Privacy Notice for California Residents

This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Privacy Policy, located on our Website (the “Site”), of Red Roof Inns, Inc. and its subsidiaries (collectively, “our” “us” “we” or “Red Roof”) “and applies solely to visitors, users, and others who reside in the State of California (“residents,” “consumers,” or “you”). We adopt this notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Privacy Notice.

This Privacy Notice was last updated on 12/30/19.

Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or reasonably could be linked, directly or indirectly, with a specific individual, consumer, or personal device (“Personal Information”).

As a hotel operator, it is necessary for Red Roof to collect and store Personal Information in connection with the delivery of lodging and related services. Although we endeavor to collect only that information that is relevant, we also must comply with many laws that require hotel operators to collect and retain Personal Information.

Red Roof collects Personal Information regarding its current, prospective and former guests, hotel property visitors, website visitors and other consumers travel and other business partners such as franchisees, and individuals who work for us including current, prospective and former employees, contractors and temporary and other seasonal workers based on the legal grounds and legitimate business purposes outlined in this Privacy Notice. The types of Personal Information we collect and our privacy practices depends on the nature of the relationship you have with Red Roof and the requirements of applicable law.

We have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Categories	Examples	Collected
Identifiers.	A real name, Internet Protocol address, email address, or other similar identifiers.	Yes
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
Biometric information.	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation data.	Physical location or movements.	Yes
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes
Professional or employment-related information.	Current or past job history or performance evaluations.	Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
Inferences are drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

Not included in the definition of Personal Information is information that is publicly available, information that has been de-identified or aggregated, or information exempt from the purview of the CCPA, such as:

• Protected Health Information (“PHI”) governed and protected by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data; and
• Personal Information regulated by specific industry-specific privacy laws, such as the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Use of Personal Information

Red Roof may use the Personal Information collected about you for a variety of purposes:

a. Information You Provide Directly: When Consumers, Business Partners, and Team Members contact us directly through our call center or website, enroll in one of our programs such as our franchise partner or RediRewards Loyalty program, or submit an application or other form, they may be asked to provide Personal Information such as name, email address and payment information like a credit or debit card number. We will use this information to respond to requests, manage our relationship with you, and /or communicate about our programs and our promotions.

b. Hotel Stay Information: During a hotel stay, our hotels will have access to reservation information and may collect additional information to authenticate the reservation such as a driver’s license or passport ID, or other information to manage and enhance the guest experience including vehicle information, onsite purchases, internet, media and wireless service usage and other information to support safety and security or as required by law. We may collect other related information such as demographic information, travel agent information, and information about preferences and interests (such as if you prefer a non-smoking room) and hotel-based activities (such as vehicle information or use of hotel services). If we combine other information with Personal Information, we will treat the combined information as Personal Information under this Privacy Notice.

c. Technology and Device Information: We may automatically collect information from when you use technology, including IP address, mobile device ID, and similar device identifiers, and information about how you use these services. We use this information for a variety of purposes, including to provide wireless services to guests and enhancing or otherwise improving our website.

d. Applicant and Team Member Information: If you apply to be a Red Roof affiliate or Franchise Partner or apply for a job, Red Roof or its Third-Party-service provider may ask you to provide self-identifying information (such as gender, and ethnicity and other background information). Red Roof or its Third-Party-service provider may use this information to determine your partnership or employment eligibility and share this information with government or regulatory agencies to fulfill reporting requirements or defend against related litigation and complaints.

e. Supplemental Information from Third-Parties: We may collect information about Consumers, Business Partners, and Team Members from Third-Party sources to provide the services you request or to supplement information we received.

For example, we may receive information about you from Third-Parties, including without limitation employment service providers, airlines, travel agents, and companies (for example, booking.com and expedia.com) and event planners. In addition, we may supplement the information we collect with outside records such as from your travel agent in order to provide you with information, services, or products you have requested, to tailor content, to offer you opportunities to purchase products or services that we believe may interest you, and for other purposes, including marketing demographics. We may combine the information we receive from those other sources with information we collect. In those cases, we will apply this Privacy Notice to the combined information.

f. Promotional Analytics and Similar Advertising Information: Red Roof works with network advertisers, ad agencies, social media services, analytics service providers, and other vendors to advertise our services and provide us with information regarding the effectiveness of our advertisements. These service providers may set and access their own tracking technologies (including cookies and local storage) and may otherwise collect or have access to information about you which we may use to target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share usage information about visitors with third-party advertising and social media companies, analytics providers, and other vendors for similar purposes.

g. Information Regarding Children: Due to the nature of Red Roof’s business, services and benefits are not marketed to minors. Red Roof does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). If we learn that we have collected Personal Information directly from a child under the age of 13 (and in certain jurisdictions under the age of 16), we will promptly delete that information. If you are under the age of 13 (and in certain jurisdictions under the age of 16), please do not submit any Personal Information to Red Roof. If a parent or guardian becomes aware that his or her child under the age of 13 (and in certain jurisdictions under the age of 16), has directly provided us with Personal Information without his or her consent, he or she should contact us at privacy@redroof.com, and we will delete such information from our files.

