GRANDLIFE^®[1]

California Privacy Policy

Effective Date: March 2, 2020

This California Privacy Policy supplements the information contained in our Privacy Policy.

 We are committed to protecting the privacy of data that is collected about you.  This California Privacy Policy (“Policy”) applies solely to individuals, visitors, users, and others who are residents of the State of California (“consumers” or “you”) and describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information you submit or we obtain when you stay with us or when you access Grandlife website or websites, apps, or other online media under our operation and control (collectively, the “Site”), as well as certain other personal information relating to you.  This California Privacy Policy is adopted to comply with the California Consumer Privacy Act (“CCPA”).  Any terms defined within the CCPA have the same meaning when utilizing within this California Privacy Policy.  Please read this carefully.

Changes to this Policy and Terms. We reserve the right to change this California Privacy Policy at any time. Changes will be effective immediately upon posting to the Site and will apply to your use of the Site and Grandlife’s practices concerning personal information after the “Effective Date” listed above.  We will include a notice on our website homepage at the time of any such change.

Information We Collect. We collect personal information in a variety of categories to carry out our business, operate the Site, comply with the law, and other purposes described in the CCPA.

This notice describes the categories of personal information (“PI”) we collect, or have collected, in the preceding 12 months and the purposes for which such PI may be used.

Grandlife may add to the categories of PI it collects and the purposes for which it uses PI. In that case, Grandlife will inform you by updating this policy.

The above categories of PI are collected for the following business or commercial purposes: to operate, manage, and maintain our business, to provide our products and services, for vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

 The above categories of PI are shared with the following categories of third parties:

(i) service providers we engage to help us run our business, such as reservation service providers, marketing service providers and event planners (ii) website analytics providers, such as Google Analytics, and (iii) affiliates.

In the preceding 12 months, we disclosed the following Personal Information to third parties (such as our service providers) for our operational business purposes:

1. Identifiers, such as name, nationality, passport, visa or other government-issued identification data, and online identifiers;
2. Personal information, such as name, contact information, employment, employment history, and financial information;
3. Characteristics of protected classifications under California or federal law, such as gender, age, medical conditions, primary language, national origin, citizenship, and marital status;
4. Commercial information, such as transaction information, purchase history, financial details, payment methods, and membership or loyalty program data;
5. Internet or network activity information, such as browsing history and interactions with our and other websites and computer systems;
6. Geolocation data, such as device location and IP location;
7. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities;
8. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

California Consumer Rights. Pursuant to the CCPA, and as detailed below, California residents have various rights with respect to their PI.

• Right to Request Deletion. You have the right to request that Grandlife delete your PI from Grandlife’s records and direct any service providers to delete your PI from their records, subject to certain exceptions.

 Upon receipt of a verifiable consumer request, Grandlife will delete and direct any service providers to delete your PI from its records.   However, Grandlife is not required to comply with your request to delete your PI if it is necessary for Grandlife (or its service providers) to maintain your PI in order to:

• Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of Grandlife’s ongoing business relationship with you, or otherwise perform a contract between Grandlife and you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when Grandlife’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Grandlife.
• Comply with a legal obligation.
• Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.

• Right to Request Information. You have the right to request that Grandlife disclose the following to you as it relates to the 12-month period preceding Grandlife’s receipt of your verifiable consumer request: 
• The categories of PI Grandlife has collected about you.
• The categories of sources from which the PI is collected.
• The business or commercial purpose for collecting or selling PI.
• The categories of third parties with whom Grandlife shares PI.
• The specific pieces of PI Grandlife has collected about you.

Upon receipt of a verifiable consumer request, Grandlife will provide a response to your request for information.

PLEASE NOTE:   Grandlife does not sell your PI to third parties.

California defines a “sale” as “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.”

• Nondiscrimination. We will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.

Manage your personal information. To submit any of the Consumer Rights requests as outlined above, please contact us using this form by calling toll-free:  1-800-218-9316.  We will respond to your request consistent with applicable law.

We reserve the right to only respond to verifiable consumer requests.  A verifiable consumer request is one made by any individual who is:

• the consumer who is the subject of the request,
• a consumer on behalf of the consumer’s minor child, or
• by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.

If Grandlife requests, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a Consumer. Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond.  PI collected from an individual to determine whether a request is a verifiable consumer request may not be used for any other purpose. We will endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt, but we may require up to ninety (90) days to respond, under which circumstances we will notify you of the need for an extension.

[1]GrandLife^® is a co-marketing brand for the Soho Grand Hotel and The Roxy Hotel New York.  GrandLife^® is a registered trademark of Hartz Hotel Services, Inc., the management company for Soho Grand Hotel, Inc. and Tribeca Grand Hotel, Inc. (dba The Roxy Hotel New York).