Privacy Policy

OUR COMMITMENT TO PRIVACY

This policy was last updated on August 18th, 2026.

Proper Hotels respects the privacy of all our guests, and we are committed to protecting privacy through our compliance with this policy. This policy describes the type of information we may collect from our guests and private members, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This statement applies to our offline and online services, any content or information therein, including the www.properhotel.com, www.avalon-hotel.com, www.shelborne.com, www.culverhotel.com, www.thehoteljune.com, www.inglesideestate.com, www.montaukyachtclub.com and www.calnevaresort.com, any subdomains of such websites, and any other website pages on which services are provided (“Website” or “Digital Access”) and (“Property” or “Properties”).

By using any of our products or services you acknowledge and agree to the privacy terms contained in this statement and related links in the context of the collection and use of personal information and/or registering for any of our product or services. Please note that this statement does not apply to our processing of personal information on behalf of and subject to the instructions and policies of third-parties such as airlines, travel services, car rental companies, marketing partners, corporate customers, and other similar services providers.

1. CATEGORIES OF INFORMATION COLLECTED

This privacy policy applies to information we collect off-line and on this Website, Digital Access, and our Properties, including, name, telephone, email address, home or business address, nationality, date of birth, gender, payment card information, private membership identification numbers, passport information or other government-issued identification information, preferred language, geolocation, additional guest names, travel itinerary, corporate travel planner contact information, including name, title, company, business phone, email and address), travel agent number and name, airline partner name and number, vehicle identification number, images or footage captured property-based cameras, internet or online network activity information, IP address, session id, booking engines, streaming service usage, prior guest stays or interactions, goods and services purchased, special service, amenity requests, and room preferences, social media account ID, profile photo and other data publicly available, or data made available by linking your social media to loyalty accounts, and where applicable, chatbot prompts, messages, and responses, voice recordings or transcripts of telephonic interactions, and other content you provide through AI-enabled tools.

2. CATEGORIES OF HOW WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Website or use Digital Access, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visit to our Website or use of Digital Access (“usage data”), including traffic data, location data, logs, and other communication data and resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, unique device ID, referral URLs and browsing type.
The technologies we use for this automatic data collection may include.

• As described further below, cookies are pieces of data stored directly on your computer or mobile device. Our Website and/or Digital services use cookies or other identifiers to improve user experience, which includes serving personal advertisements for Proper Hotel’s and third-party products and services. You may receive this type of information via email, on our Websites, or on other websites on the Internet. We also use this information to establish metrics on how users interact with our Websites to personalize your experiences. We do this through tracking technologies including cookies.

Generally there are five different types of cookies:

1. Strictly Necessary (essential) Cookies

These cookies are essential for the website to function and cannot be switched off. They are usually set in response to actions you take, such as setting your privacy preferences, logging in, or filling out forms.

2. Performance Cookies

These cookies collect anonymous data on how visitors use the website. We use this information to improve functionality and understand traffic patterns.

3. Functional Cookies

These cookies remember your preferences and choices, such as language or region, to provide a more personalized experience.

4. Targeting / Advertising Cookies

These cookies are used to deliver relevant advertisements based on your browsing behavior. They may also limit the number of times you see an ad and help measure campaign effectiveness.

5. Social Media Cookies

These cookies enable you to share content via social networks and may track your interaction with embedded services.

• Tracking Technologies. When you activate and engage in any Digital Access, digital services available at our Properties, clicking on the link to access this Website, or when you are redirected to this Website or Services via any of our digital partners your access includes our use and our digital partners’ use of standard internet data collection, processing and marketing practices that includes the use any number of tools, including, without limitation, analytic data collection technologies, chatbots, session replay technologies, identity graphing, web beacons, pixel-based technologies, and other similar technologies to collect information about your use of the Services. By reading this privacy policy, you acknowledge ours and our digital partners’ use of such technology includes your ratification of our use of such technologies in the processes related to the initial loading and execution of code within your access device or web browser. The information we collect related to these processes includes without limitation, device information including identifiers, access point information, website usage information, computer operating systems, IP addresses, the web browser that you use to connect to our Website and Service. With your consent and acknowledgment you expressly agree to waive any and all claims against us or our digital partners under state eavesdropping or pen register and/or trap and trace laws, or any similar laws related to pen register and/or trap and trace devices or processes to the extent such claims arise from standard digital operations as set forth above. If you cannot accept these terms, or if you wish to withdraw your consent, you may not use our Website, Digital Access, or digital services available at our Properties, and in either case your continued use of Services revives your consent.

