Glarros Hotels values you as our guest and recognizes that privacy is important to you. We want you to be familiar with how we collect, use, and disclose your Personal and Other Data (collectively, “Data”).

DATA COVERED BY THIS PRIVACY STATEMENT

This Privacy Statement describes the privacy practices of the Glarros OldTown for data that we collect:

• through websites operated by us from which you are accessing this Privacy Statement, including glarros.com and other websites owned or controlled by the Glarros OldTown (collectively, the Websites);
• through the software applications made available by us for use on or through computers and mobile devices (the Apps);
• through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our Social Media Pages);
• through email messages that we send you that link to this Privacy Statement and through your communications with us online or in person;
• from third parties such as Authorized Licensees, Owners and Franchisees , and Other Sources, such as public databases, marketing partners, and other third parties; and
• when you visit or stay as a guest at one of our properties, or at homes and villas offered on the Homes and Villas by Glarros OldTown platform (Homes and Villas), or through other offline interactions (collectively,Property Visits and Offline Interactions).

Collectively, we refer to the Websites, the Apps, and our Social Media Pages, as the “Online Services” and, together with the Property Visits and Offline Interactions, the “Services.

THE DATA WE COLLECT

At touchpoints throughout your guest journey, we collect Personal Data in accordance with the law, and to provide you with exemplary services. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:

• Name
• Gender
• Postal address
• Telephone number
• Email address
• Financial information (such as credit and debit card number or other payment data)
• Language preference
• Date and place of birth
• Nationality, passport, visa, or other government-issued identification data
• Important dates: birthdays, anniversaries, and special occasions
• Membership or loyalty program data (including co-branded payment cards, travel partner program affiliations)
• Employer details (for business-related bookings)
• Travel itinerary, tour group, or activity data
• Prior guest stays or interactions, goods and services purchased, special service and amenity requests
• Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts

In more limited circumstances, we may also collect:

• Data about family members and companions, names, and ages of children
• Biometric data
• Images, video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel

We may also collect information about your "Stay Preferences" that we use to make your current and future stays and experience with us more enjoyable, including information about your interests and other relevant information that we learn about you during your stay. This may also include any likes and dislikes about our services that you tell us about so that we can improve our services, and specific dietary, health restrictions or personal needs to ensure your wellbeing. We may also collect your “Personal Preferences,” that may include details of your special anniversaries (such as your birthday or wedding anniversary), what type of activities you prefer to take part in when staying with us, and your hobbies. Personal Preferences may also include details about who you usually travel with, their relationship to you, and your marital status.

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

THE ONLINE AND MOBILE DATA WE COLLECT

Typically, we do not collect Personal Data through your use of the Online Services. However, we may collect “Other Data” that does not directly identify you. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data.

Meeting rooms

There is no charge for cancellation or changes made to the booking up to seven days before your booking. In the event of a cancellation or no-show within seven days of your booking, the full value of the booking including VAT will be charged to your credit card on file as a cancellation fee.

“Other Data” includes:

System Data: When you use both desktop and mobile devices to access the Online Services, we collect certain data through your browser or automatically through your device, such as your computer type, screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services you are using.

IP Address: We also collect your IP address, a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.

Precise Location-Based Services: With your consent, we may collect the precise physical location of your device by using satellite, cell phone tower, Wi-Fi signals, or other technologies. We will collect this data if you opt-in through the App or other program (either during your initial login or later) to improve special offers and to enable location-driven capabilities on your device. If you have opted-in to share your location, the App or other program will continue to collect location data based on how you chose to share the data.

• Precise Location Opt-Out: You can specify via your device’s operating system (such as through the “Settings” icon) to always share location data, only when the App is in use, or never. If you choose only when the App is in use, we will have access to the data until you log off or close the application or until you use your phone’s or other device’s settings to disable location capabilities for the Bonvoy™ App or other program.

Cookies and Similar Technologies on our Websites:

When you visit our Websites from either a desktop or mobile device, we may collect and use cookies or other identifiers to serve you with personal advertisements for Glarros OldTown and third party products, either via email, on our website, or on other websites on the Internet; to measure how you interact with our Websites; and to maintain your preferences. We do this primarily through cookies, which are pieces of data stored directly on the computer or mobile device that you are using.

You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html.

In general, we use four different types of cookies:

• Strictly Necessary Cookies: These cookies are necessary to enable the basic features of the website or app, such as providing a secure log-in.
• Functional Cookies: These cookies allow our websites to remember your site preferences and choices you make on the site. We also use functional cookies to facilitate navigation, to display content more effectively, and or to personalize your experience.
• Advertising Cookies: Advertising cookies allow us to select which advertisements or offers are most likely to appeal to you. We also use them to track responses to online advertisements and marketing, and we may use it to better understand your interests so we may can present you with relevant messages and offers. These cookies may also allow you to share certain pages with social networks.
• Analytics Cookies: Analytics cookies help us improve our website by collecting and reporting information on how you use it.

