CALIFORNIA RESIDENTS ONLY Effective Date: January 1, 2020 Last Revised on: July 1, 2020 Last Reviewed on: July 1, 2020 This Privacy Policy and Notice at Collection advises California residents of rights provided in the California Consumer Privacy Act (the “CCPA”) and how California residents may exercise those rights. The CCPA currently exempts personal information reflecting a written or verbal business-to-business communication (“B2B Personal Information”) from certain of the law’s requirements, and also partially exempts a natural person acting as a job applicant, business’s employee or contractor (“Personnel Information”). The rights described below may not apply to B2B Personal Information or Personnel Information. Notice at Collection and Privacy Policy for California Residents NOTICE AT COLLECTION The purpose of this Notice at Collection is to provide you with timely notice, at or before the point of collection, about the categories of personal information to be collected from you and the purposes for which the personal information will be used. Do we collect? Categories of Personal Information ☒ A. Identifiers: For example, a real name, postal address, unique personal identifier, Internet Protocol address, email address, account name, social security number, or other similar identifiers. ☒ B. Personal Information Categories from Cal. Civ. Code § 1798.80(e): For example, a name, signature, Social Security number, address, telephone number, driver’s license, education, employment, employment history, debit card number, or any other financial information. We do not intentionally collect this information but it may be revealed in identity data or other information we collect C. Characteristics of CA or Federal Protected Classifications: For example, race, religion, national origin), age (40 and over), gender, sexual orientation, medical condition, ancestry, pregnancy (includes childbirth, breastfeeding and/or related medical conditions), familial status, disability, veteran status, or genetic information. ☒ D. Commercial Information: For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. ☐ E. Biometric Information: For example, physiological, biological or behavioral characteristics, including an individual’s deoxyribonucleic acid (DNA), that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. ☒ F. Internet or Other Similar Network Activity: For example, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site or application. ☒ G. Geolocation Data: For example, information that can be used to determine a device’s physical location ☐ H. Sensory or Surveillance Data: For example, audio, electronic, visual, thermal, olfactory, or similar information that can be linked or associated with a particular consumer or household ☒ I. Professional or Employment-Related Information: For example, compensation, evaluations, performance reviews, personnel files and current and past job history. ☐ J. Education Information: (defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an education institution or party acting on its behalf, for example, non-public information that can be used to distinguish or trace an individual’s identity in relation to an educational institution either directly or indirectly through linkages with other information. ☐ K. Profile Data: For example, inferences drawn from personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. PLEASE NOTE THAT PERSONAL INFORMATION DOES NOT INCLUDE: Publicly available information from government records. Deidentified or aggregated consumer information. Information excluded from the CCPA’s scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (CalFIPA), and the Driver’s Privacy Protection Act of 1994. WE USE THE PERSONAL INFORMATION WE COLLECT FOR ONE OR MORE OF THE FOLLOWING BUSINESS PURPOSES: To fulfill or meet the reason for which the information is provided For our internal operation purposes For auditing relating to consumer transactions including ad impressions and compliance with regulations Fraud and security detection Debugging to identify and repair errors Short-term data use for the current interaction that is not used to build a profile Servicing transactions and accounts (e.g., customer service, maintaining and servicing accounts, customer verification, payment processing) and providing services on behalf of business or service provider (e.g., financing, advertising or marketing, analytics) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. Undertaking internal research for technological development and demonstration Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by the business, and to improve, upgrade, or enhance the service that is owned or controlled by the business. To share the personal information with service providers to carry out other business purposes. We will not collect additional categories of personal information without providing you a new Notice at Collection disclosing those categories. We will not use your personal information for a purpose materially different from those disclosed in this Notice at Collection unless we directly notify you and obtain explicit consent to use it for the new purpose. Privacy Policy The purpose of this privacy policy is to provide you with a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of your rights regarding your personal information. Your Right to Know You have the right to request that we disclose what personal information we collect, use, disclose, and sell. You can do this through a verified consumer request. That process is described below in the sections, “How to Exercise Your Rights” and “Submitting a Verified Consumer Request.” We collect personal information, which means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The following table includes disclosures of categories of personal information we have collected about consumers, the categories we have disclosed for a business purpose, and categories of third parties with whom we shared the personal information for the preceding 12 months: Category In the preceding 12 months this category was: Categories of third parties to whom the information was disclosed Collected Disclosed A. Identifiers ☒ ☒ Affiliates Third Parties related to the provision of services Authorities and others Business transferees B. Personal Information Categories from Cal. Civ. Code § 1798.80(e) ☒ ☒ Affiliates Third Parties related to the provision of services Authorities and others Business transferees C. Characteristics of CA or Federal Protected Classifications We do not intentionally collect this information but it may be revealed in identity data or other information we collect ☐ N/A D. Commercial Information ☒ ☒ Affiliates Third Parties related to the provision of services Authorities and others Business transferees E. Biometric Information ☐ ☐ N/A F. Internet or Other Similar