Oscar Anywhere – Privacy Policy

Last Revised: June 25, 2024

Priority Hospitality Ltd., and its affiliates (the “Company”, “us” or “we”) values the privacy of users of its mobile
application “Oscar Anywhere” (hereinafter, the “App”), and wishes to let you know which personal data is collected
about you via our App and how the Company handles your personal data. Please read the following carefully to
understand our practices regarding your personal data. The terms “you” and “your” refer to hotel staff members who
receive access to the App via their organization (hotel), and participate in and/or benefit from the services provided
in connection with our App.
Capitalized terms which are not defined herein, shall have the meaning ascribed to them in ourTerms of Use (the
“Terms of Use”), into which this Privacy Policy is incorporated by reference.
By downloading, installing, connecting to, and/or using the App, you consent to all the terms and conditions set forth
in this Privacy Policy (the “Privacy Policy”), as amended from time to time. IF YOU DO NOT AGREE TO THIS PRIVACY
POLICY, PLEASE DO NOT USE THE APP. Please note that you are not obliged to provide us your personal data, however,
in case you fail to provide us your personal data, the App and/or Services (as defined under the Terms of Use) may not
be available.
The App, in general, is intended to assist hotels and their staff, and is not intended for individuals under 16. Therefore,
the Company does not knowingly collect personal data from individuals under the age of 16. If you are a parent of an
individual under 16 and believe your child has provided personal data to the Company via the App, please contact us
with the below contact information. For the avoidance of doubt. The Company reserves the right to request proof of
identification and/or age at any stage.

What does the Company do?

The Company provides next-gen property management software and comprehensive range of solutions and
automation tools to assist hoteliers in unlocking the full potential of their properties.

What kind of information we collect about you?

Personal data may be voluntarily provided by you or collected about you as a result of your use of the App, including
in the following sections and occasions:

1- When communicating with the Company – we may collect any information contained in messages that you send
to us by any means, including when you communicate with us directly. Such personal information may include
your full name, phone number, email address and any other personal information you may voluntarily provide to
us.

2- When creating and/or signing in to an Account – personal information is collected from the details you provide us
under registration process in order to open an Account. Such personal information include, inter alia, the User's
full name, phone number, e-mail address, position and hotel's information. We may require additional information
from time to time.

3- Monitoring Users' Data – App may include features for monitoring users' data via the hotel main system
integration, including User's geo-location data. Such data may be collected by the App and transferred to your
organization (hotel), through hotel main system integration, on your behalf.

4- User Content – you may voluntarily provide us with data, files, photos, content etc., that you upload to the App,
and such data may contain personal information. Please note that if you choose to upload any personal
information of any third-party to the App, you are solely responsible for obtaining all necessary approvals,
consents, and waivers as required under applicable privacy laws. We shall not be responsible for any personal
information of third parties uploaded to the App by you, and any such upload is done at your own risk.

5- Information from your device & online identifiers – we may collect non-identifiable information about your use of
the App, such as browsing history, monitoring, and system Information, your browsing habits, usage data,
information and advertisements you have viewed, web pages you have browsed, location data, IP address, device
ID number, device type and settings, language and browser type, and fields of interest you have indicated and
cookies, tags, pixels, beacons, scripts and other online identifiers. Such non-identifiable information is used for
operational reasons such as authentication, session persistence, data cache, optimization, etc.

How and why do we collect information?

We mainly use the personal data described to respond to your requests, to maintain your Account information and to
operate the App. The personal data may also be used to enhance the your experience while using the App, keep our
App safe and secured, ensure that the Content is presented in an optimal way for you and for your device, operate
our App (including by troubleshooting, data analysis, testing, system maintenance, authentication, support, reporting
and hosting of data) and to help you with your relevant inquiries, based on and our legitimate interests and subject to
your consent to provide you these. We shall only provide you with marketing and direct marketing materials according
to your consent, when required by law.

