Privacy Policy

OUR COMMITMENT TO PRIVACY
Last updated, January 2024

Your privacy is important to Proper Hotel Group and its affiliates (“Proper Hotel Group,” “us,” “we,” “our”), including Avalon Hotels, Proper Hotels, Hotel June, Ingleside Estate, Venice V Hotel and The Culver Hotel. This policy will provide information explaining our practices (in both an online and offline context) regarding the collection, use, handling, and disposal of personal data.

This Privacy Policy explains how we collect, use, disclose, secure, and dispose of your personal data.

Policy Contents
1. Changes to Your Personal Data
2. The Personal Data We Collect About You
3. How We Collect Your Personal Data
4. How We Use Your Personal Data
5. Disclosure of Your Personal Data
6. Your Choices on Collection, Use, and Sharing of Your Personal Data
7. How Long We Retain Your Personal Data
8. How We Keep Your Personal Data Secure
9. Links to Third Party Websites
10. Children
11. Public Areas
12. For Persons Within the European Union
13. Notice of Privacy Rights to California Residents
14. Changes to Privacy Policy
15. Contact Us

1. CHANGES TO YOUR PERSONAL DATA
It is important that the Personal Data we hold about you is accurate and up-to-date. Please keep us informed if your Personal Data changes during your relationship with us.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU
“Personal Data” are data that identify you as an individual or relate to an identifiable individual.
Proper Hotel Group collects the following types of Personal Data in both an online and offline context, when providing you with our products and services:

Personal Data that we collect from you:

• Name
• Gender
• Postal address
• Billing address
• Telephone number
• Email address
• Credit and debit card number or other payment data
• Financial Information (in limited circumstances)
• Language preference
• Marital status
• Date and place of birth
• Nationality, passport, visa or other government-issued identification data
• Medical history / Health information
• Religion / Religious beliefs
• Important dates, such as birthdays, anniversaries and special occasions
• Travel itinerary, tour group or activity data
• Prior guest stays, or interactions, goods and services purchased, special service and amenity requests
• Geolocation information
• Social media account ID, profile photo and other data publicly available

We will also collect the following types of personal data for the following purposes:

• Images and video and audio data via security cameras located in public areas, such as hallways and lobbies, on our properties
• Guest preferences and personalized data such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit

Personal Data that We Automatically Collect

We may use tracking technologies, such as cookies, pixels, and web beacons to collect the following information:

• IP Address
• Location/Geolocation
• Media Access Control (MAC) address
• Unique device identifier (UDID/IMEI)
• Operating system or platform
• Screen resolution
• Operating system name and version
• Device manufacturer and model
• Language preferences
• Internet browser type and version
• Name and version of the Online Services (such as the Apps) you are using
• Browser type
• Time spent on the Online Services
• Pages visited
• Referring URL
• Duration of visit to our website
• Links you click on in our emails and on our website, including ads

3. HOW WE COLLECT YOUR PERSONAL DATA
Personal Data collection is obtained in a variety of ways:

• Online Services. Personal Data is collected through online services either directly or through an affiliate booking website.
  • • Reservation Process
    • Check out process for electronic folio receipts
    • Purchase goods or services through the website or ecommerce website
    • Communication via email
    • Connect or post to social media related to the properties
    • Participate in a survey, contest or promotional offer
• Property Visits. Personal Data is collected when guests visit our properties or use on-property services and outlets, such as:
  • • Restaurants and Bars
    • Concierge services
    • Health clubs
    • Spas
• Offline Interactions. Personal Data is collected when individuals attend promotional events that we host or in which we participate, or when you provide your Personal Data to facilitate an event.
• Reservations and Customer Service Centers. Personal Data is collected when you make a reservation over the phone or communicate with us by email, fax or contact customer service. These communications may be recorded for purposes of quality assurance and training.
• Other Sources. Personal Data is also collected from other sources, such as public databases, joint marketing partners and other third parties.
• Internet-Connected Devices. Personal Data is collected from internet-connected devices available in our properties. For example, a smart assistant device may be available for your use and to tailor your accommodations and experience.
  We collect automatically-collected data in a variety of ways:
• Your browser or device. We collect certain data through your browser or automatically through your device. We use this data to ensure that the Online Services function properly.
• Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services, and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used, and assist us with resolving questions.

