Privacy Policy

Overview

First Chair Operating Company LLC (“First Chair”, “we” or “us”) is responsible for the collection and proper management of any information that we collect from you. As consumers ourselves, we believe in being transparent about how we collect, use and share your information, and we are committed to maintaining and protecting your information in a safe and secure manner. We are providing this Privacy Notice (this “Notice”) to describe our policies and procedures regarding our collection, use, and disclosure of Personal Information about users of www.firstchair.com and our other websites linking to this Notice (each, a “Website,” when referred to together, we call them the “Websites”), our mobile application(s) (each, an “App”) and other products and services that we provide (collectively the “Services”). It also describes our policies and procedures regarding our collection, use, and disclosure of Personal Information about those who apply for jobs with us through our Website. By “Personal Information” or “Personal Data”, we mean any information that relates to an identified or identifiable person. This Notice is also intended to tell you about your rights and choices regarding your Personal Information, and how to contact us if you have any questions. Before using or accessing our Services, please read the following carefully to understand how we will treat your personal data. If you do not agree with this Notice, please do not access or use our Services.

For visitors from California or those protected by the data protection laws of the European Economic Area or the United Kingdom, Sections 14 and 15 of this Notice contain specific information relevant to the collection and processing of your Personal Information.

What Personal Information do we collect about you?

In this section of the Notice, we identify the types of Personal Information we collect about you. Our Services may collect the following categories of information from and about you:

• Identifiers: such as your name, postal addresses, unique personal identifier, online identifiers, internet protocol address, email addresses, social networking account information, telephone numbers, or other addresses at which you are able to receive communications;

• Location information: such as information related to your state/province, city, or neighborhood, and, if you agree, more specific location information that is provided through the GPS functionality on mobile devices used to access the Services;

• Internet and network activity information: such as information about your browsing behavior and interactions with websites and advertisements, including data from cookies, pixel tags, and web beacons;

• Inferences regarding preferences and other characteristics: such as our assessment of the types of products or services you may have an interest in;

• Financial information: such as information collected from you as needed to process payments for products or services that you buy such as your payment card or account number, expiration date, and card verification number; and

• Commercial information: such as information that enables us to determine interests, product preferences, and information collected through your interactions with social networks.

We also collect:

Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.

Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

If you are a California resident, please see our California Privacy Notice in Section 14 below.

2. How do we collect your Personal Information?

We may collect information about you from a variety of sources.

Information that we collect directly from you.

Setting Up Your Profile on the Website. When you establish your profile for your First Chair account (“First Chair Account”) on our Website, we will ask you for certain Personal Information including your name, phone number, email address, home address, and date of birth. We will collect additional information such as your gender, zip code, individual preferences or demographic information in order to help us to administer and personalize your First Chair Account. You may also elect to voluntarily share information about yourself so we can help to personalize your stay at a First Chair property (an “Accommodation”). We ask that you do not share health information with us, please just let us know what you need.

Booking an Accommodation. When you book an Accommodation through First Chair, we will ask you for certain information including your name, your First Chair Account password, the identity of your proposed booking, and the proposed dates of stay. Your credit card information is collected by our third-party payment processor on our behalf.

Checking-in. When you check in to an Accommodation, we may collect proof of identity or proof of age, such as a government-issued driver's license, passport, or other identity information in connection with your stay. We may collect information about your automobile(s) and license plate number(s) in connection with your stay at an Accommodation that requires this information for parking permits or safety and security. We may also collect information about your age and the ages of other guests in connection with your stay at an Accommodation that imposes a minimum renter age or requires this information for check-in.

Communications. If you contact us directly through email, SMS, telephone or messaging through our App with a request or inquiry, we will collect your name, contact information, the date and time of your contact, and the content of your message. We will also keep a record of how your inquiry or request was handled. If you elect to provide a review of our Services on one of our Websites, a third-party website, or complete a survey regarding our Services, we will collect this information as well. If you share your email address or your mobile phone number on the Website in order to receive updates from us, we will also collect this information.

Referral. If an owner of a property that uses our Services refers you to us, we will collect your name, contact information, the date and time of the referral, and the name of the referring owner.

