Privacy Notice

Silverado Resort's Privacy Policy

SILVERADO RESORT

Privacy Notice

Effective Date: February 1, 2022

NOTICE: This Privacy Notice is effective as of the date below. The Silverado Resort has undergone a change of ownership resulting in the transfer of operations of the Property and this Website to KSL Resorts, Inc. Personal information collected by the former owner and operator of the Property and this Website, Wyndham Hotel Group, LLC (“WHG”), may still be under their control. Inquiries about the collection and use of your personal data collected prior to the Effective Date should be directed to WHG.

I. Introduction.

Welcome to Silverado Resorts. It is our goal to make your interactions with the Silverado Resort (the “Property”) as comfortable as possible. One of the ways that we work towards this goal is by respecting your privacy as you explore not only the Property but also this website, our social media pages, and our applications which display this Privacy Notice.

This Privacy Notice applies to information collected by us whether online through our website at , in person when you provide information at the Property, or from third parties to whom you have provided information. We process your personal information in order to ensure that your experience with us is unsurpassed—whether it be making a reservation, booking an appointment, dining at our restaurants, or any other experience you may have with us.

By becoming a guest at our property or otherwise interacting with us, you understand and agree that we may collect, use, disclose, and share your personal information in accordance with this Privacy Notice.

The Property and this website are operated by KSL Resorts, Inc. When referring to “us,” “our,” or “we,” we mean KSL Resorts, Inc. This Privacy Notice does not apply to any third party, including through any application or content (including advertising) that may be accessible from our website or any third party from or to whom we gather or share personal information. This Privacy Notice does not apply to any interactions with KSL Resorts, Inc. outside of its role as the operator of the Property.

II. The Information We Collect and How We Use It.

We may collect and process your personal information in order to provide you the optimal experience possible when you interact with us. This may include your:

• Name

• Postal address

• Phone number

• Email address

• Credit or debit card number

• Financial information (in limited circumstances)

• Social media account information

• Preferences and other information related to your stay at the Property

• Information about individuals traveling with you

• Special needs or accommodations related to your stay

• Driver’s license, government-issued ID, or passport information

• Communication, product, service, or other preferences

• Demographic information

• IP address

• ID or other information about your account with us.

We collect the above-mentioned information in a number of ways, including:

• When you or your travel agent make a reservation with us online, over the phone, or in-person

• When you contact us with a questions or request

• Use our website, visit the Property, email us, or otherwise interact with our staff or agents;

• Stay at the Property

• Provide feedback to use online, in person, or through a comment card

• Participate in a contest, sweepstakes, or other promotion of ours

• Participate in any loyalty or rewards program we offer

• Interact with us on social media

We may also collect information about you or the device you are using automatically, without it being readily apparent to you. This includes collecting the following information:

• Cookies and Similar Technologies. When you visit our website or receive an email from us, we may assign the browser, device, or application from which you access our website or email one or more cookies or similar technologies to facilitate access to our website, personalize your online experience, or otherwise operate our website. Using a cookie or similar technology, we also may automatically collect information about your online activity on our website, such as the web pages you visit, the emails you open, the links you click, and the searches you do.

Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies or decide which types of cookies to automatically accept or reject. If you choose to decline cookies or other similar technologies, please note that you may have difficulty signing in and may not be able to use some of the interactive features offered through our website. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as a GoogleAds cookie) together to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website.

You can learn how Google uses data when you use our website by visiting this link. Google uses this data to provide measurement services to us, which allows us to measure user interactions with our website and gather a general (non-specific) understanding of where our visitors are located in the world. Google also uses IP addresses for their own security purposes. Google Ads uses cookies to enable it and its partners to serve ads to our visitors based on their visit to this website and/or other sites on the Internet. Data collected from Google Ads cookies is used to report how your ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Services.

• Facebook Pixel: We use the Facebook Pixel on our website to help us understand our website audience (analytics) and to measure the effectiveness of our advertising and marketing efforts (conversion tracking). The Facebook pixel is a snippet of code that sends data back to Facebook about people who visit this site and allows the site operator to later target them with ads on Facebook. The Facebook Pixel (which implements the cookie “_fbp”) collects the following types of data:

o Http Headers: Data included in Http Headers include IP addresses, web browser information, page location, document, referrer and person using the website.

o Pixel-specific Data: Including the Pixel ID and the Facebook Cookie.

o Button Click Data: Including any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.

o Custom Data: Including conversion values and page types.

o Form Field Names – Including website field names like ‘email’, ‘address’, ‘quantity’ for when you purchase a product or service.

We may receive your personal information from other sources, such as public databases, joint marketing partners, data firms, social media platforms, booking sites and apps, from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties.

