Privacy Policy

PRIVACY POLICY FOR THE MEMBERSHIP HOTEL ORGANIZATION, LLC.

This is the Privacy Policy of the Membership Hotel Organization, LLC and its affiliates (collectively “MHO” or “us” or “we”). MHO prepared this privacy statement to inform you about how we collect, use, disclose, and safeguard your Personal Information. This Privacy Policy covers all data we collect through any channel, including:

  • When you use and interact with the websites we operate (the “Websites”);
  • When you stay as a guest at one of our franchised properties, or otherwise interact with us offline;
  • and When we email you;

Throughout this Privacy Policy, we refer to the different ways we interact with you as “Services”. We reserve the right to change the Privacy Policy at any time. Your use of the Services constitutes acceptance of the Privacy Policy, and any continued use of the Services after we modify the Privacy Policy constitutes acceptance of those changes. You should check this page periodically for updates.

The Websites may contain links to third-party websites, including our independently-owned franchisees’ websites. We do not own, operate, or control third parties or MHO franchisees,reservation agents, or travel agents. Therefore, this Privacy Policy does not apply to any third- party website. When you click on those links, you will be subject to that third-party website’sprivacy policy. We are not responsible for the privacy policy of those other websites, and disclaim any liability for their actions, including actions related to disclosure of your Personal Information. You hereby waive any claim against us with respect to, relating to, or arising from any third party website.

Personal Information We Collect

By using the Services, you provide and we collect, your Personal Information in order to provide you with the Services, maintain and improve the Websites, improve our Services, comply with our legal obligations, and inform you about other services and products we and our affiliates provide. As used in this Privacy Policy, “Personal Information” means any information that identifies or can identify you personally. The types of Personal Information we may collect include:

  • Your name;
  • Your mailing and billing addresses;
  • Your email address;
  • Your telephone number;
  • Your payment card information;
  • Government identification information;
  • Your location via IP address;
  • What type of device you are using to access the Services;
  • Cookies and similar technologies;
  • Information about your stay at independently-owned franchise locations;
  • Your preferences regarding your hotel stay; and
  • Other relevant data.
How We Collect Your Personal Information

We, or our affiliates or third parties, agents, or subcontractors acting on our behalf may collect and store your Personal Information through:

  • Direct Interactions – You may provide us with your Personal Information directly when filling out a form, making a reservation, subscribing to our email list, or otherwise by interacting with us in person, by mail, by phone, by email, or otherwise.
  • Automated Interactions – We may automatically collect information about your browsing actions, web-use patterns, and device when you interact with our Websites. We collect this information by using cookies, server logs, and similar technologies. We may also collect this information when you use other websites that employ our cookies. Although this information generally does not reveal your specific identity, to the extent that it does we will protect it in accordance with this Privacy Policy.
How We Use Your Personal Information

We do not sell, trade, rent, or release your Personal Information to anyone outside MHO, its contractors, affiliates, or independently-owned franchise locations, other than in compliance with this Privacy Policy. We use your Personal Information to administer our business activities, provide customer service, personalize your experience, contact you concerning your stay at a MHO-branded hotel, and provide you with information about our Services. We share your information with independently-owned MHO franchise locations, credit card processors, and other companies when necessary to complete your transaction. We may also use your Personal Information for marketing and promotional purposes.

When We Share Your Personal Information

When you make a reservation through our Websites, we need to transfer your Personal Information to independently-owned franchise locations. Some of these locations may be in countries other than your country of residence, and the data security laws governing those locations may differ from those in your country.

We also distribute your Personal Information to third party service providers, such as web analytics companies and market researchers. We use such third parties to conduct data processing, engage in email and direct-mail communications on our behalf, administer sweepstakes and contests, administer guest surveys, compile information about guest stays,and provide us with information about how users interact with our Services.

We may also provide your Personal Information to other companies that we may partner with to co-sponsor or co-brand sweepstakes, promotions, or loyalty programs.

Although unlikely, we may disclose your Personal Information when we believe it is necessary to identify, contact, or bring legal action against you or persons or entities who may be causing injury to you, to us, or others. We may also disclose your Personal Information when we believe it is required by law.

We may disclose your Personal Information to a third party in the event that we engage in a proposed reorganization, merger, sale, joint venture, assignment, transfer, or otherwise dispose of all or any portion of our business, including in connection with a bankruptcy or similar proceeding.

How We Store Your Personal Information

Your Personal Information is stored on our servers in the United States. We maintain reasonable technical, electronic, and organizational security procedures to maintain the security of your Personal Information and protect it against unauthorized or unlawful loss, alteration, disclosure, or access. Those procedures include contractual terms with contractors, franchisees, agents, and data processors that require those entities to protect the security and confidentiality of your Personal Information. While we strive to protect your Personal

We will maintain and store your Personal Information for as long as we are required to do so by applicable laws or for as long as necessary for use to use the information in the manner described above. When your Personal Information is no longer needed, we will take appropriate steps to anonymize or delete it, unless we must keep that information to comply with applicable laws. In any case, we will not keep your Personal Information beyond the maximum term set by any applicable law.

Children

MHO does not knowingly collect Personal Information from children under the age of 18 and users under the age of 18 should not submit any information to MHO. If MHO has actual knowledge that Personal Information about a child under the age of 18 has been collected, then MHO will take the appropriate steps regarding that Personal Information.

