At Crestline Hotels & Resorts, LLC (“Crestline”, “we”, “us”, and “our”) we are committed to protecting your privacy and support a general policy of openness about how we collect, use, and disclose your personal information.

The purpose of this Privacy Statement is to inform you about Crestline’s practices relating to personal information. By visiting our website, you consent to the collection, use, and disclosure of your personal information (as defined below) in accordance with the following terms and conditions.

This Privacy Statement explains how you may exercise certain rights relating to your personal information, depending on where you are located. We strongly recommend that you take the time to read this Privacy Statement and retain it for future reference.

Scope

This Privacy Statement applies only to the personal information of website visitors, customers, and contacts at our business partners.  It does not apply to the personal information of individuals in their capacity as applicants, employees, other workers, and their dependents, beneficiaries, and emergency contacts.  We have separate privacy statements for these individuals. If you are a California resident using this website to apply for a career with Crestline, please also review our California Privacy Statement for Job Applicants (link).

In many cases, Crestline serves as the hotel manager for a hotel brand company, for example, Marriott, Hilton, Hyatt, Radisson, etc. You may have provided personal information directly to those hotel brand companies, for example, by registering for a room with the hotel brand company. Please contact the hotel brand company regarding any personal information you have provided them.

This website may also offer links to other third-party websites. You should be aware that operators of linked websites may collect your personal information when you visit their websites. We are not responsible for third parties’ collection, use or disclosure of your personal information, so it is important to familiarize yourself with that company’s privacy policies.

Assistance For The Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact privacy@crestlinehotels.com for assistance.

Personal Information

For purposes of this Privacy Statement, “personal information” means information about an identifiable individual.

Notice at Collection for California Residents

Crestline collects the personal information identified in Section 1 for the purposes identified in Section 3 and retains it for the period described in Section 5. We do not sell your personal information or disclose it for cross-context behavioral advertising (“sharing”).  We also do not collect or process sensitive personal information for the purpose of inferring characteristics about you. To the extent you provide Crestline with personal information about other California residents, you are responsible for providing this notice to them.

Children

This website is not directed at, marketed to, nor intended for use by children under 16 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, do not use this website or any of its features and do not provide any personal information to us. If we learn that we have collected personal information regarding a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at privacy@crestlinehotels.com.

What Personal Information We Collect and How We Collect It

The categories and sources of personal information we collect may include:

• Identifiers
  (such as name and e-mail address.)
  • Your name and email address are collected only when you provide them, such as through the website’s interactive “contact us” form.
• Internet activity or other similar network activity
  (such as your internet connection, the equipment you use to access the website, usage information, browsing history, search history or information relating to your interaction with this website).
  • This information is collected automatically when you navigate through the website, via cookies or other tracking
• Geolocation data
  (such as the physical location of your device via your IP address).
  • This information is collected automatically when you navigate through the website, via cookies or other tracking
• Commercial Information
  • Records of products or services purchased and purchasing or consuming histories, for example, when you purchase from our hotel gift shops or cafés.
• Sensory or Surveillance Data
  • These might include voicemails if you leave us a message or footage from surveillance cameras.
• Other Personal Information
  • Financial Information, for example: payment card details when you book services at our spas.
  • Communications Data: During our communications with you, we collect the content of these communications as well as metadata about the communications, i.e., date and time of the call or text (SMS or MMS) message and phone numbers.
• Inferences
  • For example, Crestline might infer based on your booking history at our spas that you would be interested in certain spa services.

How We Use Your Personal Information

We use the categories of personal information we collect for one or more of the purposes below:

• Providing you with personalized, interactive communications;
• Developing and maintaining our relationship with you;
• Providing you with timely and reliable services you request;
• Responding to requests about your personal information;
• Determining the rights available to you in connection with your personal information
• Researching, developing, managing, protecting and improving services you request;
• Presenting the website and its contents to you;
• Where you have agreed to receive such information, to send you marketing information about our services, including notifying you of marketing events, membership and rewards programs, promotions, and sweepstakes;
• Administering and protecting our business and website (including troubleshooting, analysis, testing, system maintenance, support, reporting and hosting of data, and preventing fraud and abuse);
• Protecting the rights, property, or safety of Crestline, you, or others;
• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Crestline or any of its subsidiaries or affiliates;
• Reporting suspected criminal conduct to law enforcement and cooperate in investigations;
• Exercising Crestline’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel;
• Ensuring compliance with applicable laws and regulatory obligations; or
• Performing any other activity made clear to you at the time your personal information is

Incidental Purposes: Any incidental purposes related to, or in connection with, the above.

