Columbia Hospitality, Inc. ("Columbia") and its affiliated companies operate various properties throughout the United States ("Properties"), as listed at www.columbiahospitality.com ("Site"). Throughout this Privacy Policy, "Sites" refers to this Site and, as applicable, those other websites that Columbia owns or operates, and websites where this Privacy Policy is posted. Under this Privacy Policy, Columbia and its affiliates are referred to as "Columbia" or "we, us, and/or our". Except where otherwise provided, other capitalized terms have the meanings set forth in the Terms of Use at https://columbiahospitality.com/terms-of-use/ ("Terms").

Purpose

This policy (“Privacy Policy”) describes, among other things:

• The Personal Information (as defined below) we collect about you
• How we use the Personal Information we collect
• The categories of third parties with whom we share Personal Information about you
• Your right to review and correct Personal Information we have collected about you
• What we do to protect Personal Information we have collected about you
• Your right to opt-out of commercial email messages
• How we interact with linked sites
• Whether we collect Personal Information from children
• Our right to change the terms of this Privacy Policy
• State privacy rights notice
• European privacy rights notice
• How to contact us and exercise your rights
• SMS/MMS messaging terms and conditions

This Privacy Policy outlines how we handle Personal Information we collect from all residents, including those residents of the European Union, which includes the purpose and legal basis for collecting that information, how long we retain it, and your right to object to the collection of the information.

Notice to California users: If you reside in California, please see the California State Privacy Rights Notice section below for important information about your rights under applicable state privacy laws.

Notice to European users: If you reside in the European Area (“EEA”) or the United Kingdom (“UK”) (refer to below as “Europe,” “European,” or “E.U.”), please see the European Privacy Rights Notice below for important information about your rights.

This Privacy Policy sets out our practices with respect to your Personal Information including where you access or use the Sites or register for an account (a "User Account"), purchase or subscribe to any services provided by Columbia (the "Services"), or make a reservation at one of the Properties. Please read this Privacy Policy carefully.

Scope

This Privacy Policy applies only to Personal Information. It does not cover data we collect that cannot be used to identify an individual or to pseudonymous data. Nor does it include encoded or anonymized information or aggregated data which we collect or create about a group or category of services, features or users which does not contain personally identifying information. We reserve the right to share aggregate, encoded, or anonymized information with potential partners or other third parties without restriction.

What is Personal Information?

For the purposes of this Privacy Policy, "Personal Information" means, generally, information that can be linked, directly or indirectly, to you or your household, this may include your first and last name, your email address, your home or other physical address, including a street name and name of a city or town, your telephone number, your social security number, any payment or financial information, IP address or other online identifiers.

Information We Collect

We collect Personal Information you provide to us and when you use the Sites and/or our Services. We collect Personal Information in order to improve our services, to deliver services and perform obligations under contracts we have with you, to comply with our own legal obligations, and for other purposes as described below.

Information You Give Us: We receive and store any Personal Information you post to the Sites or provide to us when you set up a User Account, sign up for our newsletters or promotions, purchase Services, plan meetings or events, apply for employment, or make a reservation at one the Properties. For example, if you make a reservation at one of the Properties, we will ask you for information such as name, address, telephone number, email address, credit card number, and room preference to process your reservation. We may use your email address to send a confirmation and, if necessary, may use the other information to contact you for help to process the reservation. As indicated below, we may also use your email address to notify you about special offers and promotions, including from Columbia Hospitality, the Properties and our partners. You can choose not to provide such Personal Information, in which case you will not be able to access or use portions of the Sites or some of their features.

Automated Collection: We automatically receive and store certain types of information when you visit the Sites, such as the name of the domain and host from which you access the Internet; the IP address of the computer you are using and the browser and operating system you are using; the date and time you access the Sites; the Internet address of the website from which you linked to the Sites; any search terms you used to find the Sites; the device identifiers and mobile and network information, and your actions on the Sites.

Payment and Credit Card Information: We may require your credit card or other payment information in order to process purchases and reservations.  In limited cases, we may also collect information relating to the credit of customers.

Log Data: Our web servers may collect “log data.” Log data provides aggregate information about the number of visits to different pages on the Sites. We use log data for troubleshooting purposes and to track which pages people visit in order to improve the Sites. Third-party vendors may also collect aggregate log data independently from us.

