Privacy Policy

Effective Date: March 3, 2023

Effective Date: March 3, 2023
This Policy was last updated: March 3, 2023

This Privacy Policy ("Policy") describes how The Hay-Adams Hotel ("Hay-Adams") collects, uses, and discloses your Personal Information when you visit our website (the "Site") or otherwise interact with any of our features or services that reference this Policy (collectively, the "Services"). This Policy also explains how you can exercise certain rights you may have in connection with your privacy and personal information.

Your use of our Services, and any dispute over privacy, is subject to this Policy.

Scope of this Privacy Policy

This Privacy Policy applies to personal data collected through our "Services," which include:

Offline services you use when you visit the Hay-Adams or make reservations with us offline;
Digital services which include but are not limited to:
www.hayadams.com websites, subdomains, or mobile versions that link to or post this Privacy Policy
On-premise or web-enabled technologies, such as Hotel Wi-Fi or CCTV surveillance
If you are within or are a resident of a member nation of the EUROPEAN ECONOMIC AREA (the "EEA," which includes the 27 European Union Member States, Iceland, Lichtenstein and Norway), Switzerland or the United Kingdom ("UK") (collectively, the "EU"), these Services apply to you.

Modifications

Hay-Adams reserves the right to make changes to this Policy at any time. Since this Policy may change as we modify or expand our Services, we suggest that you check back from time to time in order to understand how we treat your information. Our Policy’s effective date will always be set forth at the beginning and end of the Policy. Any changes will be immediately incorporated into this Policy and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.

Any change to this Policy is effective immediately. Your continued use of the Services after any changes are made to this Policy constitutes your acceptance of the changes. If any changes are unacceptable to you, you should cease all use of the Services.

Accessibility Statement

Hay-Adams is committed to making its website, https://www.hayadams.com, usable by all people, including those with disabilities. We are constantly in the process of making upgrades to achieve this goal.

Our Commitment to Help

We are dedicated to meeting your accessibility needs. Should you have specific questions or concerns about the accessibility of this site or need assistance in using the processes found within this site, we have individuals here at Hay-Adams to assist you.

Please contact us directly at privacy@hayadams.com. We would be happy to assist in making your visits to our site as convenient as possible.

Third Party Applications

While you are visiting our site, you will notice that we make use of third-party sites. Though individuals may have challenges with access to these sites, Hay-Adams does not control or remedy the way content is portrayed.

Personal Information We Collect, Use and Share

Personal information is generally defined as information that, by itself or in combination with other information, identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device, or household ("Personal Information"). Personal Information can include, but is not limited to, your name, address, telephone number, email address, username and password, IP address or other online identifiers, browsing or search history, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, demographic information, consumer preferences, biometric information such as fingerprints, precise location information, or any other type of information that, directly or indirectly, can be linked to or is reasonably capable of being associated with you.

When using the Services, we may collect, use, and share the following categories of Personal Information from you in the following ways:

Categories of Personal Information we collect

· Contact information such as your home address, zip/postal code, email address, and phone number.

We may collect this Personal Information when you…

Submit the Contact Us web form.
Submit the Reserve Now web form.
Submit a job application.
Submit your email address to the Stay Connected web form.
Submit the Leaders Club web form.
Submit a Request for Proposal form.
Enter a Promotion or Sweepstakes.
Send us an email.
Any other correspondence provided or made available to Hay-Adams.
Visit the site.
Use our Services which involve our affiliates, business partners, and vendors.
We may collect information about you from third parties.
Make an online reservation through our third-party booking engine.

