CUSTOMER PERSONAL DATA PROTECTION CHARTER

1. Here For You Hospitality's commitment to protecting privacy
2. Consent
3. Here For You Hospitality's principles for protecting your personal data
4. Scope of application
5. What personal data is collected?
6. When is your personal data collected?
7. For what purposes?
8. Conditions of third-party access to your personal data
9. Protection of your personal data during international transfers
10. Data security
11. Cookies
12. Storage of data
13. Access and modifcation
14. Updates
15. Questions and contacts

1. HERE FOR YOU HOSPITALITY'S COMMITMENT TO PROTECTING PRIVACY

Because we consider you an important customer, our first priority is to offer an exceptional time and stay with us.

Your complete satisfaction and confidence in Here for you Hospitality are absolutely essential to us.

That's why as part of our commitment to meeting your expectations, we have set up a customer privacy protection policy. This Charter formalizes our commitments to you and describes how Here for you Hospitality uses your personal datas.

The main rules applicable within Here for you Hospitality are founded on six principles.

2. CONSENT

"Personal data" means any information collected and logged in a format that allows you to be identified personally, either directly (e.g name) or indirectly (e.g telephone number) as a natural person. Before providing us with this information, we recommend that you read this document describing our customer privacy protection policy.

This personal data protection charter forms part of the terms and conditions that govern our hotel services. By accepting these terms and conditions, you expressly accept the provisions of the Charter.

3. HERE FOR YOU HOSPITALITY'S SIX PRINCIPLES FOR PROTECTING YOUR DATA

The six principles below are applicable within Here for you Hospitality Group

1. Transparency: When collecting and processing your personal data, we will communicate all informationto you and inform you of the purpose and recipients of the data.

2. Legitimacy: We will collect and process your personal data only for the purposes described in the Charter.

3. Relevance and accuracy: We will only collect personal data if necessary for data processing. We will take all reasonable steps to ensure that the personal data we hold is accurate and up to date.

4. Storage: We will hold your personal data for the period necessary for processing the same in compliance with the provisions of the law.

5. Access, rectification, opposition: You may access, modify, correct or delete your personal data. You may also oppose the use of your personal data, particularly to avoid receiving sales and marketing information. The details of the relevant personnel to contact in this respect are shown below (13) in the clause "Access and modification".

6. Confidentiality and security: We will ensure reasonable technical and organizational measures are in place to protect your personal data against alteration or accidental or unlawful loss, or unauthorized use, disclosure or access.

For any questions concerning the six principles of Here for you Hospitality Data Protection, please contact the relevant person whose details appear in the clause "Access and modification".

4. SCOPE OF APPLICATION

This Charter applies to all Trading Businesses under ownership of Here for you Hospitality Ltd.

5. WHAT PERSONAL DATA IS COLLECTED?

At various times, we will be obliged to ask you, as an Here for you Hospitality customer, for information about you and/or members of your family, such as:

- Contact details (for example, last name, first name, telephone number, email)
- Personal information (for example first name, date of birth, age)
- Information relating to your children (for example first name, date of birth, age)
- Your credit card number (for transaction and reservation purposes)
- Your arrival and departure dates
- Health related questionnaire (for those cutomers joining our Escape Zone gym)
- your preferences and interests (for example, smoking or non-smoking room, preferred floor, type of bedding, type of newspapers/magazines, sports, cultural interests)
- Your questions/comments during or following a stay in one of our establishments.

The information collected in relation to persons under 18 years of age is limited to their name, nationality and date of birth, which can only be supplied to us by an adult. We would be grateful if you could ensure that your children do not send us any personal data without your consent (particularly via the Internet). If such data is sent, you can contact the relevant person detailed in the "Access and modification" to arrange for this infomation to be deleted.

We do not deliberately collect sensitive information, such as information concerning race, ethnicity, political opinions, religious and philisophical beliefs, union membership, and sexual orientation. The health questionnaire does not ask for detailed medical information.

Other information could be considered sensitive, such as your credit card number, your leisure activities, personal activities and hobbies, and whether or not you are a smoker. We may be obliged to collect such information in order to meet your requirements or provide you with an appropiate service, such as a specific diet.

In this case, depending on the law in force, your prior consent may be required with regard to the collection of sensitive information.

