Last Updated: 10/04/2026

1. Introduction & Scope
This Privacy Policy ("Policy") describes how AARO Real Estate LLC, doing business as AARO Hospitality, together with its affiliates and subsidiaries, including AARO Hospitality Management, AARO Holdings, and AARO Construction Management, and any other entities now or in the future under common ownership or control with AARO ("AARO," "we," "us," or "our"), collects, uses, and protects information gathered through this website (the "Site"). Each such affiliate and subsidiary is a covered party under, and an intended third-party beneficiary of, Sections 18 (Governing Law and Dispute Resolution), 19 (Limitation of Liability), and 20 (Indemnification). This Policy applies solely to information collected through the Site and does not apply to information provided through separate offline processes, including any investor subscription, accreditation verification, onboarding documentation, or the employment relationship following hire, which are governed by separate agreements and disclosures provided to you directly. This Policy is incorporated into and subject to our Terms and Conditions. By accessing or using the Site, you acknowledge that you have read and understood this Policy. If you do not agree, your sole and exclusive remedy is to discontinue use of the Site.

2. Categories of Information We Collect
Through the Site, we collect: (a) contact information you voluntarily submit through a form, including name, email address, phone number, and stated investment interest; (b) limited technical information, including IP address, browser and device type, and general browsing activity, collected only through the tools identified in Section 6; and (c) career and applicant information you voluntarily submit if you apply or express interest in a role, as described in Section 9.
Except as an applicant may voluntarily include in application materials (see Section 9), we do not collect, request, or store financial account information, Social Security numbers, tax records, net worth documentation, government-issued identification, biometric data, health information, precise geolocation, or protected-class information through the Site, and no part of the Site is designed to solicit them. We do not use session replay, keystroke logging, or screen-recording technology. Any accredited investor verification required before an investment occurs entirely through a separate, secure, offline process that is not part of the Site.

3. Sources of Information
We collect information directly from you when you voluntarily submit it through a Site form or when you send it to a designated AARO email address in connection with an application, and limited technical information automatically through the tools in Section 6, only after consent is obtained where required. We do not acquire information about you from third-party data brokers.

4. How and Why We Use Information
We use Site-collected information solely to respond to inquiries, follow up regarding stated investment interest, evaluate and respond to applications for employment as described in Section 9, analyze and improve the Site, and maintain records as required by law. We do not engage in automated decision-making producing legal or similarly significant effects. Submitting an inquiry or application does not constitute an offer, commitment to invest, commitment to employ, or investment advice, and does not obligate AARO to accept, respond to, or act on any inquiry, application, or communication.

5. Disclosure & Sharing of Information
We do not sell your personal information, and we have not sold personal information in the preceding twelve months. We share Site-collected information only with: our affiliates and subsidiaries, where relevant to the purpose for which you provided it, including the evaluation of candidates for roles across the AARO platform as described in Section 9; service providers acting solely on our behalf and under contractual restriction, including analytics, hosting, communications, recruiting, and record-keeping providers (currently including Google Analytics, Google Search Console, Framer's built-in site tools, and our email provider); consumer reporting agencies engaged to perform a background check, but only as described in Section 10; brand franchisors, property owners, or management counterparties where a position relates to a specific managed or franchised property and disclosure is necessary to evaluate or place a candidate; our legal counsel and professional advisors; regulators or authorities where required by law, subpoena, valid legal process, or to protect the rights, property, or safety of AARO, its affiliates, or others; and a successor entity in connection with any merger, acquisition, financing, or sale of assets. Our service providers are contractually prohibited from using Site-collected information for their own independent purposes. Except as described in Section 9, we do not share your information with any third party for that party's independent advertising or marketing.