We collect this Personal Information so that we may…

Operate our business. We use Personal Information to allow you to use our Services, and otherwise run our day-to-day operations such as register you as a hotel member or plan and purchase hotel accommodations.
For other operational purposes. If we intend to use your Personal Information for any additional purpose not specified in this Policy, we will notify you (and, if necessary, obtain your consent) before using your Personal Information in this way.
Communicate with you. We may use Personal Information to communicate with you about our Services, and to respond to your inquiries, including if you contact us with a question or concern.
Enter a promotion or sweepstakes. We may enter your email in our promotion or sweepstakes.
Provide marketing and advertising. We may use Personal Information to contact you with surveys and information regarding our Services and those of our affiliates that we believe may be of interest to you. This may include commercial emails sent on behalf of ourselves, our affiliates, and our advertisers.
Comply with legal requirements. We may use Personal Information to comply with lawful court orders, law enforcement requests, or other legal requirements.
Use for security purposes. We may use Personal Information to mitigate fraud and protect Hay-Adams.

Categories of Personal Information we collect

· Identity information such as name, age, gender, passport information or data from government-issued identity cards, or from your accounts created on our websites.

We may collect this Personal Information when you…

· Submit a job application.

· Use our Services which involve our affiliates, business partners, and vendors.

· We may collect information about you from third parties.

· Make an online reservation through our third-party booking engine.

· Any other correspondence provided or made available to Hay-Adams.

We collect this Personal Information so that we may…

· For other operational purposes. If we intend to use your Personal Information for any additional purpose not specified in this Policy, we will notify you (and, if necessary, obtain your consent) before using your Personal Information in this way.

· Communicate with you. We may use Personal Information to communicate with you about our Services, and to respond to your inquiries, including if you contact us with a question or concern.

· Provide marketing and advertising. We may use Personal Information to contact you with surveys and information regarding our Services and those of our affiliates that we believe may be of interest to you. This may include commercial emails sent on behalf of ourselves, our affiliates, and our advertisers.

· Comply with legal requirements. We may use Personal Information to comply with lawful court orders, law enforcement requests, or other legal requirements.

· Use for security purposes. We may use Personal Information to mitigate fraud and protect Hay-Adams.

Categories of Personal Information we collect
Correspondence information when you contact us, such as to send an enquiry or make a request, or any personal information you include in free text boxes.

We may collect this Personal Information when you…

· Submit the Contact Us web form.

· Submit the Reserve Now web form.

· Submit a job application.

· Submit the Leaders Club web form.

· Submit a Request for Proposal form.

· Send us an email.

· Any other correspondence provided or made available to Hay-Adams.

· Use our Services which involve our affiliates, business partners, and vendors.
We may collect information about you from third parties.

· Make an online reservation through our third-party booking engine.

We collect this Personal Information so that we may…

· Operate our business. We use Personal Information to allow you to use our Services, and otherwise run our day-to-day operations such as register you as a hotel member or plan and purchase hotel accommodations.
For other operational purposes. If we intend to use your Personal Information for any additional purpose not specified in this Policy, we will notify you (and, if necessary, obtain your consent) before using your Personal Information in this way.

· Communicate with you. We may use Personal Information to communicate with you about our Services, and to respond to your inquiries, including if you contact us with a question or concern.

· Evaluate and improve our services. We may use the Personal Information we collect to evaluate and improve our Services and to measure, improve, and understand the effectiveness of our Services and its features. We may also use this information to develop new Service offerings.

Categories of Personal Information we collect

· Financial and payment information such as your credit card details, itemized spending, billing address, and transaction history.

We may collect this Personal Information when you…

· Submit the Reserve Now web form.

· Any other correspondence provided or made available to Hay-Adams.

· Use our Services which involve our affiliates, business partners, and vendors.

· Make an online reservation through our third-party booking engine.

We collect this Personal Information so that we may…

Categories of Personal Information we collect

· Reservation information such as the type and location of the rooms you reserve and the dates of your reservations.

We may collect this Personal Information when you…

· Submit the Reserve Now web form.

· Use our Services which involve our affiliates, business partners, and vendors.
We may collect information about you from third parties.

· Make an online reservation through our third-party booking engine.

We collect this Personal Information so that we may…

· We use Personal Information to allow you to use our Services, and otherwise run our day-to-day operations such as register you as a hotel member or plan and purchase hotel accommodations.

