Privacy Statement

Effective Date: January 1, 2025

La Fontaine and its subsidiaries and affiliated companies are committed to protecting the privacy of certain data that is collected about you. This Privacy Statement describes our policies and practices regarding the collection, use, and disclosure of personal data or personal information, as defined by applicable law (“personal data”), that we collect about you.

This Privacy Statement applies to information collected by the Company and its subsidiaries and affiliates, and our third-party hotel management company (collectively referred to in this Privacy Statement as the “Company”, “we”, “us” or “our”), Davidson Hotel Company LLC and its subsidiaries and affiliated companies (collectively, “Davidson”).

Our Privacy Statement Explains

1. When This Privacy Statement Applies
2. Terms of Use
3. Information We Collect
4. How We Use Information We Collect
5. Information We Disclose
6. Your Failure to Provide Personal Data
7. Our Retention of Your Personal Data
8. Your Choices and Accessing, Updating or Deleting Your Personal Data
9. Third Party Links
10. International Transfer
11. How We Protect Personal Data
12. Children
13. Job Applicants and Team Members
14. "Do Not Track" Signals
15. Changes to this Privacy Statement
16. Applicable Law
17. California Consumer Privacy Statement
18. Other Specific States’ Privacy Rights
19. European Users’ Privacy Rights
20. How to Contact Us

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites and the Services (as hereinafter defined), you signify your acceptance of this Privacy Statement. If you do not agree to this Privacy Statement, please do not use the Sites or Services.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live.

If you provide personal data about other people (for example, you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

If you have any questions or comments about this Privacy Statement, please submit a request to privacy@davidsonhospitality.com.

When This Privacy Statement Applies

Our Privacy Statement applies to the Sites under the Company’s operation and control and to the Services offered by the Company, but excludes websites, apps, other online media and services that have separate privacy policies that do not incorporate this Privacy Statement.

The types of personal data we collect, and to which this Privacy Statement applies, may include personal data you submit or we obtain when you access or use this website or websites, apps, or other online media under our operation and control, or through HTML-formatted email messages that we send to you that link to this Privacy Statement (collectively, the “Site”).

This also includes certain other personal data relating to you that we collect when you make a reservation, stay as a guest at our property, attend events at our property or events hosted by our property, use on-property services at our property, such as concierge and meeting services, visit on-property outlets at our property, such as restaurants and spas (collectively, the “Services”), or apply for or accept a position as a Team Member at our property.

We are not responsible for data collection, data use practices, privacy policies or the use of cookies or tracking technologies on hotel brand websites or other non-Company websites that you may access from this Site or that have directed or connected you to this Site.

If you are a California consumer, as defined by the California Consumer Privacy Act, as amended (CCPA), please also see the section below regarding your California Privacy Rights. If you are a consumer from other U.S. states that have enacted legislation affecting your privacy rights, please see the section below on Other Specific States’ Privacy Rights. If you are located in the EU, please see the section below on EU specific rights.

Terms of Use

By accessing or using the Sites in any manner, you also agree to be bound by the Company’s Terms of Use (the "Agreement"). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information We Collect

We collect information, including personal data, to provide better Services to all our users. We use the term "personal data" to refer to any information that identifies or can be used to identify you.

Common examples of personal data include: full name, home address, email address, date of birth, digital identity, such as a login name or handle, information about your device, payment data, and certain metadata.

The Company may collect and use sensitive personal data relating to special accommodation requests, such as a request for an ADA accessible guest room. Otherwise, the Company does not intentionally collect or use sensitive personal data and asks that you do not provide sensitive personal data to us.

Types of Personal Information We May Collect

We may collect or you may provide the following personal data in connection with your use of the Sites or Services:

• Personal or work contact information, including your name, your employer’s name, billing address, email address, and phone number
• Personal characteristics, such as gender, date of birth, title, and nationality
• Passport number and date and place of issue
• Travel history, booking, stay or purchase history
• Payment information, such as your payment card number, authentication information, expiration date, card verification value ("CVV"), and other billing and account details
• Guest preferences
• Marketing and communication preferences
• Sensitive personal data relating to special accommodation requests
• Reviews and opinions
• Frequent flyer or similar membership program number and related information
• Information provided on membership and account applications
• User name and/or password when you create or use a user account
• Information about your use of the Sites and Services

Statistical Data

To monitor utilization of the Site and continuously improve its quality, we may compile statistical information concerning the usage of the Site using analytics services, such as those provided by Google Analytics.

Examples of information we may collect and store include:

• Your city and/or country in which you are located
• Your operating system version
• Your browser version
• The pages you visit within the Site
• The length of time you spend on pages within the Site
• The site from which you linked to ours
• Search terms you used in search engines which resulted in you linking to the Site

How We May Collect Personal Information

We may collect and you may provide personal data online via the Sites, and offline through channels other than the Sites, including via your use of the Services.

IMPORTANT: By using the Site, you consent to the processing of any personal data for the analytics purposes and functions described above.