6. Cookies & Tracking Technologies
The Site uses a limited, specifically identified set of tools: Google Analytics, Google Search Console, and Framer's built-in analytics and site tools. Google Search Console is used to monitor the Site's performance in search results and relies on data Google collects about searches and clicks relating to the Site; it does not place tracking cookies on your device through the Site. We do not use advertising pixels (such as Meta Pixel or TikTok Pixel), session replay, or keystroke-logging tools, and will not add such technologies without first updating this Policy. Non-essential cookies and analytics load only after you provide affirmative consent through the cookie consent banner presented on your first visit, and you may withdraw consent at any time through that banner or your browser settings. We honor Global Privacy Control (GPC) signals as a valid opt-out. Because no common industry standard yet exists for browser "Do Not Track" signals, we do not currently respond to them. See our separate Cookie Policy for detail.

7. Data Retention
We retain Site-collected contact information only as long as reasonably necessary to respond to your inquiry, maintain accurate business records, or satisfy applicable legal, tax, or regulatory recordkeeping obligations, after which it is securely deleted or anonymized. Application materials from candidates who are not hired are retained for the period required by applicable anti-discrimination and recordkeeping laws, generally at least one year from the date of the employment decision, and longer where a longer period is required by law or where we retain them to consider you for future opportunities, after which they are securely deleted or anonymized. Retention periods may vary with the nature of the inquiry, the role, and applicable law.

8. Data Security
We maintain reasonable administrative, technical, and physical safeguards appropriate to the nature of the information collected through the Site. Because you may choose to send application materials to us by email, please be aware that email is not a secure medium, and any materials you transmit to us by email are sent at your own discretion and risk. No method of internet transmission or electronic storage is completely secure, and we do not and cannot guarantee absolute security. You transmit information through or in connection with the Site at your own discretion and assume the inherent risks of internet and email transmission. We will provide notice of any security incident affecting your information as, and only to the extent, required by applicable law.

9. Job Applicants and Careers
This section applies to information we collect from and about individuals who apply for, express interest in, or are considered for a role with AARO or any affiliate through the Site's careers pages or related channels. It supplements the rest of this Policy.
Information we collect from applicants. Through the careers form you voluntarily submit your full name, email address, phone number, and the content of any cover letter or additional details you choose to provide. You are then directed to send your resume and supporting materials to a designated AARO email address. Any message or document you send to that address, including your resume, employment and education history, certifications, professional references, lawful work authorization to the extent you volunteer it, and any other content you choose to include, is collected and retained as part of your application. We collect only what you choose to provide, and you are not required to submit sensitive information to be considered.
Please do not send sensitive information. We do not request, and we ask that you not include in any form submission, cover letter, resume, or email, any Social Security or government identification number, date of birth, financial account information, driver's license or passport image, health or disability information, or information revealing a protected characteristic such as race, color, religion, national origin, sex, sexual orientation, gender identity, age, genetic information, citizenship status beyond lawful work authorization, or veteran status. Such information is not needed at the application stage and will not improve your candidacy. If you include it, you do so voluntarily, and we will handle it as described under "Unsolicited information" below.
How we use applicant information. We use it to evaluate your application, communicate with you about current and future opportunities, verify the information you provide, conduct interviews and assessments, make hiring decisions, and maintain records required by law. If you are hired, information collected during recruiting becomes part of your employment record, governed by our internal employee privacy practices and applicable agreements rather than by this Policy.
How we share applicant information. We may share it with the recipients identified in Section 5, including our affiliates and subsidiaries where a role spans or may suit more than one AARO entity, recruiting and record-keeping service providers under contractual restriction, consumer reporting agencies as described in Section 10, and property-related counterparties where a position relates to a specific managed or franchised property. We do not sell applicant information and do not share it for any third party's independent advertising or marketing.
Automated decision-making. We do not use automated decision-making or artificial intelligence tools that make hiring decisions about you without human involvement. Human reviewers evaluate every application. If this changes, we will update this Policy and provide any notice and choices required by applicable law.
Equal opportunity and voluntary disclosures. AARO is an equal opportunity employer. Where we invite voluntary self-identification of demographic information for equal employment opportunity recordkeeping, that information is requested separately, is strictly voluntary, is not used in hiring decisions, and is maintained apart from your application.
No employment relationship. Submitting an application or materials does not create an employment relationship, offer, or contract of any kind, does not obligate AARO to respond, interview, or hire, and does not alter the at-will nature of any employment that may result. Any employment relationship is separately documented in writing.
Unsolicited information. If you send us information we did not request, including sensitive information or information about third parties such as references, you represent that you are permitted to share it, and you authorize us to retain or delete it at our discretion in accordance with this Policy and applicable law.