Applying for a job. If you apply for a job with First Chair on our Websites, we will collect your name, contact information, email address, phone number and information from your resume or curriculum vitae. We may also ask you to share a link to your LinkedIn profile. We will also collect any other information that you share with us such as your X, GitHub or portfolio URLs, your current employer and any other information that you chose to share with us.

Information that we collect automatically.

Your usage of our Services. We may automatically collect the following information about your use of our Services through cookies, web beacons, and similar technologies: your domain name; you browser type; operating system type, name, and version; page views; the links you click; your IP address; location information; the length of time you visit our Services; referring URL; access date and time; mobile device ID; language information; device name and model; and other information about your activities within the Services and communications that we send you. Please see the section "Cookies, Web Beacons and Other Tracking Mechanisms" below for more information. Where required under applicable law, we will only perform such data collection with your consent.

Property Usage Data. We automatically collect your history of stays at an Accommodation through First Chair, and we automatically collect information about the use of an Accommodation in order to ensure that the guest terms and conditions for staying at an Accommodation (the “Terms and Conditions”) are being followed. We do not use or allow any video equipment inside the Accommodation. Where required under applicable law, we will only collect property usage data with your consent.

Smart Devices and Home Automation. We prohibit owners of Accommodations from placing any camera in the interior of the Accommodation or in any portion of the property except in an exterior area that is visible from off the premises, such as a front porch, and shall disclose the presence of permitted cameras to First Chair and guests. We also prohibit owners of Accommodations from using any microphones or other smart home devices that are capable of recording or transmitting guest conversations. Contact us immediately if you find a smart device, surveillance or other recording device that you believe violates our policy. This allows us to take the necessary steps to protect everyone's privacy and comfort.

Location Information. If you use our mobile Websites or our Apps, we may automatically collect location data obtained from your mobile device's GPS. Most mobile devices allow you to control whether an application can use the device's location services. If you use our Websites, we may collect information about your location derived from your IP address

Information we collect from third parties.

Third Party Accounts. We may obtain aggregated information provided by third party social networking services (“Social Sites”) or Personal Information if you consent to link your First Chair Account with third party accounts (“Third Party Account”) by either providing your Third Party Account login information to First Chair through the Services, or allowing First Chair to access your Third Party Account as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. We do not receive Personal Information from Social Sites without your consent.

If you are applying for a job with us, and you have provided a link to your LinkedIn profile, we will receive your basic profile and email address from LinkedIn. We may also receive any other information you authorize First Chair to access by authorizing the Social Sites to provide such information.

Third Party Travel Services. We may receive your booking information from third party travel services like Expedia, Booking.com, Vrbo or Airbnb. This information may include your name, email address, phone number, information available in your user account with such third-party travel service and information about your upcoming stay at an Accommodation through First Chair.

Vendor and Partner Relationships. We receive Personal Information of employees and other individuals who are contact persons at our partners and vendors, such as contact details and other information relevant to the particular business relationship.

3. How does First Chair use your Personal Information?

We use your Personal Information for the following purposes:

• To operate, provide, and maintain our Services. This may include communicating with you about our Services, managing bookings at each Accommodation, responding to your inquiries, completing your transactions, collecting and issuing payments in connection with an Accommodation, providing you with an entry code via text message to access your Accommodation, and other customer service purposes. When you provide your phone number and submit the contact form, you are giving consent to receive SMS text messages from us. This includes, but isn’t limited to, sharing information with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages. No mobile information will be shared with third parties 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. Standard message and data rates may apply depending on your carrier. You can opt out of receiving messages at any time by replying “STOP”.

• To communicate with third parties. This may include linking your First Chair Account at your request with Third Party Accounts to add information from Third Party Accounts to your First Chair Account and your First Chair Account profile page. Depending on the Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access make available and store (if applicable, and as permitted by the Social Sites and authorized by you) the information in your Third Party Accounts so that it is available on and through your First Chair Account on our Websites.

