Please see our Notice at Collection below for a high-level overview of our privacy practices.

Placemakr, Inc. (together with its subsidiaries, “Placemakr,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. Placemakr offers fully furnished apartments (the “Guest Units”) in newly built apartment buildings (individually or collectively, the “Property”) on a long or short-term basis for guests (“you”) to stay. As used in this Privacy Policy, the term “you” includes any individual who makes a reservation for or rents a Guest Unit, is staying at a Property, applies for employment with Placemakr, accesses or uses a Guest Unit, our website (http://Placemakr.com), Placemakr mobile applications, various systems at our properties, in-room systems, and other mobile features that we operate (collectively, the “Site”) or the other Placemakr Services (defined below).

This Privacy Policy explains our policies and practices regarding how we collect, use, and safeguard personal and other information we collect and obtain, or that you provide through the Site or Placemakr Services and how you can contact us if you have any questions or concerns.

Please note that by making a reservation for or renting a Guest Unit, staying at a Property or accessing or using the Site, applying for employment with Placemakr and/or the various other related services, features, functions, software, applications, websites and networks provided by Placemakr (together with the Guest Units, the Property and the Site, collectively, the “Placemakr Services”), you are acknowledging the practices described in this Privacy Policy. Your stays and other interactions with us are also governed by the Terms and Conditions (as modified from time to time, the “Terms”), and the various other policies, agreements and terms and conditions that govern your making a reservation or renting a Guest Unit or your use of the Site and the other Placemakr Services.

In this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could be linked, directly or indirectly, with a particular individual or household. Personal Information does not include information that has been de-identified or otherwise made anonymous or information that has been aggregated such that it is no longer possible to identify any specific individual.

This Privacy Policy applies to Personal Information we collect or may collect from you:

• In accessing and using the Site.

• In making a reservation for a Guest Unit.

• In checking-in and staying in a Guest Unit.

• In accessing and using any other Placemakr Services.

• In e-mail, text, and other electronic messages, including SMS messages, sent through or in use of the Site and the other Placemakr Services, including the Placemakr mobile application.

• When you interact with the other users of the Site and the other Placemakr Services.

• When you send any content through the Site or any of the other Placemakr Services.

We also receive your Personal Information when you make reservations for our Guest Units through one of our booking partners that sell bookings for us (e.g., Airbnb, HotelTonight, Expedia, Booking.com, Priceline, Homeaway, Craigslist, and other booking services, collectively, “Booking Partners”) or when you make a reservation for a Guest Unit offered in partnership with or co-branded by Hilton or its affiliates through the Placemakr Services or other booking channels.

This Privacy Policy does not apply to Personal Information collected and processed by third parties, including our Booking Partners, Hilton, and payment processors, where they collect, use, and process your Personal Information under their own respective privacy policies.

Personal Information We Collect About You and How We Collect It

We collect Personal Information that you submit to us in the process of creating or editing your account and profile on the Site, through your use of the Site, or when you visit or stay as a guest at one of our Properties, purchase Placemakr Services or related services, or interact with us online or offline.

We may collect the following categories of Personal Information from and about you and other guests of the Guest Units and users of the Site and the other Placemakr Services:

• Identity and Contact Information, such as your name, e-mail address, postal address, phone number, driver’s license or passport, loyalty and membership information for Booking Partners (e.g., username and loyalty number), and information collected when we scan your ID at check-in;

• Reservation Information, such as information you provide in making a reservation for a Guest Unit, billing name and address, business title, and work contact address;

• Financial Information, such as credit card or debit card number and details of transactions you carry out through the Site or any of the other Placemakr Services. Please note that credit and debit card information is processed by our payment service providers, such as Adyen, which may handle your payment information in accordance with their own privacy policies. We do not store your full payment card information;

• Stay and Travel Information, such as information relating to your use of the Guest Unit (e.g., noise levels, food and beverage usage, and internet connection information), frequent flyer numbers, honors or rewards numbers, preferred airlines, rental car providers, and travel history;

• Device and Technical Information, such as your IP address, date and time of visit, hardware model, operating system version, unique device identifiers, browser type, language, wireless network, mobile network information (including mobile phone number);

• Communications and User Content, including usage details and information about how you communicate with other users of the Site and other Placemakr Services, records and copies of your correspondence (including e-mail addresses) if you contact us, reports of problems with a Guest Unit or the Site, reviews and testimonials that you provide, and your search queries on or through the Site or the other Placemakr Services; and

• Event Information, including, if you or your organization plans an event or meeting at one of our facilities, Personal Information related to other people attending the event or meeting, such as the guest list and Personal Information about guests at your event.

