Martin Hospitality

PRIVACY POLICY

Martin Hospitality and its family of hotels and restaurants takes the issue of safeguarding your privacy very seriously. We have created this Privacy Policy in order to better familiarize you with the information we collect from hotel and restaurant guests, web site visitors, and the way in which Martin Hospitality uses this information to better serve the needs of our guests.

• WHAT IS PERSONAL INFORMATION?

The term "Personal Information" refers to any information that can be used to identify you as an individual. It can include, among other things, your name, address, age, gender, personal financial history and social insurance or social security number.

• WHY IS PERSONAL INFORMATION COLLECTED?

1. To Provide Superior Customer Service to Our Guests Personal Information is collected to assist us in making your reservation and providing the services you request at any of our properties, to ensure we meet your needs while you are staying with us and/or to allow us to contact you in relation to matters that arise from your stay. By keeping certain stay-related Personal Information on file, such as information regarding guest history and itemized spending, guests of Martin Hospitality have the ability to confirm prior transactions.

2. To Keep Our Guests Informed
We may use the Personal Information you provide to send you newsletters regarding our properties and to advise you of promotions, or to inform you of offers and/or other information that may be of your interest. In order to do this, your information may be shared with a third party, including a customer relationship management company and/or a marketing and communications company. These companies are under contract with Martin Hospitality and contractually required to protect all guest information to which they have access. If you do not wish to receive information from Martin Hospitality you may send an e-mail to: customerservice@martinhospitality.com.

3. For Marketing Research
Finally, we may wish to contact guests to conduct surveys or focus groups to receive feedback on our properties and service delivery. Such information may be collected by a third party under contract with us and they will be contractually required to protect your Personal Information as explained below. Occasionally we will combine information from a number of guests to better understand trends and guest expectations. When this occurs, all identifiers are removed and the aggregate information cannot be linked to any specific guests.

• HOW IS PERSONAL INFORMATION COLLECTED?

1. On Our Web Site

A. Initially Upon Contact With Our Web Site

When you visit our web site, you are initially given a "cookie". We also use cookies to collect and maintain aggregate web site data (such as the number of visitors to a particular site), which helps us see which areas are popular with our users and which are not. Among other things, this helps us improve and update the site, based on such data as the total number of visitors and pages viewed. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser.

B. Making a Purchase on Our Web Site

When making a purchase, such as a gift card, you will be asked to complete a form that includes your contact information and payment information. The form is secure. When the form is complete, your credit card number will be verified using a checking sequence, and once this is confirmed we authorize payment for the amount shown on your order form. Again, due to the personal nature of the information you give when making a purchase through our web site, the form is secure, such that your credit card number is protected with the most sophisticated encryption technology available and is transmitted on a private network. Purchasing transactions are assisted by third party processors who are required by contract with us to protect the privacy of your Personal Information.

We retain a log file of transactions at our web site, excluding your credit card number, connected to your ID number. We will then use that information to assist in any inquiries about your transaction. We also occasionally combine information from a number of web visitors in a way that does not identify any user, in order to identify user patterns.

2. When Making a Reservation

A. On Our Web Site
If you decide that you would like to make a reservation at any of our hotels or resorts, you will be linked to our reservation service site. Although it appears to be part of our site, the reservation site is, in fact, provided by Sceptre, which provides an automated reservations and distribution system to the travel industry. You can search for rates and availability at our hotels and resorts without providing any Personal Information.

Visitors who elect to make reservations online will be asked to provide specific Personal Information, including your name, address and contact information, as well as certain guarantee and deposit information to secure your reservation, such as a credit card number. The transmittal of your Personal Information shall constitute your acknowledgment and agreement to the terms and conditions contained in this Privacy Policy.

Your credit card number will be verified using a checking sequence, but we do not authorize any payments at this point. Once your reservation is confirmed, Martin Hospitality will be sent all of the reservation information. From this point the information is sent to the selected hotel in exactly the same way as if you called us directly, or if your travel agent made the reservation

Due to the personal nature of the information given when making a reservation through our web site, the reservation system is secure, such that your credit card number is protected with the most sophisticated encryption technology available and is transmitted on a private network.

We also occasionally combine information from a number of web visitors in a way that does not identify any user, in order to identify user patterns.

B. Through Reservations Offices
Reservations can also be made by calling a particular hotel or resort directly. When you make a reservation we may ask you for Personal Information such as your name, address, telephone number and method of payment. We may also obtain from you any room preferences or special requests. Confirmation of your reservation will be provided to you, generally by e-mail, directly from the hotel or resort.

3. During Your Stay at a Hotel or Resort

During your stay, we record your itemized spending to properly assemble your portfolio, which sets out your room rate and other expenses billed to your room. We also record this information to comply with financial reporting requirements, including those imposed by our auditors and government regulators. Information particular to your stay may also be stored (i.e., health issues, payment difficulties, special requests, service issues). This stay specific information is stored in the property management system at the particular hotel where you stayed and is combined with information from previous visits that you have made to that hotel.

In addition, we may retain the content of any document (including letters, comment cards, electronic documents such as e-mails and other similar forms of communication) that you send us before, during or following your stay. This information may be shared with employees of the hotel but will not be shared with any third party.

• HOW DO WE STORE PERSONAL INFORMATION?

1. At The Hotel or Resort
Each hotel goes to great measures to ensure that all Personal Information is kept in a secure location, be it a database or a filing cabinet. Furthermore, we take steps to ensure that only designated individuals have access to this information.

2. In Our Guest Reservation System
In order to serve you better we also store certain guest information in our guest reservation system.

The stored information includes guest name, address, phone numbers and credit card number. We may also store certain information regarding your service preferences.

We also store other transaction information in our guest reservation system, including the number of stays you have had at properties managed by Martin Hospitality and the number of nights of each stay.

5. In Our Marketing Database
Martin Hospitality maintains a database of guest information which is used for marketing, promotion and research purposes. Any information sent provides a clear notice of how to discontinue receiving promotional materials.

• WHAT INFORMATION IS NOT SECURE?


It is important to note that e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the "Contact Us" section of our web site). We recommend that you do not include any confidential information (i.e., credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any confidential information.

Finally, to be prudent, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, since while you are logged on it is easier for someone to attempt to get access to your profile.

• WHAT PERSONAL INFORMATION MAY BE PROVIDED TO THIRD PARTIES?

Agents, contractors or third party service providers of Martin Hospitality may receive your Personal Information in the course of providing services to Martin Hospitality to better serve your needs as a guest. Using contractual or other arrangements, Martin Hospitality ensures these parties protect your Personal Information in a manner consistent with the principles articulated in this Privacy Policy.

• HOW LONG IS MY PERSONAL INFORMATION RETAINED?

Your Personal Information will be stored for the period of time required by law in the jurisdiction of any hotel holding the information. It may be stored indefinitely by Martin Hospitality as long as there is a business purpose for doing so. From time to time we may delete your Personal Information if you have not stayed with us in a number of years.

• HOW WILL I KNOW IF THERE ARE CHANGES TO THIS POLICY?

If we decide to make significant changes our Privacy Policy, we will post the changes on our web site ( www.martinhospitality.com), so you are always aware of how we treat Personal Information. Minor changes may be made and posted in a revised policy. Changes of use will not apply retroactively to Personal Information for which you have given explicit consent, which was acquired before the change to the Privacy Policy except as may be required by law. If at any point we decide to use Personal Information in a manner different from that stated in this Privacy Policy, we will notify you by letter or e-mail sent to your last known address. If you do not agree with the different way we intend to use Personal Information, you may ask in writing that we will not use it in that different way. If you do not object, you will be deemed to have consented to the use of your Personal Information in the changed manner.

• TO WHOM DO I DIRECT QUESTIONS OR CONCERNS REGARDING THIS POLICY?

Questions or concerns regarding this privacy policy should be emailed directly to: customersevice@martinhospitality.com.