• To personalize your experiences while using our Services. We use your Personal Information to help us to tailor the content and information that we may send to you or display to you, to personalize your First Chair Account profile and identify you as a return guest to provide Services to you according to your preferences or restrictions. For example, we may offer discounts or sales to individuals who have an First Chair Account. We may also tailor our Services and communications on the basis of your browsing history on our Websites. Where required under applicable law, we will only use your Personal Information for such purposes with your consent.

• To communicate with you. This may include contacting you with marketing or promotional materials and other information that may be of interest to you relating to First Chair or its partners via email, SMS and phone calls. Where required under applicable law, we will only send you marketing communications with your consent. We may also use the information that we learn about you to assist us in advertising our Services on third party websites.

• For quality assurance and analytics purposes. In order to provide you with world-class Services, we want to better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve the quality and value of our Services, provide you with a better experience, speed up your searches, and develop new Services, and for other research and analytical purposes. Our analysis may include the use of technology like machine learning and large language models, which may include training these models or sharing with third parties for model training. This includes our efforts to keep the Services and our users safe and secure, enforcing the Terms of Service, to ensure our records are accurate and up to date, estimate our audience sizes and usage patterns, and to otherwise administer the Websites and App(s), including through troubleshooting, testing, and research relating to their performance.

• To avoid prohibited use of the property. Property owners may place restrictions on the home such as large-gathering or party prohibitions, limitations on noise levels, and requirements on where guests may cook. Property owners may install noise decibel meters to detect the noise associated with large gatherings, but property owners must disclose that such monitoring is occurring at the premises and in the property description on the website prior to purchase.

• To solicit a review from you about our Services.

• To comply with the law. We may in some cases need to process your Personal Information in order to comply with legal requirements.

• To establish, exercise, or defend legal claims and for related purposes such as the prevention or detection of fraud where necessary.

Your decision to provide personal information to First Chair is typically voluntary, except where Personal Information is, for example:

• collected to meet a legal requirement;

• necessary or important for the conduct of our business.

If you do not provide certain Personal Information, First Chair may not be able to achieve some of the purposes outlined in this Notice.

4. How and why do we share your Personal Information?

We do not share, sell, rent, or trade your Personal Information with third parties except as described in this Notice. We may disclose aggregated information about our users and information that does not identify any individual, without restriction. We may share your Personal Information in the following circumstances and to the following recipients:

• To our own employees, agents and officers.

• Affiliates. We may share information within our corporate family in order to provide you with the technical support or account management purposes in your region.

• Third-party Vendors. We may disclose your Personal Information we collect about you to third-party vendors, contractors or agents who perform functions on our behalf, including (i) to facilitate our Services, including the use of a property management system vendor to help coordinate the booking of an Accommodation, (ii) to provide Services on our behalf (e.g. cleaning services for Accommodations), (iii) to perform Website-related services (e.g. maintenance services, database management, web analytics, fraud detection services relating to the activity of First Chair Users and improvement of the Website features), (iv) to perform background checks, (v) to send marketing communications, (vi) to manage job applications that we receive via careers page on our Websites, (vii) to aggregate reviews of our Services, or (viii) to assist us in analyzing how our Websites and our Services are used. These service providers are bound by contractual provisions to safeguard the privacy of Personal Information they process on our behalf, and they may only use Personal Information for the purposes for which we disclose it to them.

• Third-Party Travel Services. When you book an Accommodation via a third-party travel service, we may share your Personal Information with the third-party travel service in order to manage your booking of an Accommodation.

• Homeowners. We may share reports with homeowners regarding the use of their properties that they offer as Accommodations through First Chair (for example, reports from the cleaning service about the condition of an Accommodation). We will share dates of stay with homeowners for Accommodations.

• Advertising and Analytics Partners. We do not share your Personal Information with advertising partners to serve third party advertisements regarding goods and services. We may share information about the use of our Websites and Services with third parties for analytics purposes and for us to directly advertise to you. Some of our advertising partners are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). If you do not wish to receive personalized ads, please use the NAI's Opt-out Tool https://optout.networkadvertising.org/?c=1 or the DAA's Opt-Out Tool https://optout.aboutads.info/?c=2&lang=EN to opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps. For more information please see our Cookie Policy.