We may obtain both Personal Information and non-identifiable information about you:

• Directly from you, when you provide it to us;

• Automatically, as you navigate through or use the Site, using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with our Site, stay at a Property and use other Placemakr Services;

• From third parties, such as Hilton, Booking Partners, business partners, contractors, suppliers, and other third parties that provide us or you with certain services;

• From your use of, and interactions with, us and others on social media, including, but not limited to, Facebook and similar social media platforms.

Call recording

Certain transactions may also involve you calling us or our calling you. Please be aware that we may monitor and, in some cases record such calls for staff training or quality assurance purposes.

User Content

You may now or in the future provide pictures, text, data, information and other input or any other content linked, posted, and/or submitted by you or other users to be published or displayed on or through the Site or any of our social networking pages (e.g., Facebook, Twitter, Instagram and other similar networking pages), or transmitted to third parties or other users of or any of the other Placemakr Services (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Site or the other Placemakr Services, or our social networking pages, with whom your User Content is shared. Therefore, we cannot and do not guarantee that your User Content will not be viewed, downloaded, or shared by unauthorized persons.

How We Use Your Information

We will only use Personal Information that we collect about you or that you provide to us for the purposes described in this Privacy Policy and when applicable law allows us to do so. We use your Personal Information based on the following legal grounds:

• Where the use of your information is necessary for the performance of a contract that we are about to enter into or have entered into with you or a third party;

• Where the use is necessary for the purposes of our legitimate interests (or those of a third party);

• Where we need to comply with a legal or regulatory obligation; or

• Where you have given your consent (which can be withdrawn at any time).

We use Personal Information that we collect about you or that you provide to us for the following purposes:

• To provide, maintain, and improve the Guest Units, the Site, and other Placemakr Services, including to process and manage reservations, check-ins, guest services, technical support, and any other services and products that you request from us.

• To communicate with you, including to provide you with notices about your reservation, notify you about changes to the Guest Units, the Site, or the other Placemakr Services, solicit reviews, and allow you to participate in interactive features on or through any of the Placemakr Services.

• To market and advertise our products and services and those of our partners, including to generate leads, send promotional communications (such as information about features, surveys, newsletters, offers, and events), and to enable marketing, remarketing, targeted advertising, and similar services from us or our partners, including direct and indirect marketing and online behavioral advertising for our own or third-party products and services, and to perform targeted advertising on third-party websites; provided that you have given your consent if required by applicable law.

• To carry out our obligations and enforce our rights arising from the Terms and any other agreements entered into between you and us or between us and third parties, including for billing and collection, and to enable our service providers to perform certain responsibilities and provide certain services in connection with our business and operations.

• To protect the safety, security, and integrity of the Site and the other Placemakr Services, including to verify your identity, prevent fraud or other unauthorized or illegal activity, and to protect the rights, property, or safety of you, Placemakr, the Property, our customers, or others.

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• With your consent, to post a review or testimonial along with your name (if you want your testimonial removed, please contact us), and for any other purpose disclosed by us when you provide your Personal Information or for which you provide consent.

We may also use any information that has been anonymized or aggregated that does not directly identify you for any purpose (including to create and distribute marketing materials such as testimonials, case studies, white papers, savings calculators, and other similar purposes) to the extent not prohibited under any applicable law or regulation.

Some of the information that we collect automatically is statistical data that does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from you or third parties. Such analysis helps us improve the Guest Units, the Site, and the other Placemakr Services, and deliver a better and more personalized service, including enabling us to:

• Estimate our audience size and better understand usage patterns;

• Store information about your preferences, enabling us to customize the Site according to your individual interests;

• Speed up your searches;

• Recognize you when you return to the Site.

