Studio 154 Intelity Mobile Application Privacy Policy

Effective Date: March 8, 2024

Studio 154 Luxury Hotel provides guest experience management services through mobile applications (the “Service”) owned and operated by INTELITY, Inc. (“INTELITY”, “we” or “us”). The Service includes the website located at https://www.intelity.com (the “Site”) and INTELITY mobile application(s) (“App(s)”) (collectively the “Platform”). This Privacy Policy (“Privacy Policy”) provides information on, and governs how, INTELITY/Studio 154 Luxury Hotel collects, uses, processes, and discloses the information (“Data”) we obtain from you (“Users”, “you” or “your”) in connection with your use of the Service through the Platform. INTELITY/Studio 154 Luxury Hotel understands that you care about how your Data is used and disclosed. We take your privacy seriously. This Privacy Policy also provides information on your Data access rights where applicable. INTELITY/Studio 154 Luxury Hotel may update this Privacy Policy from time to time to comply with legal and regulatory requirements or to address changes to INETLITY’s/ Studio 154 Luxury Hotel Business and Operations Services (as defined in this Privacy Policy). Changes to this Privacy Policy shall be effective upon posting and as indicated by a new effective date.

The Service may be used as part of your stay at a partner hotel, multi-unit dwelling or other location (“Accommodation(s)”) for, among other things, to check-in, check out, view a folio, create/modify your profile, make reservations, or request products and services such as concierge, valet, housekeeping or in-room dining. Your use of the Service, including, without limitation, your use of an onsite INTELITY/ Studio 154 Luxury Hotel provided in-room tablet, or by downloading the App to your mobile phone or tablet device, indicates that you have unconditionally accepted INTELITY’s/ Studio 154 Luxury Hotel’s privacy practices, as outlined in this Privacy Policy. Please read our Terms of Use which also govern your use of the Service. When you use the Service to access a reservation with, the website of, or in connection with your stay at one of our Accommodations, you will be subject to the terms and conditions and privacy policy of the applicable website you are visiting or otherwise accessing. INTELITY’s/ Studio 154 Luxury Hotel’s Privacy Policy does not apply in these instances or to these websites.

Marketing & Communications Services

Information Collected as a Data Controller

INTELITY/ Studio 154 Luxury Hotel may collect the following Data, as a Data Controller (“Data Controller”) through INTELITY’s Platform, for marketing and communications purposes (“Commercial Purposes”). This Data can be used to directly or indirectly identify you:

Your name
Your email address(es)
Your address
Your phone number
Your title
Your IP address

The level of Data collected by INTELITY/ Studio 154 Luxury Hotel varies depending upon your request. INTELITY/ Studio 154 Luxury Hotel may collect your email address only or INTELITY/ Studio 154 Luxury Hotel may collect both your name and email address. INTELITY/ Studio 154 Luxury Hotel may also collect Data that cannot be used to identify you including anonymous usage Data and Platform Data for analytical purposes. For information on INTELITY’s anonymous usage data please see the Anonymous Data section of this Privacy Policy. INTELITY/ Studio 154 Luxury Hotel may disclose your Data to its affiliated companies (“Affiliated Companies”). Where you have given us permission to do so, INTELITY/ Studio 154 Luxury Hotel may disclose your Data to advertisers and business partners that are not affiliated with INTELITY/ Studio 154 Luxury Hotel but would like to send you information about their products and services. You may visit the business partners’ websites to view their opt-out offerings and practices. Your Data will be maintained and stored by INTELITY/Studio 154 Luxury Hotel provided you consent to INTELITY/Studio 154 Luxury Hotel processing your Data for business purposes, including where you request an INTELITY demo, subscribe to the INTELITY blog, and/or subscribe to marketing and communications emails (“Marketing and Communications Services”). You may unsubscribe from the Marketing and Communications Services emails at any time. Where you have the right to request access to your Data, in accordance with applicable data protection laws (“Data Protection Laws”), and where you request deletion of your Data, INTELITY/Studio 154 Luxury Hotel will delete your Data unless otherwise prohibited by law or regulation. Your Data may be transferred outside your country of residence and if so, it will be transferred using a valid transfer mechanism; providing an adequate level of protection to any Data transferred. Your Data will be subject to the privacy and security rules and regulations of the Data hosting country and which laws, and regulations may not be as strict as your country of residence. INTELITY/Studio 154 Luxury Hotel will implement appropriate systems’ security measures designed to help ensure the confidentiality and security of Data and protect against anticipated threats and unauthorized access to Data. For additional information on INTELITY’s security practices please see the Data Security section of this Privacy Policy.

