The law in some jurisdictions may provide with you with additional rights regarding our use of Personal Information. To learn more about any additional rights that may be applicable to you as a resident of one of these jurisdictions, please see the privacy addendum for your jurisdiction that is attached to this Policy.

Your Texas Privacy Rights - Notice to Texas Residents
If you are a Texas resident, certain Personal Information that we collect about you in subject to the Texas Data Privacy and Security Act (“TDPSA”). 

Please note that the TDPSA does not apply to:

• Information that is lawfully made available from federal, state, or local government records;
• Consumer information that is de-identified or aggregated;
• Employment-related Personal Information collected from our Texas-based employees or job applicants, contractors, or similar individuals (“Personnel”) or to Personal Information reflecting a written or verbal business-to-business communication (“B2B Personal Information”);
• Other information excluded from the scope of the TDPSA, including, but not limited to, Personal Information covered by certain sector-specific laws, such as the Fair Credit Reporting Act (“FCRA”) and the Family Education Rights and Privacy Act (“FERPA”)

Information We Collect About You and How We collect It
Sandborn collects the categories of Personal Information about you as described in the “Information We Collect About You and How We Collect It” section above.

Sources of Personal Information
We collect Personal Information about you from the sources described in the “Information We Collect About You and How We Collect It” section above.

Purposes for Our Collection of Your Personal Information
We only use your Personal Information as described in the “How We Use Your Information” section above.

Third Parties with Whom We Disclose Your Personal Information for Business Purposes
We may disclose certain categories of Personal Information to the categories of third parties described in the “How We Disclose Your Information” section above.

Third Parties with Whom We Sell Your Personal Information
We do not sell Personal Information as the term “sell” is commonly understood to require an exchange for money. As noted throughout this Policy, we use advertising and analytics cookies on our Sites which is considered a “sale” of Personal Information as the term “sale” is broadly defined in the TDPSA to include both monetary and other valuable consideration. Using this broad definition, our “sale” is limited to our use of third-party advertising and analytics cookies and their use in providing behavioral advertising and their use in understanding how people use and interact with our Sites. 

Additionally, through our use of third-party advertising cookies and tracking technologies, we process your Personal Information for the purpose of targeted advertising. Our processing for the purpose of targeted advertising is limited to our use of third-party advertising cookies and tracking technologies and their use in providing you targeted advertising (i.e., advertising on or other mediums based on your browsing history and other patterns). When the recipients of your Personal Information disclosed for the purpose of targeted advertising are also permitted to use your Personal Information to provide advertising to others, we also consider this disclosure as a “sale” for monetary or other valuable consideration under the TDPSA.

Our “sales” of your Personal Information and our processing of your Personal Information for the purposes of targeted advertising is subject to your right to opt-out of those sales and such processing under the TDPSA (as further described below). For more information on how to exercise your opt-out rights, please see the “Your Choices About How We Use and Disclose Your Information” above.

Your Privacy Rights Under the TDPSA
If you are a Texas resident, the TDPSA provides you with specific rights regarding your Personal Information, subject to certain exceptions. This section describes your TDPSA rights and explains how to exercise those rights. 

• Right to Know. You have the right to request that Sandborn confirm if it processes Personal Information about you and disclose certain information to you about our collection and use of your Personal Information (a “Right to Know” Consumer Request). 
  
  
• Access to Specific Pieces of Information (Data Portability). You have the right to request that Sandborn provide you with a copy of the specific pieces of Personal Information that we have collected about you, including any Personal Information that we have created or otherwise received from a third-party about you (a “Data Portability” Consumer Request). If you make a Data Portability Consumer Request electronically, we will provide you with a copy of your Personal Information in a portable and, to the extent technically feasible, readily reusable format that allows you to transmit the Personal Information to another third-party.
  
