OUR COMMITMENT TO PRIVACY

This policy was last updated on January 4, 2023.

The Kor Group respects the privacy of all our guests, and we are committed to protecting privacy through our compliance with this policy. This policy describes the type of information we may collect from our guests and private members, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This statement applies to our www.thekorgroup.com website and digital services including mobile application (“Website”, “Digital Access”, “Property” or “Properties”).

By using any of our products or services you acknowledge and agree to the privacy terms contained in this statement and related links in the context of the collection and use of personal information and/or registering for any of our product or services. Please note that this statement does not apply to our processing of personal information on behalf of and subject to the instructions and policies of third-parties such as airlines, travel services, car rental companies, marketing partners, corporate customers, and other similar services providers.

1. CATEGORIES OF INFORMATION COLLECTED

This privacy policy applies to information we collect off-line and on this Website, Digital Access, and our Properties, including, name, telephone, email address, home or business address, nationality, date of birth, gender, payment card information, private membership identification numbers, passport information or other government-issued identification information, preferred language, geolocation, additional guest names, travel itinerary, corporate travel planner contact information, including name, title, company, business phone, email and address), travel agent number and name, airline partner name and number, vehicle identification number, images or footage captured property-based cameras, internet or online network activity information, IP address, session id, booking engines, streaming service usage, prior guest stays or interactions, goods and services purchased, special service, amenity requests, and room preferences, social media account ID, profile photo and other data publicly available, or data made available by linking your social media to loyalty accounts.

2. CATEGORIES OF INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Website or use Digital Access, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visit to our Website or use of Digital Access (“usage data”), including traffic data, location data, logs, and other communication data and resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, unique device ID, referral URLs and browsing type.

The technologies we use for this automatic data collection may include.

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will use cookies when you direct your browser to our Website.

• Flash Cookies. Certain features of our Website may use local stored objects (Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Our digital services may also host ads through third-party advertising technology. In the course of serving our advertisements to you, unique third-party persistent cookies, clear gifs or beacon gifs may be placed on your computer or device to help manage our online advertising, recognize when a device visits our Websites, learn which ads bring users to our Websites, and track whether a reservation is made. The information our ad-serving providers and we collect through this technology is not personally identifiable but is used to create an anonymous profile which allows the ad-serving provider to serve ads targeted towards you and your interests across the ad-serving network.

Our Websites do not currently respond to “Do Not Track” signals that may be sent by your device or browser. Our third-party platform service providers maintain tools that permit recognition of “opt-out preference signals.”

3. HOW WE COLLECT INFORMATION

• Through this Website, Registration at Properties and Digital Access

• Through automated business operations and customer experiences

• Through digital applications made available by us or our travel services partners for use on or through computers and mobile devices

• Through our social media pages that we control

• Through email messages that we send you

when you visit or stay as a guest at one of our properties, we collect other information in addition to your Personal Information in accordance with the law, and to serve you better. This information may in personalized preferences such room choice and other personalized amenities.

4. WHY WE COLLECT AND HOW WE USE INFORMATION[NEED TO PROVIDE A LINK TO EACH SECTION]

We use your personal data to fulfill the business and operational purposes for which it was collected, or as otherwise set forth in this policy. This following chart provide a general overview of the business purposes for our collection of personal information and reasons for such collection:

Category of Personal Information	Sources from which Personal Information was collected	Purpose of Collection	Categories of entities with which Personal Information was shared
Address and other identifiers – such as name, postal address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Automated collection on our Sites, services, products, applications, databases, devices, information systems and networks, and through cookies. Service providers, business partners, data brokers and other third-party contacts. Publicly available sources (e.g., Social Media) Government sources and records	To provide the Proper platform and related services Business Operations Marketing Cybersecurity, fraud prevention and other security purposes Personnel Services Personnel Administration Regulatory and Legal	Service Providers Government entities Third parties pursuant to lawful process Third parties to whom you have intentionally interacted with (e.g., potential recruiting services on our site) Other Proper members and service customers Third party advertisers and analytics providers Affiliates and other business partners
Unique and online identifiers – such as IP address, device IDs, or other similar identifiers	Automated collection on our Sites, services, products, applications, databases, devices, information systems and networks, and through cookies Service providers, business partners, and other third party contacts Publicly available sources (e.g., Social Media)	To provide the Proper platform and related services Business Operations Marketing Cybersecurity, fraud prevention and other security purposes Personnel Services Personnel Administration Regulatory and Legal To provide the Proper platform and related recruiting services Business Operations Marketing Cybersecurity, fraud prevention and other security purposes Regulatory and Legal	Service Providers Government entities Third parties pursuant to lawful process Other Proper members and service customers Third party advertisers and analytics providers Affiliates and other business partners
Inferences drawn from CCPA PI – such as individual profiles, preferences, characteristics, behaviors	Automated collection on our Sites, services, products, applications, databases, devices, information systems and networks, and through cookies Service providers, business partners, data brokers and other third-party contacts Publicly available sources (e.g., Social Media) Government sources and records	To provide the Proper platform and related recruiting services Business Operations Marketing Cybersecurity, fraud prevention and other security purposes	Service Providers Government entities Third parties pursuant to lawful process Other Proper members and service customers Third party advertisers and analytics providers Affiliates and other business partners