In addition to the above, there may be some circumstances where we may need to collect additional information. For example, if a guest or other person at our property requires medical or emergency assistance, we may collect and share information about individuals in order to assist with the situation. In limited cases, we may also collect information relating to the credit of customers and share it with credit reporting agencies or other parties with whom we contract to evaluate creditworthiness. If you enter into a contest, sweepstakes, or other promotion, we may collect personal information from you in order to administer the event. In doing so, we may disclose your information to our co-sponsors, service providers, and other third parties in accordance with the event’s purpose and as described in the official rules or terms.

III. Our Operational and Commercial Purposes

As part of operating a first-class luxury resort, we undertake a multitude of operations which require the processing of personal information. For example, our business purposes include: (1) accepting, coordinating, managing, and processing hotel and resort accommodations; (2) facilitating purchase transactions for goods and services; (3) providing top-level customer support, accommodations, and personalized services and amenities; (4) engaging in quality control in order to improve our offerings to you; (5) administer membership, rewards, and other incentive programs, conduct marketing and sales promotions; (6) engage in content based or interest-based advertising, (7) ensuring the safety and security of our guests, our staff, and all other persons visiting our online and real properties; (8) preventing prevent, detect, and investigate fraud, cyber incidents, or other illegal activity; (9) communicating with you and others in relation to your use of our services, including providing legal updates; (10) administering our record-keeping for legal, tax, and operational purposes; (11) exploring new and unique ways to provide products and services; and (12) doing our best to fulfill your requests. Our commercial purposes are to advance our commercial interests, including for advertising and marketing.

IV. Disclosures of Your Personal Information

In order to provide you our service and to fulfill our business and commercial purposes, we may disclose your personal information. We share your personal information with the following categories of recipients:

• Online reservations processors

• Website operations providers

• Hospitality management solutions providers

• Customer relationship management software providers

• Hotel services optimization system providers

• Online dining partners

• Our premises operations providers

• Our marketing providers

• Our communications providers

• Online reservations processors

• Transportation providers

• Social Media companies

• Advertising Partners

In addition to the above, we may disclose your information to our trusted third-party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, legal counsel, and internal and external advisors or auditors. When doing so we will, when appropriate or required by applicable law, put in place appropriate contracts containing standard data protection clauses to protect that information and the rights of individuals. We may share your personal information among KSL Resorts’ affiliates, owners and operators of our managed hotels, and KSL Capital Partners, LLC and its affiliated companies. We also will disclose your personal information to any agents our third parties to whom you authorize us to disclose it.

We may disclose personal information in the following circumstances: (1) in order to comply with an applicable federal, state, or local law; (2) in order to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) to cooperate with law enforcement agencies concerning conduct or activity that web reasonably and in good faith believes may violate federal, state, or local law; (4) to exercise and defend legal claims; (5) when such disclosure is pursuant necessary to protect the rights and freedoms of other individuals; (6) as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the Property or KSL, Resorts, Inc., and (7) in any other manner permitted by law, including engaging in protected speech.

Links

Links to websites that are not operated by or for us (“Third Party Sites”) are provided solely as a convenience to you. If you use these links, you will leave our website. This Privacy Notice does not apply to Third Party Sites. We have not reviewed the Third Party sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third Party Sites listed on or linked to from our website, you should understand that you do so at your own risk.

V. Security

We are committed to protecting the security of any personal information you provide. For these reasons, certain financial information, such as credit card data, will generally be transferred over a Secured Socket Layer (SSL) connection (provided that it is supported or enabled on your browser). In spite of these protections, any information submitted over the Internet could be intercepted or otherwise corrupted during transmission, and we cannot guarantee the complete security of any data submitted over the Internet. Sensitive personal information is stored on servers or locations protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. The servers are under our control at all times but may be hosted, managed or otherwise maintained by third party service providers with whom we contract. These third party service providers have no right to use or access this data other than in performing their services for us.

VI. International Data Transfers

For users located outside the jurisdiction of the United States, the Property and its operating company are located in the United States. Information we collect from you will be processed in the United States, and by using the our services (including our website) you acknowledge and consent to the processing of your data in the United States. While we do not target individuals in the EU or other jurisdictions outside of the United States, we are aware that individuals from outside the EU may interact with us and inquire about the adequacy of our data protection. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 41 of the GDPR. We collect and transfers to the U.S. personal data only with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms.

VII. Your Marketing and Ad Choices

• Email Marketing: We understand that your time and attention is precious to you. If you would like to opt-out from receiving marketing emails from us or our affiliates, please send us an email to privacypolicy@kslresorts.com with the phrase “Privacy Opt-out: Silverado Resort Mailings” in the subject line, or write to us at the address provided below, and we will remove you from Silverado’s mailing list. Alternatively, for e-mail communications, you may opt out of receiving such communications by following the unsubscribe instructions set forth at the bottom of most promotional e-mail messages from Silverado Resorts.

• Interest-Based Advertising: We may use cookies and related technologies to recognize you and receive information about your activity on our websites. This helps customize content and show you more relevant ads. You may limit or disable third party personalized advertising in a number of ways.