Information Obtained from You

• When you submit or provide non-electronic registration information or documents, speak with us by phone, or send an email.
• When you make online reservations, participate in contests, sweepstakes, or marketing programs, subscribe to newsletters, emails or special offers, request proposals, or sign up for events.
• When you contact us with a question or concern, or to report a problem.
• When you use site-specific mobile applications or internet-connected devices available in our properties.
• When you participate in unique offerings at any of our properties and complete a waiver or consent form.

Information You Give to Our Business Partners

We may collect your personal data from associated hotel brands, resorts and hospitality companies. We may also collect your personal data from companies with which we partner to provide goods, services or offers related to your stays or that we believe might interest you (“Strategic Business Partners”).

Information Obtained from Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit or use one of our Sites or Services. This may include using cookies or similar technologies to identify your browser or device.

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 Sites or Services.

Web Beacons

Pages of our Sites or our emails may contain small electronic files known as web beacons, also referred to as clear gifs, pixel tags and single-pixel gifs, that permit us to count users who have visited pages or opened an email and gather related website statistics.

Clickstream Data

Clickstream data is information collected by our computers when you request web pages from the Sites. It may include the page served, time spent viewing the page, source of the request, type of browser, preceding page viewed and similar information.

Embedded Content and Social Media Widgets

The Site contains embedded content and Social Media Widgets. Embedded content may place third-party cookies on your device that track your online activity. Social Media Widgets may also place third-party cookies on your device for tracking and advertising purposes.

How We Use Information We Collect

We use your personal data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following business or commercial purposes:

1. To facilitate reservations, payments, confirmations and pre-arrival messages.
2. To complete your reservation and stay.
3. To respond to inquiries and fulfill requests.
4. To manage our contractual relationship with you.
5. To personalize your experience and present tailored products and offers.
6. To authorize access to our Sites and Services.
7. To provide Services and products.
8. To administer customer loyalty and other programs.
9. To administer promotions, sweepstakes, surveys and other Site features.
10. To conduct business operations, analytics, fraud prevention and legal compliance.
11. To improve customer service.
12. To comply with applicable legal requirements.
13. To investigate possible fraud or violations of our Terms of Use.
14. For research and development.
15. For advertising and tailored offers.
16. To protect the rights, property, security and safety of our guests, team members, information systems and the public.
17. To evaluate or conduct mergers, divestitures, restructuring or other business transfers.
18. To manage recruiting efforts and employment relationships.

Information We Disclose

We do not disclose Personal Data to companies, organizations and individuals outside of our organization unless one of the following circumstances applies:

Hotel, Resort and Hospitality Companies

We disclose personal data and other data to hotel, resort and hospitality companies for purposes described in this Privacy Statement, including facilitating your stay and administering loyalty programs.

Strategic Business Partners

We disclose personal data and other data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at properties owned or managed by us.

External Processing

We provide personal information to affiliates, trusted businesses, partners or vendors to process it for us based on our instructions and in compliance with this Privacy Statement and appropriate confidentiality and security measures.

• With your consent or as you direct
• To manage the Site
• To process payments and requests
• To provide products, services or offers
• To administer loyalty programs
• To engage in marketing activities
• To enhance our services through analytics and other technologies
• To protect our interests and legal rights
• To prevent fraud, illegal activity and other liabilities

We do not disclose personal data to third parties for their own marketing purposes.

For Legal Reasons

We may disclose personal data if we have a good-faith belief that access, use, preservation or disclosure is reasonably necessary to:

• Demonstrate our relationship with you
• Meet applicable laws, regulations, legal processes or governmental requests
• Enforce applicable Terms of Use
• Detect, prevent or address fraud, security or technical issues
• Protect against harm to the rights, property or safety of the Company, our users or the public

Your Failure to Provide Personal Data

Your provision of personal data is required in order to use certain parts of our Services and Sites. If you fail to provide such personal data, you may not be able to access and use our Services and Sites, or parts of our Services and Sites.

Our Retention of Your Personal Data

We may retain your personal data for a period of time consistent with the original purpose for collection and in accordance with the Company’s data retention schedule.

We may also retain personal data as reasonably necessary to pursue legitimate business interests, conduct audits, comply with legal obligations, maintain security, prevent fraud and abuse, enforce our Terms of Use, resolve disputes, enforce agreements and fulfill lawful requests.

Your Choices and Accessing, Updating or Deleting Your Personal Data

Whenever you use our Sites and Services, we aim to provide you with choices about how we use your personal data. We also aim to provide you with access to your personal data.

If information is incorrect, we strive to give you ways to update or delete it unless we must retain that information for legitimate business or legal purposes.

Tracking Technologies and Advertising

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of this Site may become inaccessible or not function properly.

Our Unsubscribe Policy

1. Follow the unsubscribe link provided in offers, newsletters or other marketing email messages.
2. Contact us using the information in the “How to Contact Us” section to unsubscribe from the service.

Third Party Links

The Sites may contain links to websites operated by parties other than the Company, including hotel, resort and hospitality companies and Strategic Business Partners.

We do not control such websites and are not responsible for their contents, privacy policies or other practices. We encourage you to review the privacy policies and terms and conditions of linked sites.

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of personal data.

Personal data and additional information submitted may be used globally in connection with employment, business processes within the Company or communicating with our clients. Countries where we process data may have laws that are different, and potentially not as protective, as the laws of your own country.

