PRIVACY POLICY

EFFECTIVE DATE: October 1, 2025

Mullen Hospitality Management (“MHM,” “us,” “we,” or “our”) operates the mullenhospitality.com website (the “Service”).

This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of personal information when you use our Service, as well as the choices you may have regarding your information.

We may collect and use information to provide, maintain, and improve the Service; respond to inquiries; and, where permitted, communicate with you about MHM and properties within our portfolio, including news, offers, experiences, services, and events that may be of interest to you.

By using the Service, you acknowledge the practices described in this Privacy Policy.

We do not sell your Personal Data for monetary consideration.

DEFINITIONS

Personal Data

Personal Data means information that identifies, relates to, describes, or could reasonably be associated with an identifiable individual.

Usage Data

Usage Data is information collected automatically through the use of the Service or from the Service infrastructure itself, such as information regarding how and when the Service is accessed.

Cookies

Cookies are small data files stored on a User’s device or browser.

Data Controller

Data Controller means the person or organization that determines the purposes and means of processing Personal Data.

For purposes of this Privacy Policy, MHM may act as a Data Controller with respect to Personal Data collected through the Service.

Data Processor (or Service Provider)

A Data Processor or Service Provider is a person or organization that processes Personal Data on behalf of a Data Controller.

We may engage Service Providers to perform certain functions and process Personal Data on our behalf.

Data Subject

A Data Subject is an individual who is the subject of Personal Data.

User

A User is an individual accessing or using our Service.

INFORMATION COLLECTION AND USE

We may collect different types of information for purposes that include operating and improving our Service, communicating with you, responding to requests, and providing information about MHM and properties within our portfolio.

TYPES OF DATA COLLECTED

Personal Data

While using our Service, you may choose to provide us with certain personally identifiable information that can be used to contact or identify you. Depending upon how you interact with the Service, this information may include:

  • Email address
  • First and last name
  • Phone number
  • Birthday
  • Address, state, province, ZIP/postal code, city, and country
  • Information submitted through contact, inquiry, registration, or other forms
  • Communication and marketing preferences
  • Cookies and Usage Data

Where permitted by applicable law and based on the preferences or permissions you provide, we may use your Personal Data to communicate with you about MHM and properties within our portfolio. These communications may include property news, special offers, accommodations, dining, wellness, events, experiences, and other information that may be of interest to you.

You may opt out of marketing email communications at any time by using the unsubscribe instructions included in those communications or by contacting us.

Usage Data

We may automatically collect certain information regarding how the Service is accessed and used. Usage Data may include information such as your device’s Internet Protocol address (IP address), browser type and version, pages of the Service you visit, date and time of your visit, time spent on those pages, referring pages, unique device identifiers, and other diagnostic information.

Tracking Technologies and Cookies

We may use cookies and similar tracking technologies to understand activity on our Service, remember preferences, improve functionality, analyze website performance, and other.

Tracking technologies may include cookies, pixels, tags, scripts, and similar technologies.

You may be able to configure your browser to refuse some or all cookies or alert you when cookies are being sent. Certain portions of the Service may not function properly if cookies are disabled.

Cookies used on the Service may include:

  • Session Cookies – to operate and maintain the Service.
  • Preference Cookies – to remember your preferences and settings.
  • Security Cookies – to support security and fraud prevention.
  • Analytics Cookies – where applicable.
  • Advertising/Marketing Cookies – where applicable.

USE OF DATA

Mullen Hospitality Management may use information collected through the Service for purposes including:

  • Providing, operating, and maintaining the Service
  • Responding to inquiries and requests
  • Providing customer support
  • Communicating information requested by Users
  • Understanding and analyzing how the Service is used
  • Improving the Service, website functionality, and User experience
  • Monitoring website performance and usage
  • Detecting, preventing, and addressing technical or security issues
  • Maintaining and administering marketing and communications databases
  • Understanding User interests and communication preferences
  • Sending marketing and promotional communications where permitted
  • Providing news, offers, promotions, and information regarding MHM
  • Providing news, offers, promotions, experiences, services, and information regarding properties within the MHM portfolio that may be of interest to you
  • Segmenting communications based on information, interests, or preferences provided by Users
  • Complying with applicable legal and regulatory requirements

MHM PORTFOLIO COMMUNICATIONS

Information collected through the Service may be used to provide communications regarding MHM and properties within our portfolio.