You may opt out of receiving any promotional or marketing emails at any time by contacting us directly or by following the “opt out” or “unsubscribe” links in such emails. We may, however, continue to contact you with relevant information about your past or upcoming reservations with us, open transactions, and status of membership account. We may use the usage data we collect for any reason we deem appropriate, including to improve, maintain, and operate our Websites and services.

5. SHARING OF INFORMATION

We will not sell any of your personal data to any outside organization. We may disclose aggregated information about our customers, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them, as for example payment processors and customer support contractors
• To a buyer or other successor in the event of a merger, divestiture, restricting, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers is among the assets transferred.
• To fulfill the purpose for which you provide it
• For any other purpose disclosed by us when you provide the information
• With your consent
• To carry out the permitted uses described in the “WHY COLLECT AND HOW WE USE INFORMATION” section of this policy
We may also disclose your Personal Information:
• To comply with any court order, lawful discovery request, or legal process, including to respond to any government or regulatory request
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes
• If we believe disclosure is necessary or appropriate to protect the rights, property, or our safety, our customers, or others.

6. LINKS TO THIRD PARTY WEB SITES

Please be aware that third-party websites available through links on our Websites each have separate privacy and data collection practices. We have no control, responsibility or liability for these third-party websites or their applicable policies or content. We cannot ensure or warrant the security of any information you disclose on third-party sites.

7. WHERE PERSONAL INFORMATION IS PROCESSED

We is based in the United States, and personal data is collected worldwide (including within the European Economic Area, United Kingdom, and other regions around the world) and may be transferred to the United States for processing and storage.

8. RETENTION OF PERSONAL INFORMATION.

Generally, we will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To ensure that we can complete transactions related to services;
• To respond to any questions, complaints or claims made by you or on your behalf;
• To improve our business operations;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information and the reasons for processing. In the event that your personal information is deidentified, or anonymized, we will not make any efforts to reidentify such information.

9. SECURITY OF PERSONAL DATA

We are committed to the security of your personal data. We use commercially reasonable technical measures to protect personal data in our possession, and our Website uses secure socket layer (SSL) encryption technology to help protect the privacy of credit card information, name, address, email and other sensitive information you provide to us.

10. CHILDREN UNDER THE AGE OF 18

Our Websites and services are not intended for children under 18 years of age. and we do not knowingly solicit or collect personal data from children. No one under age 18 may provide any Personal Information to us. If we are notified or discover that a child under the age of 18 has submitted Personal Information to us, we will not sell such information, and we will take reasonable steps to delete the information.

11. STATE DATA PROTECTION LAW COMPLIANCE

We do not sell or share personal information. Under several new state data protection laws, consumers have the following rights regarding personal data we have collected about you. For purposes of this section only, “personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person and excludes employment data, personal data that cannot be attributed to an individual without the use of additional information, and de-identified data or publicly available information. Under these laws consumers have the right to request any of the following information from us regarding personal information collected about you:

• The right to know (i.e., the right to confirm whether we are processing your personal data). This information includes:

o The categories of personal information collected about you.
o The categories of sources from which the personal information is collected.
o The business or commercial purpose for collecting or selling personal information.
o The categories of third parties with whom we share personal information, if any.
o The specific personal information collected about you.
o For personal information sold or disclosed to a third party for a business purpose, you have a right to know the categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and the categories of personal information that we disclosed about you for a business purpose.

• The right to access (i.e., the right to access your personal data processed by us);
• The right to a copy (i.e., the right to obtain a copy of your personal data that you have previously provided to us in a portable and readily usable (if technically feasible) format);
• The right to correct inaccuracies (i.e., the right to correct inaccuracies in your personal data based on the nature of the data and the purposes of the processing);
• The right to deletion: (i.e., the right to request us to delete your personal data provided to us);
• The right to opt out of the: (1) sale or limit the use of sensitive personal information, (2) processing of your personal data for certain purposes, including, profiling in furtherance of a decision that produces a legal or similar significant effect concerning the consumer, or (3) targeted advertising.
• The right to appeal adverse decisions regarding your request exercise any of the foregoing rights.

