This Privacy Policy applies to OLS Hotels and Resorts dba Springboard Hospitality Portfolio of Brands, its subsidiaries and all of the hotels within the Springboard Hospitality Portfolio of Brands (collectively, “OLS Hotels,” “Springboard Hospitality,” “we,” or “us”). At Springboard Hospitality, we strive to deliver outstanding products, services, and experiences around the world. We value your business, loyalty, and privacy and have developed this Privacy Policy to inform you of our policies regarding the collection, use, and disclosure of your information when you use our Site and the choices you have associated with that information. This Privacy Policy also applies to information we collect in email and other electronic messages between you and this Site.

The singular term “Site” includes all websites that collect information from you that the we may have now or in the future operate that link to this Privacy Policy, web pages within each such website, device or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application and web pages that are associated with each such website, device, or application. This Privacy Policy does not apply to any website operated by third parties.

By accessing or using this Website, you agree to the collection and use of information in accordance with this Privacy Policy. This policy may change from time to time (see Changes to This Privacy Policy). Your continued use of this Site after we make changes is deemed acceptance of those changes, so please check the Privacy Policy periodically for updates. By accessing the Site, you acknowledge the applicability of this Privacy Policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from any Springboard Hospitality website.

The Springboard Hospitality Portfolio of Hotels includes Airtel Plaza Hotel, Banyan Harbor Resort, Chamberlain West Hollywood, Getaway Carmel, Grafton on Sunset, Harbor Court Hotel, Hideaway Carmel, Hotel Renew, Hotel Winters, Montrose West Hollywood, Le Parc Suite Hotel, Marin Suites, Hotel Erwin, Pacific Monarch Hotel, Plantation Hale Suites, Royal Grove, Studio City Court Yard, Carriage House Las Vegas, Hilton Garden Inn Denver Airport, Hilton St. Louis Frontenac, SFO Airport Hotel, El Rancho Inn Signature Collection, Best Western Orlando Gateway Hotel, The Wilde Resort and Spa, Hawaii, White Sands Hotel, Ohia Waikiki Studio Suites, The Virginian Lodge, Waikiki Sand Villa, Kauai Beach Resort.

INFORMATION WE MAY COLLECT

Springboard Hospitality collect several types of information from and about users of our Site, which may include information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). This may include your name, phone number, email address, mailing address, and other personally identifiable information that you provide us.

We may also collect certain information from you automatically when you use our Site (“Usage Information”). This information may include, without limitation, your IP address, MAC address, Site usage statistics, time stamps, browsing history, device information, the type of browser you use, and other information regarding your use of our Site or other services.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you direct your browser to our Site. For more information about cookies, please visit http://www.usa.gov/optout-instructions.html.
• Web Beacons. Small graphic images may be included on our Site and allow us to count users who have visited our Site or otherwise study engagement with our Site through other related website statistics (for example, recording the popularity of certain website content).
• Embedded Scripts. An embedded script is code that helps us collect information about a user’s interactions with our Site, such as the links clicked on.

HOW WE MAY USE THE INFORMATION WE COLLECT

We may use the information we collect for the following business or commercial purposes:

• To maintain, plan, and improve our Site and other services;
• To send emails or newsletters, and to provide you with general or personalized content in the newsletters as requested;
• To allow you to use certain interactive features of our Site;
• To provide customer support;
• To monitor and analyze information regarding your browsing and viewing preferences;
• To process and respond to your inquiries;
• For the purposes for which you provided the information;
• To enforce our Terms of Use;
• For fraud prevention, security, internal operations, legal compliance, and other public purposes.

WHY WE MAY DISCLOSE INFORMATION TO THIRD PARTIES

Under certain circumstances, Springboard Hospitality may disclose your Personal Information if required by law, court order, government regulation, or where we believe such action is necessary to protect your interests and ours. Specifically, we may disclose your Personal Information when such action is reasonably necessary:

• To comply with a legal obligation;
• To protect and defend the rights and property of our customers and any of the Springboard Hospitality hotels, restaurants, spas or other managed assets;
• To prevent or investigate possible wrongdoing in connection with our Site or other services;
• To protect the personal safety of our customers, Springboard Hospitality personnel, or the public;
• To protect our legal rights, such as through responding to subpoenas and defending litigation.

