Kompose Hotel

Privacy Policy

LAST UPDATED: February 19^th, 2026

This Privacy Policy describes how Kompose Hotels (the “Company,” “we,” “us,” or “our”) collects, uses, discloses, stores, and protects personal information when you use our websites, booking platforms, WiFi networks, and on-property services (collectively, the “Services”). Kompose Hotels locations are operated by one or more affiliated legal entities in the United States. The applicable operating entity will be identified upon request or as required by law.

This Privacy Policy updates and replaces our prior privacy policy and reflects our current operations and applicable privacy laws, including the Florida Information Protection Act (FIPA), the Florida Digital Bill of Rights (FDBR), and the Texas Data Privacy and Security Act (TDPSA).

By using our Services or providing personal information to us, you agree to the practices described in this Privacy Policy.

1. IMPORTANT INFORMATION

Purpose of This Privacy Policy

This Privacy Policy explains how we collect and process personal information when you:

• Make a reservation or purchase
• Use our website or submit contact forms
• Connect to our WiFi network
• Communicate with us by phone or email
• Participate in events, promotions, or surveys
• Stay at or otherwise interact with our hotel

This Privacy Policy supplements any specific privacy or processing notices provided at the time of collection and does not override them.

Children

Our Services are not intended for children under the age of 13, and we do not knowingly collect personal information from children.

2. CONTROLLER AND CONTACT INFORMATION

Controller:
Kompose Hotels locations are operated by one or more affiliated legal entities in the United States. The appropriate operating entity depends on the hotel location involved.

The applicable operating entity will be identified upon request or as required by law.

Contact:
Attn: Privacy / Legal Requests
Email: claims@ksupportsolutions.com

When submitting a privacy request, guests should specify the hotel location. The appropriate operating entity will respond.

3. SCOPE

This Privacy Policy applies to personal information collected through:

• Our websites
• WiFi networks
• Third-party booking platforms
• Contact forms and communications
• On-property interactions, including CCTV systems and incident reporting
• Any Service linking to this Privacy Policy

This Policy does not apply to unrelated third-party websites or platforms.

4. CATEGORIES OF PERSONAL INFORMATION WE COLLECT

“Personal Information” means information that identifies, relates to, or can reasonably be linked to an identifiable individual.

We may collect:

Identity Information

Name, date of birth, gender.

Contact Information

Email address, telephone number, billing or mailing address.

Reservation and Stay Information

Reservation details, stay dates, preferences, and special requests.

Transaction and Payment Information

Payments are processed by Shift4, which provides:

• Masked or tokenized card numbers
• Transaction confirmations

We do not store or access full credit card numbers.

Technical and Usage Information

Including:

• IP address
• Browser and device type
• Website interaction data
• Analytics data (when enabled)
• WiFi connection metadata (device identifiers and session duration; not browsing content)

Website Form Information

Information submitted through website contact forms (including Gravity Forms operated by our website provider).

Security and Safety Information

• CCTV footage
• Key-card access logs
• Incident reports and insurance documentation

Marketing Information

Email preferences and opt-in/opt-out status.

5. OTHER INFORMATION WE COLLECT

We may also collect information that does not directly identify you (“Other Information”), such as:

• Browser and device characteristics
• Operating system and language preferences
• Aggregated website usage statistics
• Anonymized analytics data

If Other Information is combined with Personal Information, the combined data is treated as Personal Information under this Policy.

6. HOW WE COLLECT PERSONAL INFORMATION

A. Directly From You

Through reservations, check-in and check-out, website submissions, emails, phone calls, surveys, and event participation.

B. Automatically Through Website Use

Our websites operate on WordPress and are developed and hosted by UpHotel Agency. We may automatically collect IP addresses, device data, cookies, and analytics information.

C. Through Hotel Systems

Reservations and guest profiles are processed through StayNTouch, our property-management system. Access is limited to authorized staff using role-based permissions.

D. Payment Processing

Payments are processed securely by Shift4, which stores payment data on its own secure servers.

E. WiFi Networks

When you connect to hotel WiFi, we collect limited connection metadata for network operation and security purposes.

7. HOW WE USE PERSONAL INFORMATION

We use Personal Information to:

Provide and Manage Hotel Services

• Process reservations and payments
• Manage check-in and guest services
• Communicate regarding your stay

Operate, Improve, and Secure Our Services

• Maintain website functionality
• Analyze performance and usage
• Troubleshoot technical issues
• Improve guest experience and staff training

Safety, Security, and Compliance

• Monitor premises via CCTV
• Investigate incidents and claims
• Comply with legal, tax, and regulatory obligations

Marketing

• Send newsletters or promotions
• Manage opt-outs and preferences

We do not sell personal information and do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects.

8. HOW WE SHARE PERSONAL INFORMATION

We may disclose personal information to:

Service Providers

Including:

• Website hosting and form providers
• StayNTouch (PMS)
• Shift4 (payment processing)
• IT, security, analytics, and email delivery vendors

Insurance and Legal Advisors

For incident reporting, claims handling, and compliance.

Internal Business Operations

Accounting, auditing, and authorized hotel personnel.

Government Authorities

When required by law or legal process.

We Do Not:

• Sell personal data
• Share personal data with unrelated third parties for their own marketing purposes
• Share personal data across properties for marketing purposes unless you have opted in

9. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar technologies to support website functionality, analyze traffic, and improve our Services. Cookies may include:

• Essential cookies for site operation
• Analytics cookies (such as Google Analytics, if enabled)
• Functional cookies to remember preferences or form inputs

You may control cookies through your browser settings. Disabling cookies may affect certain website features.

Do Not Track (DNT)

Our website does not respond to Do Not Track (DNT) signals. You may adjust your browser settings to limit or disable cookies.

10. SECURITY

We maintain administrative, technical, and organizational safeguards, including:

• Password-protected systems
• Role-based access controls
• Encryption through our payment processor
• Physical security and CCTV systems

No system can be guaranteed to be 100 % secure.

11. YOUR PRIVACY RIGHTS (FLORIDA & TEXAS)

Texas Residents (TDPSA)

You may request:

• Access to your data
• Correction of inaccuracies
• Deletion of personal data
• A portable copy
• Opt-out of sale, targeted advertising, or profiling

You may appeal a denied request.

Florida Residents (FDBR & FIPA)

You may request:

• Access, correction, or deletion
• Opt-out of sale or targeted advertising
• Breach notifications when required by law

Verification

We may request information to verify your identity. We generally respond within 45 days, with extensions permitted by law.

12. DATA RETENTION

We retain personal information only as long as necessary for hotel operations, legal compliance, tax and audit requirements, and safety or claim resolution. CCTV footage is retained according to operational standards unless preserved for investigations.

13. INTERNATIONAL VISITORS

Our Services are operated in the United States, and this Privacy Policy is governed by U.S. law. Guests visiting from outside the United States should be aware that their personal information will be processed and stored in accordance with applicable U.S. privacy requirements, which may differ from those in their home country.

14. INTERNATIONAL TRANSFERS

Some service providers may process personal data in the United States or United Kingdom. We implement appropriate safeguards for international data transfers as required by law.

15. CHANGES TO PROCESSING OR VENDORS

We may update our data practices or change vendors that process personal information. Material changes will be reflected in updates to this Privacy Policy.

16. NO CONTRACT FORMATION

This Privacy Policy is provided for informational purposes only and does not create any contractual or legal rights unless otherwise stated.

Severability

If any provision of this Privacy Policy is found unenforceable, the remaining provisions will remain in full force and effect.

17. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The “Last Updated” date reflects the most recent revision. Continued use of our Services constitutes acceptance of the updated Policy.