Effective Date: October 29, 2018

Sleep Intown IX, L.P. (“InTown Suites,” “we,” “us”) recognizes the importance of protecting your privacy. This Privacy Policy describes how we collect, use, share and protect information obtained from and about you and tells you how you can access and update your information and make certain choices about how your information is used. This Privacy Policy applies to information that we collect when you visit one of our properties and through our website, www.intownsuites.com (the “Site”) and mobile application. This Privacy Policy does not apply to our business customers or to InTown Suites employees or candidates for employment at InTown Suites. By accessing or otherwise using the Site or mobile application or providing your information while visiting one of our properties, you acknowledge that you have received and read this Privacy Policy.

UPDATES TO THIS PRIVACY POLICY

InTown Suites reserves the right, at any time to modify this Privacy Policy. All such modifications will be effective upon posting the revised Privacy Policy on the Site and we will revise the Effective Date at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically so that you understand our most current Privacy Policy and practices.

WHAT INFORMATION DO WE COLLECT?

InTown Suites collects information in two ways (1) directly from you and (2) automatically as a result of your use of the Site or mobile application. Depending on how you interact with InTown Suites (online, at our property, on the phone, etc.), we may collect information directly from you or automatically as part of your interaction with us, which are described in more detail below. In some instances, we may combine one type of information with another type of information, and store them together in our records.

Information Collected Directly from You: We may collect and retain information that you provide directly to us. For example, we collect information you give us when you:

• Book or renew your stay with us, either in-person, over the phone, through our call center or on our Site;
• Complete the check-in and check-out processes at our properties;
• Register for or manage an account with us;

• Communicate with us, such as asking for additional information, making a request or using the communication features of the Site or mobile application;
• Provide feedback about your experience staying at our properties, including by filling out a customer satisfaction survey during your stay; and
• Subscribe to email lists or other content that we may provide.

We may collect information such as your first and last name, home or mailing address, phone number (home, cell, etc.), email address, government issued identification, reservation details, credit card or other payment information and any other information that we request or that you provide to us. You may choose not to provide certain information to us, but doing so may restrict your ability to use the Site or book a stay with us. In some cases, the information you provide to us could include information about someone else (for example, if you book a room for someone else).

Information Collected Automatically. We may also collect certain information through the use of automated means, such as:

• Your IP address;
• The type of operating system, browser and device you use;
• Identifiers associated with the device(s) you use to access the Site;
• The pages and content you view and the features you use, including dates and times;
• If you navigated from or navigate to another website and the address of that website; and
• Information regarding your internet service provider.

In addition, we may collect information about your activities on the Site through the use of cookies, clear GIFs or web beacons, local shared objects or Flash cookies, or through other identifiers or other similar technologies, as they may evolve over time. We refer to these technologies collectively as “Data Technologies.” Data Technologies allow us to enhance your Site experience, personalize certain Site features and show you content and ads more relevant to your interests.

We may allow third parties, including Google, to use Data Technologies on the Site. The information collected by Data Technologies may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by Data Technologies may be used on this Site or on other websites or services, including those that may not be operated by us.

Email. We may collect information regarding the effectiveness of our email and other communications with you. For example, we may know if and when you open an email we send or follow a link in an email we send to you.

Information from Other Sources. We may obtain information about you from other third parties or social media sites (consistent with your settings on such services). This information may include information about your use of the Site, your use of other websites, your interests and preferences and other information about you or your household. We and others may combine this information with information we have collected about you.

