INNCAL, INC. PRIVACY POLICY

INNCAL, Inc 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.

Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement on information is addressed below.

1. Notice
The purpose of this section is to notify you about the manner and the purposes for which INNCAL may collect and transfer certain personal information. This privacy policy should be read in its entirety because anyone who submits personal information to INNCAL has certain rights regarding the use, collection and transfer of such personal information.

INNCAL maintains centralized reservations systems, a worldwide accessible website, call centers and may chose at a later date to outsource database computers in the United States which are intended to help INNCAL conduct business and to facilitate the operation and maintenance of a central reservations system. The central reservations system is maintained for the benefit of INNCAL Properties as well as for INNCAL "Affiliates" which are entities which operate under different ownership. 

INNCAL 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 INNCAL properties. Direct customers, users shall hereinafter collectively be referred to as "Travelers". Personal Information about Travelers may be collected through our websites, by our call centers or may be passed on to us by INNCAL Properties, Affiliates or other third parties. Personal Information about Travelers is collected so that Travelers can make reservations at INNCAL Properties and so that INNCAL Properties can receive and have updated reservation information about Travelers who wish to stay at such INNCAL 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 INNCAL, INNCAL Properties and Affiliates as outlined above. Personal Information for Travelers will be transferred from INNCAL to INNCAL Properties and Affiliates.

INNCAL may send marketing information about INNCAL or INNCAL Properties as well as marketing information about offers or information about third party products and services Travelers based upon the Personal Information INNCAL has collected for such Travelers.

INNCAL performs certain of its administrative tasks through the use of several wholly owned subsidiaries ("INNCAL Subsidiaries") which generally operate within the same facilities as INNCAL, employ personnel who are also INNCAL employees and use the same equipment to store and process Personal Information as INNCAL. This privacy policy applies to and is adhered to by the INNCAL Subsidiaries. INNCAL may share or transfer Personal Information with INNCAL Subsidiaries while performing the tasks described in this privacy policy.

To serve you better, we may combine information you give us online, at INNCAL Properties, through the mail, or in any other way. We may also combine that information with publicly available information and information we receive from others or cross-reference. We use that combined information for the purposes described in this privacy policy.

Although unlikely, in certain instances we may disclose your personally identifiable information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to INNCAL or to others. We may also disclose your personally identifiable information when we believe the law requires it.

INNCAL takes special care to protect the safety and privacy of children. Our web sites are general audience sites. We do not encourage anyone under the age of 13 to register with us, or make hotel reservations. We also do not send email correspondence to anyone who tells us that they are under the age of 13.

Children under the age of 13 should always ask their parents or guardians for permission before providing any personal information to anyone online. We urge parents and guardians to participate in their children's online activities and use parental control or other web filtering technology to supervise children's access to the web.

Our web sites and emails may use "cookies" and other computer code processes, such as "web beacons". These are small amounts of computer code that interact with your computer, browser or email. Generally, we use cookies to remind us of who you are, tailor our services to suit your personal interests, to process your reservations or requests, track your status in our promotions, contests and sweepstakes, and/or to analyze your visiting patterns. You can generally set your browser to not accept cookies or to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it.

We may contract with third parties who may use cookies or web beacons on our websites and collect information on our behalf. These third parties are prohibited by our contracts with them from sharing that information with anyone other than us or other third parties providing services to us.

2. Choice
All Travelers, and anyone else who submits Personal Information to INNCAL 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 INNCAL Affiliates, and INNCAL Properties, please let us know through our Customer Relations Department. The contact information for the INNCAL Customer Relations Department is located at the end of this privacy policy. Within a reasonable time after receiving your request to not distribute your Personal Information to such third parties, we will cease any distribution to such third parties. Please be aware that if you choose to not have your Personal Information distributed to such third parties, then we may not be able to provide all of the available services to you or such services may not be delivered as quickly.

If you do not wish for your Personal Information to be disclosed to INNCAL Affiliates or INNCAL Properties, please let us know through our Customer Relations Department. The contact information for the INNCAL Customer Relations Department is located at the end of this privacy policy. Within a reasonable time after receiving your request to not distribute your Personal Information to INNCAL Affiliates or INNCAL Properties, we will cease any distribution of your Personal Information to any INNCAL Affiliates or INNCAL Properties. Please keep in mind that if INNCAL cannot disclose or share your Personal Information to our INNCAL Affiliates or INNCAL Properties, we may be unable to provide you with all or certain reservation services, other services or related benefits.

3. Sensitive Information
INNCAL will only collect sensitive Personal Information related to your health if you submit such type of Personal Information and such sensitive Personal Information will only be used by INNCAL in order to allow us to help you obtain special accommodations or other health related benefits at a INNCAL Property. This type of Personal Information will be submitted to INNCAL Properties and Affiliates only if necessary for us to facilitate the reservation of a room at one of the INNCAL Properties which will help meet your health needs. If you do not want us to collect and use such type of Personal Information, please do not submit such type of Personal Information to us.

4. Onward Transfer
Please note that our descriptions of our activities under the "Notice" and "Choice" principles above describe certain transfers of Personal Information that INNCAL will be making to third parties.