We also use the information we collect to monitor and investigate fraud, identity theft, and other illegal activity and to personalize and improve the Services.

We will not collect additional categories of personal information or use personal information for materially different, unrelated, or incompatible purposes without providing you additional notice.

Sharing of Personal Information by Red Roof Inn

We use a limited number of third parties to help us respond to your requests and provide services such as processing payments, monitoring online activity at redroof.com (“Website”), communicating with you about your stay, conducting customer satisfaction surveys; maintaining our database, taking and processing employment and business partner applications, taking and processing orders and reservations, administering emails, and administering drawings or contests. Third-Parties also provide us with aggregate and comparative information on the performance of our Website.

Other than as described below, we will not sell, trade, or rent Personal Information to non-affiliates of Red Roof.

a. We may share your Personal Information with Third-Parties to offer goods and services or ask you to sign up for promotions, our affiliate or loyalty program, or other programs that we believe may be of interest you. Our partners may also contact you to inquire about your experience as a guest in one of our hotels and the prospect of future stays or improvements needed to attract additional business. Our partners and we may also create and use aggregate information that is not personally identifiable to understand more about the common traits and interests of our Customers and Business Partners. We will ask your permission to use your location to provide accurate maps or other information on your mobile device.

b. We may also share Personal Information with our affiliates, franchisees, service providers, and third-parties, for marketing purposes and building targeted ad campaigns.

c. We may utilize one or more third-party service providers to send an email or other communications to you on our behalf, including guest satisfaction surveys. These service providers are prohibited from sharing or using your email address or other contact information for any purpose other than to send communications on our behalf.

If you make a purchase on our Website, create or modify an account (including a credit card account) or sign up for our rewards program, your name, mailing address, phone number or purchase information may be made available to our co-brand partners who may provide you with information about their products or services or the products and services of their affiliates.

d. In the event, Red Roof goes through a business transition (such as a merger, acquisition by another company, bankruptcy or sale of all or a portion of its assets, including, without limitation, during any due diligence process), your Personal Information will likely be among the assets transferred. By providing your Personal Information, you agree that we may transfer such information to the acquiring entity without your further consent.

Rights and Choices

The CCPA provides California consumers and residents with certain rights regarding their Personal Information. For requests received directly from a consumer, the following section describes your CCPA rights and explains how to exercise those rights once we verify your identity.

Right to Access and Portability

California residents have the right to request that we disclose certain information about our collection and use of Personal Information over the last twelve (12) months. A consumer may request access to certain information twice over a twelve (12) month period, with that period starting from the date Red Roof receives the first request. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will disclose to you the following:

• The categories of Personal Information we collected about you;
• Our business or commercial purpose for collecting that Personal Information;
• The categories of third parties with whom we share that Personal Information; and
• The business or commercial purpose for which we disclosed the category of Personal Information.

We will deliver a verifiable access request and the accompanying information to a California resident in a portable, easily readable electronic format.

Right to Deletion

The CCPA allows California residents the right to request that we delete any Personal Information about you that we collect and retain, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, in which we may have to gather further identifiable information in order to confirm your identity, we will delete (and in turn direct our service providers to delete, if applicable) your Personal Information from our records, unless an exception applies.

We may deny a deletion request if retaining the information is necessary to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with our business partner unless otherwise specified by the business partner;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity;
• Debug products to identify and repair errors that impair existing intended functionality;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
• Enable solely internal uses that are reasonably aligned with consumer expectations;
• Comply with a legal obligation and requests from law enforcement agencies; and
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of the Sale of Your Information

Red Roof Inn does not sell data, as it is defined in the CCPA, will not sell Personal Information in the future, and in the preceding twelve (12) months, has not disclosed nor sold any Personal Information.

Request Submissions

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by calling our toll-free number 1-844-862-5610 or sending an email to redroofccpa@redroof.com.

Verifiable Requests

A verifiable request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. These requests must:

• Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Timeframe for Responding to Requests and Format

Red Roof shall confirm receipt of a consumer’s request within ten (10) days of receipt. Red Roof will respond to the request within thirty (30) days of receipt with the time period beginning on the day we receive the request.

The period of response may be extended to forty-five (45) to ninety (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing.

Fee

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination

The CCPA prohibits a business from discriminating against California consumers for exercising the rights outlined above. We will not discriminate against you for submitting such requests by:

• Denying goods or services to you;
• Charging different prices or rates for goods or services, including through the use of discounts, benefits, or other penalties;
• Providing a different level or quality of goods or services; and
• Suggesting a different price or quality of goods or services will apply if rights are exercised.

No Financial Incentive

We do not offer any financial incentives or price or service difference in an attempt to influence a consumer’s decision whether or not to exercise a right afforded to the consumer under the CCPA.

Changes to Privacy Notice

From time to time, we may change this Privacy Notice and will notify you of material changes by posting the changed or modified Privacy Notice on our Site. Any changes will be effective immediately upon the posting of the revised Privacy Notice unless otherwise specified. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Red Roof Contact Information

If you have any questions about the Privacy Notice or our privacy practices, please contact us at:

Red Roof – Privacy

7815 Walton Parkway

New Albany, OH 43054

privacy@redroof.com.