Privacy Credo and Statement

StaySmarter, Inc. is the operator of StayAtHand.com and StayFaster.com. Our Privacy Credo and Statement applies to all our mobile apps and websites. At this time only our StayAtHand App and Website have received TRUSTe's Privacy Seal.

Our Intent

We want to clearly explain our privacy practices and be as transparent as we can. In other words, we want you to always know and understand how we use your personal information. This Privacy Credo is meant to provide a summary, whereas our Privacy Statement provides the legal details. These two items are intended to be consistent with each other. Please note that this privacy statement applies to all our websites and mobile apps.

Privacy Before Profit

We are very different from the vast majority of companies you have probably encountered online. Our commitment to privacy is really quite simple. Our core value as a company is to put people first. That informs and guides our views on privacy.

We believe in privacy before profit – your privacy comes before our profit. We are not saying all privacy and no profit. Rather, when we have to make difficult choices, we know what comes first – you and your privacy.

Values Come From People, Not Technology

We believe that people live their lives by values. Therefore what is unacceptable offline should be unacceptable online. Our core values include honoring, respecting, engaging, supporting and partnering with you, our guest, and with our business partners. These values also inform our views on privacy.

Change

Given the rapid evolution of technology and privacy concerns, we are certain our Privacy Credo and Privacy Statement will change over time. When that happens we will endeavor to notify you, identify and explain the changes, and provide you access to all prior versions of these items. This Privacy Credo and Privacy Statement is effective December 3, 2013. If we make any material changes we will notify you by email or by means of a notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

We Are Serious About Your Privacy

We want to make sure that you understand that our privacy disclosures aren't just words; they represent our commitments to you. If you ever have any privacy questions or concerns please contact us at:

privacy@StaySmarter.com

StaySmarter, Inc.

1069 West Broad Street

Suite 114

Falls Church, VA 22046

Our Commitments to You

Most online businesses do not make all of these commitments. Why is that? Good question. Why don't you ask them? Really. Let us know the responses you get. Unlike most other online companies, we believe you are entitled to the following commitments:

It's Your Choice to Remain Anonymous

1. We do not try to identify who you are when you just visit our website.
2. We allow you to anonymously use most of our functionality.

We Won't Gossip About You

3. We do not sell or barter or give away your information to others.
4. We do not buy, barter, or take information about you on a personally identifiable basis from others.

We Respect Your Requests

5. We only ask for the information we need to process your requests and honor your choices.
6. We do not use your information for any other purpose.
7. Our agents can use your information only to process your requests.

We Protect What We Collect

8. We take security seriously and work hard to protect your information.
9. We delete your information as soon as practical.

It's Your Data

10. We do not think of your information as our financial asset.
11. You control your information; you can access, correct or delete it when you want.
12. When we change our privacy practices or if we experience a change of controlling ownership, we will use reasonable efforts to notify you, at which point you may request that we delete your information in accordance with our Privacy Statement.

There are few exceptions to our commitments. Specifically, we may disclose your personal information without your permission if we are:

• compelled by law, by a subpoena or court order to act differently; or
• directed by a government entity to provide personal information to support an investigation and we believe in good faith that providing the information is necessary to investigate or protect against harmful activities to or by our customers, website visitors or property.

Privacy Statement

StaySmarter Inc. (StayatHand) has received TRUSTe's Privacy Seal signifying that this privacy statement and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe program covers information that may be collected through the website www.stayathand.com and the mobile app called StayAtHand.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request .

At this time the StayFaster website and mobile app have not received the TRUSTe's Privacy Seal. However this privacy statement still applies to the StayFaster website and mobile app.

So that we are clear in this Privacy Statement, when we say personal information, we mean data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the other data.

Information We Collect on this Website and How We Use It

We collect personal information about you such as your name, email address, credit card number and any other information you choose to provide so that:

• we may process your requests;
• provide you services;
• respond to any inquiries you make; and
• we may make changes to the website that we believe will improve your experience when using the website.

When you download and use our mobile app, we automatically collect information on the type of device you use, operating system version, and the device identifier (or "UDID"). We collect your location based information for the purpose of locating hotels that you may be searching for in your area. We will only share this information with our mapping provider for the sole purpose of providing you this service. To turn off location based sharing, please adjust settings at the device level.

In addition, if you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

If you choose, we may periodically send you free newsletters and e-mails that directly promote the use of our service. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above).

Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Statement.

We do not buy or otherwise acquire any personal information about you from third parties such as data brokers.

We may use your personal information to create anonymized records by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use this anonymous information for any purpose and disclose such anonymous data to third parties in our sole discretion provided the uses are consistent with the content of this Privacy Statement.

Browsing Activity

You may browse most of this website anonymously. Similar to many websites, our web server logs maintain a record of every device's IP address, type of device you are using, and browser type (e.g., Internet Explorer, Firefox) that accesses this website along with the date, time and length of time you spent on this website. We will not associate this information with any personal information. This information is used for website usage analysis as described in the Google Analytics section of this privacy statement.

You will, however, need to identify yourself to execute a transaction or for us to communicate directly with you and for us to honor your choices.