Cookies and Other Technologies: We automatically receive and store certain types of information when you visit the Sites through the use of cookies, web beacons, or similar programs to collect the information described above. Cookies are strings of text that a website may store on your computer. Cookies enable the Sites to keep track of your preferences and activities when you use or visit the Sites.

The Sites create session cookies for each visit in order to facilitate your visit. The session cookie expires at the end of the session.

We may also use “persistent” cookies, which remain on your device for much longer. Cookies do not corrupt or damage your computer or computer files.

We use cookies for authentication, to remember your settings, to keep track of your activity during a visit to the Site, to conduct usability tests, to improve Site performance, and to implement certain features of the Site.

We use analytics and customization cookies, including third party cookies, to gather information on how our Sites are being used by our visitors and to measure how popular our marketing campaigns are. We use the data we get to help customize our Sites and services for you and make the content you see as relevant as possible. We may also use the data we collect to help identify and prevent fraud, and to track visits from our affiliates or partners.

Social networking cookies allow visitors to share our pages and content through third-party social networking websites.

Targeting/advertising cookies help us to customize and regulate (e.g., by capping the frequency of) the advertisements you receive, provide you with tailored offers, and measure the effectiveness of our advertising. For instance, if we target an ad campaign through an online advertising network, we might use cookies on our Sites to estimate how many viewers of the ad later visited our Sites – and therefore, how effective the ad campaign was. Or, we might "retarget" visitors to our Sites by providing them offers (whether through online display media, email or direct mail) similar to those they viewed or expressed interest in during their Site visits.

You can control the use of cookies at the individual browser level. In addition, some Sites may request your consent to the placement of cookies. If you consent, you may later remove cookies as your browser permits. If you reject or remove cookies, you may still use our Sites, but your ability to use some features or areas of our Sites may be limited. For more information about the use of cookies and how to block them, visit www.allaboutcookies.org, www.youronlinechoices.eu (Europe) or www.aboutads.info/choices (United States).

You may opt out of receiving personalized advertisements from advertising companies that are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising by visiting http://www.networkadvertising.org/choices and www.aboutads.info/choices.

Our business partners may also use cookies on our Sites for the same general purposes identified in this Privacy Policy, including to improve their own marketing, products or services. Third parties may use cookies and other technologies to collect information about your online activities over time and across different websites. Third parties we work with may also use other "device-graphing" information in order to make inferences and connections about our customers and potential customers across various devices – such as mobile phones, tablets and browsers. (These companies may, for instance, make inferences that devices seen at a common IP address are used by common users.) Companies that we share information with may use the information we provide to them, often in combination with their existing information, to provide you with more relevant advertising. Please see the "Do not Track" section below for more information regarding personalized advertisements and your "Do not Track" options.

Web Beacons: Some of the pages on the Sites may contain electronic images known as web beacons that allow use to count the number of users who have visited those pages. These collect only limited information such as a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These web beacons do not carry any personal Information, and you cannot opt-out or refuse them. However, where they operate with cookies, you can render them ineffective by changing the cookie setting in your browser.

Marketing emails: We use third party service providers to send our marketing emails. There are no cookies in the email. However, they may contain e-tags, which permits you to share the mail via social sites to which you subscribe. In addition, when you click on a link to the Sites included in the email, a persistent cookie is placed on your computer. This cookie is used to measure the effectiveness of our email marketing efforts, better understand how our users navigate through the Sites, and enhance user experience. To that end, we collect a variety of information about how you interact with our marketing efforts, including how many times the email is opened and/or clicked, the browser type used, operating system, user email program, etc. The cookie set by our service providers will remain on your hard drive 30 days after the last time you clicked on the coded link in the email, or until you delete it.

In addition, the third parties that assist with our marketing emails may use pixel tags that help us send the email in a format you can read, to allow us to know which emails you act upon and to better target the content of future emails. We also use these tags to track the aggregate number of emails read and whether any of the links in the email were accessed.

