Interim CCPA Privacy Notice Effective January 1, 2020 A new privacy law that provides California consumers certain rights regarding their personal information became effective on January 1, 2020. However, as of that date the California Attorney General had not completed the rule making process to establish the regulations for businesses to implement the law. Accordingly, we are delaying our full implementation of the law until we have definitive guidance from final regulations, and it will take some time following the date the regulations are final to implement them. In the meantime, we are providing you with notice of the personal information we collect and our purposes for that collection. In addition, if you are a California consumer and would like to register a request under your “right to know about personal information collected, disclosed or sold” (including right to obtain copies of specific pieces and/or information about categories of personal information practices), “right to request deletion of personal information” or “right to opt-out of the sale of personal information,” you can contact us at ccpa@sagehospitality.com and we will respond to your request as and when we have guidance on how to properly verify you and respond to your requests and are able to do so; however, be advised that these rights do not apply to personal information collected from (a) job applicants, current and former employees and independent contractors (“HR Data Subjects”), or (b) representatives of another business in connection with business communications or transactions (“B-to-B Data Subjects”). HR Data Subjects who are also California residents may learn more about our data collection practices by contacting their human resources department. We appreciate your patience. We collect personal information (PI) from California consumers (but excluding B-to-B Data Subjects, who are not entitled to this notice) for the following purposes:
| Category of PI | Examples | Purposes |
| 1. Identifiers | This may include but is not limited to: name, postal address, Internet Protocol (IP) address, email address | This may include but is not limited to: managing interactions and transactions, performing services and operations and providing benefits, processing interactions, data security. |
| 2. Personal Records | This may include but is not limited to: name, postal address, telephone number | This may include but is not limited to: managing interactions and transactions, performing services and operations and providing benefits, processing interactions, data security. |
| 3. Personal Characteristics and Traits | This may include but is not limited to: age | This may include but is not limited to: managing interactions and transactions |
| 4. Commercial Information | This may include but is not limited to: products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies | This may include but is not limited to: managing interactions and transactions, performing services and operations and providing benefits, processing interactions, data security. |
| 5. Biometric Information | N/A | N/A |
| 6. Internet Usage Information | This may include but is not limited to: browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement | This may include but is not limited to: managing interactions and transactions, performing services and operations and providing benefits, processing interactions, data security. |
| 7. Geolocation Data | This may include but is not limited to: physical location | This may include but is not limited to: managing interactions and transactions, processing interactions |
| 8. Sensory Data | N/A | N/A |
| 9. Professional or Employment Information | N/A | N/A |
| 10. Non-public Education Records | N/A | N/A |
| 11. Inferences from PI Collected | This may include but is not limited to: inferences regarding a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes | This may include but is not limited to: managing interactions and transactions, data security |
We will revise this CCPA Privacy Notice from time-to-time as the law becomes more clear and we are able to provide you with better information on your CCPA rights and how to exercise them.
For additional information on our data practices, including cookies on our web site(s), see our privacy policy available at sagehospitalitygroup.com/priva
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