Cookies

This website makes limited use of "cookie" technology. "Cookies" are strings of text that a website stores on a user's computer. This website may use one or more "session" and "persistent" cookies to know when you are a return visitor to this website, which web pages you visited on the website the sequence in which you accessed the web pages. The cookies do not contain any personal information. Session cookies are deleted when you close your browser after leaving the website. Persistent cookies remain on your computer hard drive until you delete them or are otherwise removed upon expiration. We do not use cookies to ascertain any personal information about you. Cookies do not corrupt or damage your computer, programs, or computer files. Cookies on this website may be created by us or by a third party we have engaged to optimize and measure performance on this website. You can manage your cookie acceptance or blocking preferences through your web browser. If you would like to learn more about cookies in general you can do so at a third party website called All About Cookies.

Google Analytics

We use Google Analytics to help us analyze how visitors use the website. The tool uses cookies to collect standard Internet log information and visitor behavior information. The information generated by the cookie about your use of the website, including your IP address, is transmitted to Google. This information is then used to evaluate visitors' use of the website and to compile statistical reports on website activity for us. We do not use the statistical analytics tool to track or to collect any personal information of visitors to our site. We do not seek to link an IP address with the identity of a computer user. We will not associate any data gathered from this site with any personal information from any source. If you do not want any information to be collected and used by Google Analytics you can install an opt-out in your web browser. Google's ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.

IDFA

Our iOS mobile app makes limited use of a technology created by Apple in iOS6 called ID For Advertising (IDFA) technology. An IDFA is like a web site "cookie" in that it is a string of text that an app stores on a user's iOS device. This mobile app uses a persistent IDFA to know when you are a return visitor to the app, which app pages you visited, and the sequence in which you accessed the app pages. The IDFA does not contain any personal information. The IDFA remains on your iOS device until you remove or reinstall the app. We do not use the IDFA to ascertain any personal information about you. IDFAs do not corrupt or damage your iOS device, apps, or files. In iOS6 you have the option to Limit Ad Tracking and Reset the Advertising Identifier by changing the Settings (select General, About, Advertising). In iOS7 you can also do the same by changing the Settings (select Privacy, Advertising).

Sharing Your Personal Information

We do not sell or otherwise make your personal information available to any third parties for their own use. We do use third parties to perform services such as (i) hosting our website and systems, (ii) storing personal information you expressly provide to us, (iii) storing and processing information about the use of this website, and (iv) sending you emails with your permission. These service providers are contractually prohibited from using any personal information for their own use. They were engaged to provide specific services and the use of any personal information they have access to will be dictated by us.

We may also share your personal information in the following circumstances and the receiving party will assume the rights and obligations regarding your personal information as described in this Privacy Statement:

• To third parties that you authorize to receive such information.
• With our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Statement.
• In connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, all involved parties will be required to honor this Privacy Statement.
• In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and we will use reasonable efforts to notify you, at which point you may request that we delete your information in accordance with our Privacy Statement.

Securing Your Personal Information

We understand that the security of your personal information is important. We use a variety of industry-standard administrative, technical and physical controls designed to protect your information. Geo location information and credit card numbers are protected by SSL (secure socket layer) encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

Accessing Your Personal Information

You are in control of the personal information that you provide to us. If you would like to update, change or delete any personal information we maintain about you please contact us at privacy@StaySmarter.com.

Retention of Your Personal Information

We retain your personal information and location information for as long as you are a customer and as required by law. To the extent permitted by law, we will delete your personal information 30 days after you cease to be a customer or if you request us to delete the information. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Children's Privacy

This website is not intended for the use of children and we do not knowingly collect any personal information from children. Anyone under the age of 18 is prohibited from using this website.

Change in Ownership of the Company

In the event that there is a change in control of StaySmarter, Inc., and the acquiring entity has materially different privacy practices, we will attempt to notify you. If you are unhappy, you may request that your personal information be deleted in accordance with this Privacy Statement.

Legal Issues

This is a United States website and is subject to laws of the United States. If you are a non U.S. user of the website or mobile app, by using these services and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Statement. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

There are few exceptions to our commitments. Specifically, we may disclose your personal information without your permission if we are:

• compelled by law, by a subpoena or court order to act differently; or
• directed by a government entity to provide personal information to support an investigation and we believe in good faith that providing the information is necessary to investigate or protect against harmful activities to or by our customers, website visitors or property.

If you reside in the State of California, you have the right to request from us a list of third parties with whom we shared personal information about you for their own direct marketing purposes during the previous calendar year. Please note, as previously stated, we do not share personal information with unrelated third parties for their own use. If you have any questions, please contact us at privacy@StaySmarter.com.

Other Websites

We are only responsible for the privacy statement and content of this website. We are not responsible for the data collection, data use practices, privacy statements, or the use of cookies or tracking technologies on websites that you have accessed this website from and to other websites that you may access from this website.

General Privacy Resources

If you are interested in learning more about privacy generally, there are organizations and government agencies that have publicly available information about privacy topics and how individuals can protect their privacy. A few of those organizations are:

• International Association of Privacy Professionals
• TRUSTe
• U.S. Federal Trade Commission
• State of California Attorney General