Retention

We may retain your information for the period consistent with the original purpose of collection. For instance, we may
keep your contact details for the amount of time needed to handle your request, or for a longer period of time if
necessary to maintain records, for complying with legal and regulatory duties, or to resolve future or ongoing disputes
based on our legitimate interest to do so.
We may keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete
or de-identify potentially identifiable information, when we no longer need to process the information.

Sharing of information collected

We may share information, as follows:
For legal reasons
We may share your information if we reasonably believe that:
(i) It is necessary to comply with a legal process or inquiry (such as a court order, subpoena, or search warrant) or
any other legal requirements of any governmental authority.
(ii) It would potentially mitigate our liability in an actual or potential lawsuit.
(iii) It is necessary to enforce this Privacy Policy or any other agreement executed by and between the User and us.
(iv) It is necessary to investigate and prevent illegal activities, and/or;
(v) It is otherwise necessary or appropriate to protect our rights or property or the rights or property of any person
or entity.

Service providers, affiliates, suppliers, and consultants
We use a limited number of third-party service providers, who act as our own service providers, and assist us in making
our App available. We may share information with third parties who provide services to us. These third parties may
access, process, or store the information while providing their services to us, and they may vary from time to time. We
may also share personal data within the Company and its related companies as far as the matter is required for this
and in accordance with applicable law.

Structural Changes
In any case of acquisition, merger or any other structural change, we may share the information collected, provided
that the said entity shall substantially undertake the provisions of this Privacy Policy.

Your rights

The following rights are granted to you by law. To redeem any of those please contact us directly.

Your EU/ UK Data Subject Rights
As an EU/ UK resident, you may request to review, correct, update or delete personal information, restrict the
processing of your personal information, object to the processing of your personal data, or receive an electronic copy
of your personal data for purposes of transmitting it to another company (to the extent this right to data portability is
provided to you by applicable law).
A summary and further details about your rights under EU data protection laws, is available on the EU Commission's
website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Your Rights as an Israeli Resident

Under Protection of Privacy Law, 5741 – 1981 as an Israeli resident, you may request in writing to review and correct
your personal data. Please note that we may need to verify your identity before we process any request relating to
your personal data. We may also contact you to ask You for further information in relation to your request to enable
us to carry out Your request. We will try to respond to all legitimate requests within lawful time.
If you are not a UK/EU/Israeli resident but believe that you are entitled to the rights mentioned above (or others) and
in accordance with the relevant law applied on you, from another legal source – you may contact us and request
exercise of your rights. We will examine the validity of your claim before agreeing to process any request.

How do We keep information secure?

We use security measures designed to protect against the loss, misuse, and alteration of the information under our
control.
The Company invests a lot of effort to protect information and implement various information security systems and
procedures. However, the Company protection and information security systems are not completely protected against
all unauthorized penetrations or access, and they do not provide absolute protection. The Company assumes no
liability or responsibility for any damage you may incur as a result of such penetration, unauthorized use, or theft of
information from the Company's databases or the App.
Any use of the App could expose you to a variety of dangers associated with using the Internet, such as, computer or
mobile phone penetration, viruses, malware, etc. Use of the App is under your sole responsibility. The Company
recommends that you use adequate security software and security means before using the App and/or Services.
You agree that the Company assumes no liability or responsibility for any loss or damage of any kind caused to you or
anyone on your behalf by Using the App, if any information about you is lost, disclosed to an unauthorized third party
or is used without permission.

International Transfers

The App is a web-based service. We store and process information about you on servers and databases under
appropriate safeguards according to applicable data protection laws.
If any international transfers of personal data will be conducted, it shall be exercised according to applicable data
protection laws.

Miscellaneous

We recommend that you review this Privacy Policy periodically, as we may update it from time to time. Your use of
our App constitutes your acknowledgment of the up-to-date Privacy Policy to the fullest extent permitted by law.
We may use your email address that you provide us, to send you messages about new features and App updates.
Messages which contain advertising content, will be sent only after receiving relevant explicit consent.
For any other inquiry and/or to submit a data subject request, please contact us at [email protected],
and we will do our best to reply within reasonable time.