· Communicate with you. We may use Personal Information to communicate with you about our Services, and to respond to your inquiries, including if you contact us with a question or concern.

Categories of Personal Information we collect
Preference information such as special requests, service issues, preferred floor, type of newspapers/magazines, cultural interests, food and beverages preferences and other preferences for your stay.

We may collect this Personal Information when you…

· Submit the Contact Us web form.

· Submit the Reserve Now web form.

· Send us an email.

· Any other correspondence provided or made available to Hay-Adams.

· Use our Services which involve our affiliates, business partners, and vendors.

· We may collect information about you from third parties

· Make an online reservation through our third-party booking engine.

We collect this Personal Information so that we may…

· Communicate with you. We may use Personal Information to communicate with you about our Services, and to respond to your inquiries, including if you contact us with a question or concern.

Categories of Personal Information we collect

· Employment application information when you submit an application such as the name of your current company, LinkedIn profile URL, proof of U.S. employment eligibility, age if 18 or older, names of relatives who may have worked for Hay-Adams or Hay-Adams’ affiliate, minimum salary requirement, current address, current employment status, weekly availability, gender, race, veteran status, disability status, educational institutions, work history, references, and any additional information you may provide in a resume or cover letter.

We may collect this Personal Information when you…

· Submit a job application.

· Send us an email.

· Any other correspondence provided or made available to Hay-Adams.

· Use our Services which involve our affiliates, business partners, and vendors.

· We may collect information about you from third parties.

We collect this Personal Information so that we may…

· Communicate with you. We may use Personal Information to communicate with you about our Services, and to respond to your inquiries, including if you contact us with a question or concern.

Categories of Personal Information we collect
Technical information such as information about the device you use to interact with us such as a unique device identifier, hardware model, IP address, geolocation, operating system and version, and mobile network information.

We may collect this Personal Information when you…

· Visit the site.

· Connect to our WIFI.

· We may collect information about you from third parties.

We collect this Personal Information so that we may…

· Comply with legal requirements. We may use Personal Information to comply with lawful court orders, law enforcement requests, or other legal requirements.

· Use for security purposes. We may use Personal Information to mitigate fraud and protect Hay-Adams.

Categories of Personal Information we collect

· “Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by Hay-Adams itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit the site or when you view an advertisement we have placed on another Web site.

We may collect this Personal Information when you…

· Visit the site.

· We may collect information about you from third parties.

· We collect this Personal Information so that we may…

Categories of Personal Information we collect
Engagement data such as information related to how you interact with the Services and advertisements, such as referring and exit web pages and URLs, browsing history, and other similar information.

We may collect this Personal Information when you…

· Visit the site.

· We may collect information about you from third parties.

We collect this Personal Information so that we may…

Categories of Personal Information we collect
Third-party information such as Personal Information about you collected through our affiliates, business partners, and vendors who provide services on our behalf.

We may collect this Personal Information when you…

· Use our Services which involve our affiliates, business partners, and vendors.
We may collect information about you from third parties.

· Make an online reservation through our third-party booking engine.

We collect this Personal Information so that we may…

· Communicate with you. We may use Personal Information to communicate with you about our Services, and to respond to your inquiries, including if you contact us with a question or concern.

·Enter a promotion or sweepstakes. We may enter your email in our promotion or sweepstakes.

· Comply with legal requirements. We may use Personal Information to comply with lawful court orders, law enforcement requests, or other legal requirements.

·Use for security purposes. We may use Personal Information to mitigate fraud and protect Hay-Adams.

· Use for administrative purposes. To assess the usage, value and performance of our online products and services; to improve your experience with the site; and as otherwise permitted by applicable law or regulation.
Categories of Personal Information we collect
Images such as closed-circuit television security systems and images captured while at an event or during your stay.

We may collect this Personal Information when you…

· Visit the hotel.

We collect this Personal Information so that we may…

· Comply with legal requirements. We may use Personal Information to comply with lawful court orders, law enforcement requests, or other legal requirements.
Use for security purposes. We may use Personal Information to mitigate fraud and protect Hay-Adams.

