PRIVACY POLICY

Troon Golf, LLC, and its brands, affiliates and subsidiaries (“Troon,” “we,” “our,” or “us”), respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, use and safeguard the information you provide to us in using our website, Troon.com, and the websites that link to this Privacy Policy (collectively, the “Site”), the services provided through our Site and the mobile applications we offer (collectively referred to as the “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically. Your continued use of the Site and Services after any such amendment signifies your acceptance thereof.

Personally Identifiable Information We Collect Online

Through your use of the Site and Services, we may collect Personally Identifiable Information from you. “Personally Identifiable Information” is individually identifiable information about an individual consumer that we collect online and that we maintain in an accessible form. We collect the following types of Personally Identifiable Information:

Information You Provide

We may collect the following Personally Identifiable Information that you voluntarily provide to us:

• Book Tee Times. When you book a tee time on our Site, you will provide your first and last name, email address, and telephone number, and may be asked to provide your mobile phone number, work phone number, postal address, gender, date of birth, home club membership number, and any additional Personally Identifiable Information that you choose to provide. You may be required to login with a username and password.
  
• Contact Us. When you complete a webform on our Site to contact us or request more information from us, you will provide your first and last name and email address, and may provide us with additional Personally Identifiable Information such as your postal address, telephone number, mobile phone number, home club membership number, and Troon Rewards card number.
  
• Newsletter Footer.  When you complete a newsletter form on our Site, (available on select Sites), you will provide your email address and may provide us with additional Personally Identifiable Information such as your first and last name, telephone number, address and more.
  
• Troon Rewards. When you register for Troon Rewards, you will provide your first and last name, email address, zip code, and country.  To login to Troon Rewards, you will provide your email address, password, and rewards number.
  
• Marketing Emails. When you sign up to receive marketing messages from us and our preferred partners, you will provide your first and last name, email address, and zip code and may be requested to provide your country and home club.
  
• Troon app. When you create an account on the Troon app, you are also creating a Troon Rewards profile which include the same collection of information as stated with Troon Rewards bullet above.
  
• Course Mobile App. When you create an account with our Course app, (available on select Sites), you will provide your first and last name, email address and possibly other Personally Identifiable Information.
  
• Text Club.  When you sign up for text club, (available on select Sites), you will provide your cell phone number.  It is possible at future onboarding opportunities you can provide your first and last name, email address, and other Personally Identifiable Information.  
  
• Subscribe to eMagazine. When you subscribe to our free Troon or Troon Privé e-magazine, or Cliff Drysdale Tennis’ Experience Magazine, you will provide your first and last name, state, country, and email address.
  
• Purchase Gift Cards. We use third-party payment processors to process your purchase of Troon Gift Cards.  We do not collect any of this information.
  
• Online Store. When you purchase gift cards, merchandise, prepaid rounds, and other various items on our Course Site stores (available on select Sites), you will provide your first and last name, email address, address, telephone number, and credit and debit card number or other payment data. We use a third-party payment processor to process your purchase.  We maintain this information and record of your purchase and will occasionally send marketing messages.
  
• Purchase Troon Cards. When you purchase a Troon Card (including National, State, Regional, Patriot or Executive), you will provide your first and last name, email address, shipping and billing address, telephone number, and credit and debit card number or other payment data.  We use third-party payment processors to process your purchase.  We also maintain this information and a record of your purchase.
  
• Troon Junior Club Registration. When you register your junior golfer for our Troon Junior Club, you will provide your first and last name, email address, telephone number, and postal address, and will provide certain information about the junior golfer, such as name, gender, and date of birth (must be 17 or younger).
  
• Surveys.  When you provide feedback through email or on our Site (available on select Sites), at times you will provide your first and last name, email address, telephone number, and possibly other Personally Identifiable Information.
  
• Tournament Registration. When you register on our Site for one of our tournaments, for example, the Troon Cup or Troon Challenge, you will provide your first and last name, email address, and telephone number and may provide a credit or debit card number or other payment data.
  