User Access Rights

Under applicable Data Protection Laws, you may have the right to request access to your Data where your Data is controlled by INTELITY/Studio 154 Luxury Hotel as the Data Controller. You may have the right to request that your Data controlled by INTELITY/Studio 154 Luxury Hotel be corrected. You may have the right to request that your Data controlled by INTELITY be deleted from INTELITY’s/Studio 154 Luxury Hotel systems. This process is also referred to as the ‘right to be forgotten’. INTELITY/Studio 154 Luxury Hotel will comply with this request except where INTELITY/Studio 154 Luxury Hotel is required by law or regulation to keep your Data. In such circumstances INTELITY/Studio 154 Luxury Hotel will advise you as to this legal or regulatory obligation. Where INTELITY/Studio 154 Luxury Hotel relies on your consent, to process your Data controlled by INTELITY/Studio 154 Luxury Hotel, you may have the right to withdraw such consent to further use of your Data. In certain circumstances, you may have the right to object to INTELITY/Studio 154 Luxury Hotel processing your Data. For example, you may unsubscribe from marketing messages or blogs to which you consented and subscribed by following the unsubscribe link or instructions contained in such messages or blogs. In certain circumstances, you may have the right to request that INTELITY/Studio 154 Luxury Hotel transfer Data that you have provided to us to a third-party. You may have the right to file a complaint with the local Data Protection Regulator if you believe that INTELITY/Studio 154 Luxury Hotel has breached Data Protection Laws when using your Data. You may request access to Data collected and controlled by INTELITY/Studio 154 Luxury Hotel by sending an email to privacy@intelity.com.

Business and Operations Services

Information Processed as a Data Processor

INTELITY/Studio 154 Luxury Hotel processes Data in accordance with its business operations and in providing business services (“Business and Operations Services”). Certain Data disclosed to INTELITY/Studio 154 Luxury Hotel is based on a contractual agreement for Business and Operations Services between INTELITY and certain third parties providing Accommodations (“Studio 154 Luxury Hotel”). Under this arrangement, /Studio 154 Luxury Hotel is the data collector and INTELITY is the Data Processor (“Data Processor”); and Data is processed by INTELITY, through the Platform, in order to perform the Business and Operations Services. Examples of Data a Partner Accommodation may control and disclose with INTELITY to process include:

Your name

Your email address

Your phone number

Your scheduled arrival and departure date

Your IP address

Your profile picture and other Data shared through your registration for the Service via a Social Networking Site (“SNS”)

If you are required to submit your ID when using the app’s Mobile Check-In feature to check-in to the hotel, the app may collect images you choose to submit, such as your identification card.

This Data is held on INTELITY’s systems but is not controlled by INTELITY. This Data is controlled by the Studio 154 Luxury Hotel, the originator of the Data, and in accordance with the contract and terms and conditions as set forth between you and the Studio 154 Luxury Hotel. Data that originates from the Studio 154 Luxury Hotel is stored, and controlled, by the Studio 154 Luxury Hotel on the /Studio 154 Luxury Hotel’s systems and environments. Studio 154 Luxury Hotel may disclose your Data to other third parties (“Third Parties”). INTELITY is not responsible for the maintenance or security of Data stored and controlled by such Partner Accommodation or Third Parties. INTELITY will implement appropriate systems’ security measures designed to help ensure the confidentiality and security of Data held by INTELITY/Studio 154 Luxury Hotel and protect against anticipated threats and unauthorized access to Data. For additional information on INTELITY’s security practices please see the Data Security section of this Privacy Policy. For questions regarding access to Data controlled by Studio 154 Luxury Hotel Partner Accommodations, please contact the Studio 154 Luxury Hotel directly. Any requests for Data controlled by a Partner Accommodation, and received by INTELITY, will be forwarded to the Studio 154 Luxury Hotel.