Advertisements: We use third party service providers to serve and host our advertisements. You may receive our ads on these third party sites. These third parties use persistent cookies to track the number of times our site is accessed and whether the site was accessed from the advertisement. The cookies generated from the advertisements do not contain Personal Information and may remain on your hard drive three or more years unless you delete them. If you do not want Personal Information about you used for this purpose, you may opt-out by following the procedure described below. Note, however, that where we use a third party to provide advertising, email marketing or similar services, each such third party will have its own opt-out process, which it will manage and control. You will need to follow those procedures to opt-out of the services they provide.

Personal Profiles: We may collect and maintain Personal Information about you to create a personal profile containing your preferences and other information that you voluntarily provide. This profile may also include information we have obtained from other sources. Examples of the types of information we may collect for this purpose include (i) high vs. low floor, smoking vs. non- smoking room, beverage and pillow type preferences; (ii) whether you participate in travel rewards programs; (iii) email communications with you; and (iv) responses to customer service surveys. Creating and completing a member profile allows you to make reservations more easily and also allows us to enhance your experiences. We will share your preference profile with the Property when you book with the Property. You don’t need to create a profile, but if you do, you must consent to our collection and use of any Personal Information you provide to us, the terms of this Policy, and our Terms https://www.columbiahospitality.com/terms.php. You can later withdraw your consent, but by creating a profile, you affirmatively consent to our collection and use of the information you provide as described herein.

Our Use of Personal Information

We may use the Personal Information provided or obtained through the Sites to:

• Process reservations;
• Process applications for employment;
• Perform research and analysis about your use of, or interest in, our services, or content;
• Communicate with you by email, regular mail, telephone, or texts, about services that may be of interest to you either from us or from other third parties;
• Develop and deliver our newsletter;
• Tailor your user experience;
• Develop and display third-party content and advertising tailored to your interests on the Sites;
• Enforce our Terms;
• Manage our business;
• Notify you of changes to our services;
• Send you information you have requested;
• Process entries to a competition or promotion;
• Carry out obligations under any contract we have with you;
• Perform functions as otherwise described to you at the time of collection;
• In connection with the creation and maintenance of your User Account; and
• In connection with the processing and fulfillment of services you purchase.

We generally store Personal Information in the United States as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, as we determine is necessary for business records, and as required under applicable law. However, we may transfer your Personal Information from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our business. By providing any information to Columbia, you consent to such transfer, storage, and processing.

Disclosure of Personal Information to Third Parties

General: We do not share the Personal Information provided or obtained through the Sites with third parties, except as described below and as otherwise specified in this Policy. We may share Personal Information as follows:

• With the third parties that perform(s) maintenance and operation of the Sites on our behalf. These parties are bound by a confidentiality agreement prohibiting the unauthorized disclosure and/or use of your Personal Information.
• With other third parties that perform services or functions on our behalf. We do not authorize such third parties to use your Personal Information for any other purposes.
• With third parties, such as social sites (including Facebook and Instagram), to which you subscribe in order for you to link to them through our site and view our content through those sites.
• As we believe is necessary to comply with applicable laws, statutes, or regulations, and/or to enforce this Privacy Policy and the Terms and to protect our rights and the rights of others.
• As required by a court or government agency or to respond to a claim by you or a third party
• As part of a transfer of our assets, for example in the event of a merger, acquisition, corporate change or, in the unlikely event of a bankruptcy, involving Columbia.
• As you may otherwise request or agree.

Reservations: Reservations for the Properties are handled directly with the applicable Property website or our booking partner (“Booking Company”). You can also make reservations through third party services, as described in the terms and below. If you make a reservation directly with a Property website or use the Booking Company, the Property (or, as applicable, the Booking Company) will collect and process Personal Information about you in order to process and manage your reservation and for other purposes described in the Terms and this Privacy Policy. Also, as below, by entering into a business transaction with a Property, you consent to our use of this information for direct marketing of Columbia, one or more of the Properties, other of our products, or the products of select, reputable third parties offer products or services that we believe would of interest to you. We may use the services of a third party mail house for the purpose of mailing materials.

Affiliates and Business Partners: We share much of our data, including Personal Information about you, with our affiliated entities, business partners and joint ventures when it is reasonably necessary for the purposes otherwise permitted in this Privacy Policy. This includes the owners of the Properties we manage or operate.