We collect analytical data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out by downloading the Google Analytics opt-out browser add-on at: https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt out by visiting https://www.adobe.com/privacy/opt-out.html.

• Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Online Services.
• Analytics.
• Aggregated Data. We may aggregate data that we have collected. This aggregated data will not personally identify you or any other user.

4. HOW WE USE YOUR PERSONAL DATA
We use Personal Data and Other Data to provide you with Services, to develop new offerings, and to protect Proper Hotel Group, Avalon Hotels, Hotel June and Ingleside Estate and our guests as detailed below. In some instances, we will request that you provide Personal Data or Other Data to us directly. If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services. We will let you know if this is ever the case.

We use Personal Data and Other Data for the following purposes:

• To provide services to you.
• To provide services requested by you. For example, if you sign up for our newsletter, we will use the information you give us to send you our newsletter.
• To provide our website and its functionalities to you.
• To respond to your requests. If you contact us with a question or a request, we will use your information to respond to your request. For example, if you contact us via email with a question, we will use the information in that email and the email address you used to contact us to respond to you.
• To provide you with location-specific services. If you elect to share your location information with us, we may use that information to tailor options, functionality or offers related to your location. We also may use your IP address to determine your general location, which also may be used to tailor offers to you.
• To offer and conduct promotions and contests.
• To conduct data analytics to support our website and business. Typically, these analyses are done using aggregated or otherwise de-identified data. We use information, including automatically-collected information, to manage and improve our website and our business. For example, we use such information to:
  • • Manage our business needs, such as monitoring, analyzing, and improving the services and the website’s performance and functionality. For example, we analyze website user behavior, and conduct research and analysis about the way you and other users use our website.
    • Manage risk and protect the website. We use data to better protect our services, our website, and you by helping to detect and prevent fraud and abuse of the website and our services.
• To tailor our offerings to your apparent interests.
• To develop new products, services and offers.
• To operate and improve our business.
• To maintain our records.
• To market to you. Information we collect about you and how you use and interact with the website and our services, ads, and other online content helps us to improve our website and offer additional products and services that we think might interest you. For example, we analyze information about user interactions with our marketing emails and online ads (such as whether emails have been opened or whether ads are clicked on) to determine whether those communications and ads are effective, and to understand what other website functionalities, products or services may interest you.
• For legal, contractual and safety purposes. We will use your information as necessary to enforce the terms of our website, to comply with all applicable laws and regulations, to defend or protect us, our users, you, or third parties from harm or in legal proceedings, to protect our rights, to protect our security and the security of our users, employees, and property, to respond to court orders, lawsuits, subpoenas, and government requests, to address legal and regulatory compliance, to verify your identity or communications from you, to comply with contracts and other agreements to which we are a party, and to notify you of changes to our terms, policies, or practices.
• To conduct internal monitoring and training.
  For other purposes for which you provide your consent. We will use your information for other purposes which are disclosed to you at the time your information is collected or for purposes which can be inferred from or are obvious given the circumstances of collection. For example, if you give us your personal information when entering a contest, we will use that information to facilitate your participation in that contest.

5. DISCLOSURE OF YOUR PERSONAL DATA
Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data with the following:

• Owners and Franchisees. We disclose Personal Data and Other Data to Owners of Proper Hotel Group, Avalon Hotels, Hotel June and Ingleside Estate-branded properties for the purposes described in this Privacy Statement, such as providing and personalizing the Services.
• 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 our properties or that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables spa, restaurant, health club, concierge and other outlets at our properties to provide you with services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services, such as airline tickets, rental cars and vacation packages.
• Service Providers. We disclose Personal Data and Other Data to third-party service providers for the purposes described in this Privacy Statement. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services.
• Corporate Reorganization. We may disclose or transfer your Personal Data and Other Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Proper Hotel Group, Avalon Hotels, Hotel June and Ingleside Estate business, assets or stock (including any bankruptcy or similar proceedings).

We may disclose information that we collect or you provide as described in this privacy policy for the following purposes:

• To fulfill the purpose for which you provide it.
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Website Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our business, our customers, or others.
• For any other purpose disclosed by us when you provide the information with your consent.
  Other Disclosures. We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of the Proper Hotel Group, Avalon Hotels, Hotel June and Ingleside Estate, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

In some instances, we may combine de-identified or anonymized data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data for so long as it is combined.

