OUR COMMITMENT TO PRIVACY

1. PERSONAL INFORMATION WE COLLECT

For purposes of this Privacy Policy, "personal information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household, as defined by applicable law.

We collect personal information in connection with providing hospitality services, processing reservations and payments, communicating with guests and customers, operating and securing our property and website, conducting marketing activities, complying with legal obligations, and for other purposes described in this Privacy Policy.

Identifiers and Contact Information
Name; mailing address; billing address; email address; telephone or mobile telephone number; account or reservation identifiers; online identifiers; IP address; information necessary to communicate with you; and other similar identifiers.

Reservation and Transaction Information
Reservation information; arrival and departure dates; room preferences; number of guests; special requests; guest history; purchases and services obtained; restaurant and food-and-beverage transactions; event and meeting information; gift-card or other transaction information; billing information; payment information; information concerning cancellations, refunds, charges, and adjustments; and other information reasonably necessary to complete or administer a transaction.

Payment Information
We may collect payment and financial information necessary to process reservations, payments, deposits, incidental charges, refunds, and other transactions.

Payment information may be collected and processed through third-party payment processors and other service providers. Where a third party processes payment information on our behalf, that information may be subject to the third party's privacy practices in addition to this Privacy Policy.

Guest Preferences and Information
Room and accommodation preferences; food and beverage preferences; service and amenity requests; accessibility or accommodation requests; travel preferences; special occasions; activities and interests that you voluntarily provide; prior stays and interactions with us; and other preferences or information that you choose to provide.

Government Identification Information
When necessary for hotel operations, security, legal compliance, or other legitimate purposes, we may collect information contained in government-issued identification documents, such as passport information, driver's license information, visa or immigration-related information, and other government-issued identification information.

We do not collect or retain government identification information unless there is a legitimate business, legal, security, or operational reason to do so.

Sensitive Personal Information
Depending upon the circumstances, we may collect certain information that may constitute sensitive personal information under California law, including precise geolocation information; information concerning health or medical conditions; information concerning accessibility or accommodation needs; passport or government identification information; certain financial information; religious or philosophical beliefs, where voluntarily provided; information relating to a person's citizenship or immigration status; and other information that qualifies as sensitive personal information under applicable law.

We collect and use sensitive personal information only as reasonably necessary and proportionate to provide requested services, administer transactions, provide accommodations, protect guests and employees, maintain safety and security, comply with legal obligations, prevent fraud, or for other purposes permitted by applicable law.

Internet, Device, and Website Information
When you visit or use our website or interact with our online services, we may automatically collect information such as IP address; browser type; operating system; device type and model; language preferences; referring URL; pages viewed; links clicked; date and time of visits; time spent on our website; website navigation and interaction information; general geographic location derived from an IP address; online identifiers; cookie identifiers; information concerning interactions with our emails or online advertisements; and other technical or usage information.

Geolocation Information
We may collect general or precise location information where reasonably necessary for a service that you request, where you enable location services, through certain technologies used on our website or devices, or for other purposes permitted by law.

Audio, Visual, and Security Information
For safety, security, loss prevention, incident investigation, and other legitimate purposes, our property may use security cameras and other security technologies in public and common areas.

These technologies may capture images, video, audio where applicable, vehicle or license-plate information where applicable, and other information associated with security events.

We do not place security cameras in areas where guests would reasonably expect privacy, such as guest rooms or bathrooms.

Communications
When you communicate with us by telephone, email, text message, online form, social media, or other means, we may collect and retain information concerning the communication.

Certain telephone calls or other communications may be recorded or monitored where permitted by law, including for quality assurance, training, security, dispute resolution, or other legitimate business purposes.

Information From Other Sources
We may receive personal information from reservation and booking partners; travel agencies; corporate or group customers; event organizers; marketing partners; service providers; social media platforms; publicly available sources; persons making reservations or arrangements on your behalf; and other business partners.

• Website and online services: when you visit our website, make a reservation, complete a form, contact us, subscribe to emails or newsletters, request information, purchase goods or services, participate in promotions, submit an event or meeting inquiry, interact with website features, or otherwise communicate with us online.
• Reservations: when reservations are made directly with us or through reservation, booking, travel, or distribution partners.
• Property visits: when you visit or use our property, including guest rooms, front desk, concierge, restaurant, bar, event spaces, pool, and other facilities.
• Telephone and email communications: when you contact us by telephone, email, text message, or other communication methods.
• Events and promotions: when you participate in meetings, conferences, events, contests, promotions, surveys, or other activities.
• Cookies and similar technologies: we and our service providers may use cookies, pixels, tags, web beacons, software development kits, and similar technologies to operate our website, analyze usage, personalize content, support advertising, prevent fraud, and perform other functions described in this Privacy Policy.

3. HOW WE USE PERSONAL INFORMATION

• Providing hotel and hospitality services, including reservations, stays, guest services, requested accommodations, amenities, payments, guest accounts, folios, restaurant and food-and-beverage services, events, meetings, customer service, and other requested services.
• Communicating with you, including reservation confirmations, stay information, customer-service responses, administrative notices, and communications concerning policies or services.
• Marketing, where permitted by law and consistent with your preferences, including promotional emails, offers, packages, events, restaurant offerings, services, promotional campaigns, and measuring marketing effectiveness.
• Website and business operations, including operating and maintaining our website, improving functionality, analyzing website use, conducting research and analytics, developing services, improving guest experiences, maintaining records, monitoring performance, understanding customer preferences, detecting technical problems, and protecting systems.
• Security and fraud prevention, including detecting and preventing fraud, protecting guests, employees, visitors and property, investigating incidents, monitoring security, preventing unauthorized activity, protecting systems and networks, and enforcing policies.
• Legal and regulatory purposes, including complying with laws and regulations, responding to legal process, establishing or defending claims, enforcing contracts, protecting legal rights, investigating suspected wrongdoing, and cooperating with law enforcement or regulators.
• Other purposes disclosed at the time information is collected or otherwise permitted by applicable law.

Service Providers and Contractors
We may disclose personal information to vendors and service providers that perform services on our behalf, including website hosting, information technology, reservation and booking services, payment processing, customer service, email and communications, marketing, analytics, security, fraud prevention, accounting, auditing, legal services, data storage, operational support, and other services necessary to operate our business.

Owners, Affiliates, and Related Businesses
We may disclose personal information to our owners, affiliates, subsidiaries, and related entities for purposes consistent with this Privacy Policy, including providing services, administering reservations, supporting business operations, and maintaining security.

Business Partners
We may disclose personal information to business partners where reasonably necessary to provide requested services or where permitted by law.

Advertising and Analytics Providers
We may disclose certain online identifiers, internet activity information, and related information to analytics, advertising, and technology providers that assist us with measuring website usage, advertising effectiveness, marketing, personalization, and related activities. Some disclosures for online advertising purposes may constitute 'sharing' under the CCPA. Where applicable, you may opt out of such sharing as described below.

Legal and Government Disclosures
We may disclose personal information when reasonably necessary to comply with law; respond to legal process; respond to governmental or law-enforcement requests; protect the rights, safety, or property of Santa Monica Hotel or others; investigate fraud or unlawful activity; establish, exercise, or defend legal claims; or comply with other legal obligations.

Corporate Transactions
We may disclose or transfer personal information in connection with a merger, acquisition, financing, sale of assets, reorganization, bankruptcy, joint venture, assignment, or other corporate transaction involving Santa Monica Hotel or its business.

5. COOKIES AND SIMILAR TECHNOLOGIES

Our website may use cookies and similar technologies. A cookie is a small data file placed on your browser or device that can assist with website functionality, remember preferences, provide analytics, and support other website functions.

