Privacy Policy

Troon takes your privacy and the privacy of your Personal Information seriously. This Privacy Policy explains our collection, use, disclosure, retention, and protection of your Personal Information, including information related to your past use of Troon products and services. Collection of Personal Information "Personal Information” is data and information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information when you use our Services. Such Personal Information includes, but is not limited to: • Name • Gender • Postal address • Telephone number • Email address • Credit and debit card number or other payment data • Important dates, such as birthdays, anniversaries and special occasions • Membership or loyalty program data • Prior golf rounds or interactions, and goods and services purchased • Travel itinerary, tour group or activity data • Geolocation information • Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts • In more limited circumstances, we also may collect: o Data about family members and companions, such as names and ages of children o Images and video and audio data via security cameras located in public areas in our facilities o Guest preferences and personalized data (“Personal Preferences”), such as your interests, activities, hobbies, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit If you submit any Personal Information about other people to us or our Service Providers (e.g., if you make a tee time for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Policy. What This Privacy Policy Covers – Personal Information This Privacy Policy describes the privacy practices of Troon for Personal Information that we collect: • through our websites operated by us from which you are accessing this Privacy Policy, including Troon.com and other websites owned or controlled by Troon (collectively, the “Websites”) • through the software applications made available by us for use on or through computers and mobile devices (the “Apps”) • through our social media pages that we control from which you are accessing this Privacy Policy (collectively, our “Social Media Pages”) • through HTML-formatted email messages that we send you that link to this Privacy Policy and through your communications with us • when you visit or play at one of our properties, or through other offline interactions Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Policy. This policy does not apply to the practices of companies that Troon does not own or control, or to people that Troon does not employ or manage. In addition, certain Troon associated companies that have their own privacy policies. How We Collect Personal Information • Online Services. We collect Personal Information when you make a tee time, reservation, purchase goods and services from our Websites or Apps, communicate with us, or otherwise connect with us or post to social media pages, or sign up for a newsletter or participate in a survey, contest or promotional offer. • Property Visits and Offline Interactions. We collect Personal Information when you visit our properties or use on-property services and outlets, such as golf, tennis, and restaurants. We also collect Personal Information when you attend promotional events that we host or in which we participate, or when you provide your Personal Information to facilitate an event. • Other Offline Interactions. We collect Personal Information when you communicate with us over the phone, mail or fax. • Owners. We collect Personal Information from Owners of properties we manage, or to which we provide services. Owners are independent from Troon. • Authorized Licensees. We collect Personal Information from companies when we enter into a license or similar agreement to sell goods and services under a Troon brand (“Authorized Licensees”). Examples of Authorized Licensees include Troon Golf Vacations. Authorized Licensees are independent from Troon. • Strategic Business Partners. We collect Personal Information from companies with whom we partner to provide you with goods, services or offers based upon your experiences at our properties or that we believe will be of interest to you (“Strategic Business Partners”). Examples of Strategic Business Partners include golf and tournament applications and booking applications. Strategic Business Partners are independent from Troon. • Other Sources. We collect Personal Information from other sources, such as public databases, joint marketing partners and other third parties. • Physical & Mobile Location-Based Services. We collect Personal Information if you download one of our Apps or choose to participate in certain programs. For example, we may collect the precise physical location of your device by using satellite, cell phone tower, WiFi signals, or other technologies. We will collect this data if you opt in through the App or other program (either during your initial login or later) to receive the special offers and to enable location-driven capabilities on your mobile device. If you have opted-in, the App or other program will continue to collect location data when you are in or near a participating property until you log off or close application (i.e., the App or other program will collect this data if it is running in the background) or if you use your phone’s or other device’s setting to disable location capabilities for the Troon App or other program. Collection of Other Data “Other Data” are data that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Information. Other Data include: • Browser and device data • App usage data • Data collected through cookies, pixel tags and other technologies • Demographic data and other data provided by you • Aggregated data How We Collect Other Data • Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly. • Your use of the Apps. We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers and what data and files have been downloaded to the App based on your device number. • Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails. You can choose whether to accept cookies by changing the settings on your browser. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, you will not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals. For more information on how you can block, delete, or disable Cookies and similar technologies, please review your browser or device settings. • Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services. • Analytics. We collect data through Google Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt out browser add-on, available at tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt out by visiting www.adobe.com/privacy/opt-out.html. • Your IP Address. We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address. • Aggregated Data. We may aggregate data that we collected and this aggregated data will not personally identify you or any other user. How We Use Personal Information and Other Data We use Personal Information and Other Data to provide you with Services, to develop new offerings and to protect Troon and our guests as detailed below. In some instances, we will request that you provide Personal Information or Other Data to us directly. If you do not provide the data or information that we request, or prohibit us from collecting such data or information, we may not be able to provide the requested Services. We use Personal Information and Other Data for our legitimate business interests, including the following: • Provide the Services you request. We use Personal Information and Other Data to provide Services you request, including: o To facilitate tee times, reservations, payment, send administrative information, confirmations or pre-arrival messages, to assist you with tournaments and events and to provide you with other information about the property you are visiting. o To complete your tee time, for example, to process your payment, ensure that your requested tee time is available and provide you with related customer service o To support an electronic receipt program. When you provide an email address in making a tee time or other purchase, we use that email address to send you a copy of your receipt. We will use Personal Information and Other Data to manage our contractual relationship with you, because we have a legitimate interest to do so and/or to comply with a legal obligation. • Personalize the Services according to your Personal Preferences. We use Personal Information and Other Data to personalize the Services and improve your experiences, including when you visit one of our properties or use the Online Services, to: o Customize your experience according to your Personal Preferences o Present offers tailored to your Personal Preferences We will use Personal Information and Other Data to provide personalized Services according to your Personal Preferences either with your consent or because we have a legitimate interest to do so. • Communicate with you about goods and services according to your Personal Preferences. We use Personal Information and Other Data to: o Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys We will use Personal Information and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so. • Loyalty Programs. We use Personal Information and Other Data to: o Offer and manage your participation in our loyalty programs, such as Troon Rewards and Troon Card, as well as others that are specific to certain properties or tailored to your interests o Send you offers, promotions and information about your account status and activities o Assess your benefits o Manage your choices regarding how you wish to earn, track and use your points We will use Personal Information and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so. • Sweepstakes, activities, events and promotions. We use Personal Information and Other Data to allow you to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities have additional rules and may contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully. We use Personal Information and Other Data in this way with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so. • Business Purposes. We use Personal Information and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of closed circuit television, card keys, and other security systems), developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities. We use Personal Information and Other Data in this way to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so. Sharing and Disclosure of Personal Information and Other Data Troon does not rent, sell, or share Personal Information about you with other people or nonaffiliated companies except to provide products or Services you've requested, when we have your permission, or under the following circumstances: Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Information and Other Data with the following: • Troon. We disclose Personal Information and Other Data to other companies within the Troon Family for the purposes described in this Privacy Policy, such as providing and personalizing the Services, communicating with you, facilitating the loyalty programs, and to accomplish our business purposes. Troon Golf, L.L.C. is the party responsible for the management of the jointly-used Personal Information. We share your Personal Information and Other Data used for making a tee time with the applicable property to fulfill and complete your tee time. • Owners. We disclose Personal Information and Other Data to Owners of properties we manage, or to which we provide services, for the purposes described in this Privacy Policy, such as providing and personalizing the Services and facilitating the loyalty programs. • Authorized Licensees. We disclose Personal Information and Other Data to our Authorized Licensees for the purposes described in this Privacy Policy, such as providing and personalizing the Services and fulfilling your requests. For example, this sharing enables you to purchase Troon themed vacations. • Strategic Business Partners. We disclose Personal Information and Other Data with select Strategic Business Partners who provide goods, services and offers that enhance your experience at our properties or that we believe will be of interest to you. By sharing data with these Strategic Business Partners, we are able to make personalized services and unique travel experiences available to you. For example, this sharing enables restaurants and other outlets at our properties to provide you with Services. • Service Providers. We disclose Personal Information and Other Data to third-party service providers for the purposes described in this Privacy Policy. Examples of service providers include companies that provide website hosting, customer surveys, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services. • Linked Accounts and Promotional Activity. We partner with certain third parties that allow you to enroll in their services or participate in their promotions. For example, certain companies allow you to use your loyalty program number or Online Services login to receive or register for their services. These companies include resorts, as well as sponsors of sweepstakes and contests. If you do not want us to share your Personal Information or Other Data in this way, do not provide your loyalty program number to third parties, do not use your Online Services login to register for third-party promotions and do not connect your Online Services account with accounts on third-party services. Data shared in this way will be governed by the third party’s privacy policy and not this Privacy Policy. • Corporate Reorganization. We may disclose or transfer your Personal Information and Other Data to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Troon business, shares or assets (including any bankruptcy