AI-enabled conversational tools. The use of chatbots and other conversational tools is subject to the more specific disclosures in the “Artificial Intelligence Use Disclosure” below.

We partner with third-parties like Microsoft and Monetate to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Our digital services may also host ads through third-party advertising technology. In the course of serving our advertisements to you, unique third-party persistent cookies, clear gifs or beacon gifs may be placed on your computer or device to help manage our online advertising, recognize when a device visits our Websites, learn which ads bring users to our Websites, and track whether a reservation is made. The information our ad-serving providers and we collect through this technology is not personally identifiable but is used to create an anonymous profile which allows the ad-serving provider to serve ads targeted towards you and your interests across the ad-serving network.

Our Websites do not currently respond to “Do Not Track” signals that may be sent by your device or browser. Our third-party platform service providers maintain tools that permit recognition of “opt-out preference signals.”

Artificial Intelligence and Automated Decisionmaking Technology Use Disclosure

Some services available on Proper Hotels’ platform, at our Properties, and in our internal processing may use artificial intelligence or other machine-based technology (“AI”). AI may enable computers, systems, and digital devices to learn, read, write, categorize, classify, predict, engage, interact, generate, analyze, make recommendations, or perform similar functions using historical and current information. We use AI to assist with the hospitality, reservation, folio, billing, guest-service, restaurant, marketing, security, fraud-prevention, quality-assurance, and other operational purposes described below. AI outputs may be inaccurate or incomplete and may be reviewed or corrected by human personnel. Our acceptable-use policies and procedures prohibit use of AI to generate content that is discriminatory or harmful. AI is not used by our platform to make employment-related decisions. For purposes of California law, “automated decisionmaking technology” or “ADMT” means technology that processes personal information and uses computation to replace or substantially replace human decisionmaking. AI used only to organize information or assist a human who knows how to interpret and review the output and has authority to change the decision may not constitute ADMT. If we use ADMT to make a significant decision concerning you, the notice, opt-out, access, and appeal rights described below will apply.

Guest Folio Compilation and Billing. We may use AI-enabled tools to collect, organize, reconcile, and summarize information used to prepare and process your guest folio and other bills. This information may include your name and reservation details, room and stay information, room charges, restaurant, bar, spa, event, retail, transportation, and other purchases or services, applicable taxes, fees, gratuities, payment information or payment tokens, and communications concerning charges. The output may include proposed line items, totals, tax or fee calculations, payment-status information, or flags for human review. These tools support billing, payment processing, and collection; they are not used to make employment-related decisions. You may request correction or human review of a folio or billing item through the contact methods in Section 13.

Final Folio AI Notice. If AI is used to compile, reconcile, or calculate any portion of your final folio or bill, the final folio or bill will include a clear and conspicuous notice that AI was used and will identify how you may request correction or human review. The notice will be provided with the final folio or through the channel in which the final folio is delivered. This point-of-use notice supplements the disclosures in this policy and must be implemented on the folio or in the delivery channel.

Website, Mobile Application, and Pop-Up Chatbot Interactions. When you interact with a chatbot, virtual assistant, or other AI-enabled conversational tool on our Websites, through Digital Access, in a mobile application, or in a pop-up, we will provide a clear notice at or before the start of the interaction that you are interacting with AI rather than a human. We may collect the content of your prompts, messages, and responses, together with device, network, reservation, account, and other information you provide or that is generated during the interaction, to respond to your request, assist with reservations and services, provide hotel, restaurant, spa, event, and Property information, detect fraud or security incidents, maintain and improve our services, and for other disclosed purposes. AI responses may be inaccurate or incomplete; where available, you may request human assistance. If the tool is used as ADMT for a significant decision, the applicable Pre-use Notice and rights described below will be provided before that use.