Service Providers: We use third party service providers to provide specific business support services to us which may involve limited access to Personal Information. We require these companies to use the information only to provide the contracted services and prohibit them from transferring the information to another party except as needed to provide the contracted services. Examples of such services include sending emails and/or texts, conducting and administering promotions, executing surveys, providing customer service, performing business analysis, and processing payments. We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.

Business Transactions: We may disclose your Personal Information as part of any merger, sale of company assets or acquisition, as well as in the event of an insolvency, bankruptcy or receivership. The recipient of Personal Information following such actions may have privacy policies that differ from those in this Policy. You will be notified via email and/or a prominent notice on the website, and you may opt- out of the use of your existing information in a new manner.

Special Events: If you choose to participate in a special event (for example, a promotion, contest, or sweepstakes), we may share your Personal Information with those organizations participating in the applicable event.

Other purposes: We may use and share Personal Information for other purposes with your consent.

Disclosure: Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. To request this information please contact us at [email protected].

Other Privacy Policies: Any third parties to whom we may disclose Personal Information may have their own privacy policies that describe how they use and disclose Personal Information. Those policies will govern use, handling, and disclosure of Personal Information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

Other Privacy Policies: Any third parties to whom we may disclose Personal Information may have their own privacy policies that describe how they use and disclose Personal Information. Those policies will govern use, handling, and disclosure of Personal Information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.

Children

The Sites are not directed at children, and we do not knowingly collect Personal Information directly from users under the age of 13 or from other web sites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will not knowingly request or collect Personal Information from any child under age 13 without obtaining the required parental consent.

Corrections and Updates

If you want to view your Personal Information, or delete or modify such information that is inaccurate, you may do so by sending an email to [email protected]. In making modifications you must provide only truthful, complete, and accurate information. We may limit your right to make changes to Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy or where the legitimate interests of other persons may be violated.

Please note that notwithstanding your request to change or delete Personal Information, we may be required to keep this information and not modify or delete it, or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from the active database, but may remain in our archives. In some instances, however, Personal Information that you requested to be removed may be retained in certain files for a period of time in order to troubleshoot problems. In addition, some types of Personal Information may be stored indefinitely on back-up systems or within log files due to technical constraints or financial or legal requirements. Therefore, you should not always expect that all of your Personal Information will be completely removed from our databases in response to your request.

In addition to deleting Personal Information, you may choose to opt-out of receiving future newsletters, promotions or any other email and/or text communications from us by following the unsubscribe instructions included in the communications, or by contacting us via email as provided above. All promotional emails from us include an opt-out link which can be processed within 24-hours. You may also opt-out of promotions by sending us an email in response with “unsubscribe” or “opt-out” in the subject line of the email. Opting out of promotional communications does not affect our communications with you via telephone or email and/or text related to any business we may have with you or other transactional emails.

We reserve the right to verify the identity of any person making a request to opt-out or to delete or modify incorrect Personal Information, to charge you a fee before providing access and to deny such requests, except as prohibited by law; provided, however, that we will have no liability of any kind resulting from false or erroneous requests or any change or deletion we make for any reason.

Storing Your Personal Information

We will retain the Personal Information you give us or we collect for as long as you maintain your User Account or subscription to our newsletters or other content, participate in any of the social features on the Sites, enter any promotions or use any of our other Services, and for a reasonable time thereafter. We will retain and use Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Otherwise we will retain Personal Information for up to twenty- four (24) months and thereafter may store it in aggregate. If you would like us to delete the Personal Information you have provided to us, please contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of this information may be required in order for you to make use of services and features available via the Sites. If you remove this information, you may no longer be able to use these features.

Social Media

The Sites may include social media features, such as the Facebook Like button, and widgets such as the “Share This” button or interactive mini-programs that run on the Sites. These features may collect your IP address, which page you are visiting on the Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Sites. Your interactions with these features are governed by the privacy policy of the company providing each feature.

Security

We have employed the following security measures in place to protect against loss, misuse and alteration of Personal Information under our control. When you enter Personal Information to book a reservation or set up an account, we encrypt that information using secure socket layer technology (SSL). In addition, electronically stored Personal Information is stored on a secure network with firewall protection and access to our electronic information systems requires user authentication via password or similar means. We also employ access restrictions, limiting the scope of employees who have access to Personal Information.

