Privacy Policy

Last Updated: October 30, 2026

1. Introduction

This Privacy Policy provides information about the privacy practices of GR OPCO, LLC, a Florida limited liability company (“we,” “us,” or “our”), including how we collect, use, disclose, and otherwise process personal information obtained through www.11clubhotels.com and any related webpages, mobile-enabled pages, features, content, forms, communications, and services made available thereon or through the same (the “Website”) and through our other interactions with you, including when you make a reservation, stay at or visit the E11EVEN Club Hotel & Residences property located at 20 NE 11th Street, Miami, Florida (the “Hotel”), or communicate with us. We may provide you additional privacy notices, which supplement this Privacy Policy, at the point of collection of your personal information. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy and, for significant changes in the way we treat personal information, by sending a notice to the email address you have provided to us and/or by placing a prominent notice on the Website. Your continued use of the Website after such changes will constitute your acknowledgment of the modified Privacy Policy. By accessing, browsing, submitting information through, or otherwise using the Website, you consent to this Privacy Policy and the data practices described herein.

2. Personal Information Collected

Personal information means information that identifies or could reasonably be linked to an individual. We, and our vendors, may collect personal information directly from you (such as when you book a room through the Website or contact customer service), through online technologies such as cookies, and from other third-party sources, such as online travel agencies and other booking channels, our affiliates, social media platforms, and advertising and analytics providers.

The personal information collected about you may vary depending on the nature of your interactions with us, and includes the following categories:

• Identifiers. This includes names and contact information such as phone number, email address, and mailing address.
• Personal Records and Booking Information. This includes your signature, your booking dates, room number, and other reservation details.
• Protected Characteristics. This includes age, gender, nationality, citizenship, or disability status. This information is considered sensitive under certain laws.
• Internet or Other Electronic Network Activity. This includes Internet Protocol address, device identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, traffic data, pages viewed, and information regarding interactions with the Website.
• Geolocation Data. This includes approximate location, which may be based on your ZIP code or IP address.
• Audio, electronic, visual, or similar information. This includes photographs, audio recordings of customer service calls, and security video footage.
• Communications Information. This includes email communications, customer inquiries, chat transcripts, and survey responses.
• Professional or Employment-Related Information. This includes your job title, employer, and other professional background information.
• Payment Information. This includes credit or debit card details and billing address information.
• Government Identifiers. This includes Social Security number, passport number, or other government identifiers. This information is considered sensitive under certain laws.
• Inferences. We may draw inferences from the other categories of personal information we process to create a profile about you reflecting your preferences and interests.

You may be required to provide certain personal information to us when you elect to use certain products or services, such as when you (a) make a reservation or register for an account; (b) enter a sweepstakes or contest sponsored by us or one of our partners; (c) sign up for special offers; (d) send us an email message; or (e) submit your credit card or other payment information. If you choose not to provide information, we may not be able to provide you with requested products, services, or information.

3. Cookies and Other Similar Technologies

We, and our vendors, may use cookies, web beacons, pixels, APIs, and other similar technologies to collect information when you interact with the Website. These types of technologies may collect usage information (such as the browser you are using, IP address and device identifier, length and time of visit, and pages visited), general geolocation data (to deliver content based on your location), and details about how you interact with the Website (including clicks, cursor movement, scrolls, and keystroke activity).

This information is used by us and our vendors for a variety of purposes, including to store your preferences and settings, enable you to sign in, analyze how the Website performs, track your interactions with the Website, develop inferences about you, deliver and tailor cross-context and/or interest-based advertising, combat fraud, and to fulfill other business purposes.

You may be able to use your browser settings to manage cookies and other similar technologies. In addition, advertising networks may offer you the ability to opt out of certain targeted online advertising. If you would like to find out more information, visit aboutads.info/choices or youronlinechoices.com. The Website currently does not respond to “Do Not Track” signals, but we honor the Global Privacy Control as described in Section 11.

We also may use social media technologies to conduct marketing campaigns. To change your privacy and advertising settings with a social media company, log in to your social media account and follow the instructions provided by the social media company.

