Oceanic Enterprises LLC the owners and operators of Panama Hotel and any entities affiliated with Oceanic Enterprises LLC (“Oceanic”, “we”, “us” and “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Policy describes what information we collect from hotel guests as well as visitors to the Oceanic website, and the way in which Oceanic uses this information to better serve your needs. This Privacy Notice has been adopted by all of the distinct legal entities that manage and operate Oceanic branded hotels. Those entities include Oceanic and its direct and indirect subsidiaries and affiliates, and all of the separate and distinct legal entities that manage Oceanic managed hotels worldwide. References to “we”, “us”, “our” and “Oceanic” throughout this Privacy Notice, depending on the context, refer collectively to those separate and distinct legal entities. What is Personal Information? Personal information is any information about you as an identifiable individual. The personal information that we process includes:

• Basic information – such as name, age, gender, passport/ID at check in.
• Contact information – such as your home address, zip/postal code, email address and phone number;
• Financial information – such as your credit card details, itemized spending and transaction history on our property;
• Health information where disclosed and relevant to the provision of services;
• Preferences – such as special requests, service issues and other preferences for your stay;
• Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information, in the case of our mobile App); and
• Correspondence – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.

How do we use your personal information? We use your personal information for the following purposes:

• to enable you to use our website and any mobile App;
• to help us identify you and any accounts you hold with us;
• to provide superior customer service to you;
• to assist us in making your reservation and providing the services you request at any of our properties;
• to process transactions through our website (including taking payment for purchases you may make through our website) and to assist in any inquiries about your transaction;
• for billing purposes in relation to your stay with us;
• to confirm prior transactions and reconcile statements or invoices;
• to contact you in relation to matters that arise from your stay with us;
• to send you newsletters regarding our properties and to advise you of promotions or to inform you of offers or other information that may be of interest to you (if, where required, you separately provide your consent for us to do so);
• to conduct surveys or focus groups to receive your views of our properties and service delivery (if, where required, you separately provide your consent to this);
• to respond to a specific enquiry from you about our hotels and deal with any other enquiries, correspondence, concerns or complaints you have raised;
• for you to participate in one of our on-line promotions;
• to analyze customer trends and insights; and
• to operate our business, including for internal purposes such as auditing, data analysis, statistical and research purposes and troubleshooting to help us improve our services.

Occasionally we will combine information from a number of guests to better understand trends and your expectations. When this occurs, all identifiers are removed and the aggregate, anonymized information cannot be linked to any specific individual. On what basis do we use your personal information? We use your personal information on the following basis:

• to comply with legal and regulatory obligations, including financial reporting requirements imposed by government regulators and our auditors;
• to enter into agreements with you, and to perform our agreement to provide services to you when you stay with us;
• for legitimate business purposes – using your personal information helps us to operate and improve our business and minimize any disruption to the services that we may offer to you. It also allows us to make our communications with you more relevant and personalized to you, and to make your experience of our services more efficient and effective;
• because you have given your consent – at times we may ask for your consent to allow us to use your personal information for one or more purposes. See the Your Rights section for more information about the rights that you have if we process your information on the basis of your consent; or
• for the establishment, exercise or defense of legal claims or proceedings.

How is personal information collected? We collect your personal information while monitoring our technology tools and services, including comment cards, email communications sent to and from Oceanic, and/or cookies on our website. Otherwise, we gather information when you provide it to us, or interact with us directly, for example:

• when you create a profile or sign in to access an existing profile on our website or App;
• when you make a purchase through our website;
• when you make a reservation online, by calling one of our Reservation Offices or by contacting a particular hotel directly; and
• during your stay at a hotel, including information provided during check-in.

We also receive information about you from other sources, such as our business partners and publicly available sources. We combine information that we have about you from various sources, including the information that you have provided to us. We may also collect information from you through the use of cookies, when you visit our website. For more information about our use of cookies, please see our Cookie Notice (provide hyperlink). Finally, we may collect your photograph from publicly available sources so that we can recognize you in order to provide you with superior customer service. How do we protect personal information? We use a variety of security measures and technologies to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction, consistent with applicable data protection and privacy laws including “cloud servers” owned by Google, Amazon Web Services and other property management and booking systems. Any payment transactions will be encrypted using SSL technology; all payment information is stored with our payment processor and is never stored on our servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and suggest that you change your password frequently. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the Products; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. What information is not secure? We endeavor to protect the privacy of your account and other personal information that we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. Also, while we endeavor to put adequate contractual protections in place, we cannot guarantee the security of any personal information in databases hosted by third parties. It is important to note that any e-mail communication is not secure. This is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail (for example, from the “Contact Us” section of our website). We recommend that you do not include any confidential information (i.e. credit card information) when using e-mail. For your protection, our e-mail responses to you will not include any confidential information. Finally, to be prudent, please be sure to always close your browsers when you are done using a form or the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion, especially when using a public computer. What personal information may be provided to third parties? We may share certain of your personal information with:

• other Oceanic LLC, and managed properties;
• agents, contractors or social media and advertising platforms or third party service providers of Oceanic who provide services to Oceanic to better serve your needs as a guest;
• escrow agents, third party lenders and loan-servicing agents;
• a prospective buyer or investor in the event that we sell any business or assets;
• analytics and search engine providers that assist Oceanic in the improvement and optimization of the website and our mobile App;
• our professional advisors and auditors; and
• local or foreign regulators, governments, courts, law enforcement and national security authorities.