6. WHEN IS YOUR PERSONAL DATA COLLECTED?

Personal data may be collected on a variety of occasions, including:

1. Hotel activities:

- Booking a Hotel room/wedding/conference/tribute event
- Checking - in and paying
- Eating/drinking at the hotel bar or restaurant during your stay
- Requests, complaints and/or disputes
- Joining the Escape Zone Leisure Club

2. Participation in marketing programs or events:

- Participation in customer surveys (for example, the Guest Satisfaction Survey)
- Online games or competitions
- Subscription to newsletters, in order to receive offers and promotions via email

3. Transmission of information from third parties:

- Tour operators, travel agencies, GDS reservation systems, and others

4. Internet activities

- Connection to Sporting Lodge Websites (IP address, cookies)
- Online forms (online reservation, questionnaires, Sporting Lodge Inns pages on social networks, network login devices such as Facebook login etc)

7. FOR WHAT PURPOSES?

We collect your personal data for the purposes of:

1. Meeting our obligations to our customers.
2. Managing the reservation of rooms and accommodation requests:

- Creation and storage of legal documents in compliance with accounting standards

3. Managing your stay at the hotel:

- Monitoring your use of services
- Managing access to rooms
- Internal management of lists of customers having behaved inappropriately during their stay at the hotel (aggressive, anti- social behaviour, non-compliance with the hotel contract, non-compliance with safety regulations, theft, damage and vandalism, or payment incidents)

4. Improving our hotel service:

- Processing your personal data in our customer marketing program in order to carry our marketing operations and gain a better understanding of your requirements and wishes
- Adapting our products and services to better meet your requirements
- Customizing commercial offers and the promotional messages we send to you

5. Managing our relationship with customers before, during and after your stay:

- Providing details for the customer database
- Segmentation operations based on reservation history and customer travel preferences with a view to sending targeted communications
- Knowing and managing the preferences of new or repeat customers
- Sending you newsletters, promotions, or contacting you by telephone
- Managing requests to unsubscribe from newsletters, promotions, and satisfaction surveys
- Taking into account the right to object

6. Conforming to local legislation (for example, storing of accounting documents)

8. CONDITIONS OF THIRD-PARTY ACCESS TO YOUR PERSONAL DATE

We have to share your personal date with internal and external recipients subject to the following conditions:

- Hotel staff
- Head Office Staff
- IT Support
- Commercial Partners (third party booking agents, travel agents, tour operators)
- Medical services, if applicable
- Legal services if applicable

b. With service providers, and partners your personal data may be sent to a third party for the purposes of supplying you with services and improving your stay. for example:
1. External providers: IT sub-contractors, banks, credit card issuers, external lawyers, entertainment and wedding suppliers

c. Local authorities: we may also be obliged to send your information to local authorities if this is required by law or as part of an inquiry and in accordance with local regulations.

9. PROTECTION OF YOUR PERSONAL DATA DURING INTERNATIONAL TRANSFERS

For the purposes set out in Clause 7 of this Charter, we may transfer your personal data to internal or external recipients who may be in countries offering different levels of personal data protection.

Consequently, in addition to implementation of this Charter, Here for you Hospitality employs appropiate measures to ensure secure transfer of your personal data to an Here for you Hospitality entity or an external recipient located in a country offering a different level of privacy from that proposed in the country where the personal data is collected.

Other than those that are required to carry out your reservation, dataflows to countries having different leveles of personal data protection are regulated by standard contractual manager-to-subcontractor clauses defined by the European Commission.

10. DATA SECURITY

Here for you Hospitality takes appropiate technical and organizational measures, in accordance with applicable legal provisions, to protect your personal data against illicit or accidental destruction, accidental alteration or loss, and unauthorized access or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as user ID/password system, means of physical protection etc).

When you submit credit card data when making your reservation, SSL (Secure Socket Layer) encryption technology is used to guarantee a secure transaction.

11. COOKIES

Use of cookies by

These tracers may be installed on your device depending on the preferences that you expressed or may express at any time in accordance with this policy.

1. Why have a cookies policy?

With a view to provide information and ensure transparency, Here for you Hospitality established this policy so that you can learn more about:

- The origin and purpose of the information processed when you browse Here for you Hospitality Websites

- Your rights with regard to cookies and tracers used by Here for you Hospitality

2. What is a cookie?

Cookies and other similar tracers are packets of data used by servers to send status information to a user's browser and return status information to the original server through this same browser.

The status information can be a session identifier, a language, an expiration date, a response field or other types of information.

During their validity period, cookies are used to store status information when a browser accesses various pages of a website or when the browser returns to this website at a later point.

There are different types of cookies:

- Session cookies, which are deleted as soon as you exit the browser or leave the website
- Persistent cookies, which remain on your device until their expiration or until you delete them using the features of your browser

3. Why use cookies?

We use cookies and other tracers primarily for the following purposes:

Cookies strictly necessary for browsing the Here for you Hospitality Websites and the ability to use all of their features, are intended in particular to:

 - Manage authentication of website visitors and the associated security measures, and ensure proper functioning of the authentication module
- Opimize the user experience and facilitate browsing, in particular determining "technical routes" for browsing
- Store information regarding the "cookies" information banner seen by website visitors who then continue to browse the website after agreeing to accept cookies on their device
- Implement security measures (for example, when yiu are asked to log in again for content or a service after a certain period of time, or to ensure basic operation of Here for you Hospitality Website and use of their major technical features, such as monitoring of performance and browsing errors, management of user sessions, etc.)

