Broadband Hospitality Privacy and Information Security Policy

This policy governs the collection, use, disclosure and management of the personal information that Broadband Hospitality (“BBH”) may collect and process about you, anytime you interact with Broadband Hospitality. This policy also explains what choices you have with respect to your information and how you can contact us in order to ask questions or provide instructions with respect to your personal information.

1. WHAT INFORMATION WE COLLECT

Information you provide – BBHNOW.COM website:

In order to participate in various online programs or services offered through our system or sites, such as demo requests, proposal requests, white paper downloads, or access to the BBH third-party payment portal, you may be asked to provide certain personal information to us such as your name, mailing address, e-mail address, and phone number. Your decision to disclose this information is entirely voluntary, and by doing so, you are providing us with specific consent to use your data for purposes stated in this policy. You can choose not to provide this information but then you might not be able to participate in some BBH services, including those available on the BBH website.

Information we collect automatically – BBHNOW.COM website:

In connection with our web-based services or operation or our website, we use common internet technologies, such as cookies, to improve the online experience of visitors to our website. A cookie is a piece of data on the user’s computer tied to information about the user. When you visit a BBH website, we recognize only your domain name and only analyze IP addresses in the aggregate for system administration purposes and to gather broad demographic data. Your browser can help you manage cookies. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. If you turn cookies off, you may not have access to certain features on the BBH website and some of the website services may not function properly.

2. WHY AND HOW YOUR INFORMATION IS USED

When you provide personal information to BBH (via the BBHNOW.COM website or otherwise), it is used to conduct business with you, respond to your requests for information, improve our products and services, and improve the content of our websites, proposals, and demonstrations. We may also use it to send you information about our products and services or to fulfill the requirements of hotel brands with which you may be affiliated. We will not sell your information to a third party without your permission. Examples of ways in which BBH may share your personal information include:

· To provide information and services that you request: For example, if you request that we contact you to schedule a demonstration or sales discussion, facilitate your attendance or participation at an BBH-sponsored event, or provide you with BBH materials, we will

use the personal information that you provide to process your request and support any related communications.

· To communicate information about our products, events and services: We may use your personal information in order to share updates on BBH products and services that may be of interest to you, where permitted by applicable law (unless you have opted out). We may also use your personal information to communicate with you pursuant to your express or implied consent.

· To improve and maintain our products and services: BBH may use the personal information that you provide to BBH to operate and improve our business. For example, BBH may use your personal information to enhance the BBH user experience, help us diagnose technical and services problems, and administer our products and services.

· To facilitate the protection of legal rights and facilitate compliance with law: BBH may use personal information, when appropriate or legally-required, to prevent, detect and/or investigate fraud, abuse, illegal use, violations of our Terms of Service, and in response to a court order, government request or applicable law.

· To support general research and analytics: BBH may use personal information to understand the behavior and preferences of our users and customers so that we can improve our services and offerings of services.

· Other purposes: BBH may use your personal information for other internal purposes and will provide specific notice at the time of collection and obtain your consent where necessary.

3. SHARING YOUR PERSONAL INFORMATION

We may share your personal information with certain entities, consistent with business purposes outlined above, as set forth below. We do not sell your personal information.

· Between members of the BBH family of companies

· To service providers that are engaged as agents of BBH for the business purposes outlined above. For example, BBH may engage third parties to compile form-based personal information, provide email services and generate website analytics.

· To third parties to the extent necessary or required to comply with a lawful order, prevent illegal use of our website or services, defend against legal claims by you or third parties, and to investigate fraud or unlawful conduct.

· To other third parties where you have provided your consent.

4. MANAGEMENT OF YOUR PERSONAL INFORMATION

· Data Protection. We use a variety of technical, physical and administrative safeguards to protect the security of personal information collected by BBH. Despite this, no website or records system is completely secure or completely protected against hackers.

· Data Retention. We retain your personal information for as long as reasonably appropriate, consistent with the purposes described in this policy, unless otherwise permitted or required by law.

· Your rights to manage your personal information. You may (depending on applicable law) have the right to (i) access your personal data; (ii) obtain an electronic copy of your personal data; (iii) correct your personal data if it is incomplete or inaccurate; or (iv) delete or restrict access to your personal information under certain circumstances (though removal may not encompass all locations of data, such as back-ups, created prior to removal). You can also opt-out of promotional or informational emails by following the unsubscribe or opt-out instructions in communications that you may receive from BBH. We will not discriminate against you on the basis of your exercise of your rights under applicable law. Any request to manage your personal information with BBH should be directed to the Privacy Officer.

5. LINKS

BBH’s websites may contain links to other sites over which BBH has no control. Please be aware that BBH is not responsible for the privacy practices of such other sites. Users need to be aware when they leave the BBH site. The user should also read the privacy statements of each website that collects personal information. This BBH Privacy Policy applies solely to information collected by BBH through its systems and websites.