6. YOUR CHOICES ON COLLECTION, USE AND SHARING OF YOUR PERSONAL DATA
Information Collected from you
It is optional for you to provide us with information. Depending on the activity, some of the information we ask you to provide is identified as mandatory and some is identified as voluntary. If you do not provide the mandatory information for a particular activity that requires it, you will not be permitted to engage in that activity.

Emails
You can opt out of receiving future promotional email messages received directly from us or by our authorized service providers by following the opt-out instructions provided in any such message you receive. Some of our email communications may be transmitted on our behalf by our authorized service providers. As such, the opt-out language may differ depending upon the source, but generally states: “Click here to unsubscribe from future emails.” Click here if you wish to unsubscribe now. Please note that it may take up to ten (10) days to process your request. Please also be aware that we may continue to send you transactional and administrative communications, such as emails confirming your transactions with us, and notices regarding changes to our Terms of Use and Privacy Policy.

Cookies
We provide a variety of services on our website using cookies. We place cookies on your device in order to provide you with personalized access to essential services, enhance website functionality, and to show you offers and services tailored to your interests.

What is a Cookie?
A cookie is a small piece of data that a website can send to your browser, which may then be stored on your hard drive as a “tag” that identifies your computer. Cookies help to navigate from page to page on a website, provide secure connections, gather statistics about the usage and effectiveness of our site, and remember preferences from a previous visit when you return.

We use third-party services for analytics and interest-based advertising purposes. These service providers and ad partners may use cookies alone or in conjunction with unique identifiers, beacons, and other tracking technologies to collect information about you when you use our website, open our emails, or interact with our ads. We do not combine the information collected through the use of these services with information that directly identifies you.

For example, we use Google Analytics to help us analyze how visitors use our websites and mobile applications. The information generated by the cookie, including your IP address, is transmitted to Google. This information is then used to evaluate visitors’ use of the website and mobile applications and to compile statistical reports on website activity for us. We do not use the statistical analytics tool to track visitors to our website and mobile applications. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser.

Cookie Choices
Most web browsers automatically accept cookies, but you can change your browser’s settings to disable all or certain cookies if you wish. For more information on how to manage browser cookies, see https://www.allaboutcookies.org. Click on the links below to learn how to manage cookies on these browsers:

• GOOGLE CHROME
• MICROSOFT EDGE
• MOZILLA FIREFOX
• MICROSOFT INTERNET EXPLORER
• OPERA
• APPLE SAFARI

Please note that by disabling or deleting cookies, you may not be able to access the full functionality of our website. Disabling or clearing cookies also may affect cookie-based opt-outs by either preventing you from using such cookie-based opt-outs, or clearing opt-outs that you previously set.

You may control your advertising preferences or opt out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by vising NAI’s online resources at https://www.networkadvertising.org/choices.

Some of the third parties that we may work with may participate in the Digital Advertising Alliance’s self-regulatory program, which provides consumers tools to opt-out of receiving interest-based advertising. Click here to learn more about the DAA’s WebChoices tool. To help control or block certain ads in mobile applications, you may choose to download and utilize the DAA mobile app by clicking here.

You also can learn more about opting out of third parties’ use of cookies used to tailor ads and other content to you by visiting https://www.networkadvertising.org/managing/opt_out.aspand https://www.aboutads.info/choices.

7. HOW WE KEEP YOUR PERSONAL DATA SECURE
We use appropriate organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section on the website.

8. HOW LONG WE RETAIN YOUR PERSONAL DATA
We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In specific circumstances, we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

9. LINKS TO THIRD PARTY WEBSITES
This Privacy Policy addresses the use and disclosure of information we collect from you on our websites. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. It may not always be apparent that you have gone to a third party website. For example, we have a link on our site to Trip Advisor. We are not responsible for the policies or practices of Trip Advisor or any other site for which there are links on our website. If you click on a link to any such website, we urge you review the website’s privacy policy.

10. CHILDREN
Minors under the age of 18 may not use the Website. No part of the Website is designed to attract anyone under the age of 18. However, we may collect information regarding children that stay in our hotels as guests if information is provided by their parent or legal guardian. If you believe we have information about your child and you would like it deleted from our system, please contact Privacy.Policy@Properhotel.com.

