Privacy Policy

Effective Date: July 2, 2026

The Hwood Group, LLC (d/b/a “h.wood Group”) and its subsidiaries operating under the h.wood brand (collectively, “h.wood”, “we”, “us”, or “our”) respect your privacy and use your personal information in an effort to fulfill our commitment to offering and providing exceptional service. This Privacy Policy (“Privacy Policy”) describes the privacy practices of h.wood, including the types of personal information we obtain, how we use this personal information, with whom we share it and the choices available regarding our use of the information. This Privacy Policy also describes the measures we take to safeguard the personal information and how you can contact us about our privacy policies.

This Privacy Policy applies to the personal information we obtain when you interact with h.wood, including but not limited to when you visit and use our venues (our “Venues”), use https://hwoodgroup.com and any other websites, mobile apps or online services or platforms of h.wood on which this Privacy Policy is included or linked to (collectively, the “Sites”), apply for a job with us or otherwise connect with us.

Click on one of the links below to jump to the listed section:

Information We Collect
Information We Obtain By Automated Means
Guest WiFi at Our Venues
How We Use Your Information
Third-Party Analytics Services
Internet-Based Advertising
Information Sharing
Your Choices
Text Messages
Biometric Information and AI-Enabled Systems
Automated Decision-Making and Profiling
Third-Party Sites
How We Protect Personal Information
Intended For Use By Adults
Updates To Our Privacy Policy
Contact h.wood
U.S. State Privacy Rights (including Your California Privacy Rights)

Information We Collect

The types of personal information we collect include:

Contact information, such as name, email and postal address and phone number.
Professional information, such as job title and employer details.
Login credentials (e.g. username and password).
Payment and financial information, such as your credit/debit card number, expiration date and security code, bank account number, and billing address.
Demographic information you provide when you visit a Venue or become a member of an h.wood service, such as date of birth, age, and gender identity or expression.
Membership and usage information, such as membership ID, the Venues you visit and the times you check in, products you purchase, preferences, and transaction history.
Personal preferences such as favorite Venues, services, or items.
Account information if you establish an online account with us, such as login credentials (e.g., username and password).
Images and videos, including photographs and CCTV video footage.
Biometric identifiers and biometric information derived from camera-based systems at certain Venues, as described in the “Biometric Information and AI-Enabled Systems” section below.
The geolocation of your device if you consent to the collection of this data.
Information in connection with applying for a job at h.wood such as employer and employment history, education, job function, salary, professional certifications and other resume information.
Social media handles, content and other information that you post to our social media pages or tag us on your social media pages, and information we obtain from third-party social media services (e.g., Facebook) if you choose to link to, or create or log in to your h.wood online account through, these services.
Other information you provide to us, including through emails and other communications, surveys, information or content transmitted or uploaded through your h.wood account (such as posts to message boards), and interactions with h.wood and its personnel, or information when you enter any sweepstakes, contests or promotions we may offer.

In many cases, we will collect the personal information described above directly from you. In some cases, however, we will collect the information from other sources, such as:

Affiliates, subsidiaries and parent companies: we may obtain your personal information from other h.wood Group entities and affiliated companies.
Business partners: we may obtain your information from other businesses with which we partner to provide you with products, services or offers we believe may be of interest to you.
Friends and family: we may obtain your information from your friends and family, such as when they refer to you our products, services or other offers.
Other sources: we may obtain information from other sources such as publicly available databases, joint marketing partners, social media platforms, consumer data resellers, online advertising companies, and vendors who provide services on our behalf.

Information We Obtain by Automated Means

When you interact with our Sites, we obtain certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use these automated technologies to collect information about your equipment, devices, internet connection, browsing actions, and usage patterns. The information we obtain in this manner may include your IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, browsing history, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Sites. We may also obtain information about how you interact with the Sites, such as features and pages you visit, search queries, and download errors. These technologies help us (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with our products and services; (3) tailor the products and services around your preferences; (4) measure the usability of our products and services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.

Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. At this time, our Sites are not designed to respond to DNT signals or similar mechanisms from browsers. For information about Do Not Track, please visit www.allaboutdnt.org. For California residents, please refer to the “Your California Privacy Rights” subsection of the “U.S. State Privacy Rights” section below for information on how you can opt out of the selling or sharing (for cross-context behavioral advertising purposes) of personal information using the Global Privacy Control.

Guest WiFi at Our Venues

Certain Venues offer complimentary guest WiFi. When you connect, you will be asked to provide certain information — typically your name and email address — through the WiFi login (captive portal) page. In addition, the network automatically collects certain technical information about your device and session, including your device’s MAC address, IP address, connection timestamps, session duration, bandwidth usage, device type and operating system, and session logs.

We use guest WiFi information to:

Authenticate your device and provide you with WiFi access;
Protect the security, integrity and performance of the network and the Venue, including detecting and preventing misuse;
Perform analytics regarding network usage and Venue operations; and
Conduct Venue marketing — including sending you automatic promotional emails after you connect to the WiFi network. Every promotional email we send includes an unsubscribe link, and you may opt out of these emails at any time as described in the “Your Choices” section below.

Guest WiFi personal information is not sold and is not shared for cross-context behavioral advertising purposes. Guest WiFi information is processed on the Venue’s behalf by third-party technology service providers acting as our service providers, using cloud-hosted infrastructure, under contracts that restrict their use of the information to providing services to us. Your use of guest WiFi is also subject to the WiFi terms of use presented on the captive portal page at the time you connect.

How We Use Your Information

We use the personal information we obtain about you to perform our contract with you or to take steps at your request prior to entering into a contract with you, including to:

Provide our services, products and other offerings to you.
Establish, manage and administer your membership and account with us, including verifying customer information and carrying out billing functions. We reserve the right to use any contact information held on file (including email, mailing address, and telephone or mobile phone) to contact you when administering your membership.
Provide a safe and secure environment for our guests, members and employees.
Process and fulfill your purchases in connection with our membership opportunities, products and services, and keeping you informed about the status of your membership and purchases.
Provide customer support services.
Manage career opportunities, including for recruitment purposes, candidate screening, interviewing and evaluation, and employee onboarding.
Establish and manage our relationships with our vendors, providers, suppliers and consultants.

We also use the information we obtain based on our legitimate interests and business purposes, including to:

Personalize and improve your experience on the Sites and at our Venues.
Provide you with a more personalized and relevant membership with h.wood.
Communicate with you about our products and services, and send you promotional and other marketing communications. See the “Your Choices” section below to learn how you can opt out of these communications.
Communicate with you about, and administer your participation in, sweepstakes, surveys, events, programs, contests, promotions and other offers.
Enable our affiliated companies and business partners (e.g., on-premises cafes and charitable organizations we partner with) to provide you with products and services, and send you information that you requested or that we think may interest you about their products or services.
Respond to your requests and inquiries.
Manage our business relationships.
Operate, evaluate, develop, manage and improve our business, including by operating, administering, analyzing and improving our Sites, products and services; conducting research and developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing, reconciliation and collection activities and other internal functions.
Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information);
Protect against, identify and prevent safety and security issues, fraud and other criminal activity, claims and other liabilities; and
Conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, and our policies and terms, and for the establishment, exercise or defense of legal claims, whether in court proceedings or in administrative or out-of-court procedures.

We use your personal information for these purposes because we have a legitimate business interest in providing services to our members, guests and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal information about you.

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., to process your payment). In this case, we may not be able to provide you with the product or service you have requested but we will endeavor to notify you if this is the case.

We also may use the information we collect about you in other ways for which we will provide specific notice at the time of collection and obtain your consent if required by applicable law.

Third-Party Analytics Services

We use third-party web analytics services on our Sites, such as Google Analytics. The service providers that administer these services use automated technologies to collect data (such as IP addresses) to evaluate use of the Sites.

To learn how to opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.

Internet-Based Advertising

When you visit our Sites, we may collect information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. This section of our Privacy Policy provides details and explains how to exercise your choices.

You may see certain ads on other websites because we engage third-party ad buying networks (such as Google Ads and Facebook). Through such ad networks, we can target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time and across multiple websites by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The networks use this information to show you ads that may be tailored to your individual interests. The information our ad networks may collect on our behalf includes data about your visits to websites that serve h.wood advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts.