You may advise the hotel if you do not want personal preferences shared. Where a third party is engaged by Oceanic to provide services on our behalf, Oceanic ensures these parties protect your Personal Information in a manner consistent with the principles articulated in this Privacy Notice. In the case of third party residential property developers, the particular developer’s website can be consulted for the developer’s policy on the collection, storage and use of your personal information. If you have chosen to join a subscription list, please note that they are only used for internal purposes and we do not sell or rent our subscription lists to anyone. If Oceanic suspects any unlawful activity is taking place, it may investigate and/or report its findings or suspicions to the police or other relevant law enforcement agency. Transfers of your personal information outside your home country Your personal information may be processed by Oceanic and its trusted third party suppliers anywhere in the world, including in countries where data privacy laws may not be equivalent to, or as protective as, the laws in your home country. In particular, your personal information will be stored in your guest profile in our Central Reservation System located in USA and is available to all properties owned by Oceanic. We will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your home country. These measures include data transfer agreements implementing standard data protection clauses. You can find out more about data transfer agreements here. Your rights Accessing your personal information We understand that you may like to know what personal information we hold about you. We are happy to assist you with your request. To protect your personal information, however, we require that you prove your identity to us at the time your request is made. When you make a request in person, we will require you to produce some form of photo identification such as a passport or a driver’s license and you will be asked to sign a request form. Where you make a request by other means, we request you contact us in writing via email, fax or letter including a copy of a government issued identification and signature. We require home and business addresses and phone numbers so we can check them with our files and satisfy ourselves as to your identity. The above information is required to create an audit trail of how the request has been handled. Oceanic reserves the right to decline access to your personal information under certain circumstances as permitted by law. If your personal information is not disclosed to you, you will be provided with the reasons for this non-disclosure. Other rights You may also be entitled to:

• request the correction and/or deletion of your personal information;
• request the restriction of the processing of your personal information, or object to that processing;
• opt out from processing of your personal information for direct marketing purposes;
• withdraw your consent to the processing of your personal information (where Oceanic is processing your personal information based on your consent); and
• request the receipt or transmission to another organization, in machine-readable form, of the personal information you have provided to Oceanic.

Where you are given the option to share personal information with Oceanic, you can always choose not to do so. If you do not wish to receive marketing information from Oceanic, you may indicate your wishes on your registration card when you stay with us or send an e-mail to: info@oceanicenterprises.com. You will always have the ability to accept or decline any form of communication from Oceanic. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications. If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described above (see ‘How do we use your personal information?’) or that you are unable to make use of the services offered by us. After you have chosen to withdraw your consent Oceanic may be able to continue to process your personal information to the extent required or otherwise permitted by law. If at any time you wish to exercise any of these rights, you can do so by: For hotel guests, contacting our Corporate Office: via e-mail at info@oceanicenterprises.com via fax at 619-780-0974 via letter – Attention: Oceanic Enterprises 9685 Via Excelencia, Suite 208, San Diego, CA 92126 How long is my Personal Information retained? Your personal information will be stored for the period of time required by law in the jurisdiction of any hotel holding the information. This may involve retaining information following your stay. We will delete your personal information once it is no longer required for any of the purposes described above. We will also keep your personal information where we need to do so in connection with a legal action or an investigation involving Oceanic. Any financial information Oceanic retains will be protected under the terms of this Privacy Notice. What laws apply to this notice? By choosing to use our hotels and services, website, mobile applications or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the United States and the State of California, and the adjudication of any disputes arising in connection with Oceanic, the website or mobile applications will be in accordance with the Terms. Contact Us If you have any questions or concerns regarding this Privacy Notice, please contact our Data Protection Officer by writing to the following address: Data Protection Officer Oceanic Antelope Valley LLC 9685 Via Excelencia, Suite 208, San Diego, CA 92126 E-mail: info@oceanicenterprises.com COOKIE NOTICE Like many website owners and operators, we, as well as third parties that provide content, advertising, or other functionality on our website and mobile applications (“Services”), may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices. We use automated data collection tools such as Cookies and Web Beacons to collect certain information. Cookies

• “Cookies” are small text files that are placed on your device by a web server when you access our Services. We may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services. Some third-party services providers that we engage (including third-party advertisers) may also place their own cookies on your device. Note that this Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.

Pixels

• “Pixels”/“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

Widgets

• “Social Media Widgets” such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive miniprograms) may be on our Site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics

• We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/ privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories: Operationally Necessary

• We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions

Performance Related

• We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools

Functionality Related

• We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;

Advertising or Targeting Related

• We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.