11. PUBLIC AREAS
We may provide areas on our website where you can publicly post information about yourself and communicate with others, such as discussion boards or blogs. This information may be accessible by other consumers and companies, and may appear on other websites or web searches; therefore, this information could be read, collected, and used by others.

12. FOR PERSONS WITHIN THE EUROPEAN UNION
Controller of Personal Data

For the purposes of applicable EU data protection laws, Proper Hotel Group, Avalon Hotels, Hotel June and Ingleside Estate will each be a data controller of any Personal Data about you. If you have any questions regarding our use of your Personal Data or this Privacy Policy, please contact Privacy.Policy@Properhotel.com.

How to contact us or make complaints
If you have any questions regarding our use of your personal data (including any requests to exercise your legal rights) or this privacy policy, please contact Privacy.Policy@Properhotel.com.

Our full contact details are:
Proper Hospitality
1437 7th Street, Suite 250
Santa Monica, CA 90401
Attn: Legal Department

You have the right to make a complaint at any time to the relevant supervisory authority in your country of residence for data protection issues. We always appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.

Individual Rights
You may have certain rights under European Union or Member State law or regulation. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us at Privacy.Policy@Properhotel.com.

• Access: You may have the right to ask for a copy of the Personal Data that we hold about you.
• Correction: If there are any inaccuracies in the information we hold about you, please contact us to correct them.
• Deletion: If you would like us to delete your Personal Data, you may request that we delete it. Please note that this may not always be possible.
• Restrictions on use: In certain circumstances, you may request that we stop processing your Personal Data.
• Object: You may have the right to object to processing of your Personal Data.
• Request the transfer: You may have the right to transfer your Personal Data to another organization
• Withdrawal of consent: If you previously gave us your consent to allow us to process your Personal Data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

Legal Bases for Processing

Transfer of Personal Data from the European Union
Our website is operated from and hosted on servers located in the United States. If you access and use our website from a location outside of the United States, any personal data you provide to us or that is otherwise collected may be transferred to and processed in the United States, or any other jurisdiction, in our sole discretion. Users of our website should be aware that the laws that apply to the use and protection of personal data in the United States or other countries or jurisdictions to which we transfer, or in which we process, personal data may differ from those of your country of residence. Users who access or use our website from jurisdictions outside of the United States do so at their own choice and risk, and are solely responsible for compliance with local law. While we take steps to safeguard your personal data, the United States has NOT been deemed by the European Commission to ensure an adequate level of protection for personal data. Accordingly, the level of protection provided in the United States or other non-EU countries and jurisdictions from which you may access our website may not be as stringent as that under EU data protection standards or the data protection laws of some other countries, possibly including your home jurisdiction.

13. NOTICE OF PRIVACY RIGHTS TO CALIFORNIA RESIDENTS
Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of personal information to third parties for the third parties’ direct marketing purposes, if any.

Your California Privacy Rights
By availing yourself of the rights afforded in this section of our Privacy Policy, you are declaring that you are a California resident:

Other residents: You may make a verified request to Proper regarding your personal information. While Proper does not sell your personal information, you can nonetheless make a formal request to delete your personal information held by Proper. This process is detailed in below, which also describes the designated address information for making requests to Proper regarding your personal information.

The Right to Know Your Personal Data
You have the right to request that we disclose the personal information we collect, use, disclose and “sell” about you. For more information on how to exercise this right, please see Section 6 of our Privacy Policy. The following is a Summary of the categories of personal information we collected over the past twelve (12) months:

The Right to Opt-out of the Sale of Your Personal Data
We do not “sell” your personal information in the traditional sense. As discussed above, we may share your information with our business partners and affiliates, but such sharing does not occur based on the exchange of material consideration.

To make such a request, send an email with the subject heading “California Privacy Rights” to Privacy.Policy@Properhotel.com or write to us at:

Proper Hospitality
1437 7th Street, Suite 250
Santa Monica, CA 90401
Attn: Legal Department
833-613-1919

In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by these California privacy rights requirements, and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.

14. CHANGES TO PRIVACY POLICY
We may change our Privacy Policy from time to time. If we change our Privacy Policy, we will notify you by posting those changes on our website and other places we deem appropriate. Please review this Policy frequently so that you are aware of our current practices.

15. CONTACT US
Proper Hospitality
1437 7th Street, Suite 250
Santa Monica, CA 90401
Attn: Legal Department
Privacy.Policy@Properhotel.com