Under the provision of Business and Operations Services your Data, where you consent, may be shared with an Affiliated Company. The Affiliated Company will provide us with the Data needed to provide you with the Service requested. Such Affiliated Company may also provide your mobile communications provider with the information it needs to bill you for the content and services you purchased (only if the mobile communications provider is providing billing services). Where you have given us permission to do so, INTELITY/Studio 154 Luxury Hotel may disclose your Data to advertisers and business partners that are not affiliated with INTELITY/Studio 154 Luxury Hotel but would like to send you information about their products and services. You may visit the business partners’ websites to view their opt-out offerings and practices.

Business and Operations Services Exception

INTELITY/Studio 154 Luxury Hotel may retain your Data for the following Business and Operations Services:

In order to process paperwork in connection with a Service,
As part of the business operations in servicing your account,
To share with an Affiliated Company that is providing services on behalf of INTELITY,
To improve the products and services currently offered or that may be offered in the future by INTELITY, and
To comply with legal or regulatory inquiries; or responding to court orders.

You may not opt out of the use of your Data for Business and Operations Services.

Commercial Purposes

INTELITY/Studio 154 Luxury Hotel may collect Data from you for the following Commercial Purposes:

For marketing and sales purposes in offering INTELITY’s/Studio 154 Luxury Hotel’s products and services;
For third parties with whom INTELITY has contracted for Service.

You may opt-out of the sharing of your Data for Commercial Purposes.

Cookies and Web Beacons

“Cookies” are small text files that can be used by INTELITY/Studio 154 Luxury Hotel to make your experience more efficient. Cookies used on an INTELITY Platform are related to managing your identity and personalization; and can help INTELITY remember information about your visit. Certain Cookies can make your next visit more efficient and useful to you. The law provides that INTELITY may store Cookies on your device if such Cookies are strictly necessary for the operation of INTELITY’s Platform. For all other types of Cookies INTELITY needs your consent. INTELITY obtains this consent when you access INTELITY’s Platform and where INTELITY provides you with an opportunity to opt-out of Cookies. You may exercise your Cookies preference by clicking on the appropriate opt-out links provided. INTELITY uses Cookies as outlined below.

Necessary Cookies

Necessary Cookies help make INTELITY’s Platform usable by enabling basic functions like page navigation and access to secure areas of the Platform. INTELITY’s Platforms cannot function properly without these necessary Cookies. INTELITY uses the following necessary Cookies on its Platform:

Cookies to store the user’s cookie consent state for the current domain.
Cookies used by the content network, Cloudflare, to identify trusted web traffic.

Preference Cookies

Preference Cookies enable a website to remember information that changes the way the website looks.

Statistic Cookies

Statistical Cookies assist INTELITY in understanding how users interact on digital platforms by collecting and reporting information anonymously. INTELITY uses Google Tag Manager and Google Analytics to:

Collect data on the number of times a user has visited its sites as well as dates for the first and most recent visit.
Register a timestamp with the exact time of when the user leaves a site.
Calculate the duration of a site visit.
Throttle the speed of request to the server.
Collect data on where the user came from, what search engine was used, what link was clicked and what search term was used.

Marketing Cookies

Marketing Cookies are used to track users across INTELITY’s/Studio 154 Luxury Hotel’s Platform. The intention is to display content or ads that are relevant and engaging for the user and thereby more valuable for publishers and third-party advertisers. INTELITY uses marketing Cookies from the following sources:

Google Tag Manager
Google Analytics
HubSpot

These marketing Cookies are used to: Collect anonymous statistical data related to the user’s visits, such as the number of visits, average time spent visiting a website, and what pages have been loaded. These marketing Cookies are also used to send data to the marketing platform HubSpot. HubSpot has the ability to look at user device information and behavior.