Third Party Websites

The Sites may contain links to other websites. We do not control, and make no representations whatsoever regarding, such other websites or the products and services offered by or through websites accessed through links on the Sites, even those with which we may have an affiliation.

If you visit one of our Sites and decide, for example, to purchase a gift certificate, make reservation, rent a car, submit award request forms or apply for a job online, you may be seamlessly linked to websites maintained by third parties with whom we have contracted to provide those services. In some instances these websites may be co-branded and display our logos or other trademarks.  You should always look at the location bar within your browser to determine whether you have been linked to a different website. This Privacy Policy, and our responsibility, is limited to our own information collection practices.

We are not responsible for, and cannot always ensure, the information collection practices or privacy policies of other websites maintained by third parties or our service providers where you submit your personal information directly to such websites. In addition, we cannot ensure the content of the websites maintained by these third parties or our service providers, even if accessible using a link from our websites. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites. If you decide to access third party websites linked through the Sites you do so at your own risk.

Reservations Through Third Parties

In addition to making reservations for Properties directly through us and/or our Booking Company, you may make reservations for the Properties through aggregators like Booking.com, Expedia, Orbitz, or Kayak (“Aggregators”). If you use an Aggregator to book reservations at the Properties, they may have different privacy policies and you are responsible for reviewing them before you make a reservation. If you use another online booking website to reserve lodging at a Property, you do so at your own risk and you should carefully review the privacy policy and terms of any such websites.

Commercial Electronic Message Consent

By providing your email address to us through the Sites or entering into a business transaction with one the Properties, you affirmatively and expressly consent to receiving commercial emails from Columbia, the Properties, and those parties that process email and/or text communications on our behalf. Columbia and these third parties may send you commercial emails in order to deliver the Newsletter, to provide you with more information about available services you have purchased, and to provide you with updates, special offers, and other information, including but not limited to Site updates and offers or promotions from Columbia and/or the Properties.

Other Terms and Conditions

Your access to and use of the Sites and our services are also subject to our Terms. In addition, each Property may have its own terms, including additional policies governing the collection and use of Personal Information. Your access and use of services available from each Property is also subject to the terms applicable to that Property as presented on the Site for that Property. You should carefully review the privacy policy and terms of these Property Sites.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, contact us at [email protected]. We will respond to your request to access within 30 days.

Changes to this Privacy Policy

We reserve the right to change or modify this Privacy Policy as we deem necessary or appropriate due to changes in our business practices or changes in the law. If you have provided us with your email address, we will attempt to notify you by that address of any material changes to how we use your Personal Information.

California State Privacy Rights Notice

Effective January 1, 2005, under California Civil Code Section 1798.83, if an individual who is a California resident has provided Personal Information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual’s Personal Information to a third party and knows or should have known that such third party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what Personal Information was shared and with whom it was shared.

We have summarized the Personal Information we collect and may disclose to third parties by reference below to both (a) the categories defined in the “Information We Collect” section of this Privacy Policy above and (b) the categories of Personal information specified in the CCPA (Cal. Civ. Code §1798.140). We may use each of the categories of Personal information below for the purposes identified in the “Our Use of Personal Information” section of this Privacy Policy above. This section also describes our practices currently and during the twelve (12) months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us may contain other categories of Personal information not described below. More information about the categories of sources from which we collect Personal Information and the purposes for collecting or disclosing Personal information are described in respective sections above in this Privacy Policy.