or similar proceedings). Other Uses and Disclosures We will use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence and to meet national security or law enforcement requirements; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of Troon, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Information (such as combining your name with your location). If we do, we will treat the combined data as Personal Information as long as it is combined. Non-Troon Entities and Third Party Advertisers This Privacy Policy does not address, and we are not responsible for the privacy, data or other practices of any entities outside of Troon, including, Owners, Authorized Licensees, Strategic Business Partners or any third party operating any site or service to which the Services link, payment service, loyalty program, or website that is the landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Information. In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or the Apps or our Social Media Pages. We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice, and to learn about your choices in connection with it, please contact us at [email protected]. Confidentiality and Security We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. We limit access to Personal Information about you to employees who we believe reasonably need to come into contact with that information to provide products or Services to you or in order to do their jobs. We also have physical, electronic, and procedural safeguards to protect Personal Information about you. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section, below. Updating Account Information You have choices when it comes to how we use your data and we want to ensure you have the information to make the choices that are right for you. You can edit your Troon Account Information, including your marketing preferences, at any time. New categories of marketing communications may be added to the Marketing Preferences page from time to time. Users who visit this page can opt out of receiving future marketing communications from these new categories or they can unsubscribe by following instructions contained in the messages they receive. You can unsubscribe from Troon emails by clicking on the unsubscribe link at the bottom of all of our customer emails, replying to such emails with the word "unsubscribe" in the subject line, emailing [email protected] notifying us of your desire to be removed from Troon's email list or by calling 1.888 TROON U.S. At which time, Troon will keep your Personal Information, but will no longer contact the specific email address that was unsubscribed with solicitous emails. We will try to comply with your request as soon as reasonably practicable. If you opt out of receiving marketing emails from us, we may still send you important administrative messages, from which you cannot opt out. Special Notice for California Residents: Customers who reside in California and have provided their Personal Information to us can request, once per calendar year, information about our sharing of certain categories of Personal Information to third parties and within Troon, for their direct marketing purposes. Such requests should be submitted to us at [email protected] or notifying us in accordance with the “Contacting Us” section, below. We will provide a list of the categories of Personal Information disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph. How You Can Access, Change or Suppress Your Personal Information If you would like to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by law), you can contact us at [email protected] or notifying us in accordance with the “Contacting Us” section, below. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database, or other limitations you would like to put on our use of your Personal Information. For your protection, we only fulfill requests for the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable. Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or tee time, or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase, reservation, or promotion). There may also be residual data that will remain within our databases and other records, which will not be removed. In addition, there may be certain data that we may not allow you to review for legal, security or other reasons. Retention We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include: • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services) • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them) • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations) Sensitive Data Unless specifically requested, we ask that you not send us, and you not disclose, on or through the Services or otherwise to us, any Sensitive Personal Information (e.g., social security numbers, national identification number, data related to racial or ethnic origin, political opinions, religion, ideological or other beliefs, health, biometrics or genetic characteristics, criminal background, trade union membership, or administrative or criminal proceedings and sanctions). Use of Services by Minors The Services are not directed to individuals under the age of sixteen (16), and we request that they not provide Personal Information through the Services. International Transfer of Personal Information and Other Data Troon is a global organization and provides a global service. Sharing data cross-border is essential to the Services so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to law, transfer Personal Information and Other Data collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By making a tee time, reservation, visiting or playing at a Troon managed property, or a property to which we provide services, you understand that we transfer your Personal Information globally. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Information. Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. Changes to this Privacy Policy Troon may update this Privacy Policy at any time. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Online Services. We will notify you about significant changes in the way we treat Personal Information by sending a notice to the primary email address specified in your Troon account and by placing a prominent notice on our site. Your use of the Services following these changes means that you accept the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at [email protected]. Contacting Us If you have questions or suggestions, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please complete a feedback form or you can contact us at: Troon Golf, LLC 15044 North Scottsdale Road Suite 300 Scottsdale, Arizona 85254 Phone: 480.606.1000 Fax: 480.606.1010 Email: [email protected] Additional Information If you are in the EU or EFTA, or are an EU or EFTA citizen, you can also lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=6120