Our online tracking technology vendors may include:

• Adobe. For more information on how Adobe uses data collected through tracking technologies, visit adobe.com/privacy/experience-cloud.html. To opt out of Adobe Analytics, visit adobe.com/privacy/opt-out.html.
• Amazon. For more information on how Amazon collects or receives personal information through cookies and other similar technologies, visit amazon.com/adprefs.
• Facebook. To change your settings with Facebook, login to your Facebook account and navigate to the Privacy Center at facebook.com/privacy/center or review your Ad Preferences at facebook.com/adpreferences.
• Google. We use Google Analytics, using which we implement Google advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, video ads reporting, and impression reporting. For more information on how Google Analytics uses the data it collects, visit policies.google.com/technologies/partner-sites. To opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout. To adjust your Google advertising settings, visit adssettings.google.com.
• LiveRamp. For more information on how LiveRamp collects or receives personal information through cookies and other similar technologies, including how to opt out, visit optout.liveramp.com/opt_out.
• Lotame. For more information on how Lotame collects or receives personal information through cookies and other similar technologies, visit lotame.com/about-lotame/privacy/privacy-manager-opt-out.
• Microsoft Advertising. For information on how Microsoft collects or receives personal information to provide service through Microsoft Advertising, visit microsoft.com/en-us/privacy/privacystatement.
• PubMatic. For more information on how PubMatic collects or receives personal information through cookies and other similar technologies, visit pubmatic.com/legal/opt-out.
• Snapchat. For more information on how Snapchat collects or receives personal information through cookies and other similar technologies, visit values.snap.com/privacy/privacy-policy.
• Tapad. For more information on how Tapad collects or receives personal information through cookies and other similar technologies, visit privacy.tapad.com/optout.html.
• TikTok. For more information on how TikTok collects or receives personal information through cookies and other similar technologies, visit tiktok.com/legal/privacy-policy.
• Yahoo. We have contracted with Yahoo to monitor certain pages of the Website for the purpose of reporting web traffic, statistics, advertisement “click-throughs,” and/or other activities on the Website. Yahoo may use cookies and other similar technologies to compile statistics about visitors to the Website. You may opt out from Yahoo’s collection of such information outside of the Yahoo distribution network, by visiting legal.yahoo.com/us/en/yahoo/privacy/index.html.
• YouTube. YouTube API Services may collect, store, use, process and share personal information, including from your devices, as described in this Privacy Policy and to serve content. You can revoke access to your personal information collected and processed through the YouTube API Services using Google’s security settings at security.google.com/settings/security/permissions.

We are not responsible for the effectiveness of external parties’ opt-out options or programs, or the accuracy of their statements regarding their programs. Note that opting out of these types of technologies may result in certain online features not functioning properly. In addition, using a tool to opt out of cross-context behavioral advertising may not opt you out of receiving contextual advertising.

We or our vendors may collect personal information about your online activities over time and across different devices and online websites when you access the Website.

4. How We Use and Disclose Personal Information

We use and disclose personal information for the following purposes:

• To provide services you request, including processing bookings and reservations; operating and maintaining our services; processing your payments and orders; communicating with you; and responding to your requests and questions.
• For security and integrity, including protecting against security threats; preventing, identifying, investigating, and responding to potential or actual fraud, illegal or malicious activities, and other risks; enforcing our policies and terms; and otherwise protecting our rights.
• For quality, safety, and internal research, including improving the quality of our services; assessing the Website’s performance; tracking and responding to technical issues; and developing new or enhanced products and service offerings.
• For advertising and marketing, including informing you of other products or services available from us and our affiliates; measuring Website usage; evaluating the effectiveness of our advertising and marketing; and leveraging insights to provide personalized experiences.
• To comply with legal obligations.

With respect to Government Identifiers, which may be considered sensitive under certain laws, we may use this information to verify your identity and for security and legal compliance purposes. Similarly, we may use Protected Characteristics, which may be considered sensitive under certain laws, for limited purposes (e.g., we may use disability information to provide appropriate accommodations). We do not use or disclose sensitive personal information for purposes other than those permitted under applicable state laws and regulations.

We may disclose personal information:

• To our corporate affiliates, including for the business purposes detailed in this Privacy Policy.
• To strategic partners, including to business partners, sponsors, and in conjunction with co-branded partnerships.
• To vendors, including those that help us operate our business and the Website and/or perform services on our behalf, such as analytics, sending emails, serving advertisements, processing payments, promotion administration, customer service, and detecting and deterring fraud or other illegal activities. All such vendors are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information.
• As part of a business transaction, including in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction), including negotiations of such transactions.
• As required or permitted by law, including where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process, or in the good faith belief that such action is necessary to protect and defend our rights or property or to act under exigent circumstances to protect the personal safety of our guests, users of the Website, or the public.

We do not disclose personal information obtained for text messaging purposes (e.g., mobile phone number, opt-in consent information) to third parties for those third parties’ own marketing purposes.

5. Promotions

You may provide personal information to us (or our vendors) to participate in contests, sweepstakes, and other promotions. Our use of your personal information for these promotions is subject to separate terms that are provided to you when you participate in the promotion.