  You must specifically describe if you are making a Right to Know request or a Data Portability request. If you would like to make both a Right to Know Consumer Request and a Data Portability Consumer Request you must make both requests clear in your request. If it is not reasonably clear from your request, we will only process your request as a Right to Know request. You may make a Right to Know or a Data Portability Consumer Request a total of two (2) times within a 12-month period at no charge.
  
  
• Correction. You have the right to request that we correct any incorrect Personal Information about you to ensure that it is complete, accurate, and as current as possible. You may request that we correct the Personal Information we have about you as described below under “Exercising Your TDPSA Privacy Rights.” In some cases, we may require you to provide reasonable documentation to show that the Personal Information we have about you is incorrect and what the correct Personal Information may be. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect or if the Personal Information is subject to another exception under the TDPSA.
  
  
• Deletion. You have the right to request that Sandborn delete any of your Personal Information that we collected from or about you and retained, subject to certain exceptions. Once we receive and confirm your Consumer Request (see Exercising Your TDPSA Privacy Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies pursuant to the TDPSA. Some exceptions to your right to delete include, but are not limited to, if we are required to retain your Personal Information to complete the transaction or provide you the goods and services for which we collected the Personal Information or otherwise perform under our contract with you, to detect security incidents or protect against other malicious activities, and to comply with legal obligations. We may also retain your Personal Information for other internal and lawful uses that are compatible with the context in which we collected it. 
  
  
• Opt-Out of Certain Processing. Under the TDPSA and to the extent applicable, you have the right to opt-out of our processing of your Personal Information for the purposes of: (i) targeted advertising; (ii) the sale of your Personal Information; or (iii) profiling in furtherance of decisions that produce legal effects or similarly significant effect concerning the consumer. These decisions include decisions that result in the provision or denial by the controller of financial and lending services, housing, insurance, education enrollment, criminal justice, employment opportunities, health care services, or access to basic necessities, such as food and water. Please note, however, that Sandborn does not use your Personal Information to engage in profiling within the meaning of the TDPSA.
  
  With respect to the right to opt-out of the sale of your Personal Information or our processing of your Personal Information for the purposes of targeted advertising, you (or your Authorized Agent) may exercise these rights as further described in the “Your Choices About How We Use and Disclose Your Information” section above.
  
  
• Non-Discrimination. You have the right not to receive discriminatory or retaliatory treatment for exercising any of your privacy rights under the TDPSA.

Exercising your TDPSA Privacy Rights
To exercise the rights described above, please submit a request (a “Consumer Request”) to us by either:

• Calling us at 608-213-1753.
• Emailing us at [email protected]. 
• Visiting www.Sandborn.com

If you fail to make your Consumer Request in accordance with the ways described above, we may either treat your request as if it had been submitted with our methods described above or provide you with information on how to submit the request or remedy any deficiencies with your request. 

Only you, or your Authorized Agent that you authorize to act on your behalf, may make a Consumer Request related to your Personal Information. To designate an Authorized Agent, see “Authorized Agents” below.

All Consumer Requests must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information. This may include providing certain information about yourself, such as your name, email address, and phone number.
• Be described with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm which Personal Information relates to you. Making a Consumer Request does not require you to create an account with us. We will only use Personal Information provided in a Consumer Request to verify the requestor’s identity or authority to make the request.

Authorized Agents
You may authorize your agent to exercise your rights to opt-out of the “sale” of your Personal Information or the processing of your Personal Information for cross-context behavioral advertising under the TDPSA on your behalf by providing them with written authorization or with power of attorney to exercise your rights in accordance with applicable laws, or through other technology that we may provide for this purpose (an “Authorized Agent”). We may request that your Authorized Agent submit proof of identity and that they have been authorized to exercise your rights on your behalf. We may deny a request from your Authorized Agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights. 

Appeals Process
You may appeal a refusal by us to take action on your request to exercise any of the above rights within a reasonable period of time after we provide you notice of such refusal by contacting us using the contact information listed below. Within sixty (60) days after we receive your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including any explanations for the reasons for the decision. If your appeal is denied, you may lodge a complaint with the Texas Attorney General through their contact information available at: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.