10. Background Checks and Consumer Reports
Where permitted by law and relevant to a role, a conditional offer of employment may be subject to a background check performed by a third-party consumer reporting agency. If we intend to obtain such a report, we will provide you with a separate, standalone disclosure and obtain your written authorization before any report is requested, as required by the federal Fair Credit Reporting Act and applicable state and local law. This Policy is not that disclosure and does not constitute your authorization. If information in a report may lead us to take an adverse action, we will follow the pre-adverse and adverse action notice process the law requires, including providing a copy of the report and a summary of your rights.

11. Biometric and Workplace Information
We do not collect biometric information through the Site. If you are hired into a role that uses a biometric time-and-attendance or access system, such as a fingerprint or facial-geometry time clock, we or the applicable property employer will provide a separate written notice and obtain your informed consent before any biometric identifier is captured, and will retain and destroy such data as required by applicable law, including the Texas Capture or Use of Biometric Identifier Act and comparable laws in other states in which you may work. This Policy is not that notice or consent.

12. Accuracy of Information and Your Responsibilities
You represent that information you submit through or in connection with the Site, including application materials, is true, accurate, complete, and your own to share. Providing false, misleading, or incomplete information, or omitting material information, may result in rejection of an application or, if discovered after hire, disciplinary action up to and including termination, to the fullest extent permitted by law. You are responsible for the content you transmit and for ensuring you have the right to share any third-party information you provide.

13. Your Privacy Rights and State-Specific Disclosures
Depending on your state of residence, and subject to applicable exceptions, you may have the right to request access to or a copy of the personal information we hold about you, to request correction of inaccurate information, to request deletion, to obtain information about our collection and sharing practices, and to opt out of the sale or sharing of personal information or of certain targeted advertising or profiling. We do not sell personal information and do not use it for targeted advertising or profiling that produces legal or similarly significant effects.
California residents. Under the California Consumer Privacy Act, as amended, these rights extend to personal information we collect about California residents, including job applicants. You may request the categories and specific pieces of personal information we have collected, the categories of sources, the business purpose for collection, and the categories of third parties to whom it was disclosed. You have the right to request deletion and correction, the right to limit the use of sensitive personal information where applicable, and the right to opt out of sale or sharing, which we do not conduct. California's "Shine the Light" law permits certain requests regarding disclosure to third parties for their direct marketing, which we do not do.
Texas residents. Under the Texas Data Privacy and Security Act, you may exercise the rights described above and, if we decline a request, you may appeal that decision by contacting us as described below; we will respond to an appeal within the time the law requires and, if the appeal is denied, provide a means to contact the Texas Attorney General.
Other states. Residents of other states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Oregon, Montana, and others as such laws take effect, may have comparable rights, including a right to appeal a declined request where provided by law. Nevada residents may opt out of the sale of certain covered information, which we do not conduct.
How to exercise your rights. To make a request, contact admin@aarorealestate.com. We will not discriminate against you for exercising these rights. We may require reasonable verification of your identity before responding and may accept requests from an authorized agent with proof of authorization. We may decline requests to the extent permitted by law, including where a request is unfounded, excessive, repetitive, cannot be verified, or where retention or disclosure is required or permitted by law.

14. Children's Privacy
The Site is not directed to individuals under 18, and we do not knowingly collect their information. Individuals under 18 should not submit applications or personal information through the Site except as permitted by law and with the involvement of a parent or legal guardian where required. If we learn we have inadvertently collected information from a child, we will delete it promptly. If you believe a child has provided information through the Site, contact admin@aarorealestate.com.