Types of Third Parties

· This information may be processed by us, or on our behalf by other entities, solely in accordance with our instructions.

· We disclose information we collect from you to service providers, consultants, auditors, attorneys, vendors, contractors, or agents who perform functions on our behalf. This includes entities that host our Site, perform research and development, and assist us in performing analytics on our Site.

· We disclose the information we collect from you to our affiliates or subsidiaries.

· We may disclose your information to others when it is necessary to provide the Services you requested.

· If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our shares or assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and advisors, including attorneys and consultants.

· We disclose Personal Information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

· We disclose Personal Information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Policy, or as evidence in litigation in which we are involved.

· We may disclose Personal Information for a new use or purpose not described in this Policy. If there is a "material change" to the purpose or categories of Personal Information collected or shared, we will notify you beforehand or at the time of disclosure and provide you with the choice of legally applicable opt-in or opt-out consent.

Our Use of Cookies
Cookies are small text files that may be placed on your Web browser when you visit our Sites, or when you view advertisements that we have placed on other Web sites. Cookies allow your browser to remember some specific information which the Web server can later retrieve and use. When you quit your browser, some cookies are stored in your computer's memory, while some expire or disappear.

Cookies are used primarily for administrative purposes, to improve your experience with our Web sites. Examples of this would include the use of cookies:

· To improve site security by "authenticating" you (i.e., verify that you are who you say you are) when you sign into our Sites.

· To keep track of your specified preferences such as language, time zone and timeouts after periods of inactivity.

· To allow you to navigate our Sites more easily by "remembering" your identity so that you do not have to input your password multiple times as you move between pages or services.

We use Cookies for the following purposes:

· Website Operation. Cookies help us run our websites securely and enable basic functions like page navigation.

· Performance and Analytics. Cookies help us analyze how you interact with our Sites. These Cookies enable us to monitor and improve website performance, Services, and your experience.

· Personalization. For example, your language preference is remembered.

· Advertising. We can display advertising content depending on location, language, and your past browsing history.

If you wish to prevent Cookies from tracking your activity, or visits across multiple websites, you can set your browser to block certain Cookies or notify you when a Cookie is set. If you block Cookies, certain features and Services may not work. For more information on how you can customize your browser's Cookie setting, please visit the link to your web browser below:

· Google Chrome

· Safari

· Microsoft Edge

· Mozilla Firefox

We are not responsible for the completeness, effectiveness, or accuracy of any third-party opt-out options or programs.

Do Not Track
Some website browsers offer a "Do-Not-Track" setting or extension you can activate to signal your preference not to have data about your online browsing activities monitored and collected. Currently, our Site and Services do not recognize "Do-Not-Track" requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

Information Regarding Children
The Services are intended for individuals 18 years of age and older. Our Services are not directed at, marketed to, nor intended for, children under 18 years of age. Hay-Adams does not knowingly collect, use, or sell any information, including Personal Information, directly from children under 18 years of age.

If Hay-Adams learns that it has collected any information regarding a person younger than 18 years of age without consent, Hay-Adams will delete or destroy the information immediately.

If there is concern that information regarding a person younger than 18 years of age was somehow collected by Hay-Adams, any minor, or the parent(s) or legal guardian(s) of such minor, who wishes to request the removal of the minor's information should submit their request by using the contact details provided in the "Contact Us" section below.

Your European Economic Area (EEA) Privacy Rights
Economic Area (EEA) residents should be aware that you may be entitled under applicable data protection laws to the following rights with regard to Hay-Adams' collection, use and sharing of your Personal Information:

· Right to object to certain data processing: To the extent that Hay-Adams is relying upon the legal basis of legitimate interest to process your personal data, then you have the right to object to such processing, and Hay-Adams must stop such processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where Hay-Adams needs to process the data for the establishment, exercise or defense of legal claims. Where Hay-Adams relies upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

· Information and access: You have the right to be provided with certain information about Hay-Adams' processing of your personal data and access to that data (subject to exceptions).

