California Privacy Notice
This California Privacy Notice supplements the Privacy Policy of Threshold Hospitality Group ("Threshold," "we," "us," or "our") and applies solely to visitors, users, and others who reside in the State of California ("consumers" or "you").
We provide this Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (together, the "CCPA"), and other California privacy laws. Terms defined in the CCPA have the same meaning when used in this Notice.
Under California law, "personal information" includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household. It also includes information that identifies you in your capacity as a business contact, employee, or job applicant.
1. Notice at Collection
At or before the point we collect personal information, we provide the following notice:
2. Categories of Personal Information We Collect
In the preceding twelve (12) months, we have collected the following categories of personal information:
We do not collect or process sensitive personal information as defined by the CCPA. Accordingly, we do not use or disclose sensitive personal information for purposes that would require us to offer a right to limit its use.
We do not knowingly collect personal information from consumers under 16 years of age.
3. Sources of Personal Information
We obtain the categories of personal information listed above from:
- You directly — through the Site's contact form, email, telephone, LinkedIn, meetings, and in the course of an engagement
- Automatically from your device — through our web hosting provider, server logs, and any analytics tools we use
- Third parties — including the ownership groups, investors, lenders, brokers, hotel brands, and companies you are associated with; our service providers; and publicly available professional sources such as company websites and professional networking platforms
4. Business and Commercial Purposes for Collection
We collect and use personal information for the following business purposes enumerated in the CCPA:
- Performing services on behalf of our clients and prospective clients, including hospitality management, owner advisory, and acquisitions services
- Responding to your inquiries and communicating with you about a potential or existing engagement
- Auditing interactions with consumers and measuring Site performance
- Detecting, protecting against, and prosecuting security incidents, fraud, and illegal activity
- Debugging to identify and repair errors that impair intended functionality
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality and safety of our services
- Complying with legal obligations and establishing, exercising, or defending legal claims
- Other purposes for which we provide you specific notice at the time of collection or to which you consent
We do not use personal information for purposes that are incompatible with the purposes disclosed above without providing new notice.
5. Disclosure of Personal Information
We have not sold personal information, and we have not shared personal information for cross-context behavioral advertising, in the preceding twelve (12) months. We also have not sold or shared the personal information of consumers under 16 years of age.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We may also disclose any category of personal information to government authorities or other parties when required by law or legal process, or in connection with a merger, acquisition, financing, or sale of business assets.
We require our service providers and contractors to limit their use of personal information to performing services for us, consistent with the CCPA.
6. Retention
We do not retain personal information for longer than reasonably necessary for the purposes described in this Notice. Because retention depends on context, we apply the following general criteria:
7. Your California Privacy Rights
Subject to certain exceptions, California residents have the following rights:
Right to Know. You may request that we disclose to you: the categories of personal information we collected about you; the categories of sources; our business or commercial purposes for collecting it; the categories of third parties to whom we disclosed it; and the specific pieces of personal information we collected about you. You may request this information for the 12-month period preceding your request, and—for information collected on or after January 1, 2022—for a period beyond 12 months unless doing so would be impossible or involve disproportionate effort.
Right to Delete. You may request that we delete personal information we collected from you, subject to exceptions that permit us to retain information—for example, to complete a transaction, provide a service you requested, detect security incidents, comply with a legal obligation, or exercise or defend legal claims.
Right to Correct. You may request that we correct inaccurate personal information we maintain about you, taking into account the nature of the information and the purposes of processing.
Right to Opt Out of Sale or Sharing. You have the right to direct us not to sell or share your personal information. We do not sell or share personal information, so we do not offer a "Do Not Sell or Share My Personal Information" link. If our practices change, we will update this Notice and provide the required opt-out mechanism, and we will honor opt-out preference signals such as Global Privacy Control.
Right to Limit Use of Sensitive Personal Information. We do not collect or use sensitive personal information for purposes that trigger this right.
Right to Non-Discrimination. We will not discriminate against you for exercising any CCPA right. We will not deny you services, charge different prices, provide a different level of quality, or suggest that we will do any of those things. We do not offer financial incentives in exchange for personal information.
8. How to Exercise Your Rights
To submit a request to know, delete, or correct, use either method below:
- Email: contactus@thresholdhospitalitygroup.com with the subject line "California Privacy Request"
- Mail: Threshold Hospitality Group, Attn: Privacy, 4728 Spottswood Ave PMB 127, Memphis, Tennessee 38117
Please include your name, the email address or phone number you used to contact us, the nature of your request, and enough detail for us to locate your information.
Verification. Only you, or an authorized agent acting on your behalf, may make a request. We will verify your identity by matching the information in your request against information already in our records. Depending on the sensitivity of the request, we may ask for additional information. We cannot respond to a request or provide personal information if we cannot verify that you are the person about whom we collected the information. Making a verifiable request does not require you to create an account with us. We will use personal information provided in a request only to verify the requestor's identity or authority.
Authorized agents. An authorized agent may submit a request on your behalf by providing written permission signed by you, or a valid power of attorney. We may require you to verify your own identity directly with us and to confirm that you granted the agent permission.
Response timing. We will confirm receipt within ten (10) business days and respond within forty-five (45) days of receiving a verifiable request. If we need more time, we will inform you of the reason and extension period in writing, up to a total of ninety (90) days. We deliver our response electronically unless you request otherwise. We do not charge a fee to process or respond to a verifiable request unless it is excessive, repetitive, or manifestly unfounded.
Appeals. If we deny your request, our response will explain the reason. You may appeal by replying to that response with the word "Appeal" and your reasoning. You may also contact the California Privacy Protection Agency or the California Attorney General.
9. Shine the Light
California Civil Code § 1798.83 permits California residents who have an established business relationship with us to request information about our disclosure of personal information to third parties for those third parties' direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes. To make a request under this section, email contactus@thresholdhospitalitygroup.com with "Shine the Light Request" in the subject line.
10. Minors Under 16
We do not knowingly collect, sell, or share the personal information of consumers under 16 years of age. If you believe we have inadvertently collected information from a person under 16, contact us at contactus@thresholdhospitalitygroup.com and we will delete it.
11. Accessibility
We are committed to making this Notice accessible to consumers with disabilities. If you use an assistive technology and have difficulty accessing this Notice, please contact us at contactus@thresholdhospitalitygroup.com and we will provide it in an alternative format.
12. Changes to This Notice
We review and update this Notice at least once every twelve (12) months, and more often if our practices change. Updates take effect when posted, and we will revise the "Last Updated" date above.
13. Contact
Threshold Hospitality Group
Attn: Privacy
4728 Spottswood Ave PMB 127
Memphis, Tennessee 38117
contactus@thresholdhospitalitygroup.com