When We Disclose Your Personal Information

We will never rent or sell your personal information to anyone. We may disclose information (including personal information) about you in the following limited circumstances:

Service Providers and Contractors:

We may disclose your information to third-party vendors, consultants, and other vendors (“Vendors”) that we employ to perform tasks on our behalf. For example, these companies could include our payment processing providers, website analytics companies (e.g., Google Analytics, described below), product feedback or help desk software providers, CRM service providers (e.g., HubSpot), email service providers and others.

We utilize Google Analytics, a web analysis service provided by Google, to better understand your use of our Websites and Services. Google Analytics collects information such as how often users visit the Websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the Websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Websites to contextualize and personalize the ads of its own advertising network. Google’s ability to use and disclose information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers an opt-out mechanism for the web available here.

Affiliated companies:

Other companies within the Crestline family, for example, to provide you with our products and services.

Third parties:

For example, we might disclose personal information to lawyers to assist us with legal compliance or to business partners to assist us in providing services to you.

Business Transfers:

We may choose to buy or sell assets, and we may disclose and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we are acquired, or if we go out of business, enter bankruptcy or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party. Any such sale, transfer or otherwise sharing of our assets shall be subject to the restrictions of this Privacy Statement and any applicable data protection laws.

Additional Disclosures:

We reserve the right to disclose personal information about you with your permission, as required by law, as necessary to enforce any agreements we may have with you or to comply with this Privacy Statement, to investigate or defend against third-party claims or allegations, to protect the security and integrity of our Services and property, to protect our rights or personal safety and that of our users or others, and to respond to valid requests by public authorities, including to meet national security or law enforcement requirements.

Contacting Us about Your Personal Information

You can help us maintain the accuracy of your personal information by notifying us of any changes to this information. You may contact us in any one of the ways provided below to request a correction or update to your personal information:

Via E-mail:                   privacy@crestlinehotels.com

Via Mail:                       3950 University Drive, Suite 301, Fairfax, VA 22030

Via Telephone:             (571) 529-6100

Via Fax:                        (571) 529-6091

Additional Information for California Residents

For California residents, “personal information” is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Sensitive Personal Information

Crestline does not infer characteristics from sensitive personal information.  We only use sensitive personal information as necessary to perform the services or provide the goods the average person would reasonably expect when requesting those goods or services, to ensure security and integrity, short term transient use, to maintain the quality of our products and services, or for other purposes permitted by the California Privacy Rights Act and implementing regulations (“CPRA”) without the right to opt out.

Disclosures for Business Purposes

Crestline has disclosed each of the categories of personal information it collects for the following “business purposes”, as that term is defined under the CPRA, in the last 12 months:

• Service providers: For the business purpose of performing services on Crestline’s behalf and, in particular, for the specific purposes described in Section 3, above.
• Auditors, lawyers, consultants, and accountants engaged by Crestline: For the business purpose of auditing compliance with policies and applicable laws, in addition to performing services on Crestline’s behalf.
• Affiliated companies: To other companies within the Crestline family of companies for the business purposes of (1) auditing compliance with policies and applicable laws, (2) helping to ensure security and integrity, (3) debugging, (4) short-term transient use, (5) performing services on behalf of Crestline, (6) internal research, and (7) activities to maintain or improve the quality or safety of a service or device.

If you live in California, you have the following additional rights related to your personal information collected by us:

Right to Know

As a California resident, you have the right to request that we disclose certain information to you about our collection and use of your personal information and the specific pieces of personal information obtained from you.