We may disclose your Personal Information to third party companies and individuals who facilitate our Site and other services (“Service Providers”) so that they may provide services on our behalf, perform Site-related services, or assist us in analyzing how our Site is used. Service Providers only have access to your Personal Information to perform these tasks on our behalf and are obligated not to use or disclose your Personal Information for any other reason.

Springboard Hospitality reserves the right to disclose and transfer the information we collect in connection with the negotiation, planning, or completion of a corporate merger, consolidation, restructure, or other corporate change.

RETENTION OF DATA

Springboard Hospitality will retain your Personal Information only for as long necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Springboard Hospitality will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.

TRANSFER OF DATA

Your Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside of the United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States for processing.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Springboard Hospitality will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

SECURITY

The security of your Personal Information is important to us, but please be advised that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we do our best to protect your Personal Information, we cannot guarantee the security of information transmitted to us through our Site or other electronic means. Any electronic transmission of Personal Information is at your own risk.

YOUR RIGHTS

Subject to applicable law, you may have the right to request access to, rectification, or deletion of your Personal Information. In certain circumstances, you have the right to:

• Access and receive a copy of the Personal Information we hold about you.
• Rectify any Personal Information held about you that is inaccurate.
• Request the deletion of Personal Information held about you.

You may be able to update some of your Personal Information directly through your account settings where possible. Otherwise, please note that we may need to verify your identity before responding to requests related to your Personal Information.

California consumers have additional rights to learn about the Personal Information a business has collected, sold and disclosed about them, opportunities to opt-out of such sales, opportunities to request deletion of their Personal Information, and protection from discrimination for exercising their rights. These rights are more thoroughly discussed below.

You may be able to update some of your Personal Information directly through your account settings where possible. Whenever made possible, you can update your Personal Information directly within your account settings section. If you are unable to change your Personal Information, please contact us to make the required changes. Springboard Hospitality aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information.

ANALYTICS

We may use third-party Service Providers to monitor and analyze the use of our Site.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Site available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page at http://www.google.com/intl/en/policies/privacy/.

• Behavioral Remarketing Springboard Hospitality uses remarketing services to advertise on third party websites to you after you visited our Site. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Site.
• Google AdWords Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page at http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on for your web browser at the following link: https://tools.google.com/dlpage/gaoptout . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For information on the privacy practices of Google, visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
• Facebook Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA at http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada at http://www.youradchoices.ca/, or the European Interactive Digital Advertising Alliance in Europe at http://www.youronlinechoices.eu/, or opt-out using your mobile device settings. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com https://www.facebook.com/privacy/explanation.

LINKS TO OTHER SITES

Our Site may contain links or references to other websites outside of our control. Please be aware that this Privacy Policy does not apply to those websites. We encourage you to read the privacy statements and terms of conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect or solicit your Personal Information. We do not control and are not responsible for what third parties do in connection with their websites, or how they handle your Personal Information. Please exercise caution and consult the privacy policies posted on each third-party website for further information.

SECURE RESERVATIONS

Online reservations for Springboard Hospitality is handled by a third party vendor, SynXis. When making reservations, you will leave the Site and go to a separate website maintained by SynXis and be subject to Synxis’s privacy policy regarding the collection of your information. Please note that any information you provide to SynXis to make a reservation with Springboard Hospitality will be shared with Springboard Hospitality for the purposes described above.

CHILDREN’S PRIVACY

Our Site is not intended for anyone under the age of 13 and we do not knowingly collect Personal Information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child or children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at [dataprotectionoffice@SpringboardHospitality.com].

YOUR CHOICES FOR COMMUNICATIONS

If you have a profile with Springboard Hospitality, you may change the communications you receive from us by logging on to your online account and managing your subscriptions, by writing to us (and including your email address) at Springboard Hospitality Protection Officer, 16000 Ventura Blvd Suite 1010, Encino CA 91436, USA, or by emailing us at dataprotectionoffice@springboardhospitality.com.

If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time. Any changes we make will be posted on this page. If we make material changes to how we treat your Personal Information, we will notify you via email and/or a prominent notice on our Site. The date this Privacy Policy was last updated is identified above. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

If you have any questions about this Privacy Policy or how Springboard Hospitality processes your personal information, or if you wish to either provide a compliment or a complaint, please contact us by email at dataprotectionoffice@springboardhospitality.com or send postal mail to Springboard Hospitality, 16000 Ventura Blvd, Suite 1010 Encino, CA 91436 USA. We will respond within 30 days or sooner if practicable.

PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

This section applies solely to eligible residents of California, and any terms not defined in this section have the same meanings as defined in the California Consumer Privacy Act (“CCPA”).

Springboard Hospitality may have collected the following categories of Personal Information from you within the last 12 months:

• Identifiers. This category may include: name, postal address, online identifiers, email address, account name, or other similar identifiers.
• Personal Information categories listed in the California Customer Records statute. This category may include: name, signature, address, telephone number, financial account numbers, medical information, or health insurance information.
• Internet or other electronic network activity information. This category may include: browsing history, search history, and information regarding interactions with an Internet Web site, application, or advertisement.

If you are an eligible California resident, the CCPA provides you with specific rights with respect to our collection and use of your Personal Information over the past 12 months.

Sales of Personal Information:

In the preceding twelve (12) months, Springboard Hospitality has not sold your personal information to any third parties.

Right to Know

Upon submission of a verifiable consumer request for the Personal Information that Springboard Hospitality has collected about you, subject to certain exceptions under applicable law, we will disclose to you:

• The categories of Personal Information we collected about you;
• The categories of sources from which Personal Information was collected;
• The business or commercial purpose for collecting your Personal Information;
• The business or commercial purpose for disclosing your Personal Information;
• The categories of third parties with whom we disclosed the category of personal information for a business purpose; and
• The specific pieces of Personal Information we have collected about you.

Right to Request Deletion

If you are an eligible California resident, you also have the right to request that we delete any of your Personal Information that we collect or maintain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete your Personal Information, we will conduct a reasonable search of our records in order to locate any Personal Information we have collected about you that is eligible for deletion, and delete such Personal Information. To the extent we have shared any Personal Information collected about you with other third parties that is eligible for deletion, we will direct those third parties to delete that Personal Information as well. Springboard Hospitality may not be able to comply entirely with your request to delete all of your Personal Information as set forth under the CCPA. Specifically, we are not required to delete any Personal Information we have collected about you that is necessary for us to:

• Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between Springboard Hospitality and you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
• Comply with a legal obligation, such as retaining records for a period of time as set out in local, state, or federal laws.
• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided your information.

Following a deletion request, any Personal Information about you that was not deleted from our systems due to the above exceptions will only be used for the purposes provided for by the applicable exceptions.

Right to Non-Discrimination for Exercising your Privacy Rights

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by applicable law, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising your California Privacy Rights

You do not need to create an account with us to exercise your CCPA rights. To exercise the CCPA rights described above, please submit a verifiable consumer request to us by:

• Contacting us by email at dataprotectionoffice@springboardhospitality.com;
• Postal mail to Springboard Hospitality, 1600 Ventura Blvd, Suite 1010 Encino, CA 91436 USA.

Only you, the person to whom you have given power of attorney, or an otherwise authorized agent registered with the California Secretary of State, may make a verifiable consumer request related to your Personal Information. However, you may make a verifiable consumer request on behalf of your minor child. Additionally, you may only make a verifiable consumer request for access twice within a 12-month period.

Your verifiable consumer request must provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. While we may ask for Personal Information to verify the requestor or consumer’s identity when making a request, we will only use that Personal Information provided in a verifiable consumer request to verify the requestor’s identity and authority to make the request.

Response Timing and Format

We will make our best effort to respond to a verifiable consumer request within 45 calendar days of its receipt. If we require more time (up to 90 calendar days), we will inform you of the reason and extension period in writing. Within 10 business days of receiving the request, we will confirm receipt and provide information about our verification and processing of the request. Springboard Hospitality will maintain records of consumer requests made pursuant to CCPA as well as our response to said requests for a period of at least 24 months.

If you have an account with us, we may require you to take delivery of our written response through that account. If you do not have an account with us, we will deliver our written response electronically, though you may alternatively choose to receive delivery by mail. The response will also explain the reasons we cannot comply with a request, if applicable. Requests for the specific pieces of information that we have collected about you will be sent in a portable, readily useable format that you may transmit to another entity without hindrance.

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 Rights (“Shine the Light”)

In addition to your rights under the CCPA, pursuant to California Civil Code Section 1798.83, California residents who have provided their personal information to Springboard Hospitality may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following addresses: CA-privacy@springboardhospitality.com or Springboard Hospitality 16000 Ventura Ave Suite 1010, Encino, CA 91436 USA. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

If you are a California resident under the age of 18, and a registered user of any site where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to CA-privacy@springboardhospitality.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.