To learn how to opt out of ad network interest-based advertising in the U.S., please visit http://www.aboutads.info/choices and http://www.networkadvertising.org/choices. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.

Information Sharing

We share your personal information with our vendors and other advisors such as law firms and auditors, who perform services or functions on our behalf, such as vendors who assist h.wood in maintaining the Sites, sending postal mail and email, managing and updating member lists and records, analyzing data, and facilitating customer service. In accordance with applicable law, we have entered into appropriate written agreements with our vendors and we do not authorize our vendors to retain, use or disclose the information for any purpose other than the specific purpose of performing services on our behalf or complying with legal requirements. However, in certain instances vendors may use aggregated, de-identified information for their reasonable business purposes such as improving their products or services or for statistical reporting.

We may share your personal information with our affiliates, subsidiaries and parent companies. In addition, we may share your personal information with other businesses with which we partner to provide you with products, services or offers we believe may be of interest to you, including on-premises businesses and charitable organizations we partner with. Notwithstanding the foregoing, mobile phone numbers and text messaging opt-in data and consent are never shared with third parties or affiliates for marketing or promotional purposes, as described in the “Text Messages” section below, and guest WiFi personal information and Biometric Data are handled as described in the “Guest WiFi at Our Venues” and “Biometric Information and AI-Enabled Systems” sections.

In accordance with applicable law, we may disclose information about you:

If we are required to do so by law or legal process (such as a court order or subpoena).
In response to requests by government agencies, such as law enforcement authorities.
To establish or defend our legal rights or to enforce our membership agreement, terms and conditions and other contracts with you.
When we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss.
In connection with an investigation of suspected or actual illegal activity or violation of our membership rules and policies.

We may otherwise disclose information where we have obtained your consent to do so. We also reserve the right to assign or transfer any information we have about you in the event of any merger, acquisition, sale of assets, sale of our business, joint venture, reorganization, divestiture, dissolution, liquidation or other corporate transaction, involving us or any of our parent companies or affiliates.

Social Media and Third Party Apps: We may share information with social networks when you interact with the Sites (e.g., clicking a Facebook “like” button) or connect your social media accounts to a Site. If you elect to connect Third Party Apps to the Sites, your information may also be shared with these third parties. Please see below for more information on this, as we do not control these third parties or their privacy practices.

Your Choices

Where required by applicable law, we will obtain your consent to send you marketing communications. If you do not wish to receive any marketing emails, you can opt out of future mailings by clicking on the unsubscribe link located on the bottom of the relevant email. If you are a member and have an account on the Sites, you can unsubscribe at any time by logging in and adjusting your communications preferences. If you are a member, please note that even if you opt out of receiving promotional emails, you will continue to receive administrative and operational communications regarding your membership, such as notices regarding billing, session reminders or club closures.

Text Messages

h.wood offers conversational text messaging so that our guests and members can communicate directly with our team — for example, regarding reservations, table bookings, private events, membership matters, and other guest services. These are individual, one-to-one (1:1) conversational messages sent to you by h.wood employees from their individual h.wood business phone numbers. They are person-to-person communications, not automated marketing blasts, and we do not send bulk promotional text campaigns from these numbers.

Consent. You may opt in to text messaging with h.wood by providing your mobile phone number and agreeing to receive text messages — for example, through a form on our Sites, by texting us first, or by giving your number to our team and agreeing to be contacted by text. Consent to receive text messages is not a condition of purchasing any goods or services from h.wood or of becoming or remaining a member of h.wood.

Information we collect and how we use it. When you communicate with us by text message, we collect your mobile phone number, your opt-in and consent records, and the content of the messages you send and receive (together with related delivery metadata). We use this information only to deliver and respond to your messages and to manage our messaging relationship with you, including maintaining records of your consent and honoring your opt-out requests. Text messages may be transmitted and stored by the messaging platform providers and telecommunications carriers that deliver the service on our behalf.

