PRIVACY POLICY

At Treviso Bay Golf Club, Inc. ("Treviso Bay Golf" or "we"), your privacy is very important to us. Accordingly, we have developed this privacy policy in order for you to understand how we collect, process, communicate, disclose, and make use of the Personal Data that you provide to us. Treviso Bay Golf is committed to protecting this data and will only use it where allowed by the law. The following outlines our privacy policy ("Policy").

As a preliminary matter, Treviso Bay Golf has implemented the appropriate technical and organizational measures to maintain a level of appropriate security to the data that you provide to us. Moreover, Treviso Bay Golf only allows the individuals who need access to this information to have access to this data and will not process it unless allowed by the applicable law.

This Policy is issued on behalf of Treviso Bay Golf Club, Inc. Accordingly, Treviso Bay Golf may under certain circumstances, share information obtained through this website with Treviso Bay Property Owners Master Association, Inc. This sharing of your data is made pursuant to an agreement between these two entities. If you have any concerns about the extent that your information obtained through this website will be shared among and between these two entities, please contact our General Manager, Joseph Iafe at 9800 Treviso Bay Blvd, Naples, FL 34113, or [email protected].

Additionally, Treviso Bay Club may, from time to time and under certain circumstances, share information obtained through this website between Treviso Bay Golf and PGA Tour Golf Course Properties, Inc. ("GCP"). This sharing of your Personal Data is made pursuant to an agreement between these two entities. In the event that your data is shared with GCP, those portions of your shared Personal Data maintained under the control of GCP will be governed by the GCP privacy policy. If you have any concerns about the extent that your information obtained through this website will be shared among and between these two entities, please contact our General Manager, Joseph Iafe at 9800 Treviso Bay Blvd, Naples, FL 34113, or [email protected].

Treviso Bay Golf last updated this Policy on October 1, 2018. You can obtain historic versions of this Policy by contacting General Manager, Joseph Iafe at 9800 Treviso Bay Blvd, Naples, FL 34113, or [email protected].

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

For the purposes of this Policy, Treviso Bay Golf defines the following terms:

"Comply with a legal or regulatory obligation" means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

"Consent" means the express permission that you have provided to Treviso Bay Golf to collect your Personal Data for the legitimate business purposes stated herein and subject to the limitations that you provide.

"External Third Parties" means service providers, such IT and system administration services, analytics personnel and professional advisers, such as lawyers, bankers, auditors and insurers, who provide consulting, banking, legal, insurance, and accounting services to or on behalf of Treviso Bay Golf.

"Internal Third Parties" means employees and/or authorized members of Treviso Bay Golf who provide other essential services, such as IT and system administration services or which undertake leadership reporting.

"Legitimate Interest" means the interest of our business in conducting and managing our business to enable us to give you the best and most secure experience on our website. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

"Personal Data" includes any information that can be used to directly or indirectly identify an individual, including, but not limited to, the identification of IP addresses, name, identification number, location data, online identifiers, and/or other information defined by law, statute, or regulation as "Personal Data."

Treviso Bay Golf may collect, process, store and transfer different kinds of Personal Data about you (to the extent that you provide the same to Treviso Bay Golf):

• Contact Data including your mailing address, email address, fax number, and telephone numbers;
• Identity Data including your first name, last name, golf player type, membership information (including membership number), occupation, education, and date of birth;
• Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences;
• Profile Data including your user name, your password, and any preferences that you set in any user profile;
• Technical Data including, but not limited to, internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website; and
• Usage Data including information about how you use our website, including, but not limited to, session duration, bounce rate, dynamic page views, and page views by module.

Treviso Bay Golf may also collect, process, store, and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but is not considered Personal Data under the law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we will treat the combined data as Personal Data in accordance with this Policy.

Treviso Bay Golf does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Treviso Bay Golf also does not collect any information about criminal charges, convictions, and/or offenses.

Treviso Bay Golf utilizes two methods to collect Personal Data from you and about you. Any Personal Data that Treviso Bay Golf collects through either method is subject to this Policy.

The first method is direct interactions from authorized users of our platform. This generally includes members and employees of Treviso Bay Golf, and requires the use of a username and password issued by Treviso Bay Golf. In a direct interaction, you provide us with Identity Data, Contact Data, or Marketing and Communications Data by completing forms contained on the website that pertain to your account with Treviso Bay Golf. You may provide such Personