PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) describes the measures Kemper Sports Management, Inc. (“KSM”; “we”; or “us”) takes with regard to collecting, using, protecting and disclosing personally identifiable information (including, without limitation, name, address, telephone number, and e-mail address) that you voluntarily provide through this web site or the web site of any of our Business Partners (as defined below) that is provided to us by any of our Business Partners (collectively, “personal information”). It also describes KSM’s practices with respect to certain non-personal information, which includes tracking information collected as you navigate through this web site. We and our Business Partners may use personal information subject to the terms of this Privacy Policy and applicable law. Our Business Partners may also utilize personal information that they collect pursuant to their own privacy policy(ies). We are not responsible for the policies or actions of our Business Partners with respect to personal information you provide to them. Please note that use of this web site constitutes your acceptance of this Privacy Policy.

Information Collection and Use

We collect personal information that you provide primarily to provide you with or contact you about the services, products or other matters described on this site or the sites of our affiliates, partners, advertisers or clients, including the golf course or other properties we own, lease or manage (collectively, “Business Partners”).

We collect personal information that is voluntarily provided by you in connection with our service and products. Such information may include example, information about your tee time reservation, events, offers, contests, information to respond to your inquiries and coordinate experiences; information that is used to provide clothing, event marketing, travel and other goods or services that you have requested.

Additionally, when you make a purchase or attempt to make a purchase from us or our Business Partners through this or a Business Partner’s site, we may collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, payment app details), email address, and phone number. We use this information generally to fulfill the orders placed (including payment processing, and providing invoices and/or order confirmations). This information is used to communicate with you, manage any account or loyalty program you may be a member of, screen for potential risk or fraud, and consistent with your preferences, information provided and web interactions, provide you with information or advertising relating to applicable products or services provided by us or our Business Partners.

We also collect personal information to enhance your visit to this site or our Business Partners’ sites and deliver more individualized content, advertising and/or offers. For example, we may use personal information to communicate with you regarding this Privacy Policy or regarding surveys, sweepstakes, contests, special events, promotions and other matters. We may combine information collected online with information we have collected through other means.

Personal information may also be collected and used on our behalf by, or shared with, service providers who assist us in the administration, hosting, operation, maintenance and/or technical support of this site or our Business Partners’ sites or by other third party contractors we retain to assist us or our Business Partners in the operation of our respective businesses.

We may also collect and aggregate non-personal information (information that does not personally identify you) from users of this site or our Business Partners’ sites to analyze web site traffic, e.g. determine which web site pages are visited most frequently or what features are most attractive to users or for other reasons, and take action based on the analysis, e.g. improve the sites.

At any time, if you do not wish to receive e-mail from us or you do not wish us to use your personal information, you may “opt out” by following the instructions in the e-mail that you receive from us or by contacting us as described below in the section entitled, “Opting Out.” If you do not wish to receive e-mail from our Business Partners, you may “opt out” in the same manner and we will take you off the marketing lists that we maintain related to the applicable Business Partner(s) and notify the appropriate Business Partner(s). However, we are not responsible for the actions or inactions of our Business Partners. Unless you provide instructions by “opting out,” neither we nor our Business Partners are restricted in any way with regard to how we may use personal information you supply, subject to applicable law and this Privacy Policy, and we may share it with, or sell or license it to, our Business Partners or other third parties for marketing or other purposes.

Notwithstanding anything else in this Privacy Policy, including any “opt out” instructions we receive from you, we may also disclose personal information without notifying you in the following circumstances: (i) in response to subpoenas, court orders, or legal process, or to establish or exercise our or our Business Partners’ legal rights or defend against legal claims; (ii) when we believe it necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our or our Business Partners’ Terms of Use, and/or to protect our or our Business Partners’ rights and property or those of others with which we do business; or (iii) when we or a Business Partner sells, buys, merges or partners with other companies or businesses, where user information may be among the transferred assets or disclosed information.

How We Gather Information

Log Files

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our or our Business Partners’ user base as a whole.

Cookies/Pixels

We, along with our Business Partners and service providers, use cookies and similar technologies known as “pixel tags”, “web beacons” or “clear GIFs” on our web site. Cookies are small text files that a web browser uses to store certain data which helps us to identify your preferences and to optimize your experience on our Web Sites. Cookies also allow us to hold selections when making a reservation or engaging in another transaction on one of our Business Partners’ web sites without checking out. Pixel tags, web beacons or clear GIFs are small electronic images (often a single pixel (1×1) that are ordinarily not visible to web site visitors and may be associated with cookies on the visitor’s hard drive) used by our service providers on our web sites as part of our advertising program which helps us display customized advertisements to you based on your browsing behavior and to evaluate the effectiveness of our program.

We use third-party tracking services, such as Google Analytics, that use cookies to track non-personally identifiable usage and volume statistics about visitors to this site or our Business Partners’ sites in the aggregate for the purpose of understanding how those sites are used as well as targeting advertising and marketing materials to you. . By using this web site, you consent to the processing of data about you by Google and other analytics providers in the manner and for the purposes set out above. For more information regarding Google Analytics please visit Google’s web site, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

Behavioral Advertising

We may use your personal information, transaction and interaction information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

– Facebook: https://www.facebook.com/settings/?tab=ads

– Google: https://www.google.com/settings/ads/anonymous

– Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Do Not Track Protocols

The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, the web site is not compatible with DNT and so we do not recognize DNT settings.