No sharing of mobile information. Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Message frequency and cost. Message frequency varies depending on your interactions with us. Message and data rates may apply, and you are responsible for any charges assessed by your mobile carrier or provider.

Help. For help, reply HELP to any message from h.wood, or contact us at privacy@hwoodgroup.com or +1 310-859-1011.

Opting out. You can opt out of text messages at any time by replying STOP — or QUIT, END, REVOKE, OPT OUT, CANCEL, or UNSUBSCRIBE — to any message from h.wood, or by contacting us at privacy@hwoodgroup.com. You may also revoke your consent by any other reasonable means. You may receive a single confirmation message acknowledging your opt-out. We honor opt-out requests promptly and in all cases within ten (10) business days, consistent with Federal Communications Commission rules.

SMS Terms. Our text messaging program is also governed by our SMS Terms, available at https://hwoodgroup.com/sms-terms. Please review them together with this Privacy Policy.

Biometric Information and AI-Enabled Systems

Collection. Certain of our venues use camera-based systems enhanced with artificial intelligence and computer vision. These systems may collect and process biometric identifiers and biometric information, including facial geometry and other measurements of physical characteristics derived from video imagery (“Biometric Data”). We collect Biometric Data only for the following purposes: security and loss prevention; guest safety; occupancy and operational analytics. If we intend to use Biometric Data for a materially different purpose, we will first provide notice and obtain any legally required consent.

Consent. We obtain consent before capturing Biometric Data wherever applicable law requires it. In Texas, this includes the Capture or Use of Biometric Identifier Act (CUBI) and the Texas Data Privacy and Security Act (TDPSA). We post conspicuous signage at the entrance of every venue where these systems operate, and entry into a posted venue constitutes notice of collection. Where the law requires affirmative opt-in consent, we obtain it at point of reservation confirmation.

Retention and Destruction. We retain Biometric Data only as long as reasonably necessary for the purposes described above, and never longer than 90 days for security footage-derived data. When the retention period ends, we permanently destroy the data or render it incapable of identifying an individual.

No Sale or Profit. We do not sell, lease, trade, or otherwise profit from Biometric Data, and we do not share it with third parties for their own commercial purposes. We disclose Biometric Data only to service providers who process it on our behalf under contractual confidentiality and data-protection obligations, or where a law, subpoena, or valid legal process requires disclosure.

Security. We protect Biometric Data with reasonable security measures that meet or exceed the standards we apply to our other confidential information, including encryption at rest and in transit; access controls; segregated storage.

Your Rights. Depending on your state of residence, you may have rights to know, access, correct, or delete Biometric Data we hold about you, and to limit the use of sensitive personal information. California residents may exercise these rights, including the right to limit use and disclosure of sensitive personal information, as described in the “Your California Privacy Rights” section of this Policy. To exercise any right, contact us at privacy@hwoodgroup.com. We do not discriminate against individuals who exercise their privacy rights.

Automated Decision-Making and Profiling

As described in the “Biometric Information and AI-Enabled Systems” section above, certain Venues use AI-enabled camera and computer-vision systems for security and loss prevention, guest safety, and occupancy and operational analytics. These systems assist our personnel; they operate under human oversight, and any consequential action (such as a security intervention or a decision about entry or service) is made by a person, not by the technology alone.

We do not use automated decision-making technology to make solely automated decisions that produce legal or similarly significant effects concerning consumers — such as decisions about financial or lending services, housing, insurance, education, employment, healthcare, or access to essential goods or services — without human involvement. We also do not use profiling to make such decisions on a solely automated basis.

Where the law of your state provides rights with respect to automated decision-making or profiling — such as the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, or rights of access to information about automated decision-making technology — you may exercise those rights as described in the “U.S. State Privacy Rights” section below, or by contacting us at privacy@hwoodgroup.com. If we adopt automated decision-making practices in the future that trigger additional notice, opt-out, or access obligations under applicable law (including regulations issued by the California Privacy Protection Agency), we will update this Privacy Policy and provide any required pre-use notices.