15. Third-Party Links
The Site may link to third-party websites, including hotel brand or franchise partner sites and job boards, for convenience only and without endorsement beyond what is expressly stated. We are not responsible for the content, privacy practices, or security of those sites and encourage you to review their policies before providing information.

16. Accessibility
We are committed to making this Policy and the Site accessible. If you have difficulty accessing any portion, contact admin@aarorealestate.com for assistance, including to request this Policy in an alternative format.

17. Changes to This Policy
We may update this Policy at any time in our sole discretion to reflect changes in our practices or applicable law. The "Last Updated" date reflects the most recent revision, and your continued use of the Site after an update constitutes acceptance of the revised Policy. This Policy is reviewed and, where necessary, updated at least once every twelve months.

18. Governing Law, Dispute Resolution & Class Waiver
This Policy is governed by the laws of the State of Texas, without regard to conflict-of-law principles. Any dispute, claim, or controversy arising out of or relating to this Policy or your use of the Site, including any claim that this Policy was violated, shall be resolved exclusively through final and binding individual arbitration administered in Harris County, Texas, under the rules of a recognized arbitration provider, except that either party may bring an individual claim in small-claims court where eligible.
This arbitration agreement and the class-and-representative-action waiver below apply only to disputes arising from your use of the Site. They do not apply to, and nothing in this Policy governs, any dispute arising out of an application for employment or an employment relationship with AARO or any affiliate, which is addressed, if at all, only through a separate written agreement signed by you. Nothing in this Policy requires arbitration of any claim that applicable law prohibits from being subject to a pre-dispute arbitration agreement, including claims of sexual assault or sexual harassment under the federal Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act.
To the fullest extent permitted by applicable law, you and AARO each agree that claims subject to this Section may be brought only in an individual capacity, and not as a plaintiff or class member in any class, collective, consolidated, mass, or representative proceeding. Any claim must be brought within one year after the event giving rise to it, to the extent such limitation is permitted by law. The parties waive any right to a jury trial to the fullest extent permitted by law.

19. Limitation of Liability
To the fullest extent permitted by applicable law, the aggregate liability of AARO and its affiliates arising out of or relating to this Policy or the Site shall not exceed the greater of the amount you paid to AARO in the twelve months preceding the claim, which for most Site visitors and applicants is zero, or one hundred U.S. dollars ($100). To the fullest extent permitted by law, AARO and its affiliates shall not be liable for indirect, incidental, special, consequential, or punitive damages. Nothing in this Policy limits liability that cannot be limited or excluded under applicable law.

20. Indemnification
To the fullest extent permitted by applicable law, you agree to indemnify, defend, and hold harmless AARO Real Estate LLC and its affiliates and subsidiaries, and their respective members, managers, officers, employees, and agents, from and against any claims, liabilities, damages, losses, and expenses, including reasonable attorneys' fees, arising out of or related to: (a) information you submit through or in connection with the Site that is false, infringing, or submitted without authorization, including third-party information such as references; (b) your violation of this Policy or the Terms and Conditions; or (c) your violation of any law or the rights of any third party. This provision survives termination of your use of the Site. This Section does not apply to any claim arising out of an employment relationship, which is governed solely by separate written agreement and applicable law.

21. Severability, Savings & No Waiver
If any provision of this Policy is held invalid, unenforceable, or unconscionable by a court or arbitrator of competent jurisdiction, that provision shall be modified to the minimum extent necessary to make it enforceable, or if it cannot be so modified, severed from this Policy, and all remaining provisions shall continue in full force and effect. If the class-and-representative-action waiver in Section 18 is found unenforceable as to any particular claim, that claim, and only that claim, shall proceed in a court of competent jurisdiction, while all other claims remain subject to individual arbitration. Our failure to enforce any provision shall not constitute a waiver of that or any other provision.

22. Contact Us
Questions or requests regarding this Policy:
admin@aarorealestate.com
AARO Real Estate LLC, 10050 Northwest Freeway, Suite 105, Houston, TX 77092