Personal Information (“PI”) We Collect from You	CCPA Statutory Category	Categories of Third Parties to Whom We “Disclose” PI for a Business Purpose
Contact data	IdentifiersCommercial informationCalifornia customer records	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Online identifiers and account information	Identifiers	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Communications data	IdentifiersCommercial informationCalifornia consumer records Internet or Network Information	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Payment and transactional data	Commercial informationCalifornia consumer recordsFinancial information	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Marketing data	IdentifiersCommercial informationCalifornia customer recordsInternet or Network Information	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Dietary information	IdentifiersCommercial informationCalifornia customer records	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Audio, electronic, and visual information	Sensory informationIdentifiersCalifornia customer records	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Data about others	IdentifiersCalifornia customer records	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Device data	IdentifiersInternet or Network Information	AffiliatesProperty OwnersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Online activity data	IdentifiersCommercial informationInternet or Network information	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
General location data	Geolocation data	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Communication interaction data	IdentifiersCommercial informationCustomer records informationInternet or Network Information	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Data derived from the above	Inferences	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors
Purchase history	IdentifiersCalifornia customer records Commercial information	AffiliatesTravel or accommodations providersService providersThird parties designated by youProfessional advisorsAuthorities and othersBusiness transfereesBusiness and marketing co-sponsors

Do Not Track.  Section 22575 of the California Business & Professions Code requires website and online service operators to disclose whether they honor web browser “Do Not Track” settings. We support and honor “Do Not Track” web browser settings. If you enable Do Not Track settings in the browser you are using, we will not collect, store, or use Personal Information about websites you visit using that browser other than www.columbiahospitality.com and our other Sites. Other parties, however, may not honor Do Not Track signals. These parties may collect Personal Information about your online activities over time and across different web sites when you visit the Sites, for example by using cookies on our Sites. We have no access to or control over other parties’ Personal Information collection practices, even those with which we may have an affiliation. You should carefully review the privacy policy and terms of any website you visit. For more information about Do Not Track, please visit www.allaboutdnt.org.

Any request for a disclosure required under this California law should be sent to us via email at [email protected] or via regular mail at:

Columbia Hospitality, Inc.

ATTN: Legal Department

2200 Alaskan Way, Suite 200

Seattle, WA 98121

Please note that under this law, we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email or mailing address designated above.

International Visitors

The Sites are hosted in and provided from the United States and are intended for those visiting the United States. If you use the Sites from the European Union (E.U.), Canada, or other countries or regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information to the United States for storage and processing. The United States does not have the same data protection laws as the E.U., Canada, and other countries or regions.

European Privacy Rights Notice

The Sites are directed at consumers in the United States and the Properties we own or operate are located in the United States. In most cases, the Personal Information we collect is stored and used in the United States.

While we do not direct our Services to residents of the E.U., it is possible that E.U. residents may access and use the Sites. If we collect Personal Information from E.U. residents in a manner subject to the General Data Protection Regulation then, in addition to the above, the following terms shall also apply to our collection, use and retention of that information:

Personal Information: References to “Personal Information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation – i.e., any information relating to an identified or identifiable natural person. It does not include “anonymous data” (i.e., information where the identity of individual has been permanently removed).

Basis for Collection: As set out above, we collect and process Personal Information for which you have given your express consent at the time of collection. For example, we collect Personal Information when you elect to participate in one of our promotions. We also collect and process Personal Information in order to improve our Services, to deliver Services and perform obligations under contracts we have with you, and to comply with our own legal obligations.

Sensitive Data: We do not collect sensitive data, (as defined in General Data Protection Regulation 2016/679) for example, biometric data, health data, or data revealing racial or ethnic origin, from visitors to the Sites.

Onward Transfer: Except as otherwise provided in this Privacy Policy, we only disclose Personal Information to third parties who reasonably need to have access to it for the purpose of the transaction or activity for which it was originally collected or to provide Services or to perform tasks on our behalf or under our instruction. All such third parties must agree to use such Personal Information we provide to them only the purposes for which we have engaged them and they must either: (a) comply with the E.U.-U.S. Privacy Shield Principles or another mechanism permitted by the applicable E.U. & Swiss data protection law(s) for transfers and processing of Personal Information; or (b) agree to provide adequate protections for the Personal Information that are no less protective than those set out in this Privacy Policy. Where we have knowledge that an entity to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure.

Authorized Transfer: We also may disclose Personal Information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of Personal Information to third parties.

Controller. Columbia is responsible for your personal data. Columbia is a corporation formed under the laws of the State of Washington, United States of America, with offices in the U.S. For the purposes of European data protection legislation, your data will be controlled by Columbia.

Data Processors: We may retain third parties to process or analyze Personal Information we collect from the Sites. For example, a Site may be maintained or hosted by a third party service provider, a promotion may be administered by a sales promotion agency, and/or products may be fulfilled by a wholesaler. These suppliers and other third parties who provide services for us are contractually obligated not to use Personal Information about you except as we authorize.