6. Loyalty or Rewards Programs

The Website may link out to, or allow you to participate in, loyalty or rewards programs provided by external parties. We do not own, control, or maintain these loyalty programs, which are subject to separate terms and policies.

7. Career Portals

The Website may include, or link out to, career portals powered by our vendors. These career portals allow you to submit job applications and other career-related personal information to us. These companies may provide separate terms and policies that govern their use of your personal information.

8. Other Online Services

The Website may contain links to, or features facilitated by, other online services. For example, we use vendor platforms to allow you to book reservations and to process your payment information. Or you may voluntarily choose to interact with a chat feature on the Website for customer service purposes. When you participate in interactive chats, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf. Calls with the Hotel may be monitored and recorded, and we will notify you at the beginning of any recorded call.

This Privacy Policy does not apply to the practices of companies that we do not own or control. If you choose to connect a third-party account to the Website, you should refer to that party’s privacy policy for information on how your personal information is collected, used, and protected. BY CONNECTING YOUR ACCOUNT TO A THIRD-PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD-PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THIS FEATURE. You may disconnect your account from a third-party account at any time by contacting us. We encourage you to be aware when you leave the Website and to read the privacy statements of any other site that collects personal information.

9. Data Retention

We keep personal information for as long as is necessary for the purposes described in this Privacy Policy, or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. This generally means holding the information for as long as one of the following apply:

• Your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected; or
• Your personal information is reasonably required to protect or defend our rights or property.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. At the end of the retention period, personal information will be deleted, destroyed, or de-identified.

10. Data Security

We maintain appropriate administrative, technical, and physical safeguards designed to help protect personal information collected or received through the Website. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol. We reserve the right to modify our security protocols as new systems and methods become available. We may store your data on servers provided by third-party hosting vendors with whom we have contracted. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through the Website. You acknowledge that (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through the Website cannot be guaranteed.

11. U.S. State Privacy Rights

Depending on the state in which you reside, you may have certain rights related to the personal information that we have collected about you.

You may exercise your privacy rights by submitting your requests to [email protected] or by calling us toll-free at 1-866-I-OPT-OUT (1-866-467-8688) and entering service code 2542#. If you have questions about this process, including re-examining requests we are unable to fulfill, you may contact [email protected].

Rights that may apply to you depending on your state of residency are:

• Right to confirm, know, or access. You may have the right to confirm that we process your personal information, know details concerning that processing, and to access your personal information. This covers information regarding:
  • The categories or specific pieces of your personal information that we have confirmed that we process
  • Our purposes for processing your personal information
  • The categories of personal information we disclose to external parties
  • The categories of external parties to which we disclose your personal information
  • You also may have the right to obtain your personal information in a transportable format

Depending on your state of residency, you also may request a list of third-party organizations we disclose personal information to; we may limit the list to only third-party organizations that specifically received personal information about you.

• Right to correct personal information. You may request that we correct personal information that we maintain about you if you believe such personal information is inaccurate. Upon receipt of a verifiable request to correct inaccurate personal information, we will use commercially reasonable efforts to correct the information as you direct.
• Right to request deletion of personal information. You may request that we delete your personal information, and we will direct our service providers to do the same. Please note that we may retain certain personal information as permitted by applicable law, including where it is necessary to:
  • complete the transaction for which the personal information was collected, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
  • debug to identify and repair errors that impair existing intended functionality;
  • exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • comply with the California Electronic Communications Privacy Act;
  • engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when deletion is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • comply with an existing legal obligation; or
  • otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
• Opt-out rights. Generally, we do not sell (for monetary or nonmonetary benefits) personal information. However, under some state laws, our use of certain cookies and other similar online tracking technologies, including for cross-context behavioral or targeted advertising purposes, may be considered a “sale” of personal information. You may opt out of sale or cross-context behavioral or targeted advertising through cookies and other similar technologies by accessing the Website’s cookie management tool. Depending on the current design of the Website, you may be able to access the cookie manager through a link in the footer, a visible cookie icon, or another similar link. If your browser is configured to send a Global Privacy Control (GPC) signal, we will interpret such signal as a request to opt out of any sale or sharing of personal information for that browser, and the Website will display whether your request has been honored. For more information about Global Privacy Control, please visit oag.ca.gov/privacy/ccpa.

Otherwise, you may request to exercise applicable opt-out rights by contacting [email protected].

We will comply with your request as soon as reasonably practicable, in accordance with applicable legal requirements. We will not discriminate against you for choosing to exercise any of your privacy rights.