Anonymous Data

INTELITY/Studio 154 Luxury Hotel may share your non-personally identifiable information and click stream data with vendors that help us customize the advertising and marketing messages you receive as part of the Service. Anonymous click stream and demographic information may also be shared with Partner Accommodations, INTELITY advertisers and business partners. We may disclose non-identifying, aggregated User statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third-parties. Examples of such non-personal information include the number of Users who visited the Platform during a specific time period or purchased a specific product through the Platform.

How to Remove Cookie Tracking

You have a choice whether to accept Cookies, however, if you reject Cookies or if Cookies are disabled on your web browser, some parts of INTELITY’s Platform may not be operable. You can exercise your Cookie preferences by clicking on the appropriate opt-out links provided. You can also manage Cookie settings from within your browser. For your convenience information from the browsers on how to manage Cookies from your desktop is provided below:

Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
Internet Explorer: https://support.microsoft.com/en-us/kb/278835
Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop
Safari: https://support.apple.com/kb/PH19214?locale=en_US

And if you want to manage cookies from your mobile device:

Apple: https://support.apple.com/en-gb/HT201265
Android: https://support.google.com/chrome/answer/95647?hl=en-GB
Blackberry: http://supportforums.blackberry.com/t5/Web-and-WebWorks-Development/How-to-Enable-browser-cookies-for-a-blackberry-browser/td-p/211133
Windows Phone: http://www.windowsphone.com/en-GB/how-to/wp7/web/changing-privacy-and-other-browser-settings

For additional information and/or specific questions related to INTELITY’s Cookies policy please contact privacy@intelity.com.

Legal Use

INTELITY may disclose Data in order to protect the legal rights of INTELITY, its affiliates or their employees, agents, and contractors; to protect the safety and security of visitors to our Platform; to protect the rights, property, or safety of INTELITY; or when legally required to do so, at the request of governmental authorities conducting an investigation, or to verify or enforce compliance with the policies governing the Service and applicable laws. When you ask INTELITY to stop using your Data, INTELITY will honor your request, but we will retain any record of your Data as necessary to comply with applicable federal, state, or local law.

Sale or Transfer

If INTELITY sells all or part of its business, makes a sale or transfer of assets or is otherwise involved in a merger, business transfer or other fundamental corporate change INTELITY reserves the right to disclose, share and/or otherwise transfer User information, including without limitation, Data to a third-party as part of such transaction.

Promotions

If you choose to participate in an INTELITY promotion, your Data may be disclosed to third-parties in connection with such promotion, including without limitation for purposes of posting your entry with attribution or otherwise as permitted in the official rules for the promotion in question, fulfilling your prize or including your name on a winners list. Also, by entering a promotion, we may require you to consent to the use of your Data, such as name, voice, or likeness, in advertising, promotional and marketing materials. In addition, we may offer certain promotional content sponsored by or co-branded with a third-party, who may obtain the Data that you submit.

Data Security

INTELITY holds the confidentiality, integrity, and availability of your Data in the highest regard. We use various security measures to protect Data that we collect, and we have implemented security measures as part of INTELITY’s program to protect Data it controls. All Data stored in the INTELITY Platform is encrypted. INTELITY conducts background checks on employees, utilizes web application firewalls, employs secure coding practices based on industry best practices, and performs vulnerability scans and application penetration tests on its environment as part of its risk management process. Unfortunately, no security measures are perfect or impenetrable and data transmission over the Internet cannot be guaranteed to be 100% secure. We cannot and do not ensure or warrant the security of any information you transmit to INTELITY, and you do so at your own risk.