Telephonic AI Interactions. If you communicate with us by telephone through an AI-enabled voice assistant, automated agent, or other AI system, we will provide an oral notice at or before the beginning of the interaction that you are interacting with AI. We may collect your telephone number, voice recording, transcript, call metadata, reservation and account information, payment or billing information, and other information you provide, to authenticate and assist you, manage reservations, answer questions, process or collect payments, provide guest or restaurant services, monitor quality, and prevent fraud or security incidents. You may request a human representative, subject to availability. If the interaction involves a Notice at Collection or a Pre-use Notice required by law, we will provide it orally or through a clear link or other accessible method during the call.

Hotel and Restaurant Customer Interactions. At our Properties, including front desk, concierge, guest services, room service, restaurants, bars, spas, events, and other customer-facing operations, we may use AI-enabled tools to assist with reservations, ordering, menu or service information, translation, recommendations, scheduling, requests, communications, and service quality. We may collect the information you provide in those interactions, including, where applicable, reservation, stay, preference, purchase, location, audio, image, and other information, and may disclose it to service providers and contractors that operate or support these tools. We will provide a point-of-interaction notice, such as signage, a printed notice, an in-app or kiosk notice, or an oral notice, at or before collecting information through an AI-enabled tool. Where an AI output is used to make a decision that falls within applicable ADMT requirements, we will provide the required Pre-use Notice and honor applicable opt-out, access, and appeal rights.

ADMT Pre-use Notices and Explainability. When a use of ADMT is subject to applicable law, the Pre-use Notice will be provided prominently at or before the point at which we collect or process personal information for that use and in the manner in which we primarily interact with you. It will state the specific purpose, explain how the ADMT processes relevant categories of personal information to generate an output, describe the type of output and how it is used, identify the alternative process if you opt out, describe how to opt out and request access, and state that we will not retaliate for exercising CCPA rights. If we rely on an exception to the opt-out right, the notice will identify the exception and, where applicable, the human appeal process. In response to a request to access ADMT, we will provide plain-language information about the specific purpose, logic, output, and outcome, subject to applicable legal exceptions. We may provide additional information through a simple layered notice or link and will not disclose trade secrets or information that would compromise security or safety.

3. HOW WE COLLECT INFORMATION

• Through this Website, Registration at Properties and Digital Access
• Through automated business operations and customer experiences
• Through AI-enabled chatbots, voice assistants, kiosks, and other automated customer-experience tools
• Through digital applications made available by us or our travel services partners for use on or through computers and mobile devices
• Through our social media pages that we control
• Through email messages that we send you

When you visit or stay as a guest at one of our properties, we collect other information in addition to your Personal Information in accordance with the law, and to serve you better. This information may include personalized preferences such as room choice and other personalized amenities.

4. WHY WE COLLECT AND HOW WE USE INFORMATION

We use your personal data to fulfill the business and operational purposes for which it was collected, or as otherwise set forth in this policy. This following chart provide a general overview of the business purposes for our collection of personal information and reasons for such collection:

Email and Direct Mail Marketing for U.S. Guests. If you provide your email address or mailing address when making a reservation or interacting with us, we may use that information to send you promotional emails or direct mail about our properties, services, offers, events, and related hospitality offerings, unless you opt out. You may unsubscribe from marketing emails by using the unsubscribe link included in those emails or by contacting us at the address listed below. We may continue to send transactional or service-related communications about your reservation, stay, membership, account, or transactions. We may use the usage data we collect for any reason we deem appropriate, including to improve, maintain, and operate our Websites and services.