Our Sites may contain links to third-party websites not owned or operated by Sandborn. We are not responsible for the privacy practices or content of those sites and encourage you to review their privacy policies before providing any Personal Information.

Data Security
Sandborn employs generally accepted industry security measures designed to protect Personal Information from unauthorized access, disclosure, alteration, or destruction. However, no method of electronic transmission or storage is entirely secure, and we cannot guarantee the absolute security of your information. Any transmission of Personal Information is at your own risk. We are not responsible for the security of Personal Information once it is in the possession or control of a third-party Service Provider.

Data Retention
We retain Personal Information only for as long as reasonably necessary to fulfill the purposes for which it was collected, to provide our services, to comply with legal obligations, and to resolve disputes and enforce our agreements. Specific retention periods may vary based on the type of information and the nature of our relationship with you.

Your Choices About How We Use and Disclose Your Information
We do not control the collection and use of your information collected by third parties described above in the “How We Disclose Your Information” section. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and maintain this information as strictly confidential. These third parties may, however, aggregate the information they collect about you with information from their own customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Information we have collected about you. We have created mechanisms to provide you with control over your Personal Information:

• Cookies and Tracking Technologies. We may use certain tracking technologies that may record your activities on our Sites and your other online activities, and such recordings may be disclosed and processed by third-parties who provide such technologies. This helps us understand our users and the use of our Sites. 
  
  
• Targeted and Behavioral Advertising. Our Sites may use certain technologies, including cookies, to display advertising to you based on your activities of our Sites and other online activities.
  
  You may disable these technologies through our cookie consent manager, which you may access by clicking the “Cookies Settings” link on the bottom of any page of our Sites and disabling our use of analytics cookies and similar technologies. You may also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent, however, if you disable or refuse cookies, please note that some parts of our Sites may then be inaccessible or not function properly. If you do not disable these technologies, you hereby consent to our use of your Personal Information and our recording and disclosure to third-party cookie providers of your activities on our Sites in this way.
  
  As noted above, we do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative on its website (http://www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (http://www.aboutads.info).
  
  
• Opting Out of Marketing Communications from Sandborn. You may opt out of receiving marketing emails and text messages from Sandborn at any time by following the unsubscribe instructions included in any marketing email or text message we send, or by contacting us directly using the contact information below. Please note that even if you opt out of marketing communications, we may still send you transactional or administrative emails or text messages relating to your reservations or account.
  
  
• Access, Correction, and Deletion. If you would like to access, correct, or request deletion of Personal Information we hold about you, please contact us using the information in the Contact Us section below. We will respond to verifiable requests within a reasonable time, subject to applicable law, and reserve the right to request documentation sufficient to verify your identity before processing any such request. Requests pertaining to Personal Information collected or processed directly by a third-party Service Provider should be directed to that provider. Please note that we may not accommodate a request to change or delete your Personal Information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect. 

We do not share, sell, or otherwise disclose your Personal Information for purposes other than those outlined in this Policy. 

We may disclose Personal Information that we collect or you provide as described in this Policy:

Service Providers and Third-Party Vendors
We may share your Personal Information with third-party companies and individuals that we engage to support the operation of our Facilities and Sites ("Service Providers"). These may include, without limitation, our property management company, reservation and point-of-sale system providers, payment processors, marketing and email platforms, analytics providers, technology vendors, third-party integrations used at our Facilities’ golf courses, and other operational partners. Service Providers are authorized to use your Personal Information only as necessary to perform services on our behalf and are subject to appropriate confidentiality obligations. Our payment processors’ privacy policies may be found at: https://corporate.freedompay.com/privacy-policy (payment processor used for golf reservations); https://www.shopify.com/legal/privacy (payment processor used for purchasing merchandise at our Facilities); and https://gocardless.com/privacy (payment processor used for memberships at our Facilities).