• Strictly necessary technologies: necessary for the website to operate, provide requested services, maintain security, process reservations, and perform essential functions.
• Functional technologies: may allow the website to remember preferences and provide enhanced functionality.
• Analytics technologies: help us understand how visitors use our website, including pages visited, navigation, and website performance. We may use third-party analytics providers, including Google Analytics or other analytics services, depending upon technologies deployed on our website.
• Advertising and targeting technologies: pixels, cookies, tags, and similar technologies may be used to measure advertising effectiveness, understand interactions with our website and advertisements, and provide or support interest-based or targeted advertising.

Depending upon the technology and applicable law, you may control cookies through our website's cookie or privacy preference mechanism, browser settings, device settings, and other opt-out mechanisms provided by third-party service providers. Disabling certain cookies may affect website functionality.

6. YOUR MARKETING CHOICES

You may unsubscribe from promotional email communications at any time by following the unsubscribe instructions included in the applicable communication. Even if you opt out of promotional communications, we may continue to send transactional, administrative, reservation-related, security-related, or other communications necessary to provide services you have requested or otherwise permitted by law.

7. CALIFORNIA PRIVACY RIGHTS

This section applies to California residents to the extent Santa Monica Hotel is subject to the California Consumer Privacy Act, as amended ('CCPA'). California law provides eligible consumers with certain rights concerning their personal information.

• Right to know/access personal information;
• Right to delete personal information, subject to exceptions;
• Right to correct inaccurate personal information;
• Right to opt out of the sale of personal information;
• Right to opt out of the sharing of personal information for cross-context behavioral advertising;
• Right to limit certain uses and disclosures of sensitive personal information;
• Right to receive equal treatment for exercising privacy rights; and
• Other rights provided by applicable law.

You may request that Santa Monica Hotel disclose the categories of personal information we have collected about you; the specific pieces of personal information we have collected about you, subject to applicable exceptions; the categories of sources; business or commercial purposes; categories of third parties; categories of personal information sold or shared, if applicable; and other information required by applicable law.

9. RIGHT TO DELETE

You may request that Santa Monica Hotel delete personal information that we have collected from you, subject to exceptions permitted or required by applicable law. Exceptions may include information necessary to complete a transaction, provide goods or services, detect security incidents, prevent fraud, exercise or defend legal claims, comply with legal obligations, maintain legally required records, or complete internal uses reasonably aligned with consumer expectations.

10. RIGHT TO CORRECT

You may request that Santa Monica Hotel correct inaccurate personal information that we maintain about you. When evaluating a correction request, we may consider the nature of the personal information and the purposes for which it is maintained, consistent with applicable law.

11. RIGHT TO OPT OUT OF SALE OR SHARING

California residents may have the right to opt out of the sale of personal information and the sharing of personal information for cross-context behavioral advertising. Santa Monica Hotel does not sell personal information for monetary consideration in the traditional sense. However, certain disclosures of online identifiers, internet activity information, or other information to advertising or technology providers may constitute 'sharing' under California law. If applicable, you may exercise this right through our 'Your Privacy Choices' mechanism. We will also honor qualifying opt-out preference signals, including Global Privacy Control ('GPC'), as required by applicable law.

12. RIGHT TO LIMIT USE AND DISCLOSURE OF SENSITIVE PERSONAL INFORMATION

California law may provide consumers with the right to limit certain uses and disclosures of sensitive personal information. Santa Monica Hotel generally uses sensitive personal information only for purposes permitted by applicable law, including providing services requested by you, processing transactions, maintaining safety and security, complying with legal obligations, and other purposes reasonably necessary and proportionate to the purposes for which the information is collected.

13. HOW TO EXERCISE CALIFORNIA PRIVACY RIGHTS

You may submit a request to exercise California privacy rights through the following methods:

• Online: through the privacy request mechanism made available through the 'Your Privacy Choices' or 'Privacy' section of the Santa Monica Hotel website.
• Email: Privacy@ShoreHotel.com
• Telephone: (310) 392-6806

When submitting a request, please identify the type of request and provide sufficient information for us to reasonably verify the request. You do not need to create an account with Santa Monica Hotel to submit a privacy request.