Notification of Changes

INTELITY/Studio 154 Luxury Hotel reserves the right to change this Privacy Policy from time to time, and such changes will be effective immediately upon posting to the Site. INTELITY/Studio 154 Luxury Hotel may also elect to notify you of changes or updates to the Privacy Policy, or to request your consent for such changes, by additional means, such as posting a notice on the front of INTELITY’s Site, and/or by sending you an e-mail.

Special Notice Regarding Minors

INTELITY/Studio 154 Luxury Hotel respects the privacy of children of all ages and in particular recognizes the sensitivity of Data concerning children under the age of 13 (“Minors”) and therefore provides this special notice to parents and legal guardians regarding the collection and use of Data collected from Minors. The Service is not directed toward Minors. If you are over the age of 13 but under the age of 18, you should use the Service only with the involvement of a parent or legal guardian and should not submit any Data to INTELITY/Studio 154 Luxury Hotel. If we discover that a Minor has provided us with Data, INTELITY/Studio 154 Luxury Hotel will use commercially reasonable efforts to delete such Minor’s Data from its system.

Contact Information

If you have questions regarding INTELITY’s Privacy Policy, you may contact INTELITY via email at: privacy@intelity.com. Or you may write to us at:

INTELITY, Inc.
16501 Ventura Blvd., Suite 400
Encino, CA 91436

Notice to California Residents

If you are a California resident, under the California Consumer Privacy Act (“CCPA”) you have additional rights related to your Data.

Right to Know. You have the right to know and see what Data INTELITY has collected about you over the preceding 12 months, including:

The categories of Data INTELITY has collected about you;
The categories of sources from which Data is collected;
The Business and Operations Services purposes for collecting your Data;
The Commercial Purposes for collecting your Data;
The categories of third parties with whom INTELITY has shared your Data; and
The specific pieces of Data INTELITY has collected about you.

Right to Access/Data Portability. You have the right to access and obtain a copy of the specific pieces of Data INTELITY has collected about you over the preceding 12 months, upon verification of your identity.

Right to Correct. You have the right to request inaccurate Data INTELITY collected and maintains about you be corrected.

Right to Delete. You have the right to request that INTELITY delete the Data we have collected from you and direct our partners to do the same. Deletion of your Data is not absolute, however. There are exceptions under which INTELITY may retain your Data and where INTELITY is not required to delete your Data.

Exercising Your California Data Privacy Rights

To request access to or deletion of your Data, or to exercise any other Data rights under CCPA, you may contact INTELITY using any of the following methods:

Authenticate and exercise your Data privacy rights, click here and click on “Data Questions for CA, VA, CO, & CT Residents.”
Contact us via our toll free dedicated Data Privacy line: (888) 401-1354.

Response Timing and Format. INTELITY will respond to a CA consumer request for access or deletion (“Request”) within 45 days of receiving a Request. If INTELITY requires more time, we will inform you of the reason and extension period in writing. You have the right to direct us not to sell or share Data INTELITY collected about you to our partners. You have the right to limit the use and disclosure of your Sensitive Data INTELITY has collected about you.

To opt out of the potential sale or sharing of your Data or to limit the use and disclosure of your Sensitive Data, click here and then click on “DO NOT SELL OR SHARE MY PERSONAL INFORMATION/LIMIT THE USE AND DISCLOSURE OF MY SENSITIVE INFORMATION”.

Notice to Virginia Residents

If you are a Virginia resident, under the Virginia Consumer Data Protection Act (“VACDPA”) you have additional rights related to your Data.

Right to Know. You have the right to know and see what Data INTELITY has collected about you, including:

The categories of Data INTELITY has collected about you;
The categories of sources from which Data is collected;
The Business and Operations Services purposes for collecting your Data;
The Commercial Purposes for collecting your Data;
The categories of third parties with whom INTELITY has shared your Data; and
The specific pieces of Data INTELITY has collected about you.

Right to Access/Data Portability. You have the right to access and obtain a copy of the specific pieces of Data INTELITY has collected about you, upon verification of your identity.