Cookies for features intended in particular to:

 - Store specific information that you enter on Here for you Hospitality Websites in order to facilitate and customize your subsequent visits (including displaying the visitor's names if the visitor has a user account)
- Allow you to access your personal pages more quickly by storing the login details or information that you previously entered

Cookies for visitor tracking are aimed at improving the comfort of users by helping us understand your interactions with Here for you Hospitality Websites (most visited pages, applications used etc); these cookies may collect statistics or test different ways of displaying information in order to improve the relevance and usability of our services.

Advertising cookies are intended to (i) offer you, in advertising spaces, relevant, targeted content that may be of interest to you (best offers, other destinations etc). based on your interests, browsing behaviour, preferences, and other factors, and (ii) reduce the number of times that the advertisements appear.

Affiliate cookies identify the third-party website that redirected a visitor to Here for you Hospitality Websites.

Social network cookies, set by third-parties, allow you to share your opinion about the content from Here For You Hospitality Websites on social networks (for example, the "Share" or "Like" application buttons for social networks).

 The social network applications on Here for you Hospitality Websites as mentioned above can in some cases allow the social networks concerned to identify you even if you did not click on the application button. This type of button can allow social network to track your browsing on Here for you Hospitality Websites, simply because your account in the social network concerned is enabled on your device (open session) while you are browsing.

We recommend that you read the policies of these social networks to familiarize yourself with how they use the browsing information they may collect, especially with regard to advertising. These policies must specifically allow you to make choices on these social networks, particularly by configuring your user accounts for each of them.

4. Consent

The installation of certain cookies is subject to your consent, Also, when you first visit the Here for you Hospitality Websites, you are asked whether you agree to the installation of this type of cookie, which is only activated after your acceptance.

This process is supported by means of an information banner on the home page of the Here for you Hospitality Websites, which informs you that by continuing to browse, you are agreeing to the installation of cookies that require consent to your device.

You can change your mind at any time using the various methods described in section "Deleting and/or blocking cookies"

5. Deleting and/or blocking cookies

You have several options for deleting cookies and other tracers.

Browser setttings

Although most browsers are set by default to accept cookies, you can, if you desire, choose to accept all cookies, always block cookies, or choose which cookies to accept based on their senders.

You can also set your browser to accept or block cookies on a case-by-case basis before they are installed. Your browser also allows you to regularly delet cookies from your device. Remember to configure all the browsers in your different devices (tablets, smartphones, computers etc)

Regarding management of cookies and your preferences, configuration varies for each browser. This is described in the Help menu on your browser, as well as how to edit your preferences with regard to cookies. For example:

- For Internet Explorer: http://windows.microsoft.com/en-IS/windows-vista/Block-or-allow-cookies

- For Safari: http://www.apple.com/legal/privacy/en-ww/cookies

- For Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&hlrm=en&answer95647

- For Firefox: http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

- For Opera: http://help.opera.com/Windows/10.20/en/cookies.html

Saving a cookie to your device depends on your wishes, which you can exercise and change at any time and free of charge using the settings offered by your browser software.

If your browseris set to accept cookies on your device, the cookies embedded in the pages and content that you view may be temporarily stored in a dedicated space on your device. They can only be read by their issuer. However,

You can set your browser to block cookies. Keep in mind that if you set your browser to block cookies, some features, pages and spaces on Here for you Hospitality Websites will not be accessible, and we cannot be held responsible in this case.

12. STORAGE OF DATA

We retain your personal data only for the period necessary for the purposes set out in this Charter or in accordance with the provisions of applicable law.

13. ACCESS AND MODIFICATION

You have the right to access your personal data collected by Here for you Hospitality and to modify it subject to applicable legal provisions.

You may also exercise your right to object by writing to the address below.

In the event of difficulty exercising your rights, please contact Here for you Hospitality directly by sending an email to midds.reservations@hfyh.co.uk or by writing to the address below:

Sporting Lodge Hotel
Low Lane
Middlesbrough
TS17 9LW

For the purposes of confidentiality and personal data protection, we will identify you in order to respond to your request. You will be asked to include a copy of an official piece of identification, such as driver's license or passport, along with your request.

If your personal data is inaccurate, incomplete or not up to date, please send the appropiate amendments to that contact as indicated above.

All requests will receive a response as swiftly as possible and in accordnace with applicable law.

You may also exercise your rights in respect of your personal data that is stored and processed by a hotel following a stay. to do this, you must contact the specific hotel directly.

14. UPDATES

We may modify this Charter from time to time. Consequently, we recommend that you consult it regularly, particularly when making a reservation at one of our hotels.

15. QUESTIONS AND CONTACTS

For any questions concerning Here for you Hospitality personal data protection policy, please contact the relevant person ("Access and modification" clause).