EFFECTIVE DATE MARCH 1, 2018
THIRD PARTY WEBSITES AND SERVICES
The HotelierCo website contains links to other websites, provides or facilitates services through Application Programming Interfaces (APIs) from third party websites and service providers, and provides other links and services not maintained by HotelierCo. The companies or entities providing these links, APIs and services are collectively referred to herein as “Third Party Service Providers” herein. In addition, other websites and services may also reference or link to the HotelierCo website. We encourage you to be aware when you enter or leave our website, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.
COLLECTION OF INFORMATION
HotelierCo and Third Party Service Providers collect non-personally identifiable information from you regarding your usage of our website (‘Non-Personally Identifiable Information’). Non-Personally Identifiable Information may include, without limitation, website pages viewed, articles, presentation and videos viewed, time spent using certain features of the website, demographic data such as server locations, cookies existing on your computer, search criteria used and results, date, time, connection speed, and other information which does not specifically identify you. We collect this information using various technologies, including, but not limited to, cookies and server logs. “Cookies” are pieces of information that may be placed on your computer by a website for the purpose of facilitating and enhancing your communication and interaction with that website. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.
HotelierCo and Third Party Service Providers also may collect information from you when you sign up for an account, make an investment, verify your identity or accredited investor status, provide payment instructions or send us an email or other communication through the HotelierCo website which may enable us to identify you personally, such as your email address, name, phone number, birthday, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, information from your transactions with us, such as your account balance and account usage, information obtained from others, such as the Internal Revenue Service and credit reporting agencies, physical address such as home or business address, or internet protocol (“IP”) address, which may also be contained on server logs, or other information you provide or upload to the website such as photographs, answers to questionnaires or surveys, or responses filled in on blank forms made available on the site (‘Personally Identifiable Information’ and collectively with the Non-Personally Identifiable Information, the ‘Data’). HotelierCo and Third Party Service Providers may also collect and store information, which could include Non-Personally Identifiable Information or Personally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.
HotelierCo and Third Party Service Providers use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the HotelierCo website. Google Analytics collects information including, but not limited to, the time of each of your visits to the HotelierCo website, whether you have visited the HotelierCo website before, what site referred you to the HotelierCo l website, and what pages you viewed on the HotelierCo website.
HotelierCo and Third Party Service Providers may also have access to your Personally Identifiable Information when you log into our website through certain third party social networking services, including Facebook, LinkedIn, Twitter and Internet Chat (“Third Party Services”). We encourage you to carefully review the privacy policies of any Third Party Services from which you access our website.
USE OF INFORMATION
HotelierCo will use information you provide consistent with this Notice. HotelierCo will use information you provide to us, including Non-Personally Identifiable Information or Personally Identifiable Information, to better serve you and enhance your experience with the HotelierCo website, among other things. This may include having to modify or copy such information, such as images or textual or narrative content you provide, in order to provide you with a seamless and enjoyable experience.
You consent to our use and disclosure of any information submitted to us via the HotelierCo website, or information collected when you access the HotelierCo website in any manner, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information.
HotelierCo will use Non-Personally Identifiable Information and Personally Identifiable Information (1) to market our products and services to you, (2) to provide services and products requested by you, (3) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our website and other services, (4) to meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members, (5) to engage in any other lawful activities we believe are consistent with the foregoing, and (6) to protect against legal liability. We may provide any of these services through third parties, which may necessitate sharing Personally Identifiable Information and Non-Personally Identifiable Information with them. HotelierCo will use Non-Personally Identifiable Information and Personally Identifiable Information as stated above whether you registered and created an account with the Site, whether HotelierCo registered you and created an account with the Site for you, or in any other circumstances where such Non-Personally Identifiable Information and Personally Identifiable Information came into HotelierCo’s possession through your use of the Site in any fashion.
If you provide Data for a certain reason, we may use the Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Data you provide to answer your question or resolve your problem. HotelierCo may also use your Data and other personally non-identifiable information collected through our website to help us improve the content and functionality of our website, to better understand our users and to improve our services, and to market our services, offering on the Site, and for other marketing purposes. HotelierCo may use this information to communicate with you regarding our services or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that as user of our services we will send you administrative communications that are reasonably necessary to our services, such as billing or service notifications.
HotelierCo may make your information, including Non-Personally Identifiable Information or Personally Identifiable Information, available on its website and visible to other users of or visitors to the HotelierCo website. For instance, information you provide about yourself in response to questionnaires on our site may be made available to others such as information concerning your status as an accredited investor. As such, other users of our website may be able to personally identify you based on your information made available on our site. As a further example, if you utilize Third Party Services to log into our website, other users to whom you may be connected to through such Third Party Service may be able to view or follow information about you on our website, including Non-Personally Identifiable Information or Personally Identifiable Information.