14. VERIFICATION OF PRIVACY REQUESTS

For certain privacy requests, we may need to verify your identity before completing the request. The verification process will depend upon the nature and sensitivity of the request and the information involved. We will request only information reasonably necessary to verify the request. If we cannot reasonably verify your identity, we may be unable to fulfill certain requests.

You may authorize another person to submit a California privacy request on your behalf where permitted by applicable law. We may require the authorized agent to provide evidence of authorization and may separately verify the identity of the consumer as permitted or required by law.

16. RESPONSE TO PRIVACY REQUESTS

We generally respond to verified requests within the time periods required by applicable law. For requests to know, delete, or correct, California law generally provides an initial response period of 45 calendar days, subject to applicable extensions. We will explain the reason for any denial, in whole or in part, to the extent required by law. If you disagree with our response, you may contact us using the information below to request additional review.

17. NON-DISCRIMINATION

We will not unlawfully discriminate against you because you exercise rights provided to you under applicable privacy laws. Except as permitted by applicable law, we will not deny you goods or services, charge you different prices or rates, provide a different level or quality of goods or services, or otherwise discriminate against you because you exercised a privacy right.

18. CATEGORIES OF PERSONAL INFORMATION COLLECTED DURING THE PRECEDING 12 MONTHS

During the preceding twelve months, Santa Monica Hotel may have collected the following categories of personal information, depending upon the nature of your interaction with us:

19. SOURCES OF PERSONAL INFORMATION

We may collect personal information from you directly; your authorized representatives; persons making reservations or arrangements on your behalf; your browser or device; our website; our property; reservation and booking providers; travel agencies and travel partners; business partners; marketing and advertising providers; social media platforms; service providers; publicly available sources; and other third parties.

We may use personal information for providing hotel and hospitality services; processing reservations and transactions; processing payments; customer service; communications; marketing and advertising; analytics; website operation and improvement; security and fraud prevention; maintaining business records; quality assurance and training; events and promotions; product and service development; legal and regulatory compliance; protecting our rights and property; establishing, exercising, or defending legal claims; and other purposes described at collection or otherwise permitted by law.

21. CATEGORIES OF RECIPIENTS OF PERSONAL INFORMATION

Depending upon the nature of the information and our relationship with you, we may disclose personal information to service providers and contractors; payment processors; reservation and booking providers; website and technology providers; analytics providers; marketing and advertising providers; business partners; owners and affiliates; professional advisers; auditors; legal counsel; government authorities; law enforcement; courts and other parties involved in legal proceedings; and parties involved in a corporate transaction.

22. RETENTION OF PERSONAL INFORMATION

We retain personal information only for as long as reasonably necessary and proportionate to accomplish the purposes for which it was collected, provide services, comply with legal and regulatory obligations, resolve disputes, establish or defend legal claims, maintain business and financial records, protect our systems and property, and otherwise fulfill legitimate business purposes. Retention periods vary depending upon the type of information and circumstances. When personal information is no longer reasonably necessary, we will take reasonable steps to delete, destroy, or de-identify it, subject to applicable legal and operational requirements.

23. SECURITY OF PERSONAL INFORMATION

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, or misuse. No method of transmitting or storing information is completely secure, and we cannot guarantee absolute security.

24. THIRD-PARTY WEBSITES AND SERVICES

Our website and communications may contain links to third-party websites, applications, social-media platforms, reservation services, or other online services. Those third parties may collect information directly from you and may have their own privacy policies. This Privacy Policy does not govern the privacy practices of third parties that we do not control.

25. SOCIAL MEDIA

We may maintain or participate in social-media pages, accounts, and other online platforms. If you interact with us through social media, the applicable provider may collect information about you in accordance with its own privacy policy. Information that you choose to make publicly available on social media may be visible to others.

26. CHILDREN

Santa Monica Hotel is a hotel intended for general audiences and does not knowingly use its website to solicit personal information from children for purposes prohibited by applicable law. Children may stay at Santa Monica Hotel when accompanied by a parent, legal guardian, or other responsible adult in accordance with hotel policies. If we receive personal information concerning a child in connection with a reservation, hotel stay, guest service, event, or other legitimate hotel activity, we may use that information as reasonably necessary to provide requested services, protect the child and others, comply with legal obligations, and for other purposes permitted by law.