Opt-Out of Third-Party Personalized Advertising

You may opt out of cross-site third party personalized advertising using several industry-provided frameworks that many advertisers and advertising networks, exchanges, platforms, and technology providers participate in. This includes the following;

• Network Advertising Initiative: https://optout.networkadvertising.org/

• Digital Advertising Alliance: http://optout.aboutads.info/ - !/

Adjust Your Browser Setting to Block Third Party Cookies

You can also use your web browser to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation. Guidance on how to control cookies in popular browsers is contained here:

• Microsoft Internet Explorer

• MacOS Safari

• Mozilla Firefox

• Google Chrome

Set Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. However, because there is not yet a defined response to do-not-track requests, our Site does not respond to your browser’s do-not-track request. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

Adjust Other Settings

You can adjust the information that other third parties collect about you:

• Using Google’s privacy controls to opt-out of ads and cookies set by Google. Please go here and here to opt-out of any personalized ads and cookies.

• Using Facebook’s privacy setting to restrict Facebook’s use of cookies. Please go here to do so.

VIII. Children’s Privacy

We are committed to complying with the Children's Online Privacy Protection Act (COPPA). Our website and services are not directed to children under the age of 16. We do not knowingly collect personal information from children under the age of 16. If we receive personal information that we discover was provided by a child under the age of 16, we will promptly destroy such information. Parents are encouraged to supervise their children's online activities and consider the use of other means to provide a child-friendly online environment. Additional information is available on the Direct Marketing Association's home page at http://www.the-dma.org. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.

IX. Agreement and Changes

By submitting your personal information on our through our website, you agree to the collection and use of your personal information on the basis described above. If you do not agree, please do not provide any personal information via our website. If we decide to update our Privacy Policy, we will indicate this next to the Privacy Policy link on the front page of our Site. If there are material changes to the Privacy Policy, we will prominently post and/or communicate such changes prior to implementing them. Information collected under previous versions of our Privacy Policy will then become subject to the terms of our new Privacy Policy.

X. Contact Information

If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from us in the future, you can contact us:

• by e-mail: privacypolicy@kslresorts.com

• by writing to us at:

KSL Resorts

18565 Jamboree Road, Suite 500

Irvine, CA 92612

Effective Date: February 1, 2022

Last Updated: February 1, 2022

This Privacy Policy for California Residents (“CCPA Policy”) supplements the information contained in Our Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Like our Privacy Notice, this CCPA Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this CCPA Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some of its requirements.

Categories of Personal Information We Collect Parties with Whom Information May Be Shared Business Purposes for Which Personal Information May Be Used or Disclosed

Identifiers: For example, your name, address, telephone number, email address, unique personal identifier, IP address; Our service providers, service partners, franchisors, advertisers. • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to book a reservation, we will collect that information to make that reservation and ensure a successful transaction.

• Performance of our contract with you.

• Protecting against security threats, abuse, and illegal activity.

• To provide, support, personalize, and develop our Website, products, and services.

• Use of service providers: We share information with service providers to perform services on our behalf, in compliance with our Privacy Notice and other appropriate confidentiality and security measures.

• Advertising: We process online identifiers and other information about your interactions with advertisements, to provide advertising.

• Legal reasons: We may process personal information to satisfy applicable laws or regulations, and disclose information in response to legal process or enforceable government requests, including to law enforcement.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): For example, your name, signature, address, telephone number, driver’s license number, insurance policy number, and credit card number. Our service providers, service partners, franchisors, advertisers.

Protected classification characteristics under California or federal law: For example your age. Our service providers, service partners, franchisors, advertisers.

Commercial information: For example, your reservations, appointments, cancellations, etc. Our service providers, service partners, franchisors, advertisers.

Internet or other similar network activity: For example, the pages viewed on our website. Analytics and network/webpage Security providers.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

• Right to Know and Access: You have the right to know (and request that we disclose to you) what personal information is collected, sold, and disclosed about you.

• Right to Request Deletion: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

• Right to Opt-Out of the Sale of Your Personal Information. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. We do not sell the personal information of consumers, including those under 16 years of age.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

The CCPA temporarily exempts B2B personal information from these requirements, so our B2B contacts may not receive substantive responses to these requests.

Exercising Your Rights and Choices

To exercise your rights to know or delete described above, please submit a request by either calling us at (855) 990-0207 or emailing us at info@kslresorts.com with the subject line: CCPA REQUEST.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period.

Your request to know or delete must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include providing us with your name, email address, physical address, and other information we may need to verify your identity, which varies depending on your relationship with us. 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 the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

If you would like to update your information, modify your communication preferences, or if you do not want to receive marketing communications from us in the future, you can contact us:

by e-mail: info@kslresorts.com

by writing to us at:

KSL Resorts

18565 Jamboree Road, Suite 500

Irvine, CA 92612