CHI Hospitality ONLINE PRIVACY POLICY
Our Privacy Policy has been updated and has an Effective Date of 24 September, 2020.

Thank you for visiting the Online Privacy Policy (“Policy”) of CHI Hospitality (hereinafter referred to as either “CHI Hospitality”, “we”, “our”, or “us”). CHI Hospitality holds customer privacy in the highest regard, and we are committed to protecting your privacy. This Policy applies to the websites, mobile applications and other interactive features and online services, owned or operated by CHI Hospitality that post a link to this Policy (collectively, the “Sites”).

Please take a moment to review this Policy. It provides you with information about the types of data that we collect on the Sites, how to set your privacy preferences, and your rights under this Policy concerning your personally identifiable information. This Policy does not apply to our data collection activities offline or otherwise outside of the Sites (unless otherwise stated below in accordance with specific state laws or foreign jurisdictions), and does not govern the data practices of third parties that may interact with our Sites.

We also encourage you to review CHI Hospitality’s Terms of Use for other information concerning use of the Sites. By using the Sites, creating a membership account, or contacting CHI Hospitality customer service, you agree to this Policy and Terms of Use, and consent to the collection and use of your personal information as described in this Policy. In addition, please note that this Policy applies to UAE individuals who use our products or services and/or visit our Sites, unless specific state laws or foreign jurisdictions are noted.

This Policy addresses the following topics:

Collection of Information

Cookies and Other Tracking Technologies

Use of Information

Sharing of Information

Third-Party Content

Tracking and Communications Options

Data Security

Questions and Updates to the Policy

COLLECTION OF INFORMATION

INFORMATION THAT YOU PROVIDE TO US

CHI Hospitality may collect information that you provide directly to CHI Hospitality through the Sites. For example, we collect information when you set up an account, submit an order, participate in promotional activities, or communicate with CHI Hospitality through the Sites. This information may include:

(1) personally-identifiable information, which is information that identifies you personally, such as your first and last name, email address, phone number, mailing address, financial account information, social media account handles, and/or professional information (“Personal Information”); and

(2) demographic information, such as age, gender, and recent and upcoming purchases (“Demographic Information”). The information we collect may also include information that you submit about others, including the name, e-mail address, or physical address of a gift recipient. This information will be treated as Personal Information under the Policy.

Except to the extent required by law, Demographic Information is not treated as Personal Information under this Policy. Also, in certain instances, CHI Hospitality may modify or extract personally-identifiable elements from Personal Information through anonymization, pseudonymization, or hashing. Such information is considered to be non-Personal Information and may be shared without obligation to you, except as prohibited by applicable law. However, to the extent that any non-Personal Information is combined by or on behalf of CHI Hospitality with Personal Information, we will treat the resulting data as Personal Information under this Policy.

INFORMATION COLLECTED AUTOMATICALLY

CHI Hospitality may also automatically collect and log certain information about you when you access or use the Sites (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, approximate geographic area or location positioning information, information about your use of the Sites, and data regarding network connected hardware (e.g., computer or mobile device). Usage Information may also include your mobile device such as the type and model, operating system (e.g. iOS or Android), carrier name, mobile browser (e.g. Chrome, Safari), applications using our Website, and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID (AAID), or unique device identifier. Except to the extent required by applicable law, or to the extent that Usage Information is combined with other forms of personal information, CHI Hospitality does not consider Usage Information to be Personal Information.

INFORMATION THAT WE COLLECT FROM OTHER SOURCES

CHI Hospitality may obtain information about you from other sources, including its affiliates, vendors, or third-party service providers, and combine it with your Personal Information. Notwithstanding anything to the contrary, this Policy is not intended to limit CHI Hospitality’s activities regarding such third-party-source information and, to the extent permitted by applicable law, will treat such data as Personal Information under this Policy if, and to the extent that, it is combined with other sources of information that were independently collected by CHI Hospitality.

Please note that we and/or third parties may collect personal information about your online activities over time and across different devices and online properties when you use the Sites.

USE OF INFORMATION

CHI Hospitality may use information about you for any purpose that is not inconsistent with this Policy or a statement made by CHI Hospitality at the point of collection, including, without limitation, the following:

Allow you to participate in the services offered on the Sites;
Facilitate, manage, personalize, and improve your online experience;
Process your registration or manage your membership account;
Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices or other relevant communications;
Provide you with promotional materials related to CHI Hospitality products and/or services, and the products and/or services of our partners and partnerships;
Enable you to participate in a variety of the Sites features, including online entry sweepstakes, contests, or other promotions;
Improve the Sites and for any other internal business purposes;
Tailor our content, advertisements, and offers; and
Prevent and address fraud, breach of policies or terms, and threats or harm.
We may also use your Personal Information, Demographic Information, or Usage Information to provide you with additional services and offerings that require CHI Hospitality to understand your geographic location.

If you provided CHI Hospitality with Personal and/or Demographic Information as part of an online application for employment or internship, we may use that information to make an informed decision about whether to proceed with your application. We may, as part of the recruitment process, collect information about your education, employment history, and similar matters. Where this Personal and/or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes.

SHARING OF INFORMATION
CHI Hospitality may share your Personal Information, Demographic Information, and/or Usage Information with our affiliates, business partners, and vendors that provide services on our behalf. These parties are not meant to use Personal Information except in connection with its provision of products and services. Absent your consent, CHI Hospitality does not authorize these third-parties to use Personal Information provided by CHI Hospitality to send you direct marketing messages other than communications related to our services and products.

Our sharing of Personal Information is, however, subject to the following:

Marketing. Subject to your communications choices explained below, we may use your Personal Information to send you marketing communications. However, CHI Hospitality will never provide our promotional affiliates with Personal Information unless you “opt-in” (and do not “opt-out”), in accordance with our opt-out procedure, to receiving communications.
Your Disclosure or Consent. Your activities on the Sites may, by their nature, result in the sharing of your Personal Information with third parties. By engaging in these activities, you consent to that and further sharing of your Personal Information with third parties. Such third-party data collection is subject to the privacy and business practices of that third party, not CHI Hospitality.
When You Request Us to Provide Information to Third Parties. When ordering products or interacting with certain services offered on the Sites, you may be presented with an option to have CHI Hospitality send certain pieces of information to third parties. If you permit us to share the information, your Personal Information and/or Demographic Information, once disclosed, will be subject to the privacy policies and practices of the third-parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, encourage you to review their privacy policies and notices prior to requesting that we provide them with your information.
Co-Branded Areas. Certain areas of the Sites may be provided to you in association with third parties (“Co-Branded Areas”), such as sponsors or charities, and may request or require you to disclose Personal Information to them. Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of your information. If you elect to register for products and/or services, communicate with such third parties, or download their content or applications, you may be providing your information to both CHI Hospitality and the third party. We are not responsible for such third party’s data practices and encourage you to review the third-party’s privacy policies for more information.
Sweepstakes, Contests and Promotions. CHI Hospitality may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to CHI Hospitality, co-sponsors, and other third parties. By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Policy. Please review those rules carefully.
Under certain circumstances, CHI Hospitality reserves the right to disclose your Personal Information to a third party if it is necessary to:

Comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request;
If CHI Hospitality believes your actions are inconsistent with CHI Hospitality’s Terms and Conditions, policies, or any other notice made about the use of this Website;
Protect the rights, property, life, health, security and safety of CHI Hospitality, its customers, or any third party; or
In connection with any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of CHI Hospitality assets, or transfer of all or a portion of CHI Hospitality’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
THIRD-PARTY CONTENT

The Sites include functionality that allows certain kinds of interactions with a website, platform, tool, application, or other service that is not owned or operated by CHI Hospitality (“Third-Party Services”). For example, we provide interfaces or links on the Sites to facilitate you’re sending a communication from the Sites (e.g., tweets, “likes”, content submissions, or other postings on social media platforms). Unless otherwise indicated, this Privacy Policy does not apply to Third-Party Services. We encourage you to review the applicable third-party privacy policies or notices to understand how they collect, use, or disclose your Personal Information. CHI Hospitality is not responsible for the content or privacy practices of linked websites that it does not control.

If you choose to use any Third-Party Services to enhance your use of the Sites, the providers of those Third-Party Services may send Personal Information about you to CHI Hospitality. To the extent that we combine such third-party sourced information, we will treat that as Personal Information under the Policy. If we discontinue use of any Third-Party Services, you consent that we may nevertheless retain any Personal Information, and other information or data that we may have already received in connection with this Policy.

TRACKING AND COMMUNICATIONS OPTIONS

ACCESSING AND CHANGING INFORMATION

The Sites may allow you to delete, correct, or update some of the Personal Information you provided to CHI Hospitality. We will make good faith efforts to make requested changes in our then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information as residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data as required by applicable law; and for so long as reasonably necessary to fulfill the purposes for which the data is collected (e.g., business records).

TRACKING TECHNOLOGIES GENERALLY

Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies, HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies, please reference the Cookies and Other Tracking Technologies section above. Please be aware that if you disable or remove these technologies, some parts of the Sites may not function as they ordinarily would.

While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our Sites.

PROMOTIONAL COMMUNICATIONS

You can opt out of receiving promotional communications from CHI Hospitality at any time by

(i)following the instructions provided in emails to click on the unsubscribe link; or

(ii) logging onto your membership account and changing your communication preferences.

Please note that if you select to opt-out of CHI Hospitality communications, you will also be opting-out of receiving promotional communications from its affiliates. However, even if you opt-out of receiving promotional communications, CHI Hospitality may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or CHI Hospitality’s ongoing business relations. Your opt-out preferences are limited to the e-mail address or phone number used and will not affect subsequent subscriptions.

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