INNCAL wants all individuals who submit Personal Information to INNCAL to understand that anyone who submits Personal Information, by submitting such Personal Information and checking the appropriate box which indicates that such individual is consenting to the use and transfer of Personal Information in accordance with this privacy policy, authorizes certain data transfers of such Personal Information to INNCAL Properties, INNCAL Subsidiaries and/or other third parties ("Transfer Recipients") for use of such Personal Information by Transfer Recipients in accordance with the description provided in the "Notice" section. Transfer Recipients may not be in territories like the United States where an equivalent level of data protection is not granted.

5. Security
INNCAL has conducted an internal review of its data collection and processing practices and the security measures it has implemented and believes that such security measures provide reasonable precautions against the unauthorized access, disclosure, alteration or destruction of Personal Information that INNCAL collects.

INNCAL's 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 firewalls to separate user traffic from sensitive information and the use of virus protection software on INNCAL's e-mail capturing computers.

6. Data Integrity
INNCAL has conducted an internal review of its data collection and processing practices and believes that only that Personal Information is collected and processed which is required in order for INNCAL to provide services for or to fulfill its contractual obligations with Travelers, INNCAL Properties and INNCAL Affiliates. INNCAL 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 INNCAL to provide services for or to fulfill its contractual obligations with Travelers, INNCAL Properties and INNCAL Affiliates.

7. Access
INNCAL will make a good faith attempt to allow all Travelers, or others who INNCAL collects Personal Information from, to have the opportunity to view the Personal Information it has collected for such individuals, to the extent required by applicable regulations. INNCAL may make certain Personal Information available through an on-line program, website or procedure ("On-Line Procedure") for inspection by the individual associated with such Personal Information. If Personal Information is available through the On-Line Procedure devised by INNCAL, 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. At this time, INNCAL has chosen not to allow a On-Line Procedure but reserves the right to institute an On-Line Procedure at a latter date.

If INNCAL has not set up an On-Line Procedure to allow the viewing of Personal Information, then those Travelers, or others who submitted Personal Information to INNCAL for use by INNCAL can review the Personal Information collected for them by contacting the INNCAL Customer Relations department through the contact information provided below. INNCAL will make all corrections and/or deletions of erroneous Personal Information brought to its attention within a reasonable time period and as required by applicable data privacy regulations. To the extent permissible and in compliance with applicable data privacy regulations, INNCAL shall make all corrections and/or deletions of erroneous Personal Information in a manner which does not impose undue burden or expense on INNCAL.

8. Enforcement
INNCAL engages in self-assessment on a periodic basis in order to determine its continued compliance with the terms of this privacy policy. When engaging in a self-assessment review, INNCAL may engage an outside law firm to help coordinate its review of its then current data collection practices and at a minimum, at least one representative from INNCAL's finance, information services, technology services and marketing groups or divisions is involved in the self-assessment.

9. Dispute Resolution
All Travelers, or others who submit Personal Information to INNCAL and who feel that INNCAL has mishandled their Personal Information should contact INNCAL through its Customer Relations department (with such contact information provided below) with a written description of their complaint. After receiving such written description, a representative from INNCAL's Customer Relations department will contact the Disputing Party to set up a time and manner to discuss the Disputing Party's complaint. INNCAL is interested in addressing all legitimate complaints about its adherence to the privacy policies herein, and believes that a Disputing Party and INNCAL should make a good faith effort to engage in communications to work out or settle any of a Disputing Party's complaints. If these good faith efforts fail to resolve the dispute.

If INNCAL adopts an independent service for dispute resolution and procedures, it will do so only after revising its privacy policy to reflect such new procedure and by informing all Disputing Party's of such change.

10. Remedies
If it is determined by an independent dispute resolution body or procedure that INNCAL has engaged in behavior not in compliance with the requirements applicable law, INNCAL may be ordered to engage in actions necessary to reverse or correct any actions taken by INNCAL which were in violation of the law and which were harmful to the Disputing Party. INNCAL may also be required to take all actions deemed necessary for INNCAL to be in compliance with the law in the future. INNCAL's non-compliance with an applicable law may be reported to the appropriate governmental authorities if INNCAL has engaged in a pattern of persistent failure to comply such law.

11. Links to Third Party Sites
Our web sites may contain links to web sites operated and maintained by third parties, over which we have no control. Privacy policies on such linked sites may be different from our privacy policy. You access such linked sites at your own risk. You should always read the privacy policy of a linked site before disclosing any personal information on such site.

INNCAL reserves the right to modify this privacy policy at any time without prior notice. The privacy policy posted on this Web site will be the current version dated with the last revision date. Any changes will apply to all information collected by INNCAL, including previously collected information. Users are responsible to regularly review these terms and conditions. User's continued use following any such changes shall constitute acceptance of such changes.

Last updated: October 27, 2004

CONTACTING INNCAL, INC. IF YOU HAVE QUESTIONS OR COMMENTS If you have any questions or comments about the manner in which we use or share your Personal Information, please contact our customer relations department through the contact information included below. Our customer relations department will coordinate with our designated Privacy Officer or others to best address any comments, questions or requests that you may have:

INNCAL, Inc.
Customer Relations Department
Telephone: 1-800-485-4909
Fax: 209-473-0647
Email: comments@inncal.com
Regular Mail: PO Box 7272
Stockton, CA 95207
Attn: Customer Service

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