Sandborn currently engages Kemper Sports Management, LLC ("KSM") as its property management company. KSM may independently collect or process certain Personal Information in connection with managing our Facilities pursuant to its own privacy policy, available at www.kempersports.com/privacy-policy. Sandborn is not responsible for KSM's independent privacy practices.

We may engage additional or different third-party Service Providers from time to time. In all such cases, we take reasonable steps to ensure that these parties handle your Personal Information in a manner consistent with this Policy and applicable law.

Legal and Protective Disclosures
We may disclose Personal Information when we believe disclosure is necessary or appropriate to:

• Comply with subpoenas, court orders, legal process, or governmental requests;
• Protect the safety of any person or investigate potential threats;
• Investigate, prevent, or take action against suspected fraud or illegal activity; and
• Enforce our Terms of Use or protect the rights and property of Sandborn, our Service Providers, or others.

Business Transfers
In the event that Sandborn or any of its Facilities is involved in a merger, acquisition, sale of assets, divestiture, restructuring, reorganization, dissolution, or similar transaction whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, Personal Information may be among the assets transferred or disclosed to a potential or actual buyer or other successor. To the extent required by applicable law, we will provide notice if your Personal Information becomes subject to a materially different privacy policy as a result of such a transaction.

Analytics and Targeted Advertising
We disclose Personal Information to third-party analytics providers, such as Google Analytics, to understand how visitors interact with our Sites. You can learn more about Google's data practices at https://policies.google.com/technologies/partner-sites.
We may use your Personal Information and transactional information to deliver targeted advertisements we believe may be of interest to you. Please see the “Your Choices About How We Use and Disclose Your Information” Section below for further information on how you may opt out of certain targeted advertising.

Opting out of targeted advertising does not mean you will stop seeing advertising; it means that the advertising you see may be less tailored to your interests.

Social Media
Our Sites may include social media plugins (such as Facebook, Instagram, X/Twitter, and LinkedIn) that allow you to share content or interact with those platforms. We do not control the data collected through these plugins and encourage you to review the privacy policies of any social media platform through which you interact with our content.

Additional Purposes
We may also disclose Personal Information:

• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information; 
• With our affiliates and subsidiaries; and
• With your consent.

Sandborn uses the Personal Information we collect for the following purposes:

• To process reservations, purchases, and other transactions;
• To communicate with you regarding your bookings, inquiries, or account;
• To manage loyalty programs, memberships, or other guest relationships;
• To send promotional materials, newsletters, and special offers, consistent with your preferences;
• To improve our Sites, services, and overall guest experience;
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• To personalize your experience on our Sites and our Facilities and to deliver content and product and service offerings relevant to your interests, including targeted offers and advertisements through our Sites, third-party sites, and via email or text message (with your consent, where required by law);
• To detect and prevent fraud, security incidents, and other harmful activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• To help maintain the safety, security, and integrity or our Sites, Facilities, databases and other technology assets, and businesses;
• For internal testing, research, analysis, and product development, including to develop and improve our Sites and Facilities;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and use, including for billing and collection;
• To notify you about changes to our Sites or Facilities.
• To comply with applicable legal obligations;
• To conduct surveys, sweepstakes, contests, and other promotional activities;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

We may combine information collected online with information gathered through other channels to personalize your experience across our Sites and Facilities. We may further anonymize or aggregate your Personal Information in accordance with applicable law such that it can no longer reasonably be used to identify you and use it without restriction. 

When you visit our Sites, we and our service providers may automatically collect certain Personal Information about your interaction with our Sites, including:

• IP address, browser type, and operating system;
• referring and exit pages, date and time of visit;
• pages viewed and navigation paths (clickstream data); and
• device identifiers and mobile platform information.