• Online Lessons. When you register on our Site for a golf lesson (available on select Sites), you will provide your first and last name, email address, telephone number, possibly address and may provide a credit or debit card number or other payment data.
  
• Owner Account Login. If you are an owner of properties we manage, or to which we provide services, when you login to your account, you will provide your email address and password.
  
• Buzz (Live Chat or Chat Bots). When you use the live chat feature (available on select Sites), we will collect any Personally Identifiable Information that you choose to provide.
  
• Comment on Blog Posts. When you leave a comment on any of our blogs, you will provide your first and last name and email address.
  
• Additional Information. When you submit information on the Site, send an email from the Site, respond to a survey or communication, interact with us through social media channels, or participate in another Site function or feature, you may provide us with other Personally Identifiable Information.
  

Information as You Navigate Our Site

We automatically collect certain Personally Identifiable Information through your use of the Site and Services, such as the following:

• Usage Information. We collect information such as which of the pages on the Site you access, the frequency of access, and what you click on while on the Site.
  
• Device Information. We collect information about the device you are using, such as hardware model, operating system, application version number, and browser.
  
• Mobile Device Information. In addition to the Device Information listed above, when you access our Site via a browser on your mobile device, we collect and aggregate information about whether you are accessing the Site via a mobile device or tablet, device type, and carrier.
  
• Mobile App Information. 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.
  
• Location Information. We collect location information from Site visitors on a city-regional basis.

Third-Party Information

In some cases, we may receive certain Personally Identifiable Information from you about a third party. For example, as part of booking a tee time or registering for a tournament, you may provide the name of other golfers in your party. If you submit any Personally Identifiable Information about another individual to us, you are responsible for making sure that you have the authority to do so and to allow us to use their Personally Identifiable Information in accordance with this Privacy Policy.

How We Use Your Personally Identifiable Information

We use the Personally Identifiable Information we collect to provide the Services to you, to improve our Services and Site, and to protect our legal rights. In addition, we may use the Personally Identifiable Information we collect to:

• Process your account registration;
• Offer and manage your participation in our loyalty programs, such as Troon Rewards and Troon Card;
• Populate Troon Rewards Apple Wallet Card information
• Customize your experience according to your personal preferences;
• Process tee times and reservations and provide you with information about the property you are visiting;
• Review your job application;
• Contact you regarding our products and services that we feel may be of interest to you;
• Allow you to participate in sweepstakes, contests, and other promotions and to administer these activities;
• Communicate with you about our Site or Services or to inform you of any changes to our Site or Services;
• Provide support;
• Maintain and improve our Site and Services;
• Defend our legal rights and the rights of others
• Efficiently maintain our business; and
• Comply with applicable law.

How We Share Your Personally Identifiable Information

We may share the information that we collect about you in the following ways:

• With service providers who perform data services on our behalf (e.g., email, app, apple wallet, hosting, maintenance, backup, analysis, etc.).
• To service providers to prepare, deploy and analyze advertising content;
• To process your transactions and communicate with you regarding your purchase;
• With the applicable property to fulfill and complete your tee time;
• With owners of properties we manage, or to which we provide services, for the purposes described in this Privacy Policy, such as providing and personalizing services and facilitating the loyalty programs;
• With certain third parties that sell goods and services under our Troon brand, such as Troon Golf Vacations so you can purchase Troon-themed vacations;
• 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 account 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 Personally Identifiable Information in this way, do not provide your loyalty program number to third parties, do not use your account login to register for third-party promotions and do not connect your 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.);
• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
• To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personally Identifiable Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information;
• To any other person or entity as part of any business or asset sale; and
• To any other person or entity where you consent to the disclosure.

We use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). “Cookies” are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

• Estimate audience size and usage patterns;
• Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
• Advertise content and services that relate to your interests;
• Keep track of advertisements and search engine results;
• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
• Recognize when you return to the Site.