Right to Delete

As a California resident, you have the right to request that we delete all or some of the personal information we collected from you, subject to certain exceptions. You may submit a verifiable request (see “Submitting Requests” below) that may result in:

• The permanent and complete erasing of your personal information on our existing systems, with the exception of archived or back-up systems;
• De-identifying your personal information so that it can no longer identify you. An example of deidentified information would be the data point that an unidentified visitor first entered our site through our main web page. We maintain deidentified information in a deidentified form and do not attempt to reidentify it, except that we may attempt to reidentify the information just to determine whether our deidentification processes function correctly; or
• Aggregating your personal information with other information so that it can no longer identify

Right to Correct

You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by us, taking into account the nature of the personal information and the purposes of processing the personal information.

Right to Non-Discrimination

As a California resident, you have a right not to be subject to discriminatory treatment as a result of exercising the rights conferred upon you by California law. In other words, the quality and price of the goods and services we offer will not be modified because you exercised your rights described above.

Submitting Requests

To exercise your rights to know, correct, or delete, as described above, please submit a verifiable request to us by either:

• Emailing us at privacy@crestlinehotels.com
• Calling us at (800) 282-9144

Only you, or an authorized agent, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child.

You may only make a verifiable request to know twice within a 12-month period. Each verifiable request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or an authorized representative of such person; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may ask for additional personal information to verify your identity by matching this information against information in our files.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will respond to requests to know, delete, and correct in accordance with applicable law. We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.

Authorized Agents

If an authorized agent submits a request on your behalf, the authorized agent must submit with the request another document signed by you that authorizes the authorized agent to submit the request on your behalf.  In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. You can obtain the “Authorized Agent Designation” form by contacting us at privacy@crestlinehotels.com. In the alternative, you can provide a power of attorney compliant with the California Probate Code.

Disclosures for Direct Marketing Purposes

California consumers who use the services may request that we provide certain information regarding our disclosure of your personal information to third parties for their direct marketing purposes. You can make such a request by e-mail to privacy@crestlinehotels.com .

Tracking Across Time and Different Sites

The Site tracks your online activities over time and across websites or online services on an individually identifiable basis.  For example, we may serve you advertisements on other websites based on what appeared to interest you on our Site.  We do allow third parties to use our Site to track your activities over time or across other websites.

“Cookies” and “Do Not Track” Signals

Your internet activity and geolocation data may be automatically collected by us through the standard operation of our internet servers and through the use of “cookies”. Where those cookies are not strictly necessary for the provision of the website, your consent to the use of cookies is requested when you first visit our website.

Cookies are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the website, track usage behavior, and compile aggregate data that allows for content improvements and targeted advertising. Generally, cookies work by assigning a unique number to each customer that has no meaning outside the assigning website.

If you do not want your internet activity or similar information tracked or collected through the use of cookies, you should review your web browser settings. Most web browsers allow a user to restrict these functions; however, you should note that disabling cookies may prevent certain website features from functioning properly.

Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Site, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com.

How We Retain and Protect Your Personal Information

We may retain your personal information for as long as necessary to fulfill the purpose(s) for which it was collected or as long as required or permitted by applicable laws. This means that we may continue to use your personal information after termination of our relationship with you for certain purposes permitted by law, such as record keeping or other internal purposes.

We understand that the privacy and security of your personal information is important to you. In keeping with this understanding, and with our legal obligations, we utilize appropriate administrative, technical and physical safeguards to protect your personal information.

Changes to this Privacy Statement

We reserve the right to modify this Privacy Statement at any time. When we make changes to this Privacy Statement, we will post the updated Privacy Statement on the website and provide notice to you as required by law. You are responsible for periodically reviewing this Privacy Statement. The Privacy Statement posted at any time on this website shall be deemed the Privacy Statement then in effect. Your continued use of our website following the posting of changes constitutes your acceptance of the updated Privacy Statement.

For More Information

In the event that you have any questions about this Privacy Statement, or if you have reason to believe that we may have failed to adhere to this Privacy Statement, you may contact us at:

Crestline Hotels & Resorts

3950 University Drive, Suite 301, Fairfax, VA 22030 Attention: Privacy Officer / Legal

Or call us at 1-(571) 529-6100

Or send an e-mail to privacy@crestlinehotels.com

Last Updated and Effective: March 6, 2024