Third-Party Sites

For your convenience, the Sites may contain links to other online services or otherwise enable you to connect with third party sites, features, plug-ins, tools, widgets, social media platforms or apps such as Facebook, Instagram, X (Twitter), YouTube and Apple (collectively “Third-Party Sites”). Third-Party Sites operate independently from us, and the privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy policies of those third parties. You acknowledge and agree that your interactions with those Third-Party Sites, and your rights and obligations when accessing and using Third-Party Sites, are not governed by this Privacy Policy and will instead be governed by the terms and policies of those Third-Party Sites, and we encourage you to carefully read those terms and policies, as they may differ from ours.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE ARE NOT RESPONSIBLE FOR THE NATURE OR CONTENT OF, THE PRACTICES OF, OR THE COLLECTION, USE OR SHARING OF YOUR PERSONAL INFORMATION BY, ANY THIRD-PARTY SITES.

How We Protect Personal Information

h.wood maintains administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Intended for Use by Adults

The Sites are intended for use by adults, and you may use the Sites only if you are at least eighteen (18) years of age. The Sites are not intended for or directed to children under the age of thirteen (13), and we do not knowingly collect or store any personal information from children under the age of thirteen (13).

Updates to Our Privacy Policy

We may periodically update this Privacy Policy, in our discretion, to reflect changes in our privacy practices, the Sites and applicable law. We will post a notice on the Sites to notify you of significant changes to our Privacy Policy and indicate at the top of this Privacy Policy when it was most recently updated. You should check this page from time to time to ensure you are happy with our current Privacy Policy.

Contact h.wood

If you have questions regarding our Privacy Policy, please contact us at privacy@hwoodgroup.com. You may also write to us at:

The Hwood Group, LLC 9229 West Sunset Boulevard, Suite 900 West Hollywood, CA 90069 +1 310-859-1011

For general questions regarding h.wood, our Venues or the Sites please visit https://hwoodgroup.com/contact/. Your feedback is always welcome and appreciated.

U.S. State Privacy Rights

This section describes rights that may be available to you under the privacy laws of your state of residence, and how to exercise them. It includes specific disclosures for residents of California, Texas, Florida, and New York. Residents of other states with comprehensive privacy laws may have similar rights; we will honor verified requests as required by the law applicable to you.

Submitting Requests (All States)

How to submit a request. You (or your authorized agent, where permitted) may submit a privacy rights request by emailing privacy@hwoodgroup.com or by completing our privacy request web form at https://hwoodgroup.com/privacy-request-web-form. You may also call us at +1 310-859-1011 or make a request at one of our Venues.
Verification. To help protect your privacy and maintain security, we will take steps to verify your identity before granting access to your personal information or complying with a correction or deletion request. We may ask you to confirm information we are likely to already have on file based on your relationship with us — such as your member ID and date of last visit if you are an h.wood member, your email address and the h.wood Venue you visited if you are a guest or non-member, or information contained in your résumé if you are a job applicant. If you ask us to provide specific pieces of personal information, we may require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Authorized agents. Where permitted by your state’s law, you may designate an authorized agent to submit a request on your behalf using the methods above. We will require you and/or the agent to provide written proof of the agent’s authorization to act on your behalf, and we may still require you to verify your own identity.
Non-discrimination. You will not receive discriminatory treatment from us for exercising any of your privacy rights.
Appeals. If we decline to take action on your request and the law of your state (including Texas and Florida) gives you a right to appeal, you may appeal our decision by replying to our response or by emailing privacy@hwoodgroup.com with the subject line “Privacy Request Appeal.” We will respond to your appeal within the timeframe required by applicable law and, if we deny your appeal, we will provide you with a method to contact your state Attorney General to submit a complaint.

Your California Privacy Rights

(California Consumer Privacy Statement — Last Updated: July 2, 2026)

This “Your California Privacy Rights” statement (the “Statement”) supplements The Hwood Group, LLC’s Privacy Policy and applies solely to California consumers, including job applicants and personnel of our business customers and business partners. This Statement does not apply to The Hwood Group, LLC (“h.wood”) personnel. This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (the “CCPA”), as amended by the California Privacy Rights Act of 2020 (the “CPRA”), and its implementing regulations (the “CCPA/CPRA”).

1. Collection of Personal Information

We may collect (and may have collected during the 12-month period prior to the “Last Updated” date of this Statement) the following categories of personal information about you:

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; member or customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, date of birth, Social Security number, driver’s license number, passport number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, bank account number, credit card number, debit card number, or other financial information, education information, and medical information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, national origin, religion, age, sex, gender, gender identity, gender expression, marital status, medical condition, disability, citizenship status, and military and veteran status
Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
Biometric Information: biometric identifiers and biometric information, including facial geometry and other measurements of physical characteristics derived from video imagery at certain Venues, as described in the “Biometric Information and AI-Enabled Systems” section of the Privacy Policy
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Geolocation Data
Sensory Information: audio, electronic, visual, and similar information
Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not collect or process sensitive personal information with the purpose of inferring characteristics about California consumers covered by this Statement. Where we collect sensitive personal information (such as Biometric Data), we use it only for the purposes permitted by the CCPA/CPRA, such as ensuring security and integrity, and California residents may exercise the right to limit use and disclosure of sensitive personal information as described below.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

2. Use of Personal Information

We may use (and may have used during the 12-month period prior to the “Last Updated” date of this Statement) your personal information for the purposes described in our Privacy Policy and for the following business purposes specified in the CCPA/CPRA:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytics services, providing storage, or providing similar services
Providing advertising and marketing services to you, except for cross-context behavioral advertising (which is addressed in Section 5 of this Statement)
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us
Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes
Debugging to identify and repair errors that impair existing intended functionality
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

3. Retention of Personal Information

We will retain your personal information for the period reasonably necessary to achieve the purposes described in our Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law. Biometric Data is retained for no longer than the period stated in the “Biometric Information and AI-Enabled Systems” section of the Privacy Policy.

4. Sources of Personal Information

During the 12-month period prior to the “Last Updated” date of this Statement, we may have obtained personal information about you from the following categories of sources:

Directly from you, such as when you provide us with your contact information
Your devices, such as when you visit our Sites or connect to guest WiFi at our Venues
Operators of third party apps and operating systems with whom you choose to connect
Friends and family, such as when they refer you to our products, services or other offers
Our affiliates and subsidiaries
Vendors who provide services on our behalf
Data analytics providers
Business partners and joint marketing partners
Your employer if you are a representative of a business customer
Government entities
Online advertising companies
Social networks
Data brokers, such as background check services
Publicly available databases

5. Sale or Sharing of Personal Information

We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information by allowing certain third parties (such as social networks and online advertising services) to collect your personal information via automated technologies on our Sites for social networking and cross-context behavioral advertising purposes. We also may disclose your personal information to certain affiliated companies or promotional partners to serve you with content or offers that may be of interest to you. Under California law, these kinds of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information.

We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the “Last Updated” date of this Statement) the following categories of personal information about you to the following categories of third parties:

Category of Personal Information	Category of Third Party
Identifiers	Our affiliates and subsidiaries; business partners and joint marketing partners; online advertising services; social networks
Protected Classifications	Our affiliates and subsidiaries; business partners and joint marketing partners; online advertising services
Commercial Information	Our affiliates and subsidiaries; business partners and joint marketing partners; online advertising services
Online Activity	Our affiliates and subsidiaries; business partners and joint marketing partners; online advertising services; social networks
Inferences	Our affiliates and subsidiaries; business partners and joint marketing partners; online advertising services; social networks

We do not sell, and do not share for cross-context behavioral advertising purposes, Biometric Information, guest WiFi personal information, or text messaging opt-in data and consent. We do not have actual knowledge that we sell, or share for cross-context behavioral advertising purposes, the personal information of minors under 16 years of age.

6. Disclosure of Personal Information

During the 12-month period prior to the “Last Updated” date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information	Category of Third Party
Identifiers	Our affiliates and subsidiaries; vendors who provide services on our behalf; operators of third party apps and operating systems with whom you choose to connect; professional services organizations, such as auditors and law firms; business partners and joint marketing partners; business customers; online advertising services; data analytics providers; social networks; data brokers, such as background check services
Additional Data Subject to Cal. Civ. Code § 1798.80	Our affiliates and subsidiaries; vendors who provide services on our behalf; operators of third party apps and operating systems with whom you choose to connect; professional services organizations, such as auditors and law firms
Protected Classifications	Our affiliates and subsidiaries; vendors who provide services on our behalf; operators of third party apps and operating systems with whom you choose to connect; professional services organizations, such as auditors and law firms
Commercial Information	Our affiliates and subsidiaries; vendors who provide services on our behalf; operators of third party apps and operating systems with whom you choose to connect; professional services organizations, such as auditors and law firms
Biometric Information	Vendors who provide services on our behalf (service providers only, under contractual confidentiality and data-protection obligations); Biometric Information is never sold or shared for cross-context behavioral advertising
Online Activity	Our affiliates and subsidiaries; vendors who provide services on our behalf; operators of third party apps and operating systems with whom you choose to connect; professional services organizations, such as auditors and law firms; online advertising services; social networks
Geolocation Data	Our affiliates and subsidiaries; vendors who provide services on our behalf; operators of third party apps and operating systems with whom you choose to connect; professional services organizations, such as auditors and law firms; data analytics providers
Employment Information	Our affiliates and subsidiaries; vendors who provide services on our behalf; professional services organizations, such as auditors and law firms; data brokers, such as background check services
Inferences	Our affiliates and subsidiaries; vendors who provide services on our behalf; professional services organizations, such as auditors and law firms; online advertising services; business customers

In addition to the categories of third parties identified above, during the 12-month period prior to the “Last Updated” date of this Statement, we may have disclosed personal information about you to government entities (e.g., in response to a request from law enforcement authorities) and third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions or divestitures.

7. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold or shared about you during the past 12 months.
Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale or Sharing: You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
Limit Use and Disclosure of Sensitive Personal Information: To the extent we use or disclose sensitive personal information (such as Biometric Data) for purposes beyond those permitted by the CCPA/CPRA, you have the right to limit that use and disclosure. We currently use sensitive personal information only for permitted purposes, such as security and integrity.
Shine the Light: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.

How to Submit a Request. To submit an access, correction, or deletion request, please visit and complete our privacy request web form, available at https://hwoodgroup.com/privacy-request-web-form. You can opt out of the sale or sharing of your personal information by emailing privacy@hwoodgroup.com or, for disclosures that involve automated technologies on the device and browser you are currently using, by using the Global Privacy Control signal. Requests sent using the Global Privacy Control will apply to the device and browser from which they are submitted. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org. We encourage you to use these methods to submit your request, but you may also make a request using our toll-free number at +1 310-859-1011 or in one of our California Venues. To submit a request as an authorized agent on behalf of a consumer, please visit the web form set forth above. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf, we will require you and/or the authorized agent to provide to us written proof of their authorization to act on your behalf. To submit a Shine the Light request, please contact us at The Hwood Group, LLC, 9229 West Sunset Boulevard, Suite 900, West Hollywood, CA 90069, Attention: Privacy Rights Administrator, or at privacy@hwoodgroup.com with the subject line: California Privacy Rights. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. For questions or concerns about our privacy practices, please contact us as described in our Privacy Policy.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. We may require you to verify certain information we are likely to already have on file about you based on the type of relationship you have with us, such as your member ID and date of last visit if you are an h.wood member, your email address and h.wood Venue visited if you are a guest or non-member, or information contained in your résumé if you are a job applicant. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA/CPRA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Financial Incentives Disclosure: h.wood may provide certain special offers and benefits, such as a discount offer, as an incentive for individuals who sign up to receive marketing communications from us. In exchange for these incentives, you agree to provide certain personal information for use by h.wood for the reasons described in the Privacy Policy. The value of this personal information varies based on the special offer provided at the time you sign up, the amount purchased by you when using that special offer, and value of future special offers you receive from us and use to make purchases. The incentives we offer to you are reasonably related to the value provided to us by your personal information. If we offer a financial incentive, you may opt in to it by following the prompt to enter your email address to receive a discount. You have the right to withdraw from financial incentives at any time by opting out of our marketing emails. See the “Your Choices” section of our Privacy Policy to learn how you can opt out of these communications.

Online Erasure Requests: If you are a California resident under the age of 18 and an h.wood member with a digital account, you may request and obtain removal of content or information you have publicly posted on the Sites. To make this request, please email us at privacy@hwoodgroup.com and include a detailed description of the specific content or information you would like to remove. Please note that this removal does not ensure complete or comprehensive removal of the content or information posted on the Sites by you as there may be circumstances in which the law does not require or allow removal.

Your Texas Privacy Rights

If you are a Texas resident, the Texas Data Privacy and Security Act (“TDPSA”) gives you the following rights with respect to personal data we hold about you as a controller:

Access: to confirm whether we are processing your personal data and to access that personal data.
Correction: to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of processing.
Deletion: to delete personal data provided by or obtained about you.
Portability: to obtain a copy of personal data you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Opt-Out: to opt out of the processing of your personal data for purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you. As described in the “Automated Decision-Making and Profiling” section above, we do not engage in such profiling on a solely automated basis.

To exercise these rights, use the methods described in “Submitting Requests (All States)” above. We will respond within the time required by the TDPSA (generally 45 days, extendable once by 45 days where reasonably necessary). Appeals: if we decline to take action on your request, you may appeal within a reasonable period by emailing privacy@hwoodgroup.com with the subject line “Privacy Request Appeal.” We will inform you in writing of any action taken or not taken on your appeal within 60 days, together with a written explanation of the reasons. If your appeal is denied, you may submit a complaint to the Texas Attorney General at https://www.texasattorneygeneral.gov.

Texas biometric consent (CUBI): Texas’s Capture or Use of Biometric Identifier Act requires notice and consent before capturing a biometric identifier for a commercial purpose. As described in the “Biometric Information and AI-Enabled Systems” section above, we provide notice and obtain consent as required by CUBI and the TDPSA before capturing Biometric Data at our Texas Venues, we do not sell Biometric Data, and we destroy it within the retention period stated in that section.

Your Florida Privacy Rights

Florida’s Digital Bill of Rights (“FDBR”) provides certain privacy rights to Florida consumers. By its terms, the FDBR’s core controller obligations apply to businesses that meet specific thresholds (including annual global gross revenue in excess of $1 billion and certain other criteria), which may not apply to h.wood. As a matter of good practice, we nonetheless extend the following rights to Florida residents:

Access: to confirm whether we are processing your personal data and to access that personal data.
Correction: to correct inaccuracies in your personal data.
Deletion: to delete personal data provided by or obtained about you.
Portability: to obtain a copy of your personal data in a portable and readily usable format.
Opt-Out: to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of a decision that produces a legal or similarly significant effect concerning you.
Voice and Facial Recognition: to opt out of the collection of personal data through the operation of voice recognition or facial recognition features, to the extent provided by the FDBR. Please note that our Venue security and safety systems described in the “Biometric Information and AI-Enabled Systems” section operate as described in that section, and Florida venues display the entrance signage described there.

To exercise these rights, use the methods described in “Submitting Requests (All States)” above. If we decline to take action on your request, you may appeal as described in that subsection, and if your appeal is denied, we will provide you with information on how to contact the Florida Attorney General.

Your New York Privacy Rights

New York does not currently have a comprehensive consumer privacy statute. However:

NYC Biometric Identifier Information Law (N.Y.C. Admin. Code § 22-1201 et seq.): At any New York City Venue where we collect biometric identifier information from customers (as described in the “Biometric Information and AI-Enabled Systems” section above), we post clear and conspicuous signage near all customer entrances disclosing that biometric identifier information is being collected. We do not sell, lease, trade, share in exchange for anything of value, or otherwise profit from the transaction of biometric identifier information.
New York SHIELD Act: In accordance with New York’s Stop Hacks and Improve Electronic Data Security (SHIELD) Act, we maintain a data security program with reasonable administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of private information of New York residents, and we will provide notice of security breaches as required by New York law.

New York residents may contact us at privacy@hwoodgroup.com with any questions or requests regarding their personal information, and we will honor requests as required by applicable law.