20FIRST HOSPITALITY PRIVACY POLICY

Last Updated August 2011

At 20First Hospitality, we strive to deliver outstanding products, services, and experiences for all of our guests. We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Global Privacy Policy (this "Policy") to explain our practices regarding the personal information we collect when you visit this site. Some jurisdictions also require notice concerning other means of collecting personal information; for those jurisdictions, this Policy also explains our practices regarding personal information obtained from sources other than our websites, such as written or verbal communications or information collected when you visit one of our properties or attend one of our events.

Please read this Policy carefully before submitting personal information about you to us.

Personal Information We Collect

At every touch point or guest interaction, we may collect personal information. In addition to any other information you may choose to provide to us, this personal information may include: your name and contact information; date of birth; preferred communication methods; business name, title and business address; credit card details, including the three-digit code that appears on the back of your credit card; member number, frequent flyer or travel partner program affiliation; date of arrival and departure; room and vacation preferences; travel history; and details on hotel, airline and rental car packages you book. We may also record details on joint travelers, including their names and frequent flyer numbers, and the age of the driver of the rental car.

Use of Personal Information Collected About You

We use your personal information to provide the services you request from 20First Hospitality such as to facilitate: reservations; book meeting space, event planning and access to specific account information for administrative purposes and other transactions. We also use the personal information to provide newsletters, information about sweepstakes, on-line surveys and prize draws. In addition, we may use the information to: improve 20First Hospitality's services; provide you with the expected level of hospitality; and ensure the site is of interest to you. If you apply for employment with 20First Hospitality, we use the personal information you supply to process your job application.

How We Share Personal Information

20First Hospitality does not share your personal data with outside companies.
20First Hospitality Portfolio of Brands: We may share personal information within the 20First Hospitality Portfolio of Brands that may jointly use the personal information for the purposes described above.
Electronic Billing Program: If you participate in the "eFolio program", billing information will be shared with the credit card provider and if you use a corporate credit card, possibly, your employer.
Group Events or Meetings: If you visit Hilton as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
Onsite Services: We may share personal information with providers of onsite services that provide services such as spa treatments, golf or dining experiences at a restaurant.

Sensitive Information

The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you exclusively to serve you better and meet your particular needs.
Personal Information From Children
We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not to allow your children to submit personal information without your permission.

Non-Personal Information

As with many other sites, our site may use "cookies" or other technologies to help us deliver content specific to your interests, to process your reservations or requests, and/or to analyze your visiting patterns. Cookies, by themselves, cannot be used to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit our site. If you want to remove cookies at any time from your computer, you can delete them using your browser (consult your browser's "help" menu to learn how to delete cookies).

We also may collect data by using "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "pixel tags") that allow us to know when you visit our site. Through pixel tags, we obtain non-personal information or aggregate information (i.e., the domain name, the areas of the site you visit, your operating system, your browser version, and the URL you came from) which can be used to enhance your online experience and understand traffic patterns.

In addition, we may use third party advertisers to serve advertisements on the Sites. Please note that these third party advertisers also may use cookies, pixel tags and other technologies to, among other things, enable such third party advertisers to record which ads your browser has seen and which site pages you may have been viewing when the ads were delivered. Hilton does not control the use of this technology or the resulting information and is not responsible for any actions or policies of such third parties.

Because non-personal information does not personally identify you, we may use or disclose such information for any purpose. In some instances, we may combine non-personal information with personal information (such as embedding e-mail addresses in cookies). If we do combine any non-personal information with personal information, the combined information will be treated by us as personal information in accordance with this Policy.

Links to Third-Party Websites

Our site may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on third party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

Protecting Personal Information

20First Hospitality will take appropriate measures to: (i) protect personal information collected against unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date, consistent with applicable law. We also seek to require our affiliates and service providers to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, we encourage you not to include sensitive personal information in any emails you may send to us. Please do not send credit card numbers or any sensitive personal information to us via email.

Changing Personal Information

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct, and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by the applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. Such requests must be submitted in writing to the following address: 20First Hospitality Inc. 4000 Summit Boulevard, Atlanta GA 30319 USA. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.

Retaining Personal Information

We retain personal information about you for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by applicable law.

Marketing Lists

If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you about our services or invite you to events by email, telephone or post.

If you prefer not to receive marketing materials from us, you may change your preferences at any time by: (i) writing to us (and include your email address) at 20First Hospitality Customer Privacy Department, 4000 Summit Boulevard, Atlanta, GA, USA; or (iii) using the unsubscribe function in the email you receive from us. We will update your preferences as soon as reasonably practical.

Other Information

If you choose to apply online for employment with 20First Hospitality, you will also have the opportunity to send your resume in electronic form, information on education and employment history, desired salary scale, working permits, and any other information you feel is relevant to your application. If you apply for employment online, any information about you which is obtained by us during the application process may be retained by us for purposes of considering your application for employment, as well as for more general management and research purposes. Please see our Online Recruiting Policy for further detail.

Policy Modifications

We may modify this Policy from time to time. When we make material changes to this policy we will post the revised policy on the homepage of our site. You can tell when this Policy was last updated by looking at the date at the top of the Policy. Any changes to our Policy will become effective upon posting of the revised Policy on the site. Use of the site following such changes constitutes your acceptance of the revised Policy then in effect.

Questions

If you have any questions about this Policy or how Hilton processes your personal information, please contact us by email to terri.harof@gmail.com by postal mail to 20First Hospitality Customer Privacy Department, 4000 Summit Boulevard, Atlanta, GA 30319, USA.