ENNISMORE LIFESTYLE COLLECTIVE PRIVACY POLICY

14.2. PRIVATE NOTICE FOR CALIFORNIA RESIDENTS

• This “Privacy Notice for California Residents” is part of the Ennismore Group Privacy Policy and should therefore be read in conjunction with it. 
• The California Consumer Privacy Act 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information.
• The CCPA defines “Personal Information” as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. In the context of this “Privacy Notice for California Residents” section, the term “Personal Information” will refer to this information.
• Ennismore Group may collect the categories of Personal Information as described in section 4 of the Ennismore Group Privacy Policy. 
• We collect personal data from California residents, internet service providers, booking agents, employers, and data analytics providers.
• If you would like more details about when your Personal Information is collected, what purposes it is collected for and how long we retain it, please see the Ennismore Group Privacy Policy – including section 5s 6 and Annexure A of the Ennismore Group Privacy Policy.

• In addition to the purposes set forth in the Ennismore Group Privacy Policy, we may collect and have collected and may have “sold” (see section “DO NOT SELL OR SHARE” below) Personal Information for the following business or commercial purposes:
  • auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
  • helping to ensure security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for these purposes;
  • debugging to identify and repair errors that impair existing intended functionality;
  • performing services, including maintaining or servicing accounts, providing customer service, processing reservations, verifying customer information, processing payments, or providing analytic services;
  • undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance same; and
  • commercial purposes, such as by inducing another person to buy, join, subscribe to, provide, or exchange property or information, or enabling or effecting, directly or indirectly, a commercial transaction.

• We may disclose your Personal Information with internal and external recipients subject to the conditions set forth in section 7 and for the business and commercial purposes discussed above. The categories of third parties to whom your Personal Information may be disclosed or “sold” (see section “DO NOT SELL OR SHARE” below) on a need-to-know basis are:
  • appropriate persons within hotels and Ennismore Group entities;
  • commercial partners; and
  • local authorities (if and as legally required).
• We do not knowingly “sell” the Personal Information of minors under 16 years of age. For more information on data collected in relation to persons under 16 years of age and to arrange for this information to be deleted, see section 4 of the Ennismore Group Privacy Policy.
• We do not collect or process sensitive Personal Information (as defined under California law) for the purpose of inferring characteristics about individuals and, consequently, do not use it for purposes other than allowed by the CCPA and its regulations.
• We retain your Personal Information for as long as necessary to fulfil the purposes for which we collect it, such as to provide you with the service requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us. Please see Annexure A for further information.

• Your California Privacy Rights
• As a California resident, you have the following rights with respect to your Personal Information:
  • the right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
  • the right to delete Personal Information that we collected from you, subject to certain exceptions;
  • the right to correct inaccurate Personal Information that we maintain about you;
  • if we sell or share Personal Information, the right to opt out of the sale or sharing;
  • if we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
  • the right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

• How to Submit a Request to Know, Delete, and/or Correct
  
  • You may submit a request to know, delete, and/or correct by writing to data@ennismore.com.
  • When you submit your request, we will need to verify your identity pursuant to regulations adopted by the Attorney General. As part of our verification method, we will seek to verify the information in your request with the Personal Information we maintain about you. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction, as applicable. In addition, you may be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.
  • We will respond to your request within 45 days, unless additional time is needed, in which case we will let you know.
    
• Authorised Agents
  The CCPA allows California residents to designate an authorised agent to exercise their rights. If you submit a request via an authorised agent acting on your behalf, we will require this authorised agent to provide proof that you gave the agent permission to submit the request. Authorised agents may submit requests using the same methods provided above.
  
• “Do Not Sell or Share My Personal Information”: Right to Opt-Out of the Sale or Share of Personal Information
  
  • Under the CCPA, the disclosure of Personal Information to a third party for monetary or other consideration of value can be considered as a “sale”, the term “sale” being broadly defined.
  • The CCPA defines a “sale” as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.
  • The CCPA gives California residents the right to opt out of the “sale” of their Personal Information.
  • In addition, the CCPA gives California residents the right to opt out of the “sharing” of third Personal Information, which is the transfer of Personal Information to a third party for cross-contextual behavioural advertising.
  • We offer Californian residents the opportunity to exercise these rights, should one of our business practices be considered a “sale” or “share” within the meaning of the CCPA.
  • You may submit a request to opt-out of the sale or share of your Personal Information by writing to data@ennismore.com. If you are using a browser setting or plugin that sends an opt-out preference signal to each website you visit, we will also treat that as a valid request to opt out (see section “Opt-Out Preference Signals” below for more information). To opt-out of our use of third-party advertising cookies, see our cookies policy.
• Cookies
  • On the Ennismore Group websites, Ennismore Group and its partners store or retrieve information on your device in order to: operate the websites and provide you with the services you request (these cannot be rejected), enhance and customize website functionalities, measure website audience and performance, profile your interests to provide you with relevant advertising and allow you to interact with social networks.
  • You can modify your choices at any time by clicking on the “Cookie Settings” link at the bottom of the respective website.
• Financial Incentives
  • We may offer you certain financial incentives that can result in a different price, rate, level, or quality of services.
  • Any financial incentive we offer will be reasonably related to the value of your Personal Information and your participation will be subject to any applicable terms.
  • For example, we may offer  Loyalty Programs. Categories of Personal Information that we may collect when you enter into any Loyalty Program would include your name and email address. We would take into consideration, without limitation, the anticipated revenue generated from such information, the anticipated expenses which we might incur in the collection, storage, and use of such information, and the anticipated expenses which we might incur related to the offer, provision, and imposition of any financial incentive or price difference.
  • Based on this analysis, the value of your Personal Information that allows us to make these offers and financial incentives is the value of the offer itself.
• Opt-Out Preference Signals
  • To download and use a browser supporting the GPC browser signal, click here. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
  • Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked.
  • Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
• Shine the Light Law
  • If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes (as those terms are defined in that statute).
  • This information is as follows: in accordance with European regulations, we will only disclose your personal information to third parties for the third parties’ direct marketing purposes with your express prior consent and a prior information on the third parties your information will be disclosed to.