· Rectification: If your personal data changes, we encourage you to inform us of the change. You have the right to require inaccurate or incomplete personal data to be updated or corrected.

· Erasure: You have the right to require that your data be erased in certain circumstances, including where it is no longer necessary for us to process this data in relation to the purposes for which we collected or processed the data, or if we processed this data on the basis of your consent and you have since withdrawn this consent.

· Data portability: Where we process your personal data on the basis of your consent, or where such processing is necessary for entering into or performing our obligations under a contract with you, you may have the right to have the data transferred to you or another controller in a structured, commonly used and machine-readable format, where this is technically feasible.

· Right to restriction of processing: You have the right to restrict Hay-Adams processing of your personal data while your request for data rectification or objection to personal data processing is being considered, if we no longer need to process your data but you need that data in connection with a legal claim, or if our processing is unlawful but you do not want us to erase the data. If this right applies, we will continue to store your data but will only further process it with your consent, for the establishment, exercise or defense of legal claims, to protect the rights of another person, or for reasons of important public interest.

· Right to withdraw consent: If we require your consent to process any of your information, we will request this consent separately. To the extent that Hay-Adams relies on your consent to process any of your personal data, you have the right to withdraw your consent to such processing at any time.

· Complaint: You also have the right to lodge a complaint with a supervisory authority, in particular that in your Member State of residence, where applicable.

If you would like to exercise the above rights in any way, please contact us at privacy@hayadams.com or use the mailing address provided in the "Contact Us" section below.

The lawful basis for processing your personal information is made up of one or more of the following reasons depending on the circumstances: (i) your consent, and/or (ii) providing the services you have requested, and/or (iii) legitimate interests, and/or (iv) compliance with applicable laws, regulations, court orders or other legal process.

Your California Privacy Rights
California residents should be aware that this section does not apply to: Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, the California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Depending on where you reside, you may have one or more of the following rights with regard to Hay-Adams' collection, use and sharing of your Personal Information:

· Right to Access: The right to request that we disclose what Personal Information we collect, use, disclose or sell about you.

· Right to Deletion: The right to request the deletion of Personal Information we have collected or maintain about you.

· Right to Opt-Out: The right to opt out of profiling, automated decision-making, and the sale or sharing of Personal Information.

· Right to Correct Inaccurate Personal Information: The right to request any inaccurate Personal Information about you maintained by Hay-Adams be corrected.

· Right of Restriction of Sensitive Data: The right to direct Hay-Adams to limit its use of the consumer's sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.

· Right of Portability: The right to have specific pieces of personal information transferred to another entity in a format easily understandable to the average consumer, and a commonly used, machine-readable format.

· Non-Discrimination: The right not to receive discriminatory treatment by Hay-Adams, in terms of the services and prices offered on or through our Services, because you exercised these rights regarding the collection, use and sharing of your Personal Information.

If you would like to access, review, edit, delete or have us properly dispose of any copies of the Personal Information that Hay-Adams collected about you (subject to any applicable legal exceptions), or if you would like to exercise the above rights in any other way, please contact us at privacy@hayadams.com or use the mailing address provided in the "Contact Us" section below.

You may be able to opt out of Hay-Adams sharing your Personal Information with the entities identified in this Policy by sending us an email at the address above, unless the sharing of your Personal Information is necessary to perform one of the following business purposes: to count ad impressions and evaluate their effectiveness; to detect, protect against, and prosecute security incidents; to debug or troubleshoot functional errors that may arise with the Services; to complete short-term tasks related to an existing interaction you have with Hay-Adams; to maintain or service your account; to process payments and fulfill orders or other transactions you authorize; to verify your customer information; and to ensure the safety and quality of the Services.