This information is gathered through log files, cookies, pixel tags (also called web beacons or clear GIFs), and similar technologies. This information may be maintained or associated with Personal Information we collect in other ways or received from third parties. We use this information to operate and improve our Sites by enabling us to: analyze trends, estimate our audience size and usage patterns, store information about your preferences, deliver more relevant content and advertising (including targeted advertising), speed up your searches, and recognize you when return to our Sites. 

The technologies we use for this automatic data collection may include:

• Cookies and Similar Technologies. Cookies are small text files stored on your browser that help us recognize returning visitors and improve your experience. We, along with our service providers, may use cookies to remember your preferences, facilitate reservations and transactions, analyze site traffic, and deliver targeted advertising. You may configure your browser to refuse cookies or to alert you when cookies are being sent; however, doing so may affect the functionality of certain features on our Sites. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu.
• Web Beacons. Pages of our Sites, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Sandborn, for example, to count users who have visited those pages or screens or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• Site Interaction and Performance Monitoring Tools. Our Sites may also use interaction and/or performance monitoring tools (sometimes call tracking scripts, analytics tools, session replay tools, or heatmap tools). These tools execute code in your web browser to help us collect data about your use of and interactions with the pages and content on our Sites. This may include recording your mouse movements, keystrokes, navigation pathways, other actions that you take our Sites, and information automatically transmitted from your web browser to our Sites such as information about your operating system, computer hardware, and browser preferences.

We collect Personal Information that you voluntarily provide to us, such as when you:

• make a tee time reservation or lodging booking;
• purchase merchandise, gift cards, or other products;
• register for events, tournaments, or programs;
• fill out forms on our Sites or contact us by phone or email. This includes information provided at the time of filling out our forms (e.g., signing up to join our “Insiders List”) or otherwise contacting us to inquire about our Facilities by phone, email, or web form;
• sign up for our mailing list or loyalty programs; or
• if you contact us, records and copies of our correspondence (including email addresses).

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Sites or transmitted to other users of the Sites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Sites who may view your User Contributions you agree to share with us. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

This information may include your name, mailing address, email address, telephone number, gender (when you book a tee time), billing and payment details (including credit card or payment app information), information about the Facilities you stay at and play golf at, including dates and times, your scores, and information regarding your handicap, and any other details you choose to share with us.

Throughout this Policy, the term “Personal Information” means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Information does not include any deidentified or aggregated information.

We collect Personal Information from various sources, including:

• directly from you when you voluntarily provide it to us;
• automatically as you navigate through or otherwise use the Sites;
• information that we create about you as you use our Sites and visit our Facilities; and
• from third parties, for example, our business partners.

This Privacy Policy ("Policy") describes how Sandborn, Inc. ("Sandborn," "we," "us," or "our") collects, uses, protects, discloses, or otherwise processes personally identifiable information that we collect about you when visiting or interacting with any of our facilities and their associated websites, Sandborn property-branded mobile applications, WSD, RD, and OS Loopers, reservations platforms, hospitality offerings, membership services, retail operations, events, lodging, and guest services: Wild Spring Dunes (www.wildspringdunes.com), Old Shores (www.oldshores.com), and Rodeo Dunes (www.rodeodunes.com) (our "Sites" or "Facilities").

This Policy applies to information we collect:

• on our Sites;
• on or through our Facilities;
• in email, text, and other electronic messages between you and Sandborn through any medium; and
• any other information we may collect about you offline when you visit our Sites or Facilities.

This Policy does not apply to information collected by:

• us through any other means, including on any other website operated by Sandborn or any third-party (including our affiliates and subsidiaries) unless otherwise expressly referenced herein;
• us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; or
• any third party (including our affiliates and subsidiaries not expressly identified herein), including through any application or content (including advertising) that may link to or be accessible from or on the Sites.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites or visit our Facilities. By using our Sites or visiting our Facilities, you acknowledge that you have read and understood this Policy. We encourage you to review it periodically, as it may be updated from time to time (see Changes to Our Privacy Policy). Your continued use of our Sites or Facilities after we make changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.