We set some Cookies ourselves and others are set by service providers. We use Cookies set by service providers to provide us with useful information to help us improve our Site and Services, to conduct advertising, and to analyze the effectiveness of advertising.

Cookies can be blocked by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

You can understand which third parties have currently enabled Cookies for your browser or mobile device and how to opt-out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

To ensure that your Personally Identifiable Information receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share your Personally Identifiable Information with to ensure that your Personally Identifiable Information is treated by those service providers in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, we use third-party email and marketing providers, third-party payroll processors, and third-party payment processors.

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Site and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The technologies used by Google Analytics do not gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

Review and Request Changes to Your Personally Identifiable Information

You may use your account to access, correct, or view certain Personally Identifiable Information we have collected and which is associated with your account. To review or request changes to any of your Personally Identifiable Information, please contact us at privacy@troon.com or in accordance with the “Contacting Us” section below.

Marketing Communications

To unsubscribe from emails from us, please login to your account and edit your marketing preferences, click the unsubscribe link or manage preference link included in the footer of our emails. You also may submit a request to us at privacy@troon.com or by calling 1-888-TROON US. We will try to comply with your request as soon as reasonably practicable. If you unsubscribe from our marketing emails, we may still send you important administrative messages from which you cannot opt-out.

We maintain commercially reasonable security measures to protect the Personally Identifiable Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personally Identifiable Information, we cannot guarantee absolute security. 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.

The Site and Services may contain links that will let you leave the Site and Services and access another website. Some linked websites are not under our control. Except as stated below, this Privacy Policy applies solely to Personally Identifiable Information that is acquired on the Site and Services. We accept no responsibility or liability for these other websites.

The Site is not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal information from children under 13.

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to a person for the person to license or sell the information to additional persons. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to privacy@troon.com.

The California Consumer Privacy Act (CCPA) requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and of the rights of California residents regarding their personal information.

The CCPA defines “personal information” to mean 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 does not include information that is publicly available, deidentified or aggregate information. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

Right to Know About Personal Information Collected, Disclosed, or Sold

Your Right

If you are a California resident, you have the right to request that we disclose what Personal Information we have collected about you in the 12-month period preceding your request. This right includes the right to request any or all of the following:

• Specific pieces of Personal Information that we have collected about you;
• Categories of Personal Information we have collected about you;
• Categories of sources from which the Personal Information was collected;
• Categories of Personal Information that we sold (if applicable) or disclosed for a business purpose about you;
• Categories of third parties to whom the Personal Information was sold (if applicable) or disclosed for a business purpose; and
• The business or commercial purpose for collecting or, if applicable, selling Personal Information.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

How to Submit a Request to Know

You may submit a request to know by emailing us at privacy@troon.com or by calling us at 1-866-778-624.

Our Process for Verifying a Request to Know

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

We will verify your identity as follows:

Request to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

Request to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Collection of Personal Information

The following table presents the categories of Personal Information that we have collected, the categories of sources from which that information was collected, and the categories of third parties with whom we shared that Personal Information for the 12 months preceding the Effective Date of this Privacy Policy.

The CCPA defines “business purposes” to mean:

• Auditing related to a current interaction with the consumer and concurrent transaction, including, but not limited to, counting ad impressions to unique visitors;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services;
• Undertaking internal research for technological development and demonstration; and
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device.

The CCPA defines “commercial purposes” to mean “to advance a person’s commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.”

For purposes of the below chart, we will refer to the business purposes by their above numbers and use the number 8 to reference the definition of commercial purposes.

