TRAVELOHOTEL LTD. - PRIVACY POLICY TRAVELOHOTEL LTD. ("THL") is committed to taking measures to respect and protect your privacy. This privacy policy sets forth the measures we take with regard to how we use, protect and allow others to view your personal information. Our privacy policy addresses six privacy principles: Notice, Choice, Security, Data Integrity, Access and Enforcement. Further information about how we address these privacy principles is provided below. 1. Notice The purpose of this section is to notify you about the manner in and the purposes for which THL may collect and transfer certain personal information. This privacy policy should be read in its entirety because anyone who submits personal information to THL has certain rights regarding the use, collection and transfer of such personal information. THL maintains centralized reservations systems, a worldwide accessible website and database computers in the United States as well as in other locations around the world which are intended to help THL conduct business and to facilitate the operation and maintenance of a central reservations systems. THL Properties and Affiliates are independent entities not owned or controlled by THL and may or may not be located in European Union member countries or countries whose privacy protection laws have been deemed "adequate" pursuant to the EU Privacy Directive. THL may collect certain personal information from and about individuals which can be identified with such specific individual, including without limitation, contact and payment information ("Personal Information") about customers who wish to stay or make reservations at THL member properties ("Travelers"). Personal Information about Travelers may be collected through our websites or may be passed on to us by THL Properties, Affiliates or other third parties. Personal Information about Travelers is collected so that Travelers can make reservations at THL Properties and so that THL Properties can receive and have updated reservation information about Travelers who wish to stay at such THL Properties. Some of a Traveler's Personal Information (such as a credit card number) may be stored to facilitate the making of future reservations by such Traveler. Only that Personal Information which is reasonably required to facilitate travel reservations is collected and shared between THL, THL Properties and Affiliates as outlined above. Personal Information for Travelers will be transferred from THL to THL Properties and Affiliates. THL may collect Personal Information from Travelers who are also members of the reward programs ("Reward Customers") so that THL can perform certain administrative tasks necessary for the administration and operation of the Rewards program such as the following: (1) allow Reward Customers to earn rewards, points or credit ("Reward Points") for staying at various THL Properties; (2) allow other THL Properties and Affiliates to be aware of the Reward Points earned by Reward Customers so that such THL Properties or Affiliates can redeem Reward Points; (3) allow THL Properties and Affiliates to receive and share Personal Information for Reward Customers as necessary in order for such THL Properties and/or Affiliates to satisfy contractual obligations among and between various THL Properties and/or Affiliates. Reward Customers' Personal Information may be collected through our various websites or may be passed on to us by THL Properties, Affiliates or other third parties. THL may transfer Personal Information to THL Properties and Affiliates as a part of THL administering the reward programs as outlined above. THL distributes Personal Information about Reward Customers to third parties for the purpose of having such third parties compile information about the type and frequency of use of the reward programs by such Reward Customers as well as to allow such third parties to conduct data processing for THL and to engage in communications on behalf of THL with Reward Customers. THL may also distribute Personal Information to airline companies upon request of the Reward Customer, in order to allow a Reward Customer to earn frequent customer points with such airline companies. THL performs certain of its administrative tasks through the use of several wholly owned subsidiaries ("THL Subsidiaries") which generally operate within the same facilities as THL, employ personnel who are also THL employees and use the same equipment to store and process Personal Information as THL. THL Subsidiaries employ data protection practices which are no less protective than those employed by THL. THL may share or transfer Personal Information with THL Subsidiaries while performing the tasks described in this privacy policy. 2. Choice All Travelers, Reward Customers and anyone else who submits Personal Information to THL may choose to not have any of their Personal Information submitted or transferred to third parties in accordance with the terms of this privacy policy. Please see below for further details. If you do not wish for your Personal Information to be disclosed to any third parties, besides THL Affiliates, THL Properties and THL Subsidiaries, please let us know. 3. Security THL has conducted an internal review of its data collection and processing practices and the security measures it has implemented and believe that such security measures provide reasonable precautions against the unauthorized access, disclosure, alteration or destruction of Personal Information that THL collects. THL's Systems Architecture group has also conducted an internal review of its computer network and its data protection measures and believes that it has implemented a reasonable level of technology and software to protect against the loss of Personal Information. Such measures include without limitation, the following: the use of several firewalls to separate user network traffic from server network traffic; the use by THL web applications of SSL encryption whenever sensitive information is being accessed; the use of the Secure File Transfer Protocol (SFTP) when exchanging data with third parties so that files, usernames and passwords are encrypted; the use of intrusion detection software at eleven different points in the internal THL network and the use of virus protection software on THL's e-mail servers and client computers. 4. Data Integrity THL has conducted an internal review of its data collection and processing practices and believe that only that Personal Information is collected and processed which is required in order for THL to provide services for or to fulfill its contractual obligations with Travelers, Reward Customers, THL Properties and THL Affiliates. THL will be implementing a periodic review of its data collection and processing practices to ensure that it only collects or processes Personal Information which is required in order for THL to provide services for or to fulfill its contractual obligations with Travelers, Reward Customers, THL Properties and THL Affiliates. 5. Access THL will make a good faith attempt to allow all Travelers, GCCI Customers or others who THL collects Personal Information from, to have the opportunity to view the Personal Information it has collected for such individuals. THL may make certain Personal Information available through an on-line program and website for inspection by the individual associated with such Personal Information. If Personal Information is available through the On-Line Procedure devised by THL, the Personal Information can only be reviewed through such On-Line Procedure. The On-Line Procedure will also contain information about how to request any corrections or deletions of any erroneous Personal Information. Information about the availability of On-Line Procedures for viewing certain types of Personal Information is generally available at the website or on the printed materials where such type of Personal Information was first submitted. THL will make all corrections and/or deletions of erroneous Personal Information brought to its attention within a reasonable time period but THL must make all corrections and/or deletions of erroneous Personal Information in a manner which does not impose undue burden or expense on THL. Further, THL may not necessarily allow access to review Personal Information collected for an individual for any Personal Information which THL reasonably determines to either not be sensitive for the individuals involved or is not used in a manner which will not significantly affect the individual involved if providing such review privileges would cause undue burden or expense on THL. 6. Enforcement THL engages in self-assessment on a periodic basis in order to determine its continued compliance with the requirements of this privacy policy. TRAVELOHOTEL LTD. Customer Relations Department EUROPE Email: [ TraveloHotel Worldwide ] Attn: Customer Service