At Gleneagle Golf Club (“Gleneagle”) we respect your privacy and we are committed to managing and protecting your information in accordance with this Privacy Policy (the “Policy”). This Policy describes how and why we collect, use and disclose your personal information. In this Policy, “Gleneagle”, “we” or “us”, means Gleneagle Golf Club. For the purposes of this Policy, “personal information” is information we can use, alone or in combination with other information, to identify you including, but not limited to, your name, address, email address, birth date and gender, as more particularly described under applicable privacy laws, but does not include aggregate information that does not specifically identify you.

How We Collect Personal Information

We collect personal information you provide to us or other third parties on our behalf when you use our services or otherwise do business with us, such as making a reservation, booking a tee time, participating in an on-line contest or completing a registration form or comment card, when you email or call us, or when you visit our website we operate for our golf course and properties, including www.gegolfclub.com (our “Website”).

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location, logs and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

How We Use Personal Information

We use your personal information to operate and manage our business and provide services to you, to better understand your use of our Website, and to provide you with information that we believe may be of interest to you. We may use personal information for the following purposes:

• To provide you with products, services, offers or other information that you may request from Gleneagle Golf Club;
• To establish and maintain a commercial relationship with you and provide you with ongoing services;
• To contact you about changes, enhancements or similar notices related to the Website and our services and activities;
• To better understand your individual needs, interests, preferences and eligibility for products and services;
• To perform market research, and aggregate your data to analyze trends and develop internal reports;
• For business purposes, such as customer service, quality control, administration of our Website, and security and fraud prevention;
• Based on your choices, to provide you with information on products, services, and other offers that we feel may be of interest to you; To administer contests and promotions that you have entered;
• To meet legal or regulatory requirements;
• In any other way we may describe when you provide the information; and
• For any other purpose with your consent.

Disclosure of Personal Information

We will not sell or rent your personal information to anyone. We will only disclose your personal information to the following third parties and/or as follows:

• To our subsidiaries and affiliates;
• Where you have specifically given us your consent to disclose your personal information for a designated purpose;
• To those who are acting on our behalf as our employers, agents, suppliers or service providers to enable us to (i) provide you with our products, services, activities, and Website, (ii) process transactions between you and us; and (iii) in relation to our efforts to better understand your needs and develop, enhance, market or provide our products and services; provided that such entities act under contractual controls, requiring them to maintain the confidentiality of such personal information and to use such information solely for the purposes for which the personal information was originally collected;
• As required by law, including by any order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest;
• To a collection agency for the express purpose of the collection of past due bills; and
• In accordance with applicable law, in connection with a corporate reorganization, merger or amalgamation with another entity, or a sale of all or substantially all of our assets provided that the personal information disclosed continues to be used for the purposes permitted by this Policy by the entity acquiring the information.

Safeguarding Your Personal Information

To ensure the security and confidentiality of your personal information, we use technical, administrative, and physical measures designed to protect and secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

We may process, store, and transfer your personal information in and to other countries with different privacy laws. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information under those local laws. Whenever we engage a service provider, we require that its privacy and security standards comply with this policy and applicable laws.

We retain your personal information only as long as it is required to satisfy the purpose for which it was collected or any new purpose to which you have consented or as permitted or required by applicable law.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

Links to Other Sites & Third-Party Providers

This Policy applies only to our Website and to the use of personal information we collect. This Policy does not apply to the practices of companies or websites that are not owned or controlled by us or to services on the Website that are provided by third parties. We may provide links to other websites that we believe may be of interest to our visitors; however, we are not responsible for the content of, or the privacy practices employed by, other companies or websites.

Access and Correction

We want to ensure that the personal information we hold about you is accurate and current so please keep us updated if your personal information changes. If you wish to review, correct, or withdraw consent to the use of your personal information, please email us at: info@gegolfclub.com.

Anonymous Information & “Cookies”

We may collect anonymous information from the Website, such as pages you visit and searches you perform. Anonymous information is processed by us to help us improve the contents of our Website and to compile aggregate statistics about individuals using our Website for internal and market research purposes. In doing so, we may install “cookies” that collect the first domain name level of a user and the date and time of access. Cookies by themselves are not used to discover the identity of a user. If you wish, you may set your browser to notify you when you receive a cookie, and this will enable you to determine whether to accept it or not.

Spamming

We do not condone “spamming”. Spamming is the practice of sending unsolicited emails in large numbers and repeatedly to individuals with whom the sender has had no previous contact or who have declined to receive communications. Rather, where we believe that certain product, service or other information may be of interest to you, we reserve the right to inform you by email, but we will give you the choice of opting out of such communication.

Personal Information & Children

The Website is not directed for use by children. We do not intend to collect personal information from anyone under the age of 18. If you are under the age of 18, you should not provide any personal information to us and you should use the Website only with the involvement of a parent or guardian. If you are a parent or guardian of a child under the age of 18 and suspect that he or she has provided personal information on or through the Website, please contact us at the email address below.

Acceptance of This Policy

By using our services, accessing a Website, or providing personal information to us, you agree to be bound by this Policy, as amended form time to time. We may update this Policy from time to time. Please check back to one of our Website or with us periodically for updates and changes. Any changes will be effective as of the date we post them.

Your State’s Privacy Rights

Residents of certain states may have additional personal information rights and choices. Please see your state’s privacy rights for more information.

Contact

We welcome any questions, comments or suggestions you may have about this Policy or our privacy practices. Please contact us at: info@gegolfclub.com

Effective Date: April 7, 2025