HOW WE USE YOUR INFORMATION

We use the information we collect to:

• Enhance and customize your experience at our properties;
• Process your reservations, inform you about the status of your reservations, and to follow up with you about your satisfaction with your stay with us;
• Provide you customer service, including responses to your inquiries through various forms of communication, such as email correspondence and call center support;
• For marketing and promotional activities, including sending you marketing communications, such as email communications and postal mailings (e.g., brochures) that will inform you about new properties, events, third party products, special discounts and coupons, and other news and special offers;
• Deliver the Site and mobile application to you and others;
• Personalize your experience and save you time when you visit the Site or use the mobile application;
• Maintain your accounts with us, including administering any customer loyalty or rewards programs associated with such accounts;
• Operate our business, including administering, maintaining and improving the Site;
• Improve or customize the Site or mobile application;
• Perform research and analysis aimed at improving our products, services and technologies, and for financial, operational or other purposes;
• Perform data analyses or create aggregated data sets combining information about you with that of other visitors to the Site;
• Comply with applicable laws and to enforce our policies and Terms and Conditions; and
• Prevent fraud, theft, or injury to you, us, or others.

WITH WHOM DO WE SHARE INFORMATION?

We may share the information we collect (i) as you expressly authorize us to; (ii) as permitted by law; (iii) with our parent company and affiliates; and (iv) with third parties, including:

Vendors. We may share information with outside vendors, agencies, or contractors that we hire to help us run our business (e.g., fulfill reservations, process payments, operate our Site, run promotions and marketing campaigns, operate our call center, provide data Technologies on the Site, etc.).

Advertising Networks. We may work with advertising networks that deliver targeted advertisements to consumers and generate statistics and metrics related to the delivery of such advertisements.  Advertising networks collect information about the websites that you visit and the advertisements that you interact with and uses it to serve you targeted ads based on your inferred interests and preferences as well as for auditing, research and reporting to us and other advertisers. This data collection takes place both on our Site and on third-party websites that participate in the advertising networks.

Legal Disclosures. We may need to share your information for law enforcement or other legal purposes. This type of sharing may be necessary in connection with a lawsuit, claim or investigation, governmental inquiry, court order, enforcement of legal rights (e.g., contract terms, intellectual property rights, etc.), safety issue, or other similar legal or security matter.

Business Transfers (e.g., Sale or Acquisition of Company). We may share (or receive) information about you in the event of an acquisition, merger, sale, corporate restructuring, bankruptcy, or other similar event that involves InTown Suites or its parent or affiliated companies.

YOUR CHOICES

You may limit and control the information you provided to us or that is collected about you in a number of ways; however, you may not be able to use all features of the Site or mobile application if you limit the information you share with us.

Account Information. If you have registered for an account through the Site, you may correct, update or delete the information contained in your account by logging in to your account and editing your information or by calling us at the telephone number listed in the “Contact Us” section below. Note that we may keep historical information in our backup files as permitted by law.

Emails. You can stop receiving marketing communications from us either by following the unsubscribe instructions provided in each such communication or by submitting a request to the address in the “Contact Us” section below. Please note that even if you opt-out from receiving marketing communications, you may still receive other communications from us, such as reservation confirmations, notifications about account activities (e.g., account confirmations, password changes, etc.), and other important announcements (e.g., privacy policy changes, etc.).

Cookies. Your browser and your device may provide you the option to limit the use of cookies or other Data Technologies. You should refer to your web browser’s or mobile device’s options or settings menu for more information about adjusting your settings. Disabling or rejecting cookies may disable some of the features and functionality of the Site.

Google Analytics. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Service, available at //www.google.com/analytics/terms/gb.html and the Google Privacy Policy available at //policies.google.com/privacy?hl=en. To more fully understand how Google may use the data it collects on the Site, please review “How Google uses data when you use our partners’ sites or apps,” (located here or any successor URL). In addition, you may be able to opt-out of this use of information about you by Google through an opt-out browser add-on, which can be found here: //tools.google.com/dlpage/gaoptout?hl=en.

Targeted Advertising. Many companies that collect information for targeted advertising are members of either the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). The NAI and the DAA offer the ability for you to opt-out of the targeted advertising programs of their members. The NAI op-out is available at //www.networkadvertising.org/managing/opt_out.asp and the DAA opt-out is available at //www.aboutads.info/choices. Please note that if you use a different computer, change your web browser, or delete your cookies, you will need to renew all of your opt-out choices. Please also note that this does not opt you out of being served advertising but only excludes you from targeted (i.e. interest-based) advertising. If you use the Site, you will continue to receive generic advertisements.