• Investment/Change of Control. We can also share your Personal Information as part of an investment in us, sale, merger, or change of control. We would only share aggregated information in preparation for any of these events. Any other entity that buys us or part of our business will have the right to continue to use your Personal Information in the manner set out in this Notice unless you agree otherwise.

• Compelled Disclosure. It's possible that we will need to disclose your Personal Information when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, and (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats). We will attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. While we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority, we do not promise to challenge every demand.

• Testimonials. If you provide a review of your stay at an Accommodation through First Chair or your experience using our Services, we may post your testimonial on our Websites along with your name. If you would like your testimonial or name removed, please contact us.

We may disclose the following categories of Personal Information for our own business and operational purposes:

• Identifiers;

• Demographics;

• Commercial information;

• Location information;

• Internet and network activity information; and

• Inferences regarding preferences or characteristics.

We may disclose certain Personal Information in exchange for services, insights, or other valuable consideration. These disclosures may involve:

• Identifiers

• Internet and network activity information:

• Inferences regarding preferences and other characteristics; and

• Commercial information.

Please remember that any information, photos, images or materials you voluntarily disclose through postings, comments, or forums on our Services, becomes public information, and may be available to any visitors to the Websites. In addition, when you choose to make a posting on such Services, certain personal data will be available for other users to view. We urge you to exercise discretion and caution when deciding to voluntarily post any information on the Websites.

5. Cookies, Web Beacons, and other Tracking Mechanisms

As you navigate our Websites, we may collect information through commonly used information-gathering tools such as first and third-party cookies, clear GIFs or web beacons, or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as “Metrics Tools.” These Metrics Tools gather standard information from your web browser, your internet protocol (IP address, and the actions that you take on our Website (e.g. pages opened and links clicked). As described more fully below, we and our partners use these Metrics Tools to analyze trends, administer our Websites and Services, serve targeted advertisements, and gather demographic information about our user base in general.

We may allow third parties to use Metrics Tools on our Sites. The information collected by Metrics Tools may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. Information collected by Metrics Tools may be used on this Site or on other websites or services, including those that may not be operated by us. For more information regarding our Metrics Tools, please see our cookie policy.

6. Children's Privacy

Our Websites and our marketing are not directed to visitors under 18 years of age. We do not intentionally gather information about visitors who are under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their supervision or consent, he or she should contact us. If we become aware that a visitor under 18 has provided Personal Information, we will delete such information from our files.

7. Links to Other Websites

Our Websites contain links to other websites, and if you choose to visit an advertiser by clicking on a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party's website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or informational security policies or practices. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other websites follow different rules regarding the use or disclosure of the Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

8. Security

First Chair is very concerned with protecting your Personal Information. When you enter particularly sensitive information such as a credit card number, our third-party payment processor encrypts that information using secure socket technology (SSL). We follow generally accepted industry standards to protect Personal Information submitted to us, both during transmission and once we receive it. Our safeguards are not a guarantee against loss, misuse or unauthorized access, disclosure, alteration and destruction of your Personal Information. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your encrypted electronically stored “personal data” (as defined in the applicable state statutes on security breach notifications) to you via email or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay provided that it is consistent with the needs of law enforcement or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

9. Data Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of Services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

10. Your Rights and Choices

Direct Electronic Marketing opt out. If you decide at any time that you no longer wish to receive direct electronic marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also be able to limit the information provided to us by third party social media providers by altering your privacy settings with those providers.

Advertising opt out. Your browser and your device may provide you the option to limit the use of cookies or other tracking mechanisms. You should consult documentation for your browser or device for more information. Your mobile device may have settings that allow you to prevent sharing geolocation information with us. You should consult your mobile device's settings or help documentation for more information about exercising these options. You may also be able to opt out of certain targeted behavioral advertising via the Network Advertising Initiative's opt-out (http://optout.networkadvertising.org/?c=1#!/). Additionally, we use Google Analytics, which helps us better understand our audience and target communications and advertisements based on demographic or interest-based information. You may learn more about opting out of certain Google advertising initiatives here (https://support.google.com/ads/answer/2662922?hl=en) and here (https://tools.google.com/dlpage/gaoptout/). Please note that you may still receive advertising even after opting out, but that advertising may not be tailored to you or your interests.