Santa Monica Hotel is located in the United States, and our website, service providers, and business operations may involve processing or storage of personal information in the United States or other jurisdictions. If you access our website or provide personal information from outside the United States, your information may be transferred to, processed in, or stored in the United States or other jurisdictions.

28. EUROPEAN UNION AND OTHER INTERNATIONAL PRIVACY RIGHTS

If you are located in the European Economic Area, United Kingdom, Switzerland, or another jurisdiction whose privacy laws provide additional rights, you may have rights concerning your personal information in addition to those described in this Privacy Policy. Depending upon applicable law, these may include access, correction, deletion, restriction of processing, objection, portability, withdrawal of consent where processing is based on consent, and the right to lodge a complaint with an applicable data-protection authority. Where applicable, processing may be based upon performance of a contract, legal obligations, legitimate interests, consent, or other lawful bases.

29. CALIFORNIA NOTICE AT COLLECTION

California law requires businesses subject to the CCPA to provide consumers with certain information at or before the time personal information is collected. Depending upon the method and circumstances of collection, Santa Monica Hotel may provide a separate Notice at Collection or a link to applicable information at or before the point of collection. Such notices may identify categories of personal information and sensitive personal information collected; purposes; whether categories are sold or shared; retention periods or criteria; and a link to this Privacy Policy.

30. PRIVACY CHOICES AND OPT-OUT PREFERENCES

Where required by applicable law, Santa Monica Hotel will provide mechanisms allowing consumers to exercise applicable privacy choices. Our website may include a 'Your Privacy Choices' link or similar mechanism through which you may opt out of the sale of personal information, opt out of sharing for cross-context behavioral advertising, manage applicable cookie and tracking preferences, and exercise other applicable privacy choices. We will process qualifying opt-out preference signals, including Global Privacy Control, in accordance with applicable law.

31. PRIVACY REQUESTS AND APPEALS

If you disagree with Santa Monica Hotel's response to a privacy request, you may contact us at Privacy@ShoreHotel.com or Santa Monica Hotel, Attn: Legal Department, 2102 Lincoln Blvd, Santa Monica, CA 90405. Please identify the nature of your request and, if applicable, provide information concerning the original request and Santa Monica Hotel's response. We will review appeals in accordance with applicable law.

32. DO NOT TRACK

Some web browsers may transmit 'Do Not Track' signals or similar browser preferences. Because there is not a uniform industry standard for responding to all such signals, our website may not respond to every browser-based Do Not Track signal. Where California law requires us to recognize a qualifying opt-out preference signal, including Global Privacy Control, we will process the signal in accordance with applicable law.

33. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business practices, technology, legal requirements, or other circumstances. When we make changes, we will post the revised Privacy Policy on our website and update the 'Last Updated' date. If changes are required to be communicated to you in another manner under applicable law, we will provide the required notice.

34. CONTACT US

Santa Monica Hotel, Attn: Legal Department, 2102 Lincoln Blvd., Santa Monica, CA 90405. Privacy Email: Privacy@ShoreHotel.com. General Telephone: (310) 392-6806. For California privacy requests, please use the privacy-request mechanisms described above.

35. EFFECTIVE DATE

Last Updated: September 28, 2026. This Privacy Policy supersedes and replaces Santa Monica Hotel's prior website privacy policy and privacy statements concerning the collection, use, disclosure, retention, and protection of personal information, except to the extent another notice expressly applies to a particular service, transaction, or relationship.

CALIFORNIA PERSONAL INFORMATION DISCLOSURE SUMMARY

For purposes of California privacy disclosures, the following table summarizes the principal categories of personal information that Santa Monica Hotel may collect and the purposes for which such information may be used. The actual categories collected and disclosed may vary depending upon your relationship with Santa Monica Hotel and the services you request.