5. MORE ON OUR REASONS FOR COLLECTION

We collect the following categories of personal information:

• Website and Digital Access – Internet or other electronic network activity information, including information regarding your interaction with websites, applications, or advertisements, IP address, session ID, booking engine.

We collect this type of information to provide you with targeted advertisements on marketing efforts including media, email, and chat, to optimized our Website and Digital Access properties, support marketing efforts and to perform analytics to improve business operations. We will retain this information the period of time consistent with browsing preference and as required to meet of business obligations,

• Making Reservations – Name, additional names, telephone number, address, email address, preferred language, membership, payment card information, membership identification numbers, corporation name and number, travel service account numbers, airline partner numbers, preferred language. When you make a reservation or otherwise provide information to us in connection with a booking, we collect information such as your name, email address, telephone number, mailing address, stay details, preferences, and related reservation information. We use this information to process and manage your reservation, provide guest services, send transactional reservation communications, personalize your experience, and, where permitted by law, send marketing communications about our hotels, restaurants, spas, events, offers, packages, loyalty programs, and related services.

We collect this type of information to look up and verify your reservation, to confirm and execute on your reservation, send communications for marketing purposes and regarding your reservations via text message, email or voice phone communications, send you marketing communication via email and direct mail, perform analytics in order to provide you with personalized offers and content, perform analytics to improve business operations, determine eligibility for promotional or special rates and offers, process payments, compile, reconcile, and communicate guest folios and other billing records, including through AI-assisted tools as described in the “Artificial Intelligence Use Disclosure,” process transactions with our business partners, share your information across or brand and product and service lines, optimize our services, provide premium services to you, and to detect and prevent fraud. We will retain this information the period of time consistent with your membership and reservation activities and preferences, and as required to meet of business obligations.

• Enrolling in Memberships and Guest Programs – Name, telephone number, address, email address, email subscription preferences, opt-out preferences, preferred language, payment card information, corporation name and number, travel service account numbers, airline partner numbers, preferred language.

We collect this type of information to administer your membership in our exclusive programs, verify your account, send you communications relating to your membership, send you marketing communications, perform analytics and personalize offers and promotions, to optimize our business, process payments, share information across our brands and product and service lines, and to detect and prevent fraud. We will retain this information the period of time consistent with your membership activities and preferences, and as required to meet our business obligations.

• At Property Check-In – Name, payment card information, additional guest names, and passport information.
We collect this type of information to verify your reservation, receive payment for your reservation, execute your reservation, comply with applicable laws that require the collection of certain type of information, to verify membership, guest assistance, to send you communications at the end of your stay. We will retain this information the period of time consistent with your reservation activities, membership activities, transactions requirements, preferences, and as required to meet our business obligations.

• Electronic or Digital Applications Check-In – Payment card information and precise geolocation.
We may collect this information via Digital Access in order to receive payment for your reservation, execute your reservation, personalize your experience, enable access to room assignment Property facilities, and support and guest assistance. We will retain this information the period of time consistent with reservation activities and guest assistance requirements, as required to meet our business obligations.

6. SHARING OF INFORMATION

We will not sell any of your personal data to any outside organization. We may disclose aggregated information about our customers, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates:

• We may disclose contact information, reservation information, marketing preferences, guest-service interactions, folio, billing information, and other personal information to service providers and contractors that help us operate our marketing and guest-service programs, including email, SMS, customer relationship management, analytics, preference-management, AI, machine-learning, chatbot, voice-assistance, folio, billing, and payment platforms. These service providers and contractors are authorized to use personal information only to provide services to us and not for their own independent marketing or for marketing on behalf of other businesses, unless otherwise disclosed and permitted by law.

• To a buyer or other successor in the event of a merger, divestiture, restricting, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred.

• To fulfill the purpose for which you provide it
• For any other purpose disclosed by us when you provide the information
• With your consent
• To carry out the permitted uses described in the “WHY COLLECT AND HOW WE USE INFORMATION” section of this policy

We may also disclose your Personal Information:

• To comply with any court order, lawful discovery request, or legal process, including to respond to any government or regulatory request

• To enforce or apply our 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 our safety, our customers, or others.

