Claris Hotel & Spa 5*GL, a Small Luxury Hotels of the World

Vacancy Rewards LLC, (“we”, “us”, or “Vacancy Rewards”) values you as our customer and recognizes that privacy is important to you. This Privacy Statement explains how we collect, use, and disclose data when you use our platform and associated services, and tells you how to contact us.

Privacy Statement Summary

This is a summary of our Privacy Statement. To review our Privacy Statement in full, please scroll down.

What does this Privacy Statement cover?

This Privacy Statement is designed to describe:

-How and what type of personal information we collect and use

-When and with whom we share your personal information

-What choices you can make about how we collect, use, and share your personal

information What personal information do we collect and use, and how do we collect it?

We collect personal information when:

-You give us the information

-We collect it automatically

-We receive it from others

When you create an account on one of our sites, sign up to receive offers or information, or make a booking using our platform, you give us your personal information. We also collect such information through automated technology such as cookies placed on your browser, with your consent where applicable, when you visit our sites or download and use our Apps. We also receive information from business partners and other third parties, which help us improve our platform and associated tools and services, update and maintain accurate records, potentially detect and investigate fraud, and more effectively market our services.

How is your personal information shared?

Your personal information may be shared to help you book your travel and/or vacation, assist with your travel and/or vacation stay, communicate with you (including when we send information on products and services or enable you to communicate with travel

providers and/or property owners), and comply with the law. The full Privacy Statement details how personal information is shared.

What are your rights and choices?

You can exercise your data protection rights in various ways. For example, you can opt-out of marketing by clicking the “unsubscribe” link in the emails, in your account as applicable, or contacting our customer service. Our Privacy Statement has more information about the options and data protection rights available to you.

How to contact us

More information about our privacy practices is in our full Privacy Statement. You can also contact us as described below in the “Contact Us” section to ask questions about how we handle your personal information or make requests about your personal information.

Privacy Statement

Categories of Personal Information We Collect When you use our platform, Apps, or associated tools or services, we may collect the following kinds of personal information from you as needed:

-Name, email address, telephone number, and home, business, and billing addressees.

-Government-issued Identification required for booking or identity verification, such as passport, driver’s license, and government redress numbers, and vacation property owners, tax identification number

-Payment information such as payment card number, expiration date, and billing address

-Travel-related preferences and requests such as favorite destination accommodation types, and special dietary and accessibility needs, as available and

-Loyalty program and membership information

-Birth date and gender

-Geolocation

-Images, videos, and other recordings

-Social media account ID and other publicly available information

-Communications with us (such as recordings of calls with customer service

representatives for quality assurance and training purposes) -Searches you conduct, transactions, and other interactions with you on our online

services and Apps

-Other communications that occur through the platform among partners and travelers, and in-group chat and traveler-collaboration tools

-The searches and transactions conducted through the platform

-Data you give us about other people, such as your travel companions or others for whom you are making a booking

-Information we receive about you from third parties such as our business and affiliate partners and authorized service providers which may include updated contact information, demographic information, interests, and purchase history, which we may add to your account or profile and use for market research and analysis

When you install any of our apps or use our platform, we automatically collect the following types of information from your device:

-IP address

-Device type

-Unique device identification numbers

-Internet browser-type (such as Firefox, Safari, Chrome, and Internet Explorer)

-Internet Service Provider

-Operating System

-Mobile carrier

-How your device has interacted with our online services, including the pages accessed, links clicked, trips viewed, and features used, along with associated dates and times

-Details of any referring website or exit pages, as well as general geographic location (such as at the country or city-level)

Our Cookie Statement further explains how we use cookies and similar tracking technology.

Mobile Applications

When you download and use any of our mobile apps, we collect certain technical information from your device to enable the app to work properly and as otherwise described in this Privacy Statement. That technical information includes:

-Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module (“SIM”) operator, and SIM country

-Operating system and version

-Device model

-Performance and data usage

-Usage data, such as dates and times the app accesses our servers, the features and links clicked in the app, searches, transactions, and the data and files downloaded to the app

-Device settings selected or enabled, such as Wi-Fi, Global Positioning System (“GPS”), and Bluetooth (which may be used for location services, subject to your permission as explained below)

-Mobile device

-Other technical information such as app name, type, and version as needed to provide you with services

Permissions for Location-Based Services:

Depending on your device’s settings and permissions and your choice to participate in certain programs, we may collect the location of your device by using GPS signals, cell phone towers, Wi-Fi signals, Bluetooth, or other technologies. We will collect this information, if you opt-in through the app or other program (either during your initial login or later) to enable certain location-based services available within the app (for example, locating available lodging closest to you). To disable the location capabilities of the app, you can log off or change your mobile device’s settings.

Use of Personal Information

We use your personal information for various purposes described below, which depend on the site you visit or the app you use.

Your Use of Online Sites, Apps, and Services:

-Book the requested travel or enable vacation property booking

-Provide services related to the booking and/or account

-Create, maintain, and update user accounts on our platform and authenticate you as a user

-Maintain your search and travel history, accommodation and travel preferences, and similar information about your use of Vacancy Rewards’s platform and services, as otherwise described in this Privacy Statement

-Enable and facilitate acceptance and processing of payments, coupons, and other

transactions

-Administer loyalty and rewards programs

-Collect and enable booking-related reviews

-Help you to use our services faster and easier through features like the ability to sign in using your account within the online services and sites of some of the Vacancy

Rewards companies

Communications and Marketing:

-Respond to your questions, requests for information, and process information choices

-Enable communication between you and the travel supplier like hotels and vacation

property owners

-Contact you (such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms) to provide information like travel booking confirmations and updates, for marketing purposes, or other purposes as described in this Privacy Statement

-Market our products and services, optimize such marketing to be more relevant to you and measure and analyze the effectiveness of our marketing and promotions

-Administer promotions like contests, sweepstakes, and similar giveaways

Other Business Purposes and Compliance

-Conduct surveys, market research, and data analytics

-Maintain, improve, research, and measure the effectiveness of our sites and apps, activities, tools, and services

-Monitor or record calls, chats, and other communications with our customer service team and other representatives, as well as platform communications between or among partners and travelers for quality control, training, dispute resolution, and as described in this Privacy Statement

-Create aggregated or otherwise anonymized or de-identified data, which we may use and disclose without restriction where permissible

-Promote security, verify the identity of our customers, prevent and investigate fraud and unauthorized activities, defend against claims and other liabilities, and manage other risks

-Comply with applicable laws, protect our and our users’ rights and interest, defend ourselves, and respond to law enforcement, other legal authorities, and requests that are part of a legal process

-Comply with applicable security and anti-terrorism, anti-bribery, customs and

immigration, and other such due diligence laws and requirements -Operate our business using lawful business purposes and as permitted by law Sharing of Personal Information

We share your personal information as described below and in this Privacy Statement, and as permitted by applicable law.

-Third-party service providers. We share personal information with third parties in connection with the delivery of services to you and the operation of our business (for example, to provide credit card processing, customer service, business analytics, and fraud prevention and compliance services, and to serve you with advertising tailored to your interests). These third-party service providers are required to protect the personal information we share with them and may not use any directly identifying personal information other than to provide services we contracted them for. They are not allowed to use the personal information we share for purposes of their direct marketing (unless you have separately consented with the third party under the terms provided by the third party).

-Travel suppliers. We share personal information with travel-related suppliers such as hotels, insurance, vacation rental property owners, and managers. Please note that travel suppliers may contact you to obtain additional information if and as required to facilitate your booking or to otherwise provide the travel or associated services.

-Business partners and offers. If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your information with that partner to assist in marketing or to provide the associated product or service. In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice. An example of such a business-partner relationship would be a third-party loyalty program for which you could earn points by completing a booking on our platform.

-Other Third-Parties. When you access certain features like Facebook’s “Like” button or a single sign-on that allows you to login with your social media credentials to our online services, you will share information with the third-party, like a social media company, such as the fact that you have visited or interacted with us.

-Legal rights and obligations. We may disclose your personal information to enforce our policies, or where we are permitted (or believe in good faith that we are required) to do so by applicable law, such as in response to a request by law enforcement or governmental authority, in connection with actual or proposed litigation, or to protect and defend our property, people and other rights or interests. We may also share your personal information under a subpoena or other legal request, or as necessary to remit certain taxes in the course of processing payments as required by law or legal process. -Corporate We may share your personal information in connection with a corporate transaction, such as a divestiture, merger, consolidation, assignments, or asset sale, or the unlikely event of bankruptcy. In the case of any acquisition, we will inform the

buyer it must use your personal information only for the purposes disclosed in this Privacy Statement.

Your Rights and Choices

You have certain rights and choices concerning your personal information, as described below:

-You can control our use of certain cookies by following the guidance in our Cookie Statement

-You can update the accuracy of your information at any time by either logging into your account or contacting us

-If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email.

-For our mobile apps, you can view and manage notifications and preferences in the settings menus of the app and your operating system

-If we are processing your personal information based on consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent

For questions about privacy and your rights and choices, please contact us here. For California residents:

California residents may exercise the following rights: -To request a copy of your personal information

-To request disclosure of personal information sold or disclosed for a business purpose

-To request the deletion of personal information

-To opt-out of the sale of personal informationvn

International Data Transfer

The personal information we process may be transmitted or transferred to countries other than the country in which you reside. Those countries may have data protection laws that are different from the laws of your country. The servers for our platform are located in the United States, and third-party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of those countries.

We have taken appropriate steps and put safeguards in place to help ensure that your personal information remains protected by this Privacy Statement. We also require that third-party service providers to whom a data transfer is made have appropriate safeguards in place to protect your personal information, in compliance with applicable data protection law. The particular measures used will depend on the service provider, and our agreements with them may include European Commission- approved Standard Contractual Clauses, the service provider’s certification under the EU-U.S. and/or Swiss-U.S. Privacy Shield certification, or reliance on the service provider’s Binding Corporate Rules, as defined by the European Commission.

Security

We want you to feel confident about using our platform and all associated tools and services, and we are committed to taking appropriate steps to protect the information we collect. While no company can guarantee absolute security, we do take reasonable steps to implement appropriate physical, technical, and organizational measures to protect the personal information that we collect and process.

Record Retention

We will retain your personal information by all applicable laws, for as long as it may be relevant to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. We will deidentify, aggregate, or otherwise anonymize your personal information if we intend to use it for analytical purposes or trend analysis over longer periods.

The criteria we use to determine our retention periods include:

-The duration of our relationship with you, including any open accounts you may have with Vacancy Rewards, recent bookings, or other transactions you have made on our platform

-Whether we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us

-Whether there are any current and relevant legal obligations affecting how long we will keep your personal information, including contractual obligations, litigation holds, statutes of limitations, and regulatory investigations

Contact Us

If you have any questions or concerns about our use of your personal information, please contact us. We may update this Privacy Statement in response to changing laws or technical or business developments. You can see when this Privacy Statement was last updated by checking the “last updated” date displayed at the top of this Statement.