ETC HOTELS PRIVACY POLICY
August, 2008

ETC Hotels, including Shutters On The Beach, Hotel Casa Del Mar, and Canary Hotel (hereafter referred to collectively as "ETC") are committed to maintaining the privacy of personal information that you provide to us when using our various websites. This Privacy Policy describes how we treat personal information received about you when you visit our sites.

We may make content or services from other sites including our affiliated or co-branded sites available to you from links located on our sites.

This Privacy Policy also explains our practices regarding personal information obtained from sources other than our sites, such as written or verbal communications or information collected when you visit one of our properties.

Please read this Privacy Policy carefully before submitting personal information about you to us. Also, please note that this Privacy Policy does not apply to our processing of personal information on behalf of and subject to the instructions of third parties such as airlines, car rental companies and other service providers, and companies that organize or offer packaged travel arrangements.

Personal Information We Collect

At every touch point or guest interaction, we may collect personal information. In addition to any other information you may choose to provide us, this personal information may include: your name and contact information; date of birth; preferred communication methods; business name, title and business address; credit card details, including the three-digit code that appears on the back of your credit card; date of arrival and departure; room and vacation preferences; travel history; and details on hotel, airline and rental car packages you book. We may also record details on joint travelers, including their names and the age of the driver of the rental car.

In addition, we collect other personal information when you interact with our sites in various ways such as:

• If you choose to create an online profile for meeting and event planning (e.g., weddings), we record meeting and event specifications, the date of the event, number of guests, details of the guest rooms, and, for corporate events, information on your organization (name, annual budget, number of sponsored events per year).

Use of Personal Information Collected About You

We use your personal information to provide the services you request from ETC so as to facilitate: reservations; purchases from the Shutters Beach Style; and other transactions. We also use the personal information to provide you with information about meeting and event planning and access to specific account information for administrative purposes. In addition, we may use the information to: improve ETC's services; provide you with the expected level of hospitality; and ensure the site is of interest to you. We also use details to send you newsletters, promotions and featured specials.

How We Share Personal Information

• Electronic Credit Transactions: If you reserve rooms or make some other purchase on our sites, billing information will be shared with the credit card provider and, if you use a corporate credit card, possibly, your employer.
• Group Events or Meetings: If you visit ETC as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, guests who organize or participate in the meeting or event.
• Service Providers: We rely on service providers to provide certain products and services, such as credit card billing, reservations services, and those providing services in connection with our sites, including communicating news and delivering promotional and transactional materials via email and direct mail, processing credit card transactions, as well as data hygiene and enhancement services. ETC will disclose personal information to these service providers as appropriate.
• Business Transactions: As we develop our business, we might sell, buy, restructure or reorganize businesses or assets. In the event of a merger, consolidation, sale, liquidation or transfer of assets, ETC may, in its sole and absolute discretion, transfer, sell or assign information collected, including without limitation, non-personal information and personal information, to one or more affiliated or unaffiliated third parties.
• Other: In addition, ETC may disclose personal information, with or without prior notice to you, in order to: (i) comply with applicable laws; (ii) respond to governmental inquiries or requests from public authorities; (iii) comply with valid legal process; (iv) protect the rights, privacy, safety or property of ETC, site visitors, guests, employees or the public; (v) enforce our Site Usage Agreement; and (vii) respond to an emergency.

Sensitive Information

The term "sensitive information" refers to information related to your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership. We do not generally collect sensitive information unless it is volunteered by you. We may use health data provided by you exclusively to serve you better and meet your particular needs.
Personal Information From Children

We do not knowingly collect personal information from individuals under 18 years of age. As a parent or legal guardian, please do not allow your children to submit personal information without your permission.

Non-Personal Information

When you visit and interact with our sites, ETC, and third parties with whom ETC has contracted to provide services to ETC, may collect non-personal information (for example, a catalog of the site pages you visit).

As with many other sites, our sites may use "cookies" or other technologies to help us deliver content specific to your interests, to process your reservations or requests, and/or to analyze your visiting patterns. Cookies, by themselves, cannot be used to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit our sites. If you want to remove cookies at any time from your computer, you can delete them using your browser (consult your browser's "help" menu to learn how to delete cookies).

We also may collect data by using "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "pixel tags") that allow us to know when you visit our sites. Through pixel tags, we obtain non-personal information or aggregate information(i.e., the domain name, the areas of the sites you visit, your operating system, your browser version, and the URL you came from) which can be used to enhance your online experience and understand traffic patterns.

Because non-personal information does not personally identify you, we may use or disclose such information for any purpose. In some instances, we may combine non-personal information with personal information (such as embedding e-mail addresses in cookies). If we do combine any non-personal information with personal information, the combined information will be treated by us as personal information in accordance with this Privacy Policy.

Links to Third-Party Websites

Our sites may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on third party sites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of sites that you visit before submitting personal information.

Protecting Personal Information

ETC will take appropriate measures to: (i) protect personal information collected against unauthorized access, disclosure, alteration or destruction, and (ii) keep personal information accurate and up-to-date, consistent with applicable law. We also seek to require our affiliates and service providers to exercise reasonable efforts to maintain the confidentiality of personal information about you. For online transactions, we use technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

For your own privacy protection, we encourage you not to include sensitive personal information in any emails you may send to us. Please do not send credit card numbers or any sensitive personal information to us via email.

Changing Personal Information

To the extent required by applicable law, you may be able to request that we inform you about the personal information we maintain about you and, where appropriate, request that we update, correct, and/or suppress personal information about you that we maintain in our active database. We will make all required updates and changes within the time specified by the applicable law and, where permitted by law, may charge an appropriate fee to cover the costs of responding to the request. Such requests must be submitted in writing to the following address: ETC HOTELS, One Pico Blvd., Santa Monica, CA 90405. To protect your confidentiality, we can only respond to such requests to the email address that you have registered or otherwise provided to us. Please remember that if you make such a request, we may not be able to provide you with the same quality and variety of services to which you are accustomed. In addition, in some circumstances based on applicable law, you may request that we cease sharing personal information about you with our business partners or that ETC cease the use of personal information about you on the grounds that such personal information was acquired by unjust means or used in violation of law by sending your written request to: ETC HOTELS, One Pico Blvd., Santa Monica, CA 90405 . We will seek to honor those requests consistently with applicable law.

Retaining Personal Information

We retain personal information about you for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law.

Choices - Marketing Lists

If you have given us your contact information (mail address, fax number, email address or phone number), we may want to inform you about our services or invite you to events by email, telephone or post.

If you prefer not to receive marketing materials from us, you may change your preferences at any time by: (i) sending us an email to mailing@etchotels.com; (ii) writing to us (and include your email address) at: ETC HOTELS, One Pico Blvd., Santa Monica, CA 90405; or (iii) using the unsubscribe function in the email you receive from us. We will update your preferences as soon as reasonably practical.

Please note, however, that if you "opt out" as described above, we will not be able to remove your personal information from the databases of business partners with which we have already shared your personal information (i.e., to which we have already provided your personal information as of the date of your op-out request).

Other Information

• Special Notification for California Residents. Individual customers who reside in California and have provided their personal information to ETC may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following addresses: mailing@etchotels.com; or ETC HOTELS, One Pico Blvd., Santa Monica, CA 90405. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

Policy Modifications

We may modify this Privacy Policy from time to time. When we make material changes to this Privacy Policy we will post the revised Privacy Policy on the homepage of our sites. You can tell when this Privacy Policy was last updated by looking at the date at the top of the Privacy Policy. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy on the site. Use of the sites following such changes constitutes your acceptance of the revised Privacy Policy then in effect.

Questions

If you have any questions about this Privacy Policy or how ETC processes your personal information, please contact us by email to: mailing@etchotels.com or by postal mail to ETC HOTELS, One Pico Blvd., Santa Monica, CA 90405.