which may limit our ability to control certain online behavioral advertising conducted via the Services. As new tools become available, we will review and update our practices regarding the data we collect for marketing purposes.

Also, we take reasonable measures and implement appropriate safeguards to protect your personal information that we collect. However, by agreeing to this policy, you acknowledge that transmission of information over the Internet is, inherently, not secure. Security breaches cannot be prevented entirely, and by continuing to use the Services and applications, you accept the risk that a security breach of one of our systems or those of one of our third party service providers may occur. For that reason, we ask that you do not send your social security or credit card numbers to us through an unsecured email.

How Will We Use Your Data?

We use your personal data to create a reservation for your hotel stay, restaurant visit, or fitness and/or club membership, as the case may be. In connection with your reservation, we may use your personal data to (a) send you communications regarding your stay prior to your arrival; (b) personalize your experience during your stay and to offer you the level of service and hospitality you expect while staying at one of our properties; (c) send you communications regarding your stay after your departure, such as surveys to get feedback on your stay; and (d) facilitate making future reservations for you. Your personal data will be used by our associates in connection with these uses.

We use the information collected from you in a number of other ways, including, without limitation, to improve the content and navigation of the Services, to assist in the marketing and promotion of our services in which you may be interested, to communicate with you for customer service purposes (including to respond to you and address your feedback or request that you provided), and to prevent and detect fraud or other misuse of the Services. Further, we routinely share this information with third parties, such as industry data sharing services and promotional and other business partners.

Also, your personal data may be de-identified and aggregated with data regarding our other guests so that we may analyze customer travel preferences, predict and anticipate future behaviors, develop statistics based on guest data, and other similar internal business purposes.

We do not use your personal data to make any automated decisions or to build individual profiles.

Each of our hotels, restaurants, and clubs is located in the United States. As a result, we do not transfer your personal data outside of the U.S.; however, we cannot guarantee that one of our third party service providers will not transfer your personal data through a server outside of the U.S. as they provide services to us.

Third Parties. To enhance your experience with us, we use third party software and/or applications to provide you certain of the Services, which may require us or you to input personal information to use such Services. For example, we may retain third parties to (a) provide certain of the Services through third party platforms (such as the platform through which guests make online hotel reservations), and (b) place and manage advertisements through the Services. Certain of these third parties may automatically collect information from you, through cookies and other technology, in order to provide you with tailored advertisements on websites you visit. Each these third parties will collect and handle your data consistent with the terms of their respective privacy policies.

We may obtain contact details and other personal information regarding individuals, such as media contacts and influencers, from a variety of third party sources, including Agility PR Solutions. If you wish to know more about how such information is collected and used by Agility PR Solutions, please refer to their privacy notice at https://www.agilitypr.com/privacy-policy/.

We use Google Analytics to collect information about your use of the Services, your navigation to the Services, the time and date you used the Services, and your IP address. Google uses this information to provide use reports about traffic on the Services, which we receive pseudonymously. We are not able to use the data we receive from Google Analytics to identify any particular individual. For more information, please visit www.google.com/policies/privacy/partners.

We are not responsible for the privacy practices of any of our third party providers. This policy applies only to the information collected by us as specified in this policy. It is your responsibility to understand the individual privacy policies of any software, application, or website you use. In addition, we do not endorse the content, nor make any assurances about the security, of any third party software, application, or website, or of any links to other websites that are not operated or controlled by us.

Cookies. Cookies are small files that a website installs on your hard drive. Cookies enable our web server to recognize your computer, which allows the Services to tailor content to better match your interests and preferences. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent using the Services and the websites you visit just after using the Services. This information may be used to target advertising to you for goods or services that you may be interested in. The technical limitations of certain services we use may limit our ability to inform you before a cookie is placed on your computer. As new tools become available, we will review and update our practices regarding your ability to accept cookies when you visit our websites. However, you can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to block cookies altogether; however, doing so may impair your ability to use the Services. As noted above, third party digital marketing agencies may use their own cookies, which collect their own anonymous information independent of our activities.

Permitted Users. We do not specifically target the Services to children under 13 years old. If you are under the age of 13, you should only use the Services under the supervision of a parent or guardian.

Disclosures. We may be required to share personal information with third parties, including law enforcement or government agencies, as a result of a court order, subpoena, or as otherwise required by law. Additionally, we may disclose your information as part of a planned or potential corporate sale, merger, reorganization, consolidation, or similar events. Your information will be treated as an asset and be transferred to the purchaser as part of a sale or other transaction. Otherwise, we do not share your personal data with any third parties; however, as noted earlier, your data was likely provided to us by a third party providing services to us in connection with operating our hotels, restaurants, and/or clubs.

Modification. We reserve the right to change this policy at any time and from time to time without notice. You are responsible for keeping apprised of the current policy; thus, we encourage you to check this policy periodically. Any changes or updates will be effective immediately upon the posting of the revised policy on the Services. Your continued use of the Services constitutes your acceptance of any revised policy. However, we will endeavor to provide notice of any material changes to this policy by posting notice on the Services.

Opting Out. You are never obligated to provide us with any personal information. However, if you choose not to share any personal information, we may be limited in what Services we can provide you, such as making a reservation at one of our hotels or restaurants. At any time, if you would like to cease receiving communications from us or limit our ability to share your information with third parties, you may “opt out.” You may unsubscribe to all communications from us by filling out an unsubscribe form located on the Services. To limit how we otherwise use or share your information, please send an email to marketing@geronimohospitalitygroup.com.

Last Updated: August 23, 2023