Changing or deleting information. You may review, update, correct or delete the Personal Information in your First Chair Account by contacting us at [email protected] or editing the relevant part of their profile. If you would like us to cancel your First Chair Account, please contact us and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your First Chair Account.

For visitors from California or those protected by the data protection laws of the European Economic Area or the UK, Sections 13 and 14 of this Notice provide further information on rights available to you.

11. How to Contact Us

First Chair Operating Company LLC is the entity responsible for processing your Personal Information. For privacy queries, please email us at [email protected], or write to us at First Chair Operating Company LLC, 270 Seventh Ave, New York, NY 10001.

12. Changes to this Notice

Because we're always developing and improving the Services that we provide to you, this Notice may change over time. We will post the new Notice online and we will change the “Last Updated” date. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Services after we make changes to this Notice is deemed to be acceptance of these changes so please check this Notice periodically for updates. If any modifications materially change your rights, we will provide notice on our Websites or we will notify you by email (sent to the email address specified in your First Chair Account.

13. Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.

• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.

• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law.

• Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please email [email protected].

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data "sales" as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

14. Additional Information For California Consumers

This section of our Privacy Policy applies to California consumers only. For ease of reference, we refer to this section as our “California Privacy Notice.”

Personal Information Collected on California Consumers, Sources of Collection, and Business Purposes for Collection for the Last Twelve Months

We collect information from users of our Services, as described in detail above in "What Personal Information do we collect about you?" Furthermore, we collect the following categories of personal information described in California Civil Code § 1798.80(e): (1) the personal information listed in the preceding bullet point as "identifiers," (2) the other information that identifies, relates to, describes, or is capable of being associated with, a particular individual that we describe in "What Personal Information do we collect about you?" above.

Disclosures of Personal Information on California Consumers for Business Purposes for the Last Twelve Months

We have disclosed the categories of personal information identified in this California Privacy Notice to service providers and third parties for various business purposes as specified above. For more information on the types of entities with whom we share information, please see "How does First Chair use your Personal Information?" and "How and why do we share your Personal Information?" above.

Business Purposes for Collecting Personal Information for the Last Twelve Months

We collected the personal information identified in this California Privacy Notice for the business purposes identified above in "How does First Chair use your Personal Information?"

Your California Privacy Rights

If you are a California resident, you have the following rights for purposes of the personal information covered by this California Privacy Notice:

Right to Know About Personal Information Collected, Disclosed, or Sold and Right to Access. You have the right to request that we disclose the following information about your personal information we collect, use, and disclose:

• the categories of personal information we have collected about you;

• the categories of sources from which the personal information is collected;

• our business or commercial purpose for collecting or selling personal information;

• the categories of third parties with whom we share personal information;

• the specific pieces of information we have collected about you;

• if any, the categories of personal information about you that we have sold, by category or categories of personal information for each third party to which we sold the personal information; and

• the categories of personal information about you that we disclosed for a business purpose.

Right to Request That We Do Not Sell Your Information. We provide a "Do Not Sell My Personal Information" link to comply with the CCPA. We give you the option to opt out of these sales at any time by following this "Do Not Sell My Personal Information" link. The link is also available on our Website.

Right to Deletion of Personal Information. You have the right to request deletion of your personal information we collected from you.

Right to Non-Discrimination for Exercise of a California Privacy Rights. We may not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the California Consumer Privacy Act, including by:

• Denying you goods or services;

• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• Providing you a different level or quality of goods or services; or

• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to First Chair by your personal information.

How to Exercise Your California Rights; How We May Verify Your Request

You may request the rights listed above by:

• emailing us at [email protected]

When you make a request, we may take steps to verify your identity before responding to your request. In order to verify your identity with respect to the non-sensitive data that is subject to this notice, we will ask you to confirm your email address by sending you an email, or if your request is made via telephone call or via letter, we will ask you to verify your identity by confirming your email, account or asking questions about the scope of your interaction with us. We reserve the right to take additional steps to verify your identity using other information we have about you.

