Privacy Policy

Effective Date: August 19, 2026  |  Last Updated: August 19, 2026

Threshold Hospitality Group, LLC ("Threshold," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with our corporate website at thresholdhospitalitygroup.com (the "Site") and our business-development, owner-relations, and corporate communications activities (collectively with the Site, the "Corporate Services").

Threshold is a business-to-business hospitality management and advisory firm. Our Site is an informational marketing site intended primarily for hotel owners, investors, ownership groups, lenders, brokers, brand representatives, prospective business partners, and other business professionals. We do not sell consumer products or maintain user accounts through the Site.

Scope. This Policy applies to information collected through the Site and to corporate business-contact information handled by Threshold in its own capacity. It does not govern personal information processed by Threshold solely on behalf of a hotel owner or brand in operating a hotel, or information collected through a hotel, brand reservation system, online travel agency, payroll or human-resources provider, or other third-party platform. Those activities are governed by the applicable hotel's, owner's, brand's, employer's, or provider's notices and agreements. Separate notices may apply to job applicants and members of the workforce.

Please read this Policy together with our Terms of Use. If you are a California resident, please also see our California Privacy Notice.

1. Information We Collect

a. Information You Provide Directly

The primary way we collect personal information is when you choose to give it to us. This includes:

• Contact form submissions. When you use a contact form on the Site, we collect the information shown in the form and any information you choose to provide, which may include your name, email address, telephone number, company or professional role, and the contents of your message.
• Email and other correspondence. If you email us at contactus@thresholdhospitalitygroup.com, connect with us on LinkedIn, meet with us, or otherwise contact us, we collect the information contained in that communication, including your contact details and anything you choose to tell us.
• Business and engagement information. In the course of evaluating or performing an engagement, we may receive information about you in your professional capacity—such as your name, title, employer, business contact details, and professional background—from you or from the ownership group, investor, lender, broker, or hotel you are associated with.

Please do not submit sensitive or confidential information through the Site's contact form. The form is not a secure channel and is intended only to start a conversation. Do not send financial account numbers, government identifiers, non-public deal terms, or confidential ownership information until we have established a secure channel and, where appropriate, a confidentiality agreement.

b. Information Collected Automatically

When you visit the Site, our hosting, security, form-processing, and analytics service providers may automatically collect certain information, including:

• IP address and general location derived from it (such as city, region, and country)
• Browser type and version, operating system, and device type
• Pages viewed, links clicked, referring website, and time and date of your visit
• Approximate session duration and similar usage data

This information is generally used in aggregate to understand how the Site performs, to maintain security, and to diagnose technical problems.

c. Cookies and Similar Technologies

The Site and its service providers may use cookies and similar technologies that are necessary to operate and secure the Site, prevent spam and abuse, remember settings, and understand aggregate Site usage. We do not use cookies to serve targeted advertising, and we do not knowingly permit third parties to track visitors across unrelated websites for advertising. Most browsers allow you to refuse or delete cookies through their settings; disabling cookies may affect how parts of the Site function.

d. Information We Do Not Collect

We do not knowingly collect Social Security numbers, driver's license numbers, payment card numbers, biometric data, precise geolocation, health information, or account credentials through the Site.

2. How We Use Personal Information

We use personal information for the following business purposes:

• To respond to your inquiry and communicate with you about a potential or existing engagement
• To evaluate, negotiate, enter into, and perform management, advisory, and acquisition engagements
• To provide, maintain, secure, and improve the Site and our Services
• To send you information about Threshold that you have requested or that is relevant to an existing business relationship
• To detect, investigate, and prevent fraud, spam, abuse, security incidents, and other unlawful activity
• To comply with applicable law, legal process, and our contractual and professional obligations
• To establish, exercise, or defend legal claims
• For general business, analytics, and record-keeping purposes

We do not use personal information collected through the Site for automated decision-making that produces legal or similarly significant effects, and we do not engage in profiling for targeted advertising.