Social Media Plugins

Social media plugins are plugins that enable you to ‘share’ content with friends through social networks, such as Facebook and Twitter or similar service providers. We do not control the setting of these cookies. If you are a user of the services of any of those service providers and would like to know more about what kind of data may be collected through such social plugins and how such data may be used by the respective service provider, please check the privacy policy of those service providers, including, Instagram, Twitter, Facebook and LinkedIn.

Links to Other Sites

To the extent that this site or our Business Partners’ sites contains links to other sites that are not owned or controlled by KSM or our Business Partners, please be aware that neither we nor our Business Partners are responsible for the privacy practices of those other web sites. We encourage you to be aware when you leave this site or our Business Partners’ sites and to read the privacy statements and policies of each and every web site that collects personal information.

Security

We follow generally accepted industry standards designed to protect the personal information we receive from unauthorized access or disclosure. We are not responsible for the security of personal information in the possession or control of Business Partners. No method of electronic transmission, storage or security is 100% reliable.

Right to Access, Amend, Opt Out

If you would like to know the personal information in our possession about you, if your personal information changes, or if you no longer want us to use your personal information, such as to opt out of receiving electronic communications from us (except as expressly provided above), please contact us via e-mail at [email protected], or via postal mail at: Kemper Sports Management, Inc., Web Site Opt Out, Legal Departmentt., 500 Skokie Boulevard, Suite 444, Northbrook, IL 60062. Except as required by applicable law, please allow up to thirty days for response. Please note that we may ask for additional information in order to authenticate your identity and/or request. Our sole obligation, unless otherwise required by law, shall be to exercise commercially reasonable efforts to comply with your request. Requests pertaining to our Business Partners should be directed to the applicable Business Partner.

International Users

This is a U.S. focused web site. The web site is not directed to users outside of the United States and are administered from the United States. To the extent information is provided through the web site or web sites of our Business Partners, it may be uploaded to a cloud and/or transferred to the U.S. for processing. By providing information to the web site or to those operated by our Business Partners you consent to the transfer to , and processing and/or use of the information in the U.S. and/or through a cloud. In the event you utilize the web site from outside of the U.S., you consent to the uploading of any information to a cloud and the transfer of the information to the U.S.

California Residents

California Law provides residents of California a number of rights as they relate to personal information. These are the “right to know”, the “right to delete”, and the “right to opt out”.

Right to Know. You may request KSM provide you the specific pieces of personal information that KSM has about you; categories of personal information we have collected about you; categories of sources from which the personal information is collected; categories of personal information that KSM sold or disclosed for a business purpose about you; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information.

Right to Delete. California law gives residents a limited right to request deletion of their personal information. However, this right is limited by a number of exceptions. Fundamentally, if KSM has a permissible need to retain personal information, we are not under an obligation to delete such information, even when requested. Generally, we retain personal information so we may complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with KSM; comply with a legal obligation; or otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. As such, we generally do not accept requests to delete personal information in its entirety. However, we will respond to requests to remove personal information from some of our systems as a part of a request to close or otherwise disable a membership account.

Right to Opt Out. KSM shares personal information with Business Partners for marketing purposes and to permit our Business Partners to collect data directly from you. You may choose to opt out of the sharing of your personal information with third parties for marketing purposes at any time by submitting a request in writing to our contact address below or using one of the Opt Out tools noted in the “Behavioral Advertising” Section above. Please note that this opt out does not prohibit disclosure made for non-behavioral advertising purposes.

Designating an Authorized Agent. California law permits California residents to designate an agent to manage their rights under California law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Exercising California privacy rights”.

Non-discrimination. California law does not permit KSM to discriminate against you because you exercised any your rights under this title, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising California privacy rights. If you are a California resident and would like to exercise any of your rights you may do so by emailing us at [email protected] [insert toll-free number] . You may also contact us at the mailing address set forth above. Please note that with respect to any request we reserve the right to seek additional personal information in order to verify your identity and your or your agent’s rights to the data subject to your request.

Children

The web site and the web sites of our Business Partners provide the opportunity for parents and/or guardians to register their children for activities such as camps and junior golf. We do not knowingly collect or solicit personal information from any child under 16 years of age. If you believe that a child under the age of 16 has provided us with personal information, please contact us at the address listed below so that we may take appropriate action.

Careers

Information about potential employment opportunities with KSM and at properties we manage can be accessed from the career section of this web site KSM is an equal opportunity employer. Information provided through the careers section will be used to process employment applications, including by assessing qualifications, verifying information, conducting reference or other employment-related checks (if you submit an application for employment). Applicants may exercise their rights under this Privacy Policy in the same manner as set forth above.

Changes to this Privacy Policy

KSM reserves the right to change this Privacy Policy at any time by posting revisions to it on this site. Please check this page periodically for changes. Your continued use of this site following the posting of changes to this Privacy Policy will mean that you accept those changes.

Kemper Sports

500 Skokie Blvd., Suite 444

Northbrook, IL 60062

847.850.1818