We will provide this information free of charge up to two (2) times in any twelve (12) month period within 45 days of receiving your verifiable request (including verification of your identity and your California residency), subject to delays and exclusions permitted by law. Specific personal information about you or your account that is categorized as sensitive or confidential may be redacted.

We will not discriminate against you if you choose to exercise any of these rights. You may exercise the rights described above by clicking “Personal Data Request” at the bottom of this page and following the instructions. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request.

You or your agent may exercise your data privacy rights here: Emailing Privacy.Policy@thekorgroup.com. 

12. EUROPEAN ECONOMIC AREA (EEA) RESIDENTS AND UNITED KINGDOM (UK), AND SIMILAR APPLICABLE JURISDICTIONS

Data Controller

The data controller for the information you provide or that is collected by Kor Real Estate Partners, LLC or its affiliates is:

Kor Real Estate Partners, LLC
1437 7th Street, Suite 250
Santa Monica, CA 90401
Attn: Legal Department
Privacy.Policy@thekorgroup.com

Legal Basis for Processing Personal Information
By using this Website and Digital Properties and voluntarily providing us with your personal information you are consenting to the processing your personal. Our processing requirements are also based on contractual obligations and responsibilities related to the performance of agreements related to the service you purchase from us. Finally, we have regulatory and rules-based compliance obligations that require us to use your personal data during your engagements with us.
Data Localizations and Consent to Transfer
This Website and Digital Properties are hosted and operated in the United States. However, we and our service providers may store information about users and other individuals in the United States, or we may transfer it to, and store it within, other countries.
United States may not have data privacy laws that are deemed to afford an equal level of protection for your personal information as those laws legislated at the direction of the European Union or similar geopolitical, national, or regional legislative bodies. However, please be assured that we will continue to adhere to the principles stated in this Privacy Policy and will make reasonable efforts to comply with applicable international, national, regional, territorial, and provincial laws in connection with any information collected through the Website and Digital Properties.
For those users located EEA or UK, we advise you that your information may at times be accessible by individuals who are located worldwide, including in countries that the European Commission or other geopolitical regions have not deemed to provide the same level of data protection as in your country, province, territory, or geopolitical region. By providing us with your personal information, you are consenting to our use of it in accordance with this Privacy Policy, including the transfer of your information across international boundaries to jurisdictions anywhere in the world as permitted by local law.

Data Privacy Rights Statement

If you reside in U.K. the European Economic Area (EEA) you may have the following additional rights under the GDPR as applicable:

• The right to access (i.e., the right to be provided with a copy of your personal information);
• The right to rectification (i.e., the right to require us to correct any mistakes in your personal information);
• The right to be forgotten (i.e., the right to require us to delete your personal information – in certain situations);
• The right to restriction of processing (i.e., the right to require us to restrict processing of your personal information – in certain circumstances, e.g., if you contest the accuracy of the data);
• The right to data portability (i.e., the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party – in certain situations);
• The right to object (e.g., the right to object to your personal information being used for direct marketing, and in certain other situations, to object to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests);
• The right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent – without affecting the lawfulness of processing based on consent before its withdrawal);
• The right to information regarding consent (i.e., to obtain information about the possibility or providing or denying your consent and the consequences of such consent or denial of consent); and
• The right not to be subject to automated individual decision-making (i.e., the right not to be subjected to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you).

You or your agent may exercise your data privacy rights here: Calling +1 (888) ___-____ / Pin Number: _________________ or Completing a Data Access Request form found [here].

We will not discriminate against you if you choose to exercise any of these rights. You can exercise your rights under the U.K. GDPR or GDPR by contacting us as follows:

Email: privacy.policy@thekorgroup.com (please use “GDPR” or “U.K. GDPR” in the subject line as applicable)

Kor Real Estate Partners, LLC
1437 7th Street, Suite 250
Santa Monica, CA 90401
Attn: Legal Department

The U.K. GDPR and GDPR also gives individuals the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

13. CHANGES TO THIS POLICY

We may update this policy from time to time. We will always post the then-current version of this policy on our Websites, and will indicate at the top of the policy the date on which the latest version took effect. Please review this policy from time to time to stay updated on our privacy practices.

14. CONTACT

If you have any questions, comments and complaints about our data practices can be sent to our data protection office by sending an email to privacy.policy@thekorgroup.com or writing us at: Kor Real Estate Partners, LLC, 1437 7th Street, Suite 250, Santa Monica, CA 90401Attn: Legal Department.