Opting Out of Cookies

There are several ways to opt-out of cookies. If, however, you do not accept any cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You also will not receive advertising or other offers from us that are relevant to your interests.

Glarros OldTown recognizes the Global Privacy Control.

1. Browser settings: You can opt out of cookies on your browser. Every browser is different so please check the instructions provided by your browser.
2. Through our “Tracking Preferences ” site.
3. Google Analytics: We collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about use of the Online Services. These services also collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt out by visiting http://www.adobe.com/privacy/opt-out.html.

Advertising Choices

We may use third-party advertising companies to serve advertisements on our Websites, Apps, and other websites regarding both Glarros OldTown and third-party goods and services that may interest you when you access and use the Online Services or other websites or online services.

Apps and Mobile Devices

We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers, and what data and files have been downloaded to the App based on your device id. We use this data to ensure that the Online Services function properly.

Our Apps may also contain software development kits (SDKs) from third parties which may collect and transmit data to enable various features in the App.

With your consent if required by the operating system, we may also collect mobile device advertising identifiers to enhance and personalize your experience and deliver relevant products, content, or ads to show you on our Websites, Apps, or external advertising.

• Optional App Features. Our Apps may contain optional features made available to developers by the device’s operating system. To improve your experience, we may require your permission for the use of your device’s location, camera, or other functions (e.g., using your device’s camera to capture your credit card information). You may choose not to allow the use of such functions, in which case the App features relying on such functions may not be available to you. Go to your device’s settings to manage these permissions.

Aggregated and Segmented Data.

We may aggregate data that we collect, and this aggregated data will not personally identify you or any other user. We may also use both Personal Data and Other Data to divide customers into segments, or groups, in order to provide more relevant advertising, including third party advertising.

HOW AND WHERE WE COLLECT YOUR DATA

This Privacy Statement describes the privacy practices of the Glarros OldTown for Personal and Other Data that we collect through the following:

• Glarros OldTown. We collect Personal Data and Other Data from other companies within the Glarros OldTown for the purposes described in this Privacy Statement, such as providing and personalizing the Services, communicating with you, facilitating the loyalty programs and to accomplish our business purposes.
• Owners, Franchisees & Joint Ventures. We collect Personal Data and Other Data from Owners of Glarros OldTown branded properties that we manage, from Franchisees of Glarros OldTown branded properties that are independently owned and operated under a franchise agreement with us, and from Joint Venture Partners. Owners and Franchisees are independent from the Glarros OldTown. Franchisees include their third- party operators and management companies.
• Authorized Licensees. We collect Personal Data and Other Data from companies when we enter into a license or similar agreement to sell goods and services under a Glarros OldTown brand (“Authorized Licensees”). On-Property and/or Travel Providers. We may collect your Personal Data and Other Data from spa, restaurant, health club, concierge, and other outlets at our properties.
• Linked Accounts. We collect Personal Data and Other Data when you use your loyalty program number or Online Services login to receive or register for certain third- party services. These companies include businesses such as airlines and rental car providers, and restaurant reservation and car services partners. Additionally, your social media account provider allows you to connect your social media account to your Online Services account or log into your Online Services account from your social media account. When you enroll in those services, we disclose your Personal Data and Other Data to those third parties. If you do not want us to collect your Personal Data or Other Data in this way, do not provide your loyalty program number to third parties, do not use your Online Services login to register for third-party promotions and do not connect your Online Services account with accounts on third-party services.
• Promotional Activity. We collect Personal Data and Other Data from with third parties who may provide promotions to you, such as sweepstakes, contests, or other offers.
• eFolio Program. If you are an employee of a company that participates in the Glarros OldTown eFolio Program and book your room using a company corporate code or pay for your expenses using a corporate credit card, we may collect Personal Data and Other Data related to your stay or employment. This Privacy Statement does not apply to the handling of your Personal Data by your employer, credit card company or bank, and we are not responsible for their practices.
• Other Sources & Service Providers. We collect Personal Data and Other Data from various third parties, such as public databases, joint marketing partners, and online travel agencies (OTAs).
• Online Services. We collect Personal or Other Data when you interact with our Online Services, by performing such actions as, but not limited to, browsing, making a reservation, purchasing goods and services from our Websites or Apps, communicating with us or otherwise connecting with us or posting to social media pages, or signing up for a newsletter or participating in a survey, contest or promotional offer.
• Customer Care Centers. We collect Personal Data when you make a reservation over the phone, communicate with us by email, fax, or via online chat services or contact customer service. These communications may be recorded for purposes of quality assurance and training.
• Internet-Connected Devices. We collect Personal and Other Data from internet-connected devices available in our properties. For example, when you connect a device to the hotel’s internet, or when a smart home assistant may be available for your use to tailor your accommodations and experience.