CALIFORNIA CONSUMER PRIVACY RIGHTS SUPPLEMENT


I. Introduction and summary of rights.

This notice for California Residents (“California Supplement”) supplements the information contained in our online general Privacy Policy available here and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. If there is any discrepancy between the California Supplement and the Privacy Policy, the California Supplement shall control for visitors, users, and others who reside in the State of California. Under the CCPA, California residents have certain rights around HHG’s (as defined in our general Privacy Policy) collection, use, and sharing of their personal information. HHG does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.

HHG collects various categories of personal information, as identified in the general Privacy Policy. These categories included identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow HHG to retain and use certain personal information notwithstanding your deletion request.

You can learn more about how to submit a data rights request by contacting privacy@hawaiianhostgroup.com. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at privacy@hawaiianhostgroup.com.

II. Detailed information regarding California Consumer’s rights.

HHG is committed to respecting the privacy of the personal data of the individuals with whom we interact. This notice explains the steps we take to protect personal data that we collect, including on our websites or related communication channels. We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

In most instances, you can visit HHG pages without providing any personal information. However, on some pages, we may ask you for personal data to provide a service or carry out a transaction you request. The personal information that we collect or may have collected from our consumers within the last twelve (12) months includes:

  • Contact details, such as your name, title, company/organization name, email address, telephone and fax numbers, and physical address
  • Billing and payment information such as billing addresses, credit card information, and bank account information, when you order goods and services from us.
  • Information about your company and job position, when you apply for a job with us.
  • Your preferences with respect to email marketing
  • Commercial information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or preferences
  • Your inquiries about and orders for our products and services, as well as information that assists us in identifying the best products and services for you
  • Feedback from you about our products and services, including our websites
  • Any other information that you choose to provide by:
  • participation in any contest, sweepstakes, survey, or other promotional event;
  • using the “contact us” pages;
  • applying for a position with HHG; or
  • corresponding with a representative of HHG

You are not required to provide this information. However, if you choose not to, we may not be able to provide you the requested service or complete your transaction.

III. Data collected by automated means.

We collect certain data about all visitors to our websites, including what pages they view, the number of bytes transferred, the links they click, and other actions taken within our websites. On websites to which you log on, we may connect this information with your identity to determine your potential interests in our products and services. We may also use this information to improve our security measures. We also collect certain standard information that your browser sends to every website you visit, such as your Internet Protocol (IP) address, your browser type and capabilities and language, your operating system, the date and time you access the site, and the website from which you linked to our site. Additional information about data collected by automated means is found in our general Privacy Policy.

IV. Children under the age of 13.

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us by calling us at (808) 848-0500 or sending an email to privacy@hawaiianhostgroup.com.

V. Use of personal data.

Services and transactions. We use personal data to deliver services or execute transactions you request, such as providing information about HHG products and services, processing orders, answering customer service requests, facilitating use of our websites, and so forth. In order to offer you a more consistent experience in interacting with HHG, information collected by our HHG pages may be combined with information we collect by other means.

Website improvement. We may use data about you to improve our websites (including our security measures) and related products or services, or to make our websites easier to use by eliminating the need for you to repeatedly enter the same information, or by customizing our websites to your particular preference or interests.

Employment Applications. In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background, résumé or curriculum vitae, references, disability status, veteran status, and other information, including your ethnicity where required or permitted by law. We may contact the third party references you provide in your job application or inquiry. We may use the information provided by you or the third-party references throughout HHG, its subsidiaries and affiliates, and its joint ventures for the purpose of employment consideration. We will keep the information for future consideration unless you direct us not to do so.

VI. Data sharing.

WE DO NOT SELL PERSONAL INFORMATION: We do not sell, rent or otherwise disclose the personal data that we collect for monetary or other valuable consideration. We may disclose personal information that we collect, or you provide as described in our general Privacy Policy and this notice:.

  • To the HHG companies, its subsidiaries, affiliates, agents, and business partners.
  • To contractors, suppliers, service providers, consultants, contractors, licensors, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of HHG (or subsidiary) assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by HHG about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

Please be advised, however, that we reserve the right to disclose any personal information about you without your prior consent if we have a good faith belief that such disclosure is necessary, including:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of HHG our customers, or others.

We may collect, use or disclose your personal data without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

VII. Use of cookies.

Cookies are small files that websites save to your hard disk or to your browser’s memory for recordkeeping and other legitimate business purposes. Our websites may use them to track the number of times you have visited the website, to track the number of visitors to the website, to determine and analyze visitors’ use of our websites, to store data that you provide (such as your preferences), and to store technical information related to your interactions with our websites. We may also use session cookies, which are deleted when you close your browser, to store your user ID, to facilitate your movement around our websites, and other information useful in administering the session. Additional information about use of cookies is found in our general Privacy Policy.

VIII. Security.

HHG is committed to protecting the security of personal data. While no security measure can guarantee against compromise, we use a variety of security technologies and procedures to help protect data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer systems with limited access that are located in facilities to which access is limited. When you move around a site to which you have logged in, or from one site to another that uses the same login mechanism, we verify your identity by means of an encrypted cookie placed on your machine. When you place an order with us, view account information, or provide financial information, we protect the transmission of such data using Secure Socket Layer (SSL) encryption.

IX. Access to specific information.

You have the right to request that HHG disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:.

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained. Please note that we will not sell your personal information.

You may have the right to request that HHG delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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 you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

X. Verifiable consumer requests.

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by one of the following methods:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. .

The verifiable consumer request must:.

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

    We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.
    .

    We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

    XI. Response timing.

    We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days, for a total of 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. We will deliver our written response by mail or electronically, at your option.

    Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. .

    We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

    XII. Non-discrimination.

    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:.

    • Deny you goods or services.
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
    • Provide you a different level or quality of goods or services.
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

    However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

    XIII. California’s ‘Shine the Light” law.

    Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. HHG does not share your personal information with third parties for their direct marketing purposes and will obtain your opt-in consent for any such disclosure to affiliates or other third parties for their direct marketing purposes.

    XIV. Changes to notice.

    HHG reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you of any material changes by posting the updated notice on the Website, and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. .