You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may take steps to verify your own identity in response to a request even if you choose to use an agent.

California Do-Not-Track Disclosure

At this time, our websites are not set up to honor web browser do-not-track settings. Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites requesting them not to track the user. For more information about do-not-track matters, please visit www.allaboutdnt.org.

Information on Marketing Disclosures

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at First Chair Operating Company LLC, 270 Seventh Avenue, New York, NY 10001.

15. Additional information for users protected by the data protection laws of the European Economic Area or the United Kingdom

Legal Basis We Rely On

If you are located in the European Economic Area or the United Kingdom, we will collect, use and share your Personal Data only where we have a legal right to do so. This section explains our legal basis for processing Personal Data:

• Consent. We may rely on your (explicit) consent in order to process your personal data. ”Consent” is a freely given, specific, informed and unambiguous indication of your wishes. You give consent when you, by a statement or by a clear affirmative action, signal your agreement to the processing of Personal Data. If you consent, you may also withdraw your consent at any time – see “European Privacy Rights” below.

• Legitimate Interests. We also rely on legitimate interests to process the Personal Data we collect when you use the Services. We process this data based on our legitimate interest in providing our Services, understanding how our Services are being used, and your legitimate interest in using our Services. We only rely on legitimate interests to use your Personal Information when these interests are not overridden by your rights and freedoms. If you would like further information about how we have balanced our interests about your rights and freedoms, please contact us using the contact details in Section 11 (How to Contact Us).

• Legal Obligations. In some circumstances, we may need to process Personal Data where necessary to comply with applicable laws.

• Contract Necessity. In some circumstances, we may need to process Personal Data for the performance of an agreement we have with you or in order to take steps at your request prior to entering into an agreement with you.

To the extent that First Chair processes Personal Data which reveals criminal convictions or offences, we will ensure that the law authorizes us to process such Personal Data.

For further information on the legal basis we rely on to process your Personal Data, please contact us using the contact details in Section 11 (How to Contact Us).

European Privacy Rights.

If you are located in the European Economic Area or the United Kingdom you have certain data protection rights, which may be limited by law. One key right is the right to object to our processing of your Personal Data. Other rights are:

• The right to access, update, or delete the information we have on you. Whenever made possible, you can access, update, or request deletion of your Personal Data within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• The right of rectification. You have the right to have your Personal Data rectified if that information is inaccurate or incomplete.

• The right to restriction. You have the right to request that we restrict the processing of your Personal Data.

• The right to data portability. You have the right to be provided with a copy of the Personal Data that we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where First Chair relied on your consent to process your Personal Data.

You may exercise these rights by contacting us using the contact details in Section 11 (How to Contact Us).

If you wish to raise an issue in respect of our use of your personal data, we encourage you to get in contact with us in the first instance. However:

• You have a right to file a complaint with a supervisory authority, in particular in the country in which you live, your place of work, or of an alleged infringement of the GDPR.

• If we do not act on your request to exercise a data subject right, you have the right to lodge a complaint with a supervisory authority or to seek a judicial remedy.

Data Controller

First Chair operates in the United States. The First Chair entity that is responsible for your Personal Information under this Notice is First Chair Operating Company LLC.

Cross Border Transfers

We process data in the United States, and the Personal Data that we collect is transferred to our affiliates, subsidiaries, branches, service providers and agents, who may be located in the United States or in other jurisdictions worldwide. We may transfer your personal data to the jurisdiction where the owner of the Accommodation which you rent is located.

The United States and the other jurisdictions to which we transfer information may not have equivalent data protection laws to your home jurisdiction. We comply with applicable legal requirements for the transfer of Personal Data to countries outside of the European Economic Area or the United Kingdom. We may, for example, transfer your Personal Data to countries for which adequacy decisions have been issued (e.g., Canada), use contractual protections for the transfer of Personal Information, or transfer on the basis of one of the derogations contained in data protection laws. You may contact us as specified above to obtain a copy of any safeguards we use to transfer Personal Data outside of the European Economic Area or the United Kingdom.