Legal Basis for Processing: In respect of each of the purposes for which we use your Personal Information, the European data protection legislation requires us to ensure that we have a legal base for that use. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. If you have questions about the legal basis of how we process your personal information, contact us at [email protected]. 

Processing purpose Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information.”	Categories of personal information involved Details regarding the categories of personal information listed below are provided in the section above titled “Personal information we collect.”	Legal basis
1. Service delivery and operations: We need to process your personal information to operate the Services, including responding to your requests or inquiries, providing you with access to content or information you requested, etc.	Contact dataCommunications dataOnline identifiers and account informationPayment and transactional dataDietary information/general preferencesMarketing dataAudio, electronic, and visual informationInternet activity or electronic network activity information Other dataDevice Data	Processing is necessary to perform the contract governing our provision of our Services or to take steps that you request prior to signing up for the Services.   We also process this information where we have collected your consent.
2. For research and development: We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.	Any and all data types relevant in the circumstances	These activities constitute our legitimate interests. We do not use your Personal Information for these activities where our interests are overridden by the impact on you.
3. We may need to process your personal information for additional purposes, such as: To ensure access and maintenance of the Services, and to ensure their proper functioning.For compliance, fraud prevention and safety.For sharing your personal information with third parties as described in this Privacy Policy.To disclose your personal information to a prospective or actual purchaser or seller in the context of a merger, acquisition or other reorganization or sale of our business or assets. For the collection of statistical information about the use of the Services.To protect our interests as a company, for different purposes, such as:Enforcement of the Terms of Service.Assess claims that any content violates the rights of third-parties.For the establishment or exercise our legal rights or defending against legal claims.	Contact dataCommunications dataOnline identifiers and account informationPayment and transactional dataDietary information/general preferencesMarketing dataAudio, electronic, and visual informationInternet activity or electronic network activity information Other dataDevice Data	We rely on our legitimate interests to process your Personal Information when performing these processing activities. We do not use your Personal Information for these purposes where our interests are overridden by the impact on you.
4. For marketing and advertising purposes: We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes.	Contact dataCommunications dataDevice dataInternet activity or electronic network activity information Marketing dataOther data	Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.
5. Compliance with legal obligations and protection purposes: We are subject to certain legal obligations that may oblige us to disclose your personal information to courts, law enforcement or regulatory authorities.	Any and all data types relevant in the circumstances.	Processing is necessary to comply with our legal obligations. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
6. Further uses: We may use your personal information for reasons not described in this Privacy Policy.	Any and all data types relevant in the circumstances.	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.  Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Your Rights: Your rights include: (a) a right to withdraw your consent to the processing of Personal Information about you to which you have previously given consent; (b) a right to object to processing of Personal Information about you for the purpose of direct marketing; and (c) a right to have any incorrect part of the Personal Information about you corrected or removed. If you wish to exercise any of these rights, send an email to us at [email protected].

If you request to have incorrect Personal Information removed, we may retain some of your Personal Information as necessary for the purposes of our legitimate business interests or in furtherance of public interests in accordance with the Privacy Shield Principles. Any Personal Information you have shared publicly with others may continue to be publicly visible on the Sites.

You also have the right to obtain a copy of the Personal Information we have about you, although we reserve the right to charge a reasonable fee for this depending on the nature and frequency of your request(s) and our cost to provide the information.

Questions and Complaints: If you have questions or complaints regarding this Privacy Policy or our handling of Personal Information about you, please contact us at [email protected].

Enforcement and Disputes: We commit to resolve complaints about your privacy and our collection or use of your Personal Information in a timely and reasonable manner. If you do not receive timely acknowledgement of your request or have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at [email protected].

In addition to the above, you may lodge a complaint with your home data protection authority and can invoke binding arbitration for residual claims not resolved by other redress mechanisms. Contact details for the E.U. data protection authorities can be found at http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.

