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Effective as of June 4, 2018

WE RESPECT THE PRIVACY OF EVERY INDIVIDUAL WHO VISITS THIS WEBSITE

This Privacy Policy explains how http://www.reverbhotels.com ("Website") collects and otherwise processes personally identifiable information ("Personal Information”). Please note that this policy does not apply to Personal Information collected in our Rewards Program or Rewards App, which are governed by the policy at members.hardrock.com/privacy-policy (the “Rewards Privacy Policy”), or to Personal Information collected on our www.hardrock.com websites or apps. You may choose to submit Personal Information (such as your name, address, e-mail address, and telephone number) to us in requesting further information. We collect, use and disclose Personal Information for business purposes only unless otherwise set out herein. We will not share this information in ways different from what is disclosed in this Privacy Policy. If you have any questions about this Privacy Policy or the Website, please contact us at dataprotection@hardrock.com.

WHO IS COLLECTING YOUR INFORMATION

The Website is owned and operated by Hard Rock Cafe International (USA), Inc., 5701 Stirling Road, Davie, Florida 33314 ("Hard Rock", “we”, “us” or “our”), which is the controller for purposes of this Website.

LINKS

The Website contains links to other sites whose privacy policies may differ from those of Hard Rock, which we recommend you carefully review and consider. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our Website.

WHAT INFORMATION WE COLLECT

Personal Information from the Website is gathered in several ways: (1) indirectly, i.e., certain website information about you, such as domain name, IP address, browser type and page views, which is collected through our Website's technology; and (2) directly, when you voluntarily submit Personal Information, such as first and last names, addresses, email address(es), and phone numbers when submitting requests for information through the Website. When we collect this type of information, we will notify you as to why we are asking for information and how this information will be used.

RIGHT NOT TO PROVIDE INFORMATION

In certain jurisdictions, you may have the right not to provide Personal Information. However, if you elect not to provide such information, you may not be able to utilize certain services on the Website.

COOKIES

Some information that we collect about you is collected passively through the use of "cookies." Cookies are small files of information, which save and retrieve information about your visit to the Website — for example, how you entered and navigated our Website, and what information was of interest to you. We use this information to remember you when you return and to customize our Website to your preferences. You may set your Web browser to notify you when you receive a cookie or to not accept certain cookies. However, you may find that some parts of the Website will not function properly if cookies are refused. Please see our Cookie Settings for more information.

DO NOT TRACK SIGNALS

Currently, our systems do not recognize browser "do-not-track" requests. You may, however, disable certain tracking as discussed in the Cookies section (e.g., by disabling cookies).

THIRD PARTY ANALYTICS AND TRACKING

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Website. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties. If you wish to opt out of such tracking, please see https://tools.google.com/dlpage/gaoptout. Please note that Hard Rock does not collect, and is not aware of third parties that collect, from users of the Website Personal Information about users’ online activities across third party websites.

ACCESS, CORRECTION, DELETION AND PORTABILITY

To the extent required by applicable privacy laws in your jurisdiction, Hard Rock will permit individuals to access, correct, amend or delete their Personal Information, or obtain a copy of their Personal Information in a structured, commonly used and machine-readable format. If you request access, correction, amendment, deletion or a copy of your Personal Information and you have more than one account with us, you will need to instruct us on each account separately. Any such requests can be submitted by email to dataprotection@hardrock.com. In some cases we may need to use Personal Information obtained previously or request additional Personal Information to verify your identity.

HOW WE SHARE YOUR INFORMATION AND WHO WE SHARE IT WITH

During the course of business, we may disclose, transfer or otherwise make available Personal Information to our affiliates and third-party service providers who have been legally contracted to provide services on our behalf, and are prohibited from using it for any other purpose. Your Personal Information may be maintained and processed by our affiliates and other third party service providers in the US, Canada or other jurisdictions. In addition, we may share your Personal Information with local, state, federal and foreign governmental authorities to comply with legal, regulatory or administrative requirements, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by Canadian, US or other law. We may also disclose your Personal Information where necessary for the establishment, exercise or defense of legal claims, to investigate or prevent actual or suspected loss or harm to persons or property, or as otherwise permitted by law.

We may transfer your Personal Information as an asset in connection with the sale or transfer of all or part of the Hard Rock business (including transfers made as part of insolvency or bankruptcy proceedings) or as part of a corporate reorganization or other change in corporate control.

CHOICE/OPT-IN

Our users are given the opportunity to 'opt out’ of having their Personal Information used for purposes not directly related to the purposes for which it has been collected. Some jurisdictions may require ‘opt-in’ only, such as for marketing email communications. Users who no longer wish to receive our promotional or marketing emails may opt out of receiving these communications by clicking the unsubscribe link at the bottom of the email or contacting dataprotection@hardrock.com.