Disclosure of Your Information

We may share or disclose Personal Information and other information that we collect or you provide as described in this Privacy Policy, including:

• With Hilton, when you make a reservation for a Guest Unit offered in partnership with or co-branded by Hilton or its affiliates through the Placemakr Services or other booking channels. Hilton’s use of the shared Personal Information will be governed by Hilton’s own privacy policy.

• To our subsidiaries, affiliates, and the owners and/or managers of the Property.

• To our service providers, which include third-party companies, agents, and contractors to enable them to perform services in connection with our business and operations, including, some of our Booking Partners and other businesses that assist us in making reservations, bookings, texting, ID scanning, CRM, property management, cloud hosting, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you.

• To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Placemakr’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.

• To professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

• To fulfill the purpose for which you provided it, or for any other purpose disclosed by us when you provide Personal Information.

• With your consent.

We may also disclose your Personal Information and other information to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply the Terms and any other agreements between you and us, including for billing and collection purposes; or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Placemakr, the Property, our customers, or others.

Storage and Transfer of Your Information

We may store your Personal Information ourselves or in databases owned and maintained by us, our affiliates, agents, or service providers. If you access or use the Site or any of the other Placemakr Services outside of the United States, we may store your Personal Information in servers inside the United States, which may involve the transfer of your Personal Information out of countries located in the European Economic Area and other parts of the world, unless otherwise prohibited by applicable law. By allowing Placemakr to collect your Personal Information, you consent to such international data transfers.

We may also store information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.

Although users from all over the world may access the Site and the other Placemakr Services, you consent to us processing and transferring information in and to the United States and other countries whose data protection and privacy laws may offer fewer protections than those in your home country.

Choices About How We Use and Disclose Your Information

We offer you choices regarding the Personal Information you provide to us, including:

• Promotional Offers from Placemakr. If you do not wish to have your e-mail address or contact information used by Placemakr to promote our own or third parties’ products or services through marketing e-mails, you can opt out through the unsubscribe mechanism at the bottom of each email. You can also contact us at privacy@Placemakr.com or the address provided in the “Contact Information” section below to unsubscribe from such communications.

• SMS Messages. If you do not wish to receive SMS messages, you can cancel SMS services at any time. To do so, text “STOP” to our short code. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, text “UNSTOP” to our short code and we will start sending you SMS messages again.

• We do not control third parties’ collection or use of your information to serve interest-based advertising. However, there are a number of ways to limit online tracking, which we have summarized here. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

  • Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.

  • You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

  • You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TrustArc’s preference manager at http://preferences-mgr.truste.com.

  • You can also use the opt-out features offered by third-party advertising platforms, such as: LinkedIn opt-out, Google opt-out, and Facebook opt out. Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Your Choices When We Process Your Personal Information

Account choices. If you have a Placemakr account, you can review and update certain account information by logging into your account. Registered users may also contact us to request deletion of their account and certain Personal Information.

Opt out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions at the bottom of the emails or within the messages or other communications you receive from us. You may continue to receive service-related and other non-marketing emails or other communications.

Personal information requests. We also offer you choices that affect how we handle the Personal Information that we control. Depending on your location and the nature of your interactions with Placemakr Services, you may request the following in relation to Personal Information:

• Information about our collection and use of your Personal Information over the past 12 months. We have made this information available to you without having to request it by including it in this Privacy Policy.

• Access to portable copy of your Personal Information that you have submitted to us in a readily usable format. Generally, this means you may have a right to request that we provide your Personal Information in a format that allows you to transmit it to another entity without hindrance.

• Correction of your Personal Information that is inaccurate or out of date.

• Deletion of your Personal Information that we collected from you and retained, subject to certain exceptions.

• Opt-out of the sale of your Personal Information or sharing of your Personal Information for interest-based advertising. We may share Personal Information with third-party advertising partners and allow them to collect information about your use of the website to show you ads as described in this Privacy Policy. Our disclosure of information to these partners may be considered a “sale” or “sharing” of Personal Information under applicable laws. You can opt out of these disclosures and limit our use of tracking technologies as described in this Privacy Policy, or by clicking the “Do Not Sell or Share My Personal Information” link in the footer of our website. You may also have the ability to reject or toggle off optional cookies by enabling the Global Privacy Control setting within the browser that you use to access our website. Learn more at the Global Privacy Control website. Please note that your opt out in a signed-out state will be specific to the device and browser you use when you opt out.