7. LINKS TO THIRD PARTY WEBSITES

Please be aware that third-party websites available through links on our Websites each have separate privacy and data collection practices. We have no control, responsibility or liability for these third-party websites or their applicable policies or content. We cannot ensure or warrant the security of any information you disclose on third-party sites.

8. WHERE PERSONAL INFORMATION IS PROCESSED

We are based in the United States, and personal data is collected worldwide (including within the European Economic Area, United Kingdom, and other regions around the world) and may be transferred to the United States for processing and storage.

9. SMS, MMS TEXT MESSAGING AND PUSH NOTIFICATION

Our services may include certain features and services that may be available via your mobile phone, including, without limitation: (a) the ability to receive information and reply to messages via in-app push notifications, and to send content and messages using text messaging (Mobile Texts), and (b) the ability to access our services from your mobile phone (Mobile Web) (collectively, the “Mobile Services”). We do not charge for Mobile Services. Your carrier’s normal messaging, data and other rates and fees will still apply. Certain Mobile Services may be incompatible with your carrier or mobile device. Marketing Text Messages. We will send marketing text messages only where we have obtained any consent required by applicable law. If you choose to opt in, you authorize Proper Hotels to send recurring marketing text messages to the mobile number you provide, including messages sent using automated technology, about offers, promotions, events, packages, and related services. Consent to marketing text messages is not required as a condition of making a reservation or purchasing any goods or services. Message and data rates may apply. You may opt out of marketing texts at any time by replying STOP, or by using any other method we make available. By providing us with your mobile number and using the Mobile Services you explicitly consent and agree that we may communicate with you regarding the Website and our partners by in-app push notifications, SMS, MMS, text message or other electronic means to your mobile device and that certain information about your usage of the Mobile Services will be communicated to us. Our Mobile Services also use cookies and other tracking technologies to keep track of items or services that you have entered into our digital shopping cart, and to provide you notice, including when you have abandoned selected items or services that you have placed into your cart. This information is used to determine when to send you digital shopping cart reminder messages via SMS. In connection with the Mobile Services we may send communications to your mobile device regarding us or other parties.

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

10. RETENTION OF PERSONAL INFORMATION.

Generally, we will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To ensure that we can complete transactions related to services;
• To respond to any questions, complaints or claims made by you or on your behalf;
• To improve our business operations;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information and the reasons for processing. In the event that your personal information is deidentified, or anonymized, we will not make any efforts to reidentify such information.

11. SECURITY OF PERSONAL DATA

We are committed to the security of your personal data. We use commercially reasonable technical measures to protect personal data in our possession, and our Website uses secure socket layer (SSL) encryption technology to help protect the privacy of credit card information, name, address, email and other sensitive information you provide to us.

12. CHILDREN UNDER THE AGE OF 18

Our Websites and services are not intended for children under 18 years of age. and we do not knowingly solicit or collect personal data from children. No one under age 18 may provide any Personal Information to us. If we are notified or discover that a child under the age of 18 has submitted Personal Information to us, we will not sell such information, and we will take reasonable steps to delete the information.

13. STATE DATA PROTECTION LAW COMPLIANCE

We do not sell or share personal information. Under several new state data protection laws, consumers have the following rights regarding personal data we have collected about you. For purposes of this section only, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person and excludes employment data, personal data that cannot be attributed to an individual without the use of additional information, and de-identified data or publicly available information. Under these laws consumers have the right to request any of the following information from us regarding personal information collected about you:

The right to know (i.e., the right to confirm whether we are processing your personal data). This information includes:

• The categories of personal information collected about you.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose for collecting or selling personal information.
• The categories of third parties with whom we share personal information, if any.
• The specific personal information collected about you.
• For personal information sold or disclosed to a third party for a business purpose, you have a right to know the categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and the categories of personal information that we disclosed about you for a business purpose.
• The right to access (i.e., the right to access your personal data processed by us);
• The right to a copy (i.e., the right to obtain a copy of your personal data that you have previously provided to us in a portable and readily usable (if technically feasible) format);
• The right to correct inaccuracies (i.e., the right to correct inaccuracies in your personal data based on the nature of the data and the purposes of the processing);
• The right to deletion: (i.e., the right to request us to delete your personal data provided to us);
• The right to opt out of the: (1) sale or limit the use of sensitive personal information, (2) processing of your personal data for certain purposes, including, profiling in furtherance of a decision that produces a legal or similar significant effect concerning the consumer, or (3) targeted advertising.
• The right to appeal adverse decisions regarding your request exercise any of the foregoing rights. We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your California residency), subject to delays and exclusions permitted by law. Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.

Automated Decisionmaking Technology Rights. If we use ADMT to make a significant decision concerning you, you may opt out of that use of ADMT, subject to applicable exceptions, and you may request access to information about how the ADMT was used with respect to you. We will provide a Pre-use Notice before collecting or processing your personal information for that use. The notice will identify the specific purpose, how to opt out or appeal where an exception applies, how to request access, and the alternative process if you opt out. We will not retaliate against you for exercising these rights.

We will not discriminate against you if you choose to exercise any of these rights. You may exercise the rights described above by clicking “Personal Data Request” at the bottom of this page and following the instructions, by emailing [email protected], or, where the applicable right is provided through an offline interaction, by calling 833-613-1919 or asking a Proper Hotels representative. We will maintain at least two designated methods for submitting requests to opt out of ADMT, including the Personal Data Request process and email at [email protected], and at least one method will reflect the way we primarily interact with you. To opt out of ADMT, use the “Opt-Out of Automated Decisionmaking Technology” option in the Personal Data Request process or email [email protected] with that subject line. To request access to ADMT, use the same process or email [email protected] with “Request to Access Automated Decisionmaking Technology” in the subject line. An ADMT opt-out request will not require identity verification, although we may request information reasonably necessary to identify the consumer or process the request, and we will process the request as soon as feasibly possible and no later than 15 business days after receipt. We will provide a means to confirm that the opt-out request has been processed. We may require verification of your identity before further processing other requests where verification is permitted or required by law. In certain instances, we may be permitted by law to decline some or all of such request.

Notice to Oregon Residents: In addition to your rights to obtain a copy of your personal data, require us to delete your data, or opt out of sale or sharing of your data, Oregon law allows consumers to confirm whether we are processing your personal data and the categories of personal data we are processing or have processed. Additionally, Oregon law allows consumers to, at our option, obtain a list of specific third parties, other than natural persons, to which we have disclosed your personal data or any personal data. To make a request for this listing, please use this Form. Please note that responses to these requests will be subject to Proper Hotels’ intellectual property rights as permitted under Oregon law.

Appeals Process
Automated Decisionmaking Technology Appeals. If we rely on an applicable human-appeal exception to the right to opt out of ADMT, you may appeal the decision to a human reviewer who has authority to overturn it. To submit an appeal, use the “Personal Data Request” process, email [email protected], call 833-613-1919, or ask a Proper Hotels representative, and provide any information you would like the human reviewer to consider. The appeal process will be easy to use and will allow you to provide information in support of your appeal.

• Subject to our obligations under state law to verify the identity of individuals making certain requests, please note that it will be the extremely rare case where a consumer’s request will be denied. If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request. In some instances, this will require us to provide links to your state’s Attorney General’s Office or other similar state consumer protection agencies or departments in order to further appeal our decision. Those links can be found:

• New Jersey
 https://www.njconsumeraffairs.gov/Pages/Consumer-Complaints.aspx

• Oregon
https://justice.oregon.gov/consumercomplaints/

You or your agent may exercise your data privacy rights here: Emailing [email protected].