HARD ROCK THIRD-PARTY DISCLOSURE POLICY

We may, under limited circumstances, send you offers for related products or services from affiliated Hard Rock companies or jointly offered by Hard Rock together with select third parties. These offers are sent only to those users who have given their consent or not 'opted out' of receiving marketing materials from Hard Rock.

TRANSFER OF PERSONAL INFORMATION

As a global organization, data we collect may be transferred internationally throughout Hard Rock's worldwide organization and to Hard Rock’s headquarters in the United States. Some of these jurisdictions, including the United States, may not provide the same level of privacy protection as your local jurisdiction. Such transfer of information is necessary to provide the Websites and our services to you. In addition, except where prohibited by law, by submitting Personal Information through the Website, you consent to such transfers of your Personal Information. If you do not consent to such transfer, we may not be able to provide you certain services or respond to your inquiries.

EU/US PRIVACY SHIELD COMPLIANCE

Hard Rock complies with the EU/US Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member and treaty countries. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program and to view our certification page, please visit www.privacyshield.gov.

In compliance with the EU/US Privacy Shield Principles, Hard Rock commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact dataprotection@hardrock.com or
Hard Rock Cafe International (USA), Inc.
Attn: Kelly Reese
Privacy Officer
5701 Stirling Road
Davie, Florida 33314

Please include your name, address and phone number or e-mail in all communications and state clearly the nature of your request or concern.

Hard Rock Cafe International (USA), Inc. has provided a private sector independent recourse mechanism (located in the United States) to investigate and expeditiously resolve individual complaints and disputes. This dispute mechanism will cover all personal data except for human resource data. For more information, visit the website for ICDR®/AAA® EU-U.S. Privacy Shield: International Centre for Dispute Resolution®, the international division of the American Arbitration Association® (ICDR/AAA) at go.adr.org/privacyshield.html. Under certain limited conditions and as a last resort, the individual can invoke binding arbitration. The Federal Trade Commission has jurisdiction over Hard Rock’s compliance with the Privacy Shield.

If Hard Rock transfers your personal data to a third party, we will ensure the third party is contractually obligated to process your data only for limited, specific purposes consistent with this policy, to apply the same level of protection to that data as the EU-U.S. Privacy Shield Principles, and notify us if it makes a determination that it can no longer meet this obligation. Upon notice, Hard Rock will take reasonable and appropriate steps to stop and remediate unauthorized processing. In cases of onward transfer to third parties of data received pursuant to the EU-US Privacy Shield, Hard Rock is potentially liable for violations of Privacy Shield principles.

PROTECTING CHILDREN

Hard Rock Cafe takes special care to protect the safety and privacy of children. For that reason, we never collect or maintain information at our Website from those we actually know are under 13 and under 16 for residents of the European Union. The Website is general audience site.

HOW WE ENSURE THE SECURITY OF YOUR DATA

When users submit Personal Information via the Website, your information is protected both online and offline. We have implemented technical, physical and administrative measures, as well as policies and procedures designed to safeguard your privacy from unauthorized access, use, disclosure, modification or destruction and will continue to update these measures as new technology becomes available. Although we take efforts to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through the Website, or collected by the Booking Engines or independent owners and operators of the Hard Rock Hotels. Any transmission of Personal Information is at your own risk.

HOW TO CONTACT US

You may address all communications to Kelly Reese, Privacy Officer, Hard Rock Cafe International (USA), Inc., 5701 Stirling Road, Davie, Florida 33314, or e-mail dataprotection@hardrock.com. Please include your name, address and phone number or e-mail in all communications and state clearly the nature of your request.

COMPLAINTS

If you feel that Hard Rock has not complied with the policies outlined in this Privacy Policy, please contact us at dataprotection@hardrock.com, attention: Privacy Compliance. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy within fifteen (15) days of receiving the complaint, unless a shorter period is required by law.

CHANGES TO OUR PRIVACY POLICY

This Privacy Policy is effective as of June _, 2018. If we make any changes to our Privacy Policy, we will post the updated Privacy Policy, provided on an updated homepage link, and may post other places we deem appropriate. Users who have authorized e-mail communication will be notified via e-mail of any material changes to the Policy. We will only use Personal Information in accordance with the Privacy Policy under which it was collected.

YOUR CALIFORNIA PRIVACY RIGHTS / NOTICE FOR CALIFORNIA RESIDENTS

California residents who have provided Personal Information to Hard Rock may obtain information regarding Hard Rock's disclosures, if any, of Personal Information to third parties for third-party direct marketing purposes. Requests must be submitted to the following address: Hard Rock Cafe International (USA), Inc., 5701 Stirling Road, Davie, Florida 33314. Attn.: Kelly Reese, Privacy Officer. Within thirty (30) calendar days of receiving such a request, we will provide a California Privacy Disclosure, which will include a list of certain categories of Personal Information disclosed during the preceding calendar year to third parties for their direct marketing purposes, along with the names and addresses of the third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.