HotelierCo employs or contracts with other third parties, companies, or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification, accreditation/financial/credit verification, electronic document signing, payment storing and processing, broker dealer services, sending postal mail and e-mail, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to your information, including Non-Personally Identifiable Information or Personally Identifiable Information, as needed to perform their functions or services, and may not use it for other purposes. Issuers using HotelierCo to assist in raising capital for their companies will also have access to your Non-Personally Identifiable Information or Personally Identifiable Information provided through forms you fill out on the Site, and may use it to contact you about their company, for marketing purposes, and for any purpose they see fit.
HotelierCo may also use and disclose Personally Identifiable Information and Non-Personally Identifiable Information: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our website or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of HotelierCo’s business or assets. Any successor in interest to our business would acquire the information we maintain, including Personally Identifiable Information, and may alter the terms of this Privacy Notice.
HotelierCo may disclose your Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of HotelierCo, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public against fraud or other harm, or (iv) protect against legal liability.
HotelierCo does not and will not sell any of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to any third party for purposes of advertising, soliciting, or telemarketing.
North Capital Private Securities Corp.("North Capital" or “NCPS”), a Delaware corporation, is a securities broker-dealer registered with the U.S. Securities and Exchange Commission and a member of FINRA and SIPC. North Capital is a provider of execution and other brokerage services related to our equity securities transactions, and certain individual personnel of HotelierCo are registered representatives of North Capital. North Capital is headquartered at 623 E Fort Union Boulevard, Suite 101, Salt Lake City, UT 84047. Tel: (415) 315-9916 (https://www.northcapital.com/).
We may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name and other information. If you wish to update or delete your testimonial, please contact us at email@example.com.
SOCIAL MEDIA FEATURES
We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, you may unsubscribe completely by emailing us at: firstname.lastname@example.org. Please note that opt-out requests may take up to one (1) week to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.
You will be able to modify the information concerning your account by visiting your profile page and editing any information you wish to change. You will be able to change your e-mail address, password, contact information, or other log in information by visiting your account’s settings page subject to site policy. If you wish to delete your account or need help modifying account information, please contact us at email@example.com.
Through your account settings you will be able to set certain preferences and permissions regarding the visibility of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to others. You may stop or restrict the placement of HotelierCo’s cookies, Google’s cookies and third party cookies on your computer by adjusting your web browser preferences or a ‘Do Not Track’ setting in your web browser. If you do so, you may still use our website, but this may interfere with some of its functionality.
You may also clear cookies from your computer via your web browser settings. You may also wish to use a Google Analytics opt-out web browser add-on. Information on this option is available from Google. If you would like us to remove your Personally Identifiable Information from our database, please send a request to: firstname.lastname@example.org.
We are not responsible for removing your Personally Identifiable Information from the lists of any third party who has previously been provided your information in accordance with this notice.
We use reasonable efforts to secure access to Personally Identifiable Information in our possession, including bank-level encryption, support instant identification and account verifications, and may partner with third party providers that provide monitoring to ensure that you have a safe experience on HotelierCo, but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Personally Identifiable Information is also stored with third parties who have informed us that they also use reasonable efforts to secure access to Personally Identifiable Information, but we will not be liable for the failure of any third party to safeguard Personally Identifiable Information, whether inadvertent or otherwise.
We protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input. Wherever appropriate, we obfuscate and/or encrypt information in our systems and/or during information transfer. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
We utilize third party service providers who may store on their servers social security numbers, addresses, financial information, electronic signatures, and payment information. For your security, we only display the last four digits of your bank account information when confirming an investment.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to log off when finished using a shared computer.
The HotelierCo website is not intended for use by children, especially those under age thirteen (13) years of age. No one under age thirteen (13) years of age is allowed to use the site, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children or teenagers under the age of thirteen (13). If you believe that a minor has disclosed Personally Identifiable Information to HotelierCo, please report this to us immediately by emailing us at email@example.com.
CHANGES TO THIS PRIVACY NOTICE
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this notice at any time. Any changes or updates will be effective immediately upon posting to the web site and sending a notification to all registered users via email regarding such update. You should review this notice regularly for changes, and can determine if changes have been made by checking the Effective Date above. Your continued use of our website following the posting of any changes to this notice means you accept such changes.
APPLICABLE LAW AND JURISDICTION
The HotelierCo website is maintained in the United States of America. By accessing the HotelierCo website, you consent to and authorize the export of Personally Identifiable Information to the United States of America and its storage and use as specified in this Privacy Notice.
This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of Georgia applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard either in the Georgia state, or the federal district court for the Middle District of Georgia. You consent to the in personam jurisdiction and venue of such courts.
YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.