SMS/MMS Messaging Terms and Conditions

A. The Program. 

We may offer one or more mobile messaging programs (each, a “Program”). By opting in to one or more text messaging Programs, you:

• consent to receive non-marketing and marketing text messages from us and others on our behalf, including text messages made with an autodialer, at the telephone number(s) that you provide; and
• agree that the Programs are subject to the SMS/MMS messaging terms and conditions set forth in this Section 2 (“SMS Terms”), these Terms, and our Privacy Policy (collectively, the “SMS/MMS Agreement”).

Your agreement to this SMS/MMS Agreement includes your agreement to resolve any disputes with us through binding, individual-only arbitration, as detailed in the “Binding Arbitration; Class Action Waiver” section in our Terms of Use. This SMS/MMS Agreement is limited to the Program and is not intended to modify these Terms or our Privacy Policy that may govern the relationship between you and us in other contexts.

B. Program Description. 

Without limiting the scope of the Program, users that opt into the Program can expect to receive messages relating to the marketing, sale and promotional material related to the sale of our services available through our Site. 

C. Eligibility.

To receive our text messages, you must be 13 years of age or older.

D. User Opt In. 

To opt-in to receive text messages from one of our Programs, please follow the instructions provided via the Site. While you consent to receive messages sent using an autodialer, the foregoing shall not be interpreted to suggest or imply that any or all of our mobile messages are sent using an automatic telephone dialing system (“ATDS” or “autodialer”). Note that message and data rates may apply.

E. User Opt Out. 

If you do not wish to continue participating in the Program or no longer agree to this Agreement, you agree to reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any mobile message from us in order to opt out of the Program.  You may receive an additional mobile message confirming your decision to opt out. You understand and agree that the foregoing options are the only reasonable methods of opting out. Note that all message and data rates may apply.

E. Cost and Frequency. 

Your mobile carrier message and data rates may apply to communications we send you via the Program and any messages that you send to Columbia. The Program involves recurring mobile messages, and additional mobile messages may be sent periodically based on your interaction with us.

F. Program Support.

If you have any questions or need any support regarding the Program, including help with opting-out of the Program, please text “HELP” to the number you received messages from or email us at [email protected].

Opt outs must be submitted in accordance with the procedures set forth above. Note that all message and data rates may apply.

G. Program User Notification and Indemnification. 

You represent that you are the account holder for the mobile telephone number(s) that you provide. You are responsible to notify us immediately if you change your telephone number, cancel your service plan or transfer your phone number to another party. You can do so by completing the User Opt Out process set forth above prior to ending your use of the mobile telephone number and by changing the number on your profile for the website associated with the Program(s) you opted into. You understand and agree that your agreement to do so is a material part of these terms and conditions. You further agree that, if you discontinue the use of your mobile telephone number without first opting-out of the Program, you agree that you will be responsible for all costs (including attorneys’ fees) and liabilities incurred by us, or any party that assists in the delivery of the mobile messages, as a result of claims brought by individual(s) who are later assigned that mobile telephone number. This duty and agreement shall survive any cancellation or termination of your agreement to participate in any of our Programs. YOU AGREE THAT YOU SHALL INDEMNIFY, DEFEND, AND HOLD US HARMLESS FROM ANY CLAIM OR LIABILITY RESULTING FROM YOUR FAILURE TO NOTIFY US OF A CHANGE IN THE INFORMATION YOU HAVE PROVIDED, INCLUDING ANY CLAIM OR LIABILITY UNDER THE TELEPHONE CONSUMER PROTECTION ACT, 47 U.S.C. § 227, et seq., OR SIMILAR STATE AND FEDERAL LAWS, AND ANY REGULATIONS PROMULGATED THEREUNDER RESULTING FROM US ATTEMPTING TO CONTACT YOU AT THE MOBILE TELEPHONE NUMBER YOU PROVIDED.

H. MMS Disclosure. The Program will send SMS TMs (terminating messages) if your mobile device does not support MMS messaging.

I. Our Disclaimer of Warranty. The Program is offered on an “as-is” basis and may not be available in all areas at all times and may not continue to work in the event of product, software, coverage or other changes made by your wireless carrier. We will not be liable for any delays or failures in the receipt of any mobile messages connected with this Program. Delivery of mobile messages is subject to effective transmission from your wireless service provider/network operator and is outside of our control. 

Updated 10/31/2024