How We Protect Personal Data

The Company maintains reasonable administrative, technical and physical safeguards designed to protect users' personal data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of the Site, you are responsible for keeping this password confidential.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that the security of your account has been compromised, please notify us immediately.

Children

The Sites are not intended for use by children. We do not intentionally gather personal data about visitors who are under the age of 18.

If a child has provided us with personal data, a parent or guardian may contact us to have the information deleted from our records.

Job Applicants and Team Members

For job applicants and team members, please see our job applicants and team members privacy statement to learn more about how we collect, use and disclose personal data.

"Do Not Track" Signals

Some browsers offer a “Do Not Track” (DNT) setting. Because there is not yet a common industry standard for how websites should respond to DNT signals, the Company Sites do not currently respond to them. You can still manage cookies and similar technologies through your browser settings, as described in the section on Your Choices above.

Changes to this Privacy Statement

We may update this Privacy Statement from time to time to reflect changes in our practices, our Services or applicable law. When we do, we will revise the Effective Date at the top of this page. If we make material changes, we will provide notice on the Site or by other appropriate means. We encourage you to review this Privacy Statement periodically. Your continued use of the Sites or Services after an update means you accept the updated Privacy Statement.

Applicable Law

The Sites are operated from the United States. This Privacy Statement is intended to comply with applicable United States federal and state privacy laws, and, where they apply to you, the privacy laws of the country or region in which you live. Where local law gives you additional rights, those rights are described in the sections that follow.

California Consumer Privacy Statement

This section applies to California residents and supplements the rest of this Privacy Statement, as required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”).

Personal Information We Collect

In the past twelve months we may have collected the categories of personal information described in the section on Information We Collect, including identifiers (such as name, email address and postal address), commercial information (such as booking and stay history), internet or other electronic network activity (such as how you interact with the Sites), approximate geolocation, and inferences drawn from this information. We collect this information from the sources, and use it for the business and commercial purposes, described in this Privacy Statement.

Sale and Sharing of Personal Information

We do not sell personal information for money. Some cookies and similar technologies on the Sites may be considered “sharing” of personal information for cross-context behavioral advertising under the CCPA. You may opt out of such sharing by contacting us as described below. We do not knowingly sell or share the personal information of consumers under 16 years of age.

Your California Privacy Rights

Subject to certain exceptions, as a California resident you have the right to:

• Know what personal information we have collected about you, including the categories of personal information, the sources from which it was collected, the purposes for collecting it, and the categories of third parties to whom we disclose it
• Obtain a copy of the specific pieces of personal information we have collected about you
• Request that we delete personal information we have collected from you
• Request that we correct inaccurate personal information we maintain about you
• Opt out of the sale or sharing of your personal information
• Limit our use and disclosure of sensitive personal information to purposes permitted by the CCPA
• Not be discriminated against for exercising any of these rights

How to Exercise Your Rights

To make a request, please contact us at privacy@davidsonhospitality.com. We will need to verify your identity before fulfilling your request, which may include asking you to confirm information we already hold about you. You may use an authorized agent to submit a request on your behalf; we may ask the agent for proof of authorization and ask you to verify your identity directly. We will respond within the time required by law.

Shine the Light

California Civil Code Section 1798.83 permits California residents to request information about the disclosure of certain personal information to third parties for their direct marketing purposes. As stated above, we do not disclose personal data to third parties for their own marketing purposes.

Other Specific States’ Privacy Rights

Residents of other U.S. states that have enacted comprehensive privacy laws, such as Colorado, Connecticut, Oregon, Texas, Utah and Virginia, may have rights similar to those described above. Depending on where you live, these may include the right to confirm whether we process your personal data, to access, correct or delete it, to obtain a portable copy of it, and to opt out of the sale of personal data, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise these rights, please contact us as described in the section on How to Contact Us. If we decline to take action on your request, you may appeal our decision by replying to our response and explaining why you disagree. If your appeal is denied, you may contact the attorney general of your state.

European Users’ Privacy Rights

If you are located in the European Economic Area, the United Kingdom or Switzerland, the following applies to you in addition to the rest of this Privacy Statement.

We process your personal data on one or more of the following legal bases: to perform a contract with you or take steps at your request before entering into one, such as a reservation; with your consent, such as to send you marketing emails; for our legitimate interests, such as operating, securing and improving the Sites and Services, where those interests are not overridden by your rights; and to comply with our legal obligations.

Subject to applicable law, you have the right to access, correct or delete your personal data, to restrict or object to our processing of it, to receive it in a portable format, and to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. You also have the right to lodge a complaint with the data protection authority in the country where you live or work.

As described in the section on International Transfer, your personal data may be transferred to and processed in the United States. Where required, we rely on appropriate safeguards for such transfers, such as standard contractual clauses approved by the European Commission.

How to Contact Us

If you have any questions or comments about this Privacy Statement or our privacy practices, or would like to exercise any of the rights described above, please contact us at:

privacy@davidsonhospitality.com
La Fontaine
2151 Avenue of the Stars
Los Angeles, CA 90067