Cookies and Other Tracking Technologies

We may use cookies and other tracking technologies in connection with our Websites. Cookies are small amounts of computer code that interact with your computer, mobile device, browser,or email. The cookies on our website typically fall into one of the following categories:

  • Strictly Necessary Cookies – These cookies are required for the operation of our Website, for example the cookies that allow you to log into a secure area.
  • Analytical/Performance Cookies – These cookies allow us to recognize and count the number of users on our Websites, track how our Websites perform, and improve the function of our Websites.
  • Functional Cookies – These cookies improve the functional performance of our Websitesand make them easier for you to use.
  • Targeting Cookies – These cookies record your visit to our Websites, the pages that you visited, and the links you followed. These cookies remain on your device, and you can delete these cookies via your browser settings. We will not collect these cookies from individuals in the EU or in California without first obtaining consent.
  • We may use cookies in a number of ways, including to facilitate our reservation process, tailor our services to suit your personal interests track your status in our promotions, and analyze your visiting patterns. We do not use your cookies to ascertain any personally identifiable information that you do not otherwise voluntarily provide us.

    We may use cookies to form an association between multiple of your devices, such as your computer and smartphone. This is called device fingerprinting, and provides you with a more convenient and personal digital experience.

    You can generally set your browser to not accept cookies or to notify you when you are sent a cookie. Not accepting cookies will adversely impact your ability to perform certain transactions and use certain functions of our Websites.

    We, our affiliates, and third-party contractors on our behalf may also use cookies for targeted advertising purposes. You may opt out of allowing us to use your information for targeted ads by contacting Mahendra Patel at info@mhohotels.com or 609-756-9300.

    We also work with third parties that use tracking technologies to collect data or provide tailored advertisements on our behalf, including Google Analytics, among others. To prevent Google’s collection and use of data, download and install a browser plug in available at https://tools.google.com/dlpage/gaoptout. For information about other targeted advertisements, visit www.allaboutads.info.

    Your Rights as a California Resident

    This section contains disclosures required by the California Consumer Privacy Act of 2018 (“CCPA”) and applies only to the Personal Information subject to the CCPA.

    The information we collect and disclose is the same for guests from all geographies, except as otherwise noted in this Privacy Policy. Regarding selling personal information as defined in the CCPA, we do not sell any of the Personal Information we collect.

    We collect, use, and share Personal Information from California residents for commercial purposes, including marketing, advertising, sweepstakes, facilitating transactions, and co-sponsored and co-branded promotions, contests, products and services; for business purposesas defined in the CCPA including, auditing and analysis related to our interactions with you, legal compliance, detecting and protecting against security incidents, fraud, and illegal activity,debugging, performing services, internal research, internal operations, activities to maintain and improve our services, to facilitate services you request, and in the event of reorganizations, mergers, sales, joint ventures, assignments, transfers, or other dispositions of part or all of our business assets or stock.

    We disclose the categories of personal information designated in our privacy policy to the following categories of third parties for business purposes: service providers, MHO affiliates government entities, franchisees, legal entities, advertising networks, internet service providers, data analytics providers, operating systems and platforms, social networks business partners.

    YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

    California consumers have certain rights with respect to the personal information collected by MHO. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

    • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
    • The right to request that we delete the personal information we have collected from you or maintain about you;
    • The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we may be unable to provide you with the services that rely on such sales;
    • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.
    • To exercise your right to know or right to request that we delete, please submit your request by calling us at 609-756-9300 or sending an email to info@mhohotels.com. To exercise your rightto opt out of our sale(s), please click on the ‘Do Not Sell My Personal Information’ link in the footer of our Website.

    Your Rights as an EU Citizen

    This section contains disclosures required by the Global Data Protection Regulation Act (“GDPR”). It applies only to residents of the European Economic Area. The information we collect and disclose is the same for guests from all geographies, except as otherwise noted in this Privacy Policy. We do not sell any Personal Information we collect.The GDPR gives you certain rights. Those rights are:

    • The right to be informed; This means anyone collecting your Personal Information must make clear what they are collecting, why, and who else the information may be passed to.
    • The right of access; this is your right to see what information about you we hold;
    • The right to rectification; the right to have your information corrected or amended if it is incorrect in some way;
    • The right to erasure; under certain circumstances, you can ask for your Personal Information to be deleted. This would apply if the information is no longer required for the purpose it was collected or, you withdraw your consent to collect your information, or the information has been used unlawfully;
    • The right to restrict processing; this gives you the right to ask for a temporary pause to processing your Personal Information in certain circumstances;
    • The right to data portability; this gives you the right to ask for any information you provide us to be made available to you in a structured, commonly used, and machine- readable format;
    • The right to object; this gives you the right to object to further use of your information in ways inconsistent with the primary purpose for which it was collected, for example marketing; and
    • Rights in relation to automated decision making and profiling; you have the right to not be subject to a decision based solely on automated processing.

    To exercise your right to know, right to request that we delete, or any other rights under the GDPR, please submit your request by calling us at 609-756-9300 or sending an email to info@mhohotels.com. To exercise your right to opt out of our sale(s), please click on the ‘Do Not Sell My Personal Information’ link in the footer of our Websites.

    Questions and Concerns

    You may direct any questions or concerns about this Privacy Policy or the ways we use your Personal Information to info@mhohotels.com or by writing to 187 Route 130, Bordentown, NJ 08505.