Network Activity ☒ ☒ Affiliates Third Parties related to the provision of services Cybersecurity service providers Web analytics providers Web hosting service providers Authorities and others Business transferees G. Geolocation Data ☒ ☒ Affiliates Third Parties related to the provision of services Cybersecurity service providers Web analytics providers Web hosting service providers Authorities and others Business transferees H. Sensory or Surveillance Data ☐ ☐ N/A I. Professional or Employment-Related Information ☒ ☒ Affiliates Third Parties related to the provision of services Authorities and others Business transferees J. Education Information ☐ ☐ N/A K. Profile Data ☐ ☐ N/A What We Sell and Right to Opt-out Starwood does not and will not sell personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age. Your Right to Request Deletion of Your Personal Information You have the right to request that we delete any of your personal information collected by us, subject to certain exceptions. You can do this through a verified consumer request. That process is described below in the sections, “How to Exercise Your Rights” and “Submitting a Verified Consumer Request.” We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: Complete your transaction; Provide you a good or service; Perform a contract between us and you; Protect your security and prosecute those responsible for breaching it; Fix our Site in the case of a bug; Protect the free speech rights of you or other users; Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.); Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws; Comply with a legal obligation; or Make other internal and lawful uses of the information that are compatible with the context in which you provided it. How To Exercise Your Rights Please direct any such rights requests (as further described below) or additional questions that you may have regarding this Privacy Policy to: sptlegal@starwood.com or by post at 1601 Washington Ave., Suite 700, Miami Beach, Florida 33139 or by calling our toll-free number at 1-833-431-1245. Also, if you need to edit or update your information, you may contact us at sptlegal@starwood.com, or for prospective applicants on the Careers section of our Site, you may do so directly by editing your account profile. Submitting a Verified Consumer Request You have the right to submit verified consumer requests to know information or for deletion. The request to know can be for any or all of the following: (1) Specific pieces of personal information that we have collected about you; (2) Categories of personal information we have collected about you; (3) Categories of sources from which the personal information was collected; (4) Categories of personal information that we sold or disclosed for a business purpose about you; (5) Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and (6) The business or commercial purpose for collecting or selling personal information. The response to a request for any of the categories above will cover the preceding 12 months. Please note that we are not required to provide personal information to you more than twice in a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. We may ask that you provide certain information to verify your identity. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Your request will be verified by matching the information you provide to information that we have collected. The information that we ask you to provide to verify your identity will depend on your current or prior interaction with us and the sensitivity of the personal information at issue. Once we receive your verifiable consumer request, we will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 calendar days, if we are able to verify your identity. Requests for deletion will require a separate confirmation that you want your information deleted. If requests from you are manifestly unfounded or excessive in particular because of their repetitive character, we may either charge a reasonable fee or refuse to act on the request, notifying you of our reason for refusing to act. If we determine that the request warrants a fee, we will notify you of the reason for that determination and provide you with a cost estimate before completing your request. Please note that, in responding to your request, we are not permitted to disclose or provide you with your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics. However, we will inform you with sufficient particularity that we have collected the type of information without disclosing the actual data. Requests to Know or Delete for Child Under the Age of 13: We do not knowingly collect information of minors under the age of 13. Using an Authorized Agent to Submit a Request Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets the above provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request, verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request. An authorized agent should submit proof that they have been authorized by the consumer to act on the consumer’s behalf as noted above and direct any such rights requests to: sptlegal@starwood.com or by post at 1601 Washington Ave., Suite 700, Miami Beach, Florida 33139 or by calling our toll-free number at 1-833-431-1245. Requests to Access or Delete Household Information We will not comply with a request to know specific pieces of information or a request to delete household person information unless all consumer of the household jointly request access to specific pieces of information or deletion, we can individual verify all members of the household and we can verify each is currently a member of the household. If a member of a household is a minor under 13, we must obtain verifiable consent before complying with a request for specific pieces of information for the household or deletion of household personal information. Your Right to Non-Discrimination for the Exercise of a Privacy Right Businesses may not, and we do not, discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above. Unless permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Other California Privacy Rights We do not respond to Web browser “do not track” signals or other mechanisms. Other parties may collect personally identifiable information about your activities over time and across different Web sites when a consumer uses our Web site or service. Changes to Our Privacy Notice We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. Contact for More Information If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: Phone: 1-833-431-1245 Email: sptlegal@starwood.com Postal Address: Starwood Property Trust, Inc. 1601 Washington Ave., Suite 700 Miami Beach, FL 33139 Attn: SPT Legal – CCPA Notices © Starwood Property Trust 2021 Privacy Policy California Notice & Privacy Policy Terms of Use