Privacy Policy

Effective date: May 24, 2018

Spanish Court Hotel ("us", "we", or "our") understands that our guests, customers, clients, users, visitors ("Guests and Clients") put their trust in us, and we are committed to protecting personal data that we collect through websites we operate ("Websites"), software applications ("Apps") we make available on or through mobile devices or computers ("Apps"), through wireless/wi-fi connectivity that may be offered at our properties ("Wi-Fi Access"), and through social media channels that we control ("Social Media Channels," collectively with Websites, Wi-Fi Access and Apps, the "Services") that link to this Privacy Statement. This Privacy Statement describes our global practices regarding the collection, use, and sharing of data about identified or identifiable individuals through the Services ("Personal Data").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services and the choices you have associated with that data.

We use your data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this policy.

This Privacy Statement covers the following topics:

• Definitions
• Data Collection
• Use of Data
• Retention of Data
• Transfer of Data
• Disclosure of Data
• Security of Data
• Your Rights Regarding Personal Data
• Service Providers
• Email, Opt-Out, and Marketing Communications
• Links to Third-Party Websites and Services
• Children’s Privacy
• Changes to This Privacy Policy
• Contact Us

Definitions

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on a User’s device.

Data Controller

Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers)

Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject

Data Subject is any living individual who is the subject of Personal Data.

User

The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Data Collection

We collect a variety of Personal Data from you through the Services. Some Personal Data is collected automatically when you use or browse the Services, while other data is only collected when you provide it to us directly.

As a result, you have choices about the data we collect. When you are asked to provide data, you may decline; but if you choose not to provide data that is necessary to provide a service or feature, you may not be able to use that service or feature.

Types of Data Collected

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally, identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

Usage Data

We may also collect information on how the Services are accessed and used ("Usage Data"). When you download and/or use an App or browse a Website, we collect information about your device and the network you use to access the Services, as well as information about your use of the Services. This includes software and hardware attributes of the device used, unique device information (such as unique International Mobile Equipment Identity (IME) numbers for smartphones), regional and language settings, network provider, and IP address, as well as Service performance data, dates and times that you use the Services, the amount of time spent on specific pages or in specific channels, and other similar usage information.

Location Data

We may also collect location data, depending on the Services you use or the permissions you provide. "Precise" location data may be derived from your device's GPS and location systems, as well as nearby wi-fi networks and cell phone towers. Imprecise location data may include your IP address or other data that may identify you as being located in a specific region, city, or postal code. You can manage the Services' ability to track your location by allowing or disallowing that access for a given Service in your computer or mobile device's settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies we use:

• Session Cookies. We use Session Cookies to operate our Services.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.

Use of Data

Spanish Court Hotel uses the collected data for various purposes:

Providing Services

We use Personal Data to provide products, services, and information to our Guests and Clients, including for the purposes of booking rooms, providing food and beverages, and providing other amenities and services.

Customer Service and Support

We use the Personal Data we collect for customer service and support, as well as to deliver and personalize communications with our Guests and Clients. This includes communicating with you regarding products, services, and discounts; answering questions and inquiries; responding to complaints and requests; and providing customer care.

Business Operations

We use the Personal Data we collect to operate our businesses. This includes marketing; monitoring usage of products, services, and systems; analyzing and storing Guest and Client preferences, and traffic patterns; operating our hotel and serving our Guests and Clients; and improving the Services, offerings, and products.

Marketing and Communications

We use Personal Data to deliver and personalize communications with our Guests and Clients, including providing recommendations, special offers, information on benefits, information about our hotel, restaurants, bars and other facilities, information about events and activations on site at our properties and off-site, and other marketing communications. For information about managing email subscriptions and marketing or promotional communications, review the Email, Opt-Out, and Marketing Communications section of this Statement.

Safety, Security, and Dispute Resolution

We use Personal Data to protect ourselves and our employees, Guests and Clients, as well as any vendors and service providers ("Providers"), and others. This includes authenticating user activity; enforcing our and our Providers' Terms of Use and monitoring and preventing fraudulent, abusive, or unlawful activity. In addition, we use and disclose Personal Data to the extent we deem necessary to protect the rights, property, safety, operations, and privacy of Spanish Court Hotel and its Guests and Clients, personnel, providers, affiliates, or others and as we deem necessary to comply with applicable laws, regulations, rules, and requests of law enforcement and/or other governmental agencies.

Employment or Other Engagement

If you are applying for a position, we use Personal Data to process and evaluate your application and, if you are engaged, in connection with your engagement.

When information is collected from you, the description of how we will use the Personal Data will be available to you at the time of collection through this Privacy Statement.

Retention of Data

Spanish Court Hotel will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data 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.

Spanish Court Hotel 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 Services, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your Personal Data may be stored, used, and processed in any country where we have facilities or where we have engaged a Provider, and by your use of the Services you acknowledge that we may transfer information to countries outside of your country of residence, which may have different data protection rules than in your country. All Personal Data held by Spanish Court Hotel directly is stored at the property and/or in the United States, which may require transfer of the Personal Data from your location to the property's location and/or the United States.

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

Spanish Court Hotel will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data 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.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, Spanish Court Hotel may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Spanish Court Hotel may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Spanish Court Hotel
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Security of Data

We maintain reasonable physical, administrative, and technical security measures to protect the confidentiality, availability, and integrity of Personal Data.

It is important to note that no method of safeguarding information is completely secure. While we try to ensure the protection of your Personal Data, we cannot guarantee (or be accountable/liable) that our safeguards will be 100% effective or sufficient.

Your Rights Regarding Personal Data

Spanish Court Hotel aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

Users of the Services, including you, have a variety of legal rights regarding the processing of Personal Data. These rights vary depending on applicable law, but may include by way of example:

• The right to know what Personal Data we maintain about you;
• The right to know with whom we have shared your Personal Data;
• The right to receive a copy of your Personal Data; and
• The right to access, correct, or delete your Personal Data.

You may exercise any rights you have under your applicable law with respect to Personal Data by contacting us as described below. We may request additional information from you to authenticate any such requests.

Service Providers

We may employ third party companies and individuals to facilitate our Services ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

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

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 Service. 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 Service 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: http://www.google.com/intl/en/policies/privacy/

Behavioral Remarketing

Spanish Court Hoteluses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

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: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout- for your web browser. 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 more information on the privacy practices of Google, please 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 http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/or the European Interactive Digital Advertising Alliance in Europe 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/privacy/explanation

Email, Opt-out and Marketing Communications

If you no longer wish to receive email communications from us, you can follow the specific unsubscribe instructions in the email you receive or contact us at the address below. If you do business with us, you may not opt out of certain automated notifications (including confirmation, welcome, and post-departure emails) based on the particular transaction.

Links to Third-Party Websites and Services

The Services may contain links to third-party services, content, or products that are not affiliated with us. We are not responsible for examining or evaluating the content or accuracy of such third-party websites, and we do not warrant and will not have any liability or responsibility for any third-party materials or websites, or for any other materials, products, or services of third parties. Refer to the privacy statements for such third-party services for information about what they collect and how they use your data.

We are not liable for any harm or damages related to the purchase or use of goods, services, resources, content, or any other transactions made in connection with any third-party websites. Please review carefully the third party's policies and practices and make sure you understand them before you engage H any transaction. Complaints, claims, concerns, or questions regarding third-party products should be directed to the third party

Children's Privacy

Our Services do not address anyone under the age of 13 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

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, please contact us:

• By email: info@spanishcourthotel.com
• By phone number: 876.926.0000