3. How We Share Personal Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising or targeted advertising. We disclose personal information only as described below:

• Service providers. We use vendors that perform services on our behalf, such as website hosting, form processing, email and productivity platforms, cloud storage, analytics, and professional services. These providers are permitted to use personal information only to perform services for us.
• Professional advisors. Our attorneys, accountants, insurers, and similar advisors, subject to obligations of confidentiality.
• Engagement counterparties. In connection with an actual or prospective engagement, we may share business contact information with the relevant ownership group, investor, lender, brand, broker, or hotel, as reasonably necessary to advance or perform the engagement.
• Legal and safety. When we believe disclosure is required by law, subpoena, court order, or other legal process, or is reasonably necessary to protect the rights, property, or safety of Threshold, our clients, or others.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, personal information may be transferred as a business asset, subject to reasonable confidentiality protections.
• With your direction or consent. When you ask us to share information or otherwise authorize it.

4. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy. Inquiries that do not lead to an engagement are generally retained for up to 24 months after the last substantive contact so that we can maintain business context and respond to follow-up. Records relating to an actual engagement are retained for the duration of the engagement and afterward for the period required by our contractual, tax, insurance, professional, and legal obligations. Server logs and analytics data are retained for shorter periods consistent with our providers' practices and our configuration.

When information is no longer needed, we delete it or take reasonable steps to de-identify it.

5. Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction. However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security, and any transmission of information to us is at your own risk.

6. Third-Party Sites and Services

The Site contains links to third-party websites, including our LinkedIn page. We are not responsible for the privacy practices or content of those sites and services. We encourage you to review the privacy policies of any third party before providing information to it.

7. Children's Privacy

The Site and our Services are directed to business professionals and are not intended for children. We do not knowingly collect personal information from anyone under the age of 16. If you believe a child has provided us with personal information, please contact us at contactus@thresholdhospitalitygroup.com and we will take appropriate steps to delete it.

8. Your Privacy Choices and Rights

Everyone. You may contact us at any time at contactus@thresholdhospitalitygroup.com to ask what information we hold about you, to request that we correct or delete it, or to ask that we stop contacting you. If we send you email of a promotional nature, you may unsubscribe using the link in the message or by replying with a request to be removed. We may still send you communications necessary to an ongoing engagement.

State privacy rights. To the extent applicable law grants you privacy rights, those rights may include confirming whether we process your personal data, accessing it, correcting inaccuracies, deleting it, obtaining a portable copy, and opting out of targeted advertising, sale, or certain profiling, as well as appealing a denial of a request. We do not sell personal data or use it for targeted advertising or profiling that produces legal or similarly significant effects. Statutory rights apply only where the relevant law applies to Threshold and to the information at issue.

To exercise any right, email contactus@thresholdhospitalitygroup.com with the subject line "Privacy Request." We will verify your request by matching the information you provide against our records and may ask for additional information reasonably necessary to confirm your identity. An authorized agent may submit a request on your behalf with written proof of authorization. We will respond within the timeframe required by applicable law, generally 45 days, and may extend that period where permitted with notice to you. We will not discriminate against you for exercising your rights.

If we decline a request, you may appeal by replying to our response with the word "Appeal" and the reason you believe the decision was incorrect. If your appeal is denied, you may contact your state attorney general.

California residents. Please see our California Privacy Notice for additional disclosures and rights under the California Consumer Privacy Act.

9. Do Not Track

Some browsers offer a "Do Not Track" ("DNT") signal. There is no consistent industry standard for responding to DNT signals, and we do not currently respond to them. We do not track visitors across third-party websites over time to deliver targeted advertising.

If we use technologies that qualify as a "sale" or "share" under applicable law in the future, we will honor opt-out preference signals such as Global Privacy Control (GPC) as required.

10. Individuals Outside the United States

Threshold is based in the United States, and the Site is hosted and operated in the United States. If you access the Site or contact us from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your jurisdiction. The Site is not directed to individuals in the European Economic Area, the United Kingdom, or Switzerland.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date above. Material changes will be indicated by a prominent notice on the Site where required by law. Your continued use of the Site after an update constitutes acceptance of the revised Policy.

12. Contact Us

Questions, requests, or complaints about this Policy or our privacy practices may be directed to:

Threshold Hospitality Group, LLC
Attn: Privacy
4728 Spottswood Ave PMB 127
Memphis, TN 38117
contactus@thresholdhospitalitygroup.com