To exercise your rights to access, correct and delete your Personal Information as described above, please submit a request to us by either:

• Calling us at +1-877-468-0946

• Via our Privacy Request Portal

• Emailing us at privacyrequests@placemakr.com

• Sending written correspondence to us at the United States mailing address listed under, “Contact Information” section of the Privacy Policy.

When it comes to fulfilling a right to access, correct, or delete your Personal Information, we may need to verify your identity. Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Our Response to Your Request

Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete Personal Information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the Placemakr Services you have requested. Where this is the case, we will inform you of specific details in response to your request.

As described further in our Cookie Notice, the technologies we use for automatic data collection may include:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand website user activity and patterns. For example, Google Analytics collects information about how users use our website, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our website. For more information on Google Analytics, click here.

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services.

Links to Other Websites

Our Site may contain links to other websites. If you choose to click on a link to an advertiser or other third-party website, you will be directed to that party’s website. We do not control third party websites which may place their own cookies or other files on your computer, collect data, solicit personal information, or follow different rules regarding the use or disclosure of the personal information. We encourage you to read the privacy policies or statements of the other websites you visit. The fact that we link to a website or present an advertisement is not an endorsement or representation of our affiliation with that party, nor an endorsement of its privacy policies.

How Long We Store Your Personal Information

We will only retain your Personal Information, in a form which permits us to identify you, for as long as necessary to fulfill the purposes for which we collected it. We will retain and use your Personal Information as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. After that, we will either securely delete or anonymize your Personal Information so that it cannot be linked back to you.

Data Security

We understand that the security of your Personal Information is important. We provide reasonable administrative, technical, and physical security controls to protect your Personal Information. However, despite our efforts, no security controls are 100% effective and Placemakr cannot ensure or warrant the security of your Personal Information. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Site.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to and use of the Site and/or the other Placemakr Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of any of the Placemakr Services because the information you share in public areas may be viewed by any other user of the Site and the other Placemakr Services.

SMS Terms Related to Employment Applications

We offer you the option to engage in SMS text conversations about your application for employment with Placemakr. By participating, you also understand that message frequency may vary depending on the status of your application for employment, and that message and data rates may apply. Please consult your carrier for further information on applicable rates and fees. Carriers are not liable for delayed or undelivered messages. Reply STOP to cancel and HELP for help.

By opting-in to receiving SMS text messages about your application for employment, you acknowledge and agree that your consent data, mobile number, and Personal Information will be collected and stored solely for the purpose of providing you with updates and information related to your application for employment with Placemakr. We are committed to protecting your privacy and shall not share or sell your consent data, mobile number, or Personal Information collected in connection with your application for employment with any third parties under any circumstances.

Minors under the Age of 21

Minors under 21 years of age may not make a reservation for a Guest Unit (although minors under 21 years of age may stay with a guest who is 21 years or older in accordance with the Terms).

No one under age 13 may provide any information on or through the Site or the other Placemakr Services. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provide any information on or through any of the Placemakr Services or any of its features on the Site. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at privacy@Placemakr.com.

Changes to Our Privacy Policy

We may post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the home pages of the Site and/or notify you of such changes by email. If we make material changes to how we treat your Personal Information or other information that are materially less protective than provided in this Privacy Policy, we will use reasonable efforts to notify you by e-mail using the e-mail address specified in your account and/or through a notice on the home page of the Site to attempt to secure your consent to the changes. The date the Privacy Policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date, active and deliverable e-mail address for you, and for periodically visiting the Site and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices or if you need to reach us for any other reason, you may contact us by e-mail at privacy@Placemakr.com or by mail at Placemakr, Inc., 1701 Rhode Island Avenue, NW, Suite 124, Washington, DC 20036, USA.

Notice at Collection

Below is a high-level snapshot of how we collect, use, and disclose your personal information. Please read the entire Privacy Policy for complete information:

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