Privacy Policy

Last Updated: July 16, 2020

Pro Hospitality Group (together with its affiliates, “PHG,” “we,” “us,” or “our”) takes seriously the confidentiality of your personal information, which is information that can be used to identify, locate, or contact you. This Privacy Policy describes the information collected by PHG (such information, “Collected Information”) through this website (https://www.phgproperties.com/) and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services"). This Privacy Policy explains how that information is collected, used, and shared, your rights and choices regarding your personal information, how we communicate changes to this Privacy Policy, and how you may contact us regarding questions or issues with respect to anything contained in this Privacy Policy.

By accessing or using the Site or by accepting our Terms of Use, you (“you”) agree that you have read and understand this Privacy Policy. This Privacy Policy is incorporated into and made a part of our Terms of Use. We may modify this Privacy Policy at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. 

What Information do we collect?

The information that we may collect from or about you broadly falls into the following categories:

·        Information that you voluntarily provide to us, for example, your contact information.

·        Information that we automatically collect through your use of the Site, for example, data collected by servers, cookies, and analytics and advertising services.

personal information you disclose to us.

In Short:  We collect personal information that you voluntarily provide to us.

We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

· Contact Information. You can visit and use the Site without voluntarily sharing your personal information with us, but you must provide your contact information to use certain features of the Site.

· Information We Collect When You Opt In to Marketing Communications. If you sign up or otherwise opt in to receive marketing communications from us, you may need to submit your name, phone number, mailing address, and email address. We may use this information to provide you with marketing communications, such as offers, updates and other physical and electronic communications. You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions contained in the applicable email or by contacting us at info@phgproperties.com. We may use third-party providers to deliver marketing communications to you.

· Business Inquiries. If you fill out an inquiry form on the Site with respect to opportunities with PHG, you will need to submit various information, including your name, your business name, phone number, and email address. You may also provide other information. 

information we collect through your use of the site.

In Short:   Some information — such as IP address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

· IP Addresses and Related Data. When you use the Site, we may automatically collect certain information from your device. In some countries, including countries in the European Economic Area (“EEA”), this information may be considered personal information under applicable data protection laws. Specifically, the servers used to operate and provide the Site may collect data pertaining to you and the equipment, software, and communication methods you use to access the internet and the Site, including internet protocol (“IP”) addresses assigned to the computers and other devices from where you access the internet, your internet service provider (ISP), your device ID number, your approximate geographic location, your browser type, the pages you access on the Site, the websites you access before and after visiting the Site, the length of time you spend on the Site, date and time stamps, and clickstream data. PHG may use this information to administer the Site and its servers, to generate statistical information, to monitor and analyze Site traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, and to improve the Site’s content and the products, services, materials, and other content that we describe or make available through the Site (see also how we use Google Analytics as described below). We may combine this information with other Collected Information (including personal information) and information obtained from third parties for security reasons and to protect our rights or the rights of others as discussed below. The suppliers that we use to provide the Site may collect information about your visits to the Site and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained further below under “Cookies.”

· Location. We may use Google Maps API(s). Pursuant to the Google Maps APIs Terms of Service, use of this location feature is also subject to Google’s Privacy Policy. For information on how Google categorizes location information, please visit Types of location data used by Google. Both the Google Terms of Service and Google’s Privacy Policy are incorporated into this Privacy Policy by this reference.

· Cookies. The Site automatically uses cookies to track your use of the Site to facilitate and enhance the user experience on the Site and for other purposes as described below. “Cookies” are small pieces of information that are stored on your device’s hard drive by your browser. The Site may use both cookies that we implement and cookies implemented by our suppliers and other third parties. We use cookies to track how you access and use the Site, to learn when and how users visit the Site, to learn how popular Site pages are and aren’t, to learn which search terms are used to find the Site, and to learn which websites direct you to the Site. We also use cookies to help display certain information on the Site and to improve your enjoyment of the Site, for example, by remembering your contact and other information when you access or use the Site. Most browsers automatically accept cookies. You can disable this function but disabling cookies may impact your use and enjoyment of the Site. Our Site suppliers may use cookies and other tracking technologies, such as pixel tags, to track Site visitors across the internet to understand how you get to the Site. We do not have access or control over these cookies and this Privacy Policy does not cover the use of third-party cookies. Due to this automatic collection of data using cookies, we do not honor “do not track” requests.

Our use of cookies falls into the following categories:

o   Operationally necessary. These are cookies that are required for the operation of the Site. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of the Site to make use of its functions.

o   Functionality related. These cookies allow us to offer you enhanced functionality when accessing or using the Site. This may include to remembering choices you make, for example and as applicable, remembering your username, preferences, or settings, remembering if you reacted to something on or through the Site so that you are not asked to do it again, remembering if you have used any feature of the Site before, restricting the number of times you are shown a particular advertisement, remembering your location, and enabling social media components. As described above, you may disable functional cookies, but if you do so then various functions of the Site may be unavailable to you or may not work the way you want them to.

o   Performance related. These cookies assess the performance of the Site, including as part of our analytic practices to help us understand how visitors use and interact with the Site, for example, which pages users visit most often. These cookies also enable us to personalize content and remember your preferences. These cookies help us improve the way our Site works and provide a better, personalized user experience. Some of our performance-related cookies are managed for us by third parties.

o Advertising or targeted related. These cookies record your visits to the Site, the pages you have visited, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a particular website. PHG and its third-party advertising platforms or networks may use this information to make the Site, its content, and advertisements displayed on our websites more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed below). These types of cookies are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns.