Hay-Adams will attempt to accommodate any request to delete or properly dispose of any copies of your Personal Information, but we cannot guarantee we can eliminate all Personal Information from the specified uses. Therefore, please be as specific as possible in any request to delete or dispose of copies of your Personal Information. We may deny your deletion request if retaining the information is necessary for us or our service providers 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 to perform a contract we entered into 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);

· 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; or

· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you choose to delete certain portions of your Personal Information, it may affect your ability to use certain Services. If the request relates to information that Hay-Adams needs to make the Site or other Services function properly for you, you may no longer be able to use those Services. Any removal of content by Hay-Adams does not ensure or guarantee complete or comprehensive removal of the content in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.

You may grant an authorized agent written permission to submit requests regarding your Personal Information, but we may deny authorized agent requests absent proof that you authorized such agent to act on your behalf, or if we are unable to verify your identity.

Hay-Adams is required to verify the identity of any person or entity that requests the disclosure or deletion of Personal Information. If you have a password-protected account with us, we will use our existing authentication procedures to verify your identity. For most other consumer requests, Hay-Adams will ask you to provide information that matches at least two pieces of personal information we store about you before responding to your request. If you would like to request the specific pieces of your personal information that Hay-Adams has collected, or if you would like us to delete highly sensitive information, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the consumer whose personal information you are requesting.

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.

We may send periodic promotional emails to you. You may opt out of promotional emails by following the opt-out instructions contained in the email. If you opt out of receiving promotional emails, we may still send you emails about other services you have requested to receive from us.

Global Privacy Control
We respond to the Global Privacy Control signal for California residents. California residents may use the Global Privacy Control (GPC) to communicate your privacy preferences. If Hay-Adams detects the GPC signal from your device, Hay-Adams will not share your data. To learn more, visit Global Privacy Control — Take Control of Your Privacy.

Do Not Sell or Share My Personal Information
To request an opt-out of the sale or sharing of your Personal Information you may contact us at privacy@hayadams.com or use the mailing address provided in the "Contact Us" section below.

Limit the Use of My Sensitive Personal Information
To request for a restriction of the processing of your Sensitive Personal data you may contact us at privacy@hayadams.com or use the mailing address provided in the "Contact Us" section below.

Your Virginia Privacy Rights
Subject to certain exceptions, Virginia residents also have the right to request confirmation of processing activities of their Personal Information and to request access, deletion, correction, and portability of said Personal Information. Virginia residents have the right to opt-out of processing of Personal Information for the purposes of targeted advertising, profiling, and the sale of Personal Information. You have the right not to be discriminated against if you choose to exercise those rights. If you are a Virginia resident and would like to exercise the above rights in any way, please contact us at privacy@hayadams.com or use the mailing address provided in the "Contact Us" section below.

Retention and Disposal of Personal Information
Hay-Adams retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. Hay-Adams will also retain collected information connected to business records for periods of time required by law. If Hay-Adams determines that collected information is no longer needed, it will delete such information.

Securing Personal Information
Hay-Adams is committed to protecting the privacy and confidentiality of your personal information. We maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

· A dedicated group that designs, implements and provides oversight to our information security program;

· The use of specialized technology such as firewalls;

· Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;

· Internal and external reviews of our Internet sites and services;

· Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;

· Implementing controls to identify, authenticate and authorize access to various systems or sites;

· Protecting information during transmission through various means including, where appropriate, encryption; and

· Providing Hay-Adams personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Legal Disclaimers
Nothing in this Policy restricts our ability to:

Comply with federal, state, or local laws;

· Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;

· Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law;

·Exercise or defend legal claims;

· Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or

· Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of our business.

Links
Our Site and Services may contain links to unaffiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.

Updates to This Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, and any material change to this Policy will be effective immediately.

Contact Us
If you have questions about this Policy, the privacy aspects of our Site or Services, or would like to make a privacy-related inquiry, complaint, or dispute, please contact us at:

Privacy Team c/o Legal Department
7501 Wisconsin Avenue
Suite 1500E
Bethesda, Maryland 20814
Email: privacy@hayadams.com

Hay-Adams intends to strictly enforce this Policy. If you believe there has been some violation of this Policy, please contact our Legal Department.

This Policy was last updated: March 3, 2023