Right to Correct. You have the right to request inaccurate Data INTELITY collected and maintains about you be corrected.

Right to Appeal. If INTELITY is unable to comply with all or a portion of your request, INTELITY will explain the reasons why. You may appeal the decision by resubmitting a request and INTELITY will inform you of any action taken or not taken in response to the request and explain the reasons for the decision within 60 days of receiving the request.

Right to Opt-Out of Targeted Advertising, Sale or Sharing of Data.

You have the right to direct INTELITY not to: (i) process your Data for the purposes of targeted advertising; (ii) sell or share Data INTELITY has collected about you to and with our partners. You have the right to limit the use and disclosure of Sensitive Data INTELITY has collected about you.

Exercising Your Virginia Data Privacy Rights

To request access to or deletion of your Data, or to exercise any other Data rights under VACDPA, you may contact INTELITY using any of the following methods:

Authenticate and exercise your Data privacy rights, click here and click on “Data Questions for CA/VA Residents.”
Contact us via our toll free dedicated Data Privacy line: (888) 401-1354.

Response Timing and Format. INTELITY will respond to a VA consumer request for access or deletion (“Request”) within 45 days of receiving a Request. If INTELITY requires more time, we will inform you of the reason and extension period in writing.

Notice to Colorado Residents

If you are a Colorado resident, the Colorado Privacy Act (“CPA”) you have additional rights related to your Data.

Right to Know. You have the right to know and see what Data INTELITY has collected about you, including:

The categories of Data INTELITY has collected about you;
The categories of sources from which Data is collected;
The Business and Operations Services purposes for collecting your Data;
The categories of third parties to whom INTELITY has disclosed your Data; and
If INTELITY sold or disclosed your Data for Business and Operations Services purposes.

Right to Access/Data Portability. You have the right to access and obtain a copy of the specific pieces of Data INTELITY has collected about you, upon verification of your identity.

Right to Correct. You have the right to request inaccurate Data INTELITY collected and maintains about you be corrected.

Right to Opt-Out of Targeted Advertising, Sale or Sharing of Data.

Exercising Your Colorado Data Privacy Rights

To request access to or deletion of your Data, or to exercise any other Data rights under CPA, you may contact INTELITY using any of the following methods:

Authenticate and exercise your Data privacy rights, click here and click on “Data Questions for CA, VA, CO, & CT Residents.”
Contact us via our toll free dedicated Data Privacy line: (888) 401-1354.

Response Timing and Format. INTELITY will respond to a CO consumer request for access or deletion (“Request”) within 45 days of receiving a Request. If INTELITY requires more time, we will inform you of the reason and extension period in writing.

Notice to Connecticut Residents

If you are a Connecticut Resident, An Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”) grants you additional rights related to your Data.

Right to Know. You have the right to know and see what Data INTELITY has collected about you, including:

The categories of Data INTELITY has collected about you;
The categories of sources from which Data is collected;
The Business and Operations Services purposes for collecting your Data;
The categories of third parties to whom INTELITY has disclosed your Data; and
If INTELITY sold or disclosed your Data for Business and Operations Services purposes.

Right to Access/Data Portability. You have the right to access and obtain a copy of the specific pieces of Data INTELITY has collected about you, upon verification of your identity.

Right to Correct. You have the right to request inaccurate Data INTELITY collected and maintains about you be corrected.

Right to Opt-Out of Targeted Advertising, Sale or Sharing of Data.

Exercising Your Connecticut Data Privacy Rights

To request access to or deletion of your Data, or to exercise any other Data rights under CTDPA, you may contact INTELITY using any of the following methods:

Authenticate and exercise your Data privacy rights, click here and click on “Data Questions for CA, VA, CO, & CT Residents.”
Contact us via our toll free dedicated Data Privacy line: (888) 401-1354.

Response Timing and Format. INTELITY will respond to a CT consumer request for access or deletion (“Request”) within 45 days of receiving a Request. If INTELITY requires more time, we will inform you of the reason and extension period in writing.