Depending on your communication preferences and applicable law, this may include information regarding accommodations, property experiences, dining, wellness, meetings and events, weddings and celebrations, special offers, openings, news, and other hospitality-related services or experiences.

RETENTION OF DATA

MHM will retain Personal Data only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including satisfying applicable legal, regulatory, accounting, reporting, or operational requirements.

The specific retention period may depend upon the nature of the information, the purposes for which it was collected, applicable legal requirements, and other.

Usage Data may generally be retained for a shorter period unless it is needed to strengthen security, improve functionality, comply with legal obligations, or for other legitimate business purposes.

TRANSFER OF DATA

Your information, including Personal Data, may be processed or maintained using systems located outside your state, province, country, or other governmental jurisdiction. Privacy and data-protection laws in those jurisdictions may differ from those in your jurisdiction.

Where required by applicable law, MHM will take appropriate measures regarding transfers of Personal Data.

DISCLOSURE OF DATA

MHM may disclose Personal Data to Service Providers that perform services on our behalf, subject to appropriate contractual and legal requirements.

Disclosure for Law Enforcement

Under certain circumstances, MHM may be required to disclose Personal Data if required by applicable law or in response to valid requests from governmental or public authorities.

Legal Requirements

MHM may disclose Personal Data in good faith when it believes such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of MHM
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users or the public
  • Protect against legal liability

SECURITY OF DATA

The security of Personal Data is important to us. We use reasonable administrative, technical, and organizational measures designed to protect Personal Data.

However, no method of transmission over the Internet or method of electronic storage is completely secure, and absolute security cannot be guaranteed.

YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you reside and applicable law, you may have certain rights regarding your Personal Data, which may include rights to:

  • Request access to Personal Data we maintain about you
  • Request correction of inaccurate Personal Data
  • Request deletion of Personal Data
  • Request restriction of certain processing
  • Object to certain processing
  • Request portability of certain Personal Data
  • Withdraw consent where processing is based upon consent
  • Opt out of marketing communications

These rights are subject to applicable legal limitations and exceptions.

To submit a privacy-related request, please contact us using the information provided in the Contact Us section below. We may need to verify your identity before processing certain requests.

MARKETING COMMUNICATIONS

You may opt out of receiving promotional email communications from us at any time by selecting the unsubscribe link included in our marketing emails.

Opting out of marketing communications does not necessarily prevent us from sending non-promotional communications when appropriate, such as communications relating to a request you have made or other administrative communications.

SERVICE PROVIDERS

We may engage third-party companies and individuals to facilitate or support our Service, provide services on our behalf, perform Service-related functions, or assist us in understanding how our Service is used.

These Service Providers may have access to Personal Data only as necessary to perform services on our behalf and are subject to applicable contractual and legal obligations regarding the handling of that information.

Analytics

Google Analytics

Email Marketing / CRM

Cendyn

Behavioral Advertising and Remarketing

Google Ads, Meta

LINKS TO OTHER SITES

Our Service may contain links to websites that are not operated or controlled by MHM, including websites operated by properties within our portfolio, hotel brands, booking platforms, and other third parties.

If you follow a link to a third-party website, that website’s own privacy policy and practices will apply. We encourage you to review the privacy policy of each website you visit.

MHM does not control and is not responsible for the content, privacy policies, or practices of third-party websites or services.

CHILDREN’S PRIVACY

The Service is not directed to children under the age of 18.

We do not knowingly collect Personal Data from children in violation of applicable law. If you believe a child has provided Personal Data to us, please contact us so that appropriate action may be taken.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to reflect changes in our practices, technologies, legal requirements, or other factors.

When changes are made, we will post the updated Privacy Policy on this page and revise the effective date as appropriate. Where required by applicable law, we may provide additional notice regarding material changes.

CONTACT US

If you have questions about this Privacy Policy, wish to exercise applicable privacy rights, or have questions regarding how your Personal Data is handled, please contact us:

Mullen Hospitality Management
Email: jessica.gonzalez@mullenhospitality.com