Disclosure or Sale of Personal Information

The following is a list of categories of Personal Information that we have sold to third parties in the 12 months preceding the Effective Date of this Privacy Policy:

• Name
• Email address
• Telephone number
• Postal address
• Account name
• Internet protocol address
• Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology
• Search history and information regarding consumer’s interaction with the website, application or advertisement

The following is a list of categories of Personal Information that we have disclosed for a business purpose in the 12 months preceding the Effective Date of this Privacy Policy:

• Name
• Email address
• Telephone number
• Postal address
• Account name
• Internet protocol address
• Credit and debit card number
• Date of birth
• Gender
• Marital status
• Military or veteran status
• Imagery of face and voice recordings (i.e., images and video and audio data via security cameras located in public areas at our facilities)
• Records of products or services purchased, obtained, or considered
• Purchasing or consuming histories or tendencies
• Customer number, unique pseudonym or user alias
• Geolocation data
• Cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology
• Browsing history
• Search history and information regarding consumer’s interaction with the website, application or advertisement
• Inferences drawn from above information to create a consumer profile reflecting personal preferences (e.g., interests, activities, food and beverage choices, services and amenities of which you advise us or which we learn about during your visit)

We do not knowingly sell the Personal Information of minors under 16 years of age.

Right to Request Deletion of Personal Information

Your Right

If you are a California resident, you have the right to request that we delete the Personal Information about you that we have collected or maintain. However, a business is not required to comply with a request to delete if it is necessary for the business to maintain the Personal Information in order to, for example, complete a transaction, detect security incidents, comply with a legal obligation, or otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

How to Submit a Request to Delete

You may submit a request to delete by emailing us at privacy@troon.com or by calling us at 1- 866-778-6245.

Our Process for Verifying a Request

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized deletion.

We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable the purpose of verifying identities. In addition, you will be required to submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Notice of Right to Opt-Out of Sale of Personal Information

Your Right

If you are a California resident, you have the right to direct a business that sells your Personal Information to stop selling your Personal Information and to refrain from doing so in the future.

The CCPA defines “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a California resident’s Personal Information to another business or a third party for monetary or other valuable consideration.

We do sell Personal Information as such term is defined under the CCPA.

How to Submit a Request to Opt-Out

You may submit a request to opt-out of sales by clicking on this link and filling out a form: “Do Not Sell My Personal Information.” You also may submit a request by emailing us at privacy@troon.com or by calling us at 1-866-778-6245.

How We Process a Request to Opt-Out

We will act upon your request to opt-out within 15 business days from the date that you submit the request. The CCPA does not require that we verify the identity of individuals who submit requests to opt-out of sales. However, we may deny the request if we have a good-faith, reasonable, and documented belief that the request is fraudulent. If we deny the request on this basis, we will notify the requesting party and provide an explanation why we believe the request is fraudulent.

Right to Non-Discrimination for the Exercise of a California Resident’s Privacy Rights

We will not discriminate against California residents if they exercise any of the rights provided in the CCPA as described in this section “Notice to California Residents.” As such, we will not deny goods or services to that California resident; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to the California resident; or suggest that the California resident will receive a different price or rate for goods or services or a different level or quality of goods or services. However, we are permitted to charge a California resident a different price or rate, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by the individual’s data.

Authorized Agents

California residents may use an authorized agent to submit a request to know, delete, or opt-out of sales on your behalf.

If you use an authorized agent to submit a request to know or request to delete, we may require that (1) the authorized agent provide proof of your written permission, (2) you verify your identity directly with us, and (3) you directly confirm with us that you provided the authorized agent permission to submit the request. These requirements do not apply if you have provided the authorized agent with a power of attorney pursuant to California Probate Code sections 4000 to 4465.

If you use an authorized agent to submit a request to opt-out of sales, you will need to provide that authorized agent with written and signed permission.

Shine the Light Law

If you are a California resident, California Civil Code § 1798.83 permits you to request, once per calendar year, information regarding the disclosure of your personal information by us to third parties for the third-parties’ direct marketing purposes (as those terms are defined in that statute). To make such a request, please send an email to privacy@troon.com or notify us in accordance with the “Contacting Us” section below.

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

If you have questions or concerns about our privacy policies or practices, please contact us at:

Troon Golf, LLC
15044 North Scottsdale Road
Suite 300
Scottsdale, Arizona 85254
Phone: 480.606.1000
Fax: 480.606.1010
Email: privacy@troon.com