INFORMATION SECURITY

We take reasonable measures designed to secure and protect information transmitted via or stored on the Site and at our properties. Despite these measures we cannot guarantee the security of networks, servers and databases we operate or that are operated on our behalf, or that information you transmit to us over the Internet will not be intercepted, deleted or altered.

Please assist us in protecting your information. If a password is used to help protect your account and information, it is your responsibility to keep your password confidential.  Do not share this information with anyone and please notify us if you believe that your password has been stolen or might have otherwise been misused. While staying with us, please be patient as our staff follows processes designed to verify your identity when they provide you with room keys, messages or other information.

Visiting the site from outside the united states

If you are visiting the Site, or any part thereof, from outside of the United States, please be aware of the following:

Controller.  The controller of the personal data we collect through the Site is Sleep Intown IX, L.P.

Transfer of Personal Data.  We process and store the personal data collected through the Site in the United States.  Please be aware that the data protection laws of the United States may not be as protective as the laws of the country in which you reside.

Data Technologies.  In accordance with applicable law, we may obtain your consent separately before collecting information by automated means using cookies or similar technologies.

Data Retention.  Your personal information will not be stored for longer than necessary for the purposes for which they were collected, or as required under applicable retention policies or in accordance with applicable law.

Your Privacy Rights.  If provided by applicable law, you may have (i) the right to receive access to certain personal information we collect about you, (ii) the right to have such personal information corrected, if inaccurate, (iii) the right to request the transmission of the personal information you have provided to us to you or another company, (iv) the right to object to certain uses or disclosures of your personal information, (v) the right to withdraw your consent in relation to our processing of your personal information based on your consent, (vi) the right to request deletion of your personal information and (vii) the right to request that we restrict processing of your personal information.

You may exercise these rights free of charge unless the request is unfounded, excessive, or otherwise unreasonable, for instance because it is repetitive. In some situations, we may refuse to act or may impose limitations on your rights, as permitted by law. Before we are able to provide you with any information or correct any inaccuracies, we may ask you to verify your identity and/or provide other details to help us respond to your request. For the exercise of your rights, please contact us using the contact information provided below in the “Contact Us” section. In all cases, you may have a right to file a complaint with a Data Protection Authority.

CHILDREN

The Site is intended for general audiences and is not directed to children under 13 years of age. We do not knowingly collect personal information from children under the age of thirteen (13). No information should be submitted to or posted to the Site by visitors younger than thirteen (13) years old.

Links and third party sites

This policy discloses the privacy practices for our Site. However, our Site contains links to other sites operated by third parties, including social media websites. Once you link to a third party site, you are subject to the privacy and security policies of the third party site. We encourage you to read the privacy policies of all third party sites that you visit, to learn how they will handle any information they collect from or about you. We are not responsible for the content of third party sites or services, your use of those sites or services, or the privacy practices of the third party operating those sites or services.

Please note that there are many independent e-commerce sites that facilitate booking rooms at InTown Suite’s properties that are not controlled or operated by InTown Suites. Because these sites may have different privacy and security practices than we do, we recommend that you read their privacy policies before making any purchases on those sites. We are not responsible for the content of any independent e-commerce sites, your use of those sites, or the privacy practices of the third party operating those sites.

California Consumer Privacy Act 

If you are a California resident and are interested to learn more about the California Consumer Privacy Act (CCPA), please click here.

California and Delaware “Do Not Track” Disclosure 

California and Delaware law require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. At this time, there is no worldwide uniform or consistent industry standard or definition for responding to, processing, or communicating Do Not Track signals. Thus, like many other sites and online services, we are currently unable to respond to Do Not Track Signals. To find out more about “Do Not Track”, you may wish to visit http://www.allaboutdnt.com.

Contact Us

If you have any privacy concerns, questions or suggestions, you can email us at legal@intownsuites.com.