14. EUROPEAN ECONOMIC AREA (EEA) RESIDENTS AND UNITED KINGDOM (UK), and Similar APPLICABLE JURISDICTIONS

Data Controller

The data controller for the information you provide or that is collected by Proper Hospitality or its affiliates is:

Proper Hospitality
225 Arizona Avenue, Suite 350
Santa Monica, CA 90401
Attn: Legal Department

833-613-1919
[email protected]

Legal Basis for Processing Personal Information

By using this Website and Digital Properties and voluntarily providing us with your personal information you are consenting to the processing your personal. Our processing requirements are also based on contractual obligations and responsibilities related to the performance of agreements related to the service you purchase from us. Finally, we have regulatory and rules-based compliance obligations that require us to use your personal data during your engagements with us.

Data Localizations and Consent to Transfer

This Website and Digital Properties are hosted and operated in the United States. However, we and our service providers may store information about users and other individuals in the United States, or we may transfer it to, and store it within, other countries.

United States may not have data privacy laws that are deemed to afford an equal level of protection for your personal information as those laws legislated at the direction of the European Union or similar geopolitical, national, or regional legislative bodies. However, please be assured that we will continue to adhere to the principles stated in this Privacy Policy and will make reasonable efforts to comply with applicable international, national, regional, territorial, and provincial laws in connection with any information collected through the Website and Digital Properties.

If you are located in the European Economic Area or the United Kingdom, we will send you marketing emails or marketing text messages only where permitted by applicable law. This may include where you have given consent, or, where legally available, where we obtained your contact details directly from you in connection with a reservation or inquiry for our services, gave you a clear opportunity to opt out when we collected your details, and market only our own similar products or services. You may withdraw consent or opt out of marketing at any time.

For those users located EEA or UK, we advise you that your information may at times be accessible by individuals who are located worldwide, including in countries that the European Commission or other geopolitical regions have not deemed to provide the same level of data protection as in your country, province, territory, or geopolitical region. By providing us with your personal information, you are consenting to our use of it in accordance with this Privacy Policy, including the transfer of your information across international boundaries to jurisdictions anywhere in the world as permitted by local law.

Data Privacy Rights Statement

If you reside in U.K. the European Economic Area (EEA) you may have the following additional rights under the GDPR as applicable:

• The right to access (i.e., the right to be provided with a copy of your personal information);
• The right to rectification (i.e., the right to require us to correct any mistakes in your personal information);
• The right to be forgotten (i.e., the right to require us to delete your personal information – in certain situations);
• The right to restriction of processing (i.e., the right to require us to restrict processing of your personal information – in certain circumstances, e.g., if you contest the accuracy of the data);
• The right to data portability (i.e., the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations);
• The right to object (e.g., the right to object to your personal information being used for direct marketing, and in certain other situations, to object to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests);
• The right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent – without affecting the lawfulness of processing based on consent before its withdrawal);
• The right to information regarding consent (i.e., to obtain information about the possibility or providing or denying your consent and the consequences of such consent or denial of consent); and
• The right not to be subject to automated individual decision-making (i.e., the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you).
You or your agent may exercise your data privacy rights here: Emailing [email protected] or Completing a Data Access Request form found here.
We will not discriminate against you if you choose to exercise any of these rights. You can exercise your rights under the U.K. GDPR or GDPR by contacting us as follows:

Email: [email protected] (please use “GDPR” or “U.K. GDPR” in the subject line as applicable)

Proper Hospitality
225 Arizona Avenue, Suite 350
Santa Monica, CA 90401
Attn: Legal Department

833-613-1919
[email protected]

The U.K. GDPR and GDPR also gives individuals the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

15. CHANGES TO THIS POLICY

We may update this policy from time to time. We will always post the then-current version of this policy on our Websites, and will indicate at the top of the policy the date on which the latest version took effect. Please review this policy from time to time to stay updated on our privacy practices.

16. CONTACT

If you have any questions, comments and complaints about our data practices can be sent to our data protection office by sending an email to [email protected] or writing us at:

Proper Hospitality
225 Arizona Avenue, Suite 350
Santa Monica, CA 90401
Attn: Legal Department

833-613-1919
[email protected]