· Analytics; Google Analytics Solutions. The Site uses third-party analytics tools (e.g., Google Analytics), to collect and process data (including personal information) about your use of the Site, including when you visit the Site, URLs of the websites that you visit prior to visiting the Site and when you visit those websites, and IP addresses assigned to the devices from where you access the internet. Our analytics providers set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Site’s structure and content. For more information on how Google uses this data, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners' sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent PHG from using other analytics tools and will not prevent data from being sent to the Site itself or to Google. For more information about how Google Analytics uses cookies to measure user interactions on websites, visit Google Analytics Cookie Usage on Websites. You may disable cookies as discussed above, but that may impact your use and enjoyment of the Site.

· From time to time, we may enable and implement various Google Analytics solutions, such as Remarketing with Google Analytics, Demographics and Interest Reporting, Segments, Campaign Manager, and Display & Video 360. Remarketing with Analytics uses Google Analytics cookies to show you advertisements across the internet based on your visits to the Site. Demographics and Interest Reporting uses a third-party cookie to collect information about our Site traffic by tracking users across websites and across time. Segments isolates and analyzes subsets of Site users by sorting our Google Analytics data. Campaign Manager and Display & Video 360 allow us to view, analyze, and create remarketing lists using our Campaign data. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

· Advertising Networks, Personalized Advertising, Remarketing, and Retargeting. The Site may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including advertising retargeting services provided by Facebook (sometimes referred to the Facebook “tracking pixel”) and Google Ads. These services collect information about your visits to and interactions with the Site and other websites and will use that information to target advertisements for goods and services. The information collected may be associated with your personal information. These targeted advertisements may appear on the Site or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of internet browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Site and other websites, the location of your internet service provider, the date and time of a visit to a website, and other interactions between you and a website.

· We may use Google Ads to serve ads on our behalf across the internet and on the Site. Google uses your internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect anonymous information about your visits to the Site and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the internet. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

· To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

· Social Media. PHG is active on social media, including Facebook, Instagram, Twitter and LinkedIn. You have the opportunity to comment on those social media platforms regarding PHG and the products and services we offer. PHG reserves the rights to post on its websites and social media pages any comments or content that you post on our social media pages. PHG will be held harmless and without liability for the results of any and all third party reposts to any and all other locations, including the direct or assumed meaning regarding content from all social media websites.

· Embedded Content. The Site may incorporate content, including feeds scripts embedded in the Site’s code and visible content (for example, videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content. For example, YouTube may collect or otherwise have access to usage data on videos embedded on the Site as described in YouTube’s Privacy Policy.

How do we use your information?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

· To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).

· Deliver targeted advertising to you. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

· To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

· To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

· To respond to user inquiries /offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

will your information be shAred with anyone?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

  • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

  • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

More specifically, we may need to process your data or share your personal information in the following situations:

  • Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

Do we use google maps?

In Short:  Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link. By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.

how long do we keep your information?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than 2 years past the start of idle period of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

how do we keep your information safe?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

Do we collect information from minors?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at info@phgproperties.com.

what are your privacy rights?

In Short:  You may review, change, or terminate your account at any time.

Your Rights and Choices Regarding Your Personal Information

You have the following data protection rights:

· If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by contacting us.

· In addition, if you are a resident of the European Union, you can object to the processing of your personal information, you can ask us to restrict processing of your personal information, and you can request portability of your personal information. You can exercise these rights by contacting us.

· You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt out” link in the marketing emails we send you. To opt out of other forms of marketing, such as postal marketing or telemarketing, if applicable, then please contact us.

· Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

· If you are a resident of France, you may provide us with instructions regarding the manner in which we may continue to store, erase, and share your information after your death, and, where applicable, the person you have designated to exercise these rights after your death.

· You have the right to complain to a data protection authority about our collection and use of your personal information. For more information please contact your local data protection authority.

· For details on how to manage your preferences for cookies and tracking technologies within your web browser, please read the information provided above under “Cookies.”

· We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list.

data breach

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when Pro Hospitality Group, LLC. believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Pro Hospitality Group, LLC. becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information Pro Hospitality Group, LLC. will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

do california residents have specific privacy rights?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.

third-party websites

The Site may link to, or be linked to, websites not maintained or controlled by PHG. PHG is not responsible for the privacy policies or practices of any third-parties or any third-party websites. This Privacy Policy does not apply to any third-party websites or to any personal or other information that you may provide to third-parties. You should read the privacy policy for each website that you visit.

questions? contact us.

If you have questions or comments about this policy, you may email us at info@phgproperties.com or by mail to: 300 West Clarendon Avenue, Suite 325, Phoenix, AZ 85013.