To prevent unauthorized requests related to your personal information, we take steps to verify that you are the person that is the subject of the request and, where applicable, your state of residence. Following verification of your identity, we will process your request; if we are unable to fulfill your request, we will let you know why.

Depending on your state of residency, you may have the right to designate an authorized agent to make certain privacy rights requests on your behalf. We will subject privacy rights requests we receive from agents to our verification process, which includes verifying the identity of the agent and their authorization to make the request, and agents must provide documentation demonstrating their authority to act on the individual’s behalf.

Additional Disclosures for California Residents

The California Consumer Privacy Act (“CCPA”) requires businesses to provide California residents with certain disclosures regarding the collection, use, and disclosure of their personal information.

We do not sell personal information for monetary consideration. Depending on how certain Website technologies are implemented (such as analytics tools, tracking technologies, or similar technologies), we may disclose or make available identifiers, internet or other electronic network activity information, geolocation data, and inferences to third parties in ways that could be considered “selling” or “sharing” for cross-context behavioral advertising under California law.

We may also allow certain third parties, such as analytics providers or service providers acting on our behalf, to collect or process personal information through the Website or our communications. These third parties are subject to contractual restrictions that limit their retention, use, and disclosure of personal information to our business purposes, except as otherwise permitted by applicable law.

We do not knowingly sell or share personal information of individuals under 16 years of age.

Categories of Personal Information Collected and Disclosed. During the preceding 12 months, we may have collected and disclosed for business purposes the following categories of personal information:

We collect and disclose these categories of personal information for the business and commercial purposes described in this Privacy Policy, including to operate our business, manage relationships, comply with legal obligations, and improve our services, and we retain them in accordance with Section 9.

12. Visitors Located Outside of the United States

If you are located outside the United States, you acknowledge that your personal information will be transferred to and processed in the United States, or in other jurisdictions which may have data protection laws and regulations that are different from the laws in your country of residence.

13. Email Communications

From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our services, we may receive a notification when you open an email from us or click on a link therein. If you would like to stop receiving marketing or promotional communications via email from us, you may opt out of such communications by clicking on the “unsubscribe” link in any such email.

14. Text Communications

If you provide us with your telephone number and the consent requested at the point of collection, we may send you text messages for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. You agree to hold us harmless for any fees that are incurred via your telephone provider. By providing that consent, you agree that you have consented to such contact for the purposes of the Telephone Consumer Protection Act (47 U.S.C. § 227) and similar or equivalent state and foreign laws. Consent to receive marketing text messages is not a condition of purchase. If you would like to stop receiving text messages from us, you may opt out by replying “STOP,” by emailing us with the phone number you would like to have removed from our records, or by any other reasonable means.

15. Children Under Thirteen

We do not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use the Website. If you are the parent or guardian of a child under thirteen who you believe has accessed the Website in a way that would lead to the collection of their personally identifiable information, please contact us so that we can delete your child’s information.

16. Agreement to Arbitrate and Class Waiver

By accessing the Website or by providing your information, you acknowledge that part of the valuable consideration for your use of the Website is your agreement to arbitrate all claims through New Era ADR (www.neweraadr.com). If New Era ADR is no longer available, all claims will be arbitrated in another agreeable arbitration forum. In the event that you assert a combination of claims, including some classified as non-arbitrable under a relevant state or federal law, you agree that the non-arbitrable claims may be brought as a separate action in the appropriate state or federal court. You also agree that all remaining arbitrable claims, including but not limited to those relating to reservations, employment applications, data privacy, and/or use of image, shall be severed and subject to arbitration. These arbitration provisions shall be read broadly and interpreted under the Federal Arbitration Act (9 U.S.C. § 1, et seq.) or any other version of the Act that may come into existence. If there is a dispute regarding the applicability of these arbitration provisions, that issue will be submitted for arbitration to New Era ADR or, if it is unavailable, an arbitrator agreed upon or appointed by the court.

You further agree not to seek any relief as a member of a class and irrevocably agree to opt out of any class action litigation. You acknowledge that by doing so you are waiving your right to have this matter heard by a jury or a judge. In the event that you seek to file any claim in court and GR OPCO, LLC or any of its affiliates are required to compel arbitration or seek to dismiss the class claims, you acknowledge that the prevailing party in such litigation may be entitled to reasonable attorneys’ fees and costs.

17. Contact Us

We welcome your questions or comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy, please contact us at: GR OPCO, LLC, 20 NE 11th Street, Miami, Florida 33132; Email: [email protected]; Telephone: (305) 360-1111; Toll-free (privacy requests): 1-866-I-OPT-OUT (1-866-467-8688), service code 2542#.