Convene Hospitality Group Privacy Notice
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This Privacy Notice applies to personal information processed by Convene Hospitality Group LLC and/or members of the Convene Hospitality Group corporate family including, but not limited to, Convene, etc. venues, The Mallory, The Aperture, and NeueHouse (collectively “Convene Hospitality Group,” “we,” “us,” and “our”) in our business, as collected from our website(s) (each a “Site”), mobile application (the “App”), virtual event services, Convene Hospitality Group properties, and related online or offline offerings (collectively, the “Services”).
California Notice at Collection: See the “Supplemental Notice for California Residents” section below for important information about our processing of personal information that is subject to the California Consumer Privacy Act.
Notice to European users: If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”) (which we refer to as “Europe,” and “European” should be understood accordingly), see the “International Transfers of Personal Information” section below.
PERSONAL INFORMATION WE COLLECT
When you use our Services, we may collect the following categories of personal information:
Information You Provide to Us.
Contact Information including your name, email address, phone number, and other information.
Verification Information including a photo or government issued ID and your date of birth.
Professional Information including your company name, title, role, team, and other related information.
Preference Information including dietary restrictions or other information you have shared with us.
Payment Information including your payment card details or other financial information necessary to facilitate a transaction you request.
Health and Safety Information including proof of COVID-19 vaccination and your responses to our questions related to our COVID-19 prevention efforts. If you are visiting a Convene Hospitality Group property and refuse to provide this information when requested, then you may not be permitted entry to the Convene Hospitality Group property.
Convene Hospitality Group Wi-Fi. If you use one of the Wi-Fi networks in one of our properties, we will collect personal information from you to log you on to the network, including your name and email address. We may also collect information about your use of the Wi-Fi, such as the web pages you visit, your MAC or IP address, and your inferred location while using the Wi-Fi.
Email Calendar Information. If you choose to integrate your email calendar with our room scheduling software, we will collect information regarding the rooms you book.
Communications with Us. We may collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, sign up for our newsletter, request customer or technical support, or otherwise communicate with us.
Customer Service and Support. If you call or otherwise interact with our customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.
Interactive Features. We may offer interactive features such as commenting functionalities, chat services, collaboration tools, review forums, and social media pages. We and the individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and may not be subject to the privacy protections referenced herein.
Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in the Convene Hospitality Group and/or the Services.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Job Applications. We may post job openings and opportunities on the Services. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.
Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
Information We Collect Through Your Use of the Service
We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, Technologies including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off your IP address), Internet service provider, pages that you visit while using the Services, analytics and details about your activities when attending one of our virtual events, and other information about how you use the Services. Information we collect may be associated with your account and the devices you use.
Cookies, Web Beacons, and Personalized Advertising. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with the Services.
- Cookies. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
- Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These Technologies allow us to better understand how our digital Services are used and to continually improve and personalize our Services. Some of the analytics providers we may use include:
- Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
- Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.
- LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.
BLE Beacons. If configured properly, our App may include the capability to read and process Bluetooth (BLE) “beacons.” “Beacons” are small Bluetooth-enabled devices that may be placed throughout Convene Hospitality Group properties that emit a unique signal that our App can detect and process.
When the App on your mobile device detects a BLE beacon, we will collect your mobile identifier (e.g., IDFA or Ad Id), the location data and metadata associated with the BLE Beacon signal (e.g., the known location and ID of the BLE beacon detected, the App’s latitude/longitude coordinates, and the date and time the BLE beacon was detected), and information about your mobile device such as the device type, model and operating system version, device language, mobile carrier, device name, device processes, device battery state, device speed, and current IP address.
Please note that in order for our App to detect and process BLE beacons, you must have: (i) the App open on your mobile device; (ii) Bluetooth enabled on your mobile device; and (iii) Location Services enabled for the App.
To opt-out of our collection of BLE beacon signals using the App, disable your mobile device’s Bluetooth capabilities and/or Location Services for the App.
If you have any questions about our use of BLE beacons, please contact us as set forth below.
CCTV. Some of the Convene Hospitality Group’s properties may have CCTV installed to protect the safety of our employees, members, guests, and properties. In addition, we may also use CCTV footage to improve our products and Services, including to analyze how individuals navigate and utilize our spaces.
Recordings at Virtual Events. If you use our Services to attend a virtual event, the virtual event buyer may record certain audio and/or video footage which may include your personal information.
De-Identified and Aggregated Information. When you visit Convene Hospitality Group properties, we may generate and/or collect de-identified and/or aggregated information from your use of the Services, including information about how individuals navigate and utilize our properties. For example, we may place sensors in rooms that inform us when an individual has entered or exited a room. De-identified and/or aggregated information is not personal information.
Personal Information from Other Sources
Third Party Organizations. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as a social networking service or a third-party login service, we may collect information about you from that third party that you have made available via your privacy settings.
Members of our Corporate Family. We may obtain personal information from members of our corporate family including our affiliates.
Convene Hospitality Group Customers. We may receive personal information from our customers in the form of an attendee, invitee, or employee list. Our use of this information may be governed by a separate contract with our customer, but typically it is used to facilitate your access to and enjoyment of our properties and events.
Verification Information. Building management or security in some of the Convene Hospitality Group’s properties may require you to provide personal information (such as a photo or government issued ID, and/or your date of birth) and may use the information or a copy thereof to produce a badge or other identification for you to use to gain access to and while in the building. We do not control or otherwise participate in the building’s collection of verification information by building management and/or security. If a copy of this information is provided to us, we will use it in accordance with this Privacy Notice.
HOW WE USE YOUR PERSONAL INFORMATION
We process personal information for a variety of business purposes, including:
To Provide the Services, Products, or Information Requested.
- Perform our contract with you;
- Manage your account and information;
- Allow you to register for events;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of our Services; and
- Answer requests for customer or technical support.
Administrative Purposes.
- Measure interest and engagement in the Services;
- Improve our products and Services;
- Develop new products and services;
- Ensure internal quality control;
- Verify individual identity;
- Communicate with you about your account, activities on the Services and policy changes;
- Process your payment card information and/or other payment methods for products or services purchased;
- Process applications if you apply for a job we post;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms of Service; and
- Comply with our legal obligations.
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we may market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising” including through cross-device tracking.
We may use personal information to understand and measure advertising campaigns, including to understand whether or not you saw one of our ads and measure conversions.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
De-identified and Aggregated Information Use. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified and/or aggregated trends, reports, or statistics, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws.
Technologies. Our uses of such Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services and keeping track of your specified preferences or past pages viewed;
Advertising or Targeting Related. We may use first-party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our Services or on third-party sites. Some of the advertising Technologies we may use include:
- Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
- Microsoft For more information about Microsoft’s use of your personal information, please review Microsoft’s Privacy Statement. To control the use of your personal data in Microsoft advertising, please visit their opt-out page.
- LinkedIn For more information about LinkedIn’s use of your personal information, please refer to the LinkedIn Privacy Policy. Your choices related to LinkedIn advertising can be found here.
Other Uses. We may use personal information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention. In addition, we may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We Use Service Providers. We may share any personal information we collect about you with our third-party service providers. The types of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment processing; (v) customer service activities; and (vi) the provision of IT and related services.
Members of our Corporate Family. We may share personal information with members of our corporate family including, but not limited to, affiliates and parent organizations. In some cases, these entities may use the personal information we provide to them to send marketing and other information that may be of interest to you.
Customers. If your use of our Services is based on a contract we have with our customer (e.g., your employer, a landlord for whom we manage a physical space, or an event buyer that is using the Convene Hospitality Group to host an event), we may share information about your use of our Services with the relevant customer(s).
For example, if you use our workspaces under a contract we have with your employer or an organization with which you are affiliated, we may provide information about your use to your employer and/or the organization with which you are affiliated. Similarly, we provide our event services so that you can interact with event buyers. If you attend a virtual event or an event at one of our physical spaces, we may provide your contact information and information about your attendance (including analytics about your activities in the case of virtual events) to our customer that organized the event.
Once your personal information has been shared with our customer, it will also be subject to our customer’s privacy policy. Please note that we do not control and we are not responsible for our customer’s processing of your personal information.
Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide relevant personal information to business partners with whom we jointly offer products or services.
Landlords, Building Management, and Security. In some cases, we may share your personal information with our landlords, building management and/or security at Convene Hospitality Group properties (each a “Property Management Party”). Your personal information may also be subject to the privacy policy of the Property Management Party. We are not responsible for the processing of personal information by Property Management Parties.
Interest-Based or Personalized Advertising. Through our Services, we may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar event, then your information may be sold or transferred in connection with such a transaction as permitted by law and/or contract.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States and other countries, which may have data protection laws that are different from the laws where you live.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
YOUR CHOICES
General. You may be able to opt out of certain uses of your personal information.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).
Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.
Phone Calls. If you receive an unwanted marketing phone call from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
Mobile Devices. We may send you push notifications through the App. You may opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect location-based information when you use the App. You may opt-out of this collection by changing the settings on your mobile device.
To opt-out of our collection of BLE beacon signals using the App, disable your mobile device’s Bluetooth capabilities and/or disable Location Services for the App.
Technologies and Personalized Advertising. If you would like to opt-out of the Technologies we employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
INDIVIDUAL RIGHTS IN PERSONAL INFORMATION
In accordance with applicable law, you may have the right to:
- Confirm Whether We Are Processing Your Personal Information (the right to know);
- Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (also known as the “right of data portability”);
- Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
- Request Deletion of your personal information;
- Request Restriction of or Object to our processing of your personal information, including for direct marketing purposes and profiling related to such direct marketing; and
- Withdraw Your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
- EEA Data Protection Authorities (DPAs)
- Swiss Federal Data Protection and Information Commissioner (FDPIC)
- UK Information Commissioner’s Office (ICO)
RETENTION OF PERSONAL INFORMATION
We retain the personal information we receive as described in this Privacy Notice for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
LEGAL BASIS FOR PROCESSING
If you your personal information is subject to the EU or UK General Data Protection Regulation, our processing of your personal information may be supported by one or more of the following legal bases:
- Performance of a Contract: we may need to process your personal information to perform our contract with you or your employer.
- Legitimate Interest: we may process your personal information to further its legitimate interests but only where our interests are not overridden by your interests or fundamental rights and freedoms.
- Consent: In some cases, we may also rely on your consent to process your personal information.
- Compliance with our Legal Obligations: we may process your personal information to comply with our legal obligations.
THIRD PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
CHILDREN’S INFORMATION
The Services are not directed to children under 16 (or other age as required by local law outside of the United States), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any child’s personal information in violation of applicable law, we will promptly take steps to delete such information.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents supplements our Privacy Notice and only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (as amended from time to time) (“CCPA”).
The CCPA provides California residents with the right to know what categories of personal information Convene Hospitality Group has collected about them, whether Convene Hospitality Group disclosed that personal information for a business purpose (e.g., to a service provider), whether Convene Hospitality Group “sold” that personal information, and whether Convene Hospitality Group “shared” that personal information for “cross-context behavioral advertising” in the preceding 12 months. California residents can find this information below:
| Category of Personal Information Collected by Convene Hospitality Group | Category of Third Parties Personal Information is Disclosed to for a Business Purpose | Category of Third Parties to Whom Personal Information is Sold and/or Shared |
|---|---|---|
| Identifiers |
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| Internet or other electronic network activity |
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| Sensory data |
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| Professional or employment-related information |
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| Inferences drawn from other personal information to create a profile about a consumer |
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| Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
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| Personal information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
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| Personal information collected and analyzed concerning a consumer’s health |
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| Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation |
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The categories of sources from which we collect personal information and our business and commercial purposes for using and disclosing personal information are set forth in “Personal Information We Collect”, “How We Use Your Personal Information”, and “How We Disclose Your Personal Information” above, respectively. We will retain personal information in accordance with the time periods set forth in “Retention of Personal Information.”
We “sell” and “share” your personal information to provide you with “cross-context behavioral advertising” about our products and services.
Additional Disclosures for California Residents
Right to Opt Out of “Sales” of Personal Information and/or “Sharing” for “Cross-Context Behavioral Advertising”
California residents have the right to opt out of the “sale” of personal information and the “sharing” of personal information for “cross-context behavioral advertising.” California residents may exercise these rights by clicking here and following the instructions on that page.
Disclosure Regarding Individuals Under the Age of 16. We do not have actual knowledge of any “sale” of personal information of minors under 16 years of age. We do not have actual knowledge of any “sharing” of personal information of minors under 16 years of age for “cross-context behavioral advertising.”
Disclosure Regarding Sensitive Personal Information. Convene Hospitality Group uses and discloses sensitive personal information only for the purposes set forth in Section 7027(m) of the CCPA regulations.
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To authorize an agent, provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.
Verification. To protect your privacy, we will take steps to reasonably verify your identity before fulfilling requests submitted under the CCPA. These steps may involve asking you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Examples of our verification process may include asking you to provide the email address we have associated with you, as well as details about your last visit to a Convene location, and following the instructions we provide to you.
CHANGES TO OUR PRIVACY NOTICE
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that your personal information will be subject to the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
CONTACT US
If you have any questions about our privacy practices or this Privacy Notice, or if you wish to submit a request to exercise your rights as detailed in this Privacy Notice, please contact us at:
Our US Headquarters:
Convene Hospitality Group
Attention: Legal Affairs
530 Fifth Avenue, Suite 709
New York, NY 10036
privacy@convenehospitality.com and legal@convene.com
Our UK Headquarters:
etc.venues
Attention: Convene Hospitality Group Legal Affairs
200 Aldersgate Street
London, United Kingdom, EC1A 4HD
Our Designated EU Representative:
DataRep
Attention: Convene Hospitality Group Legal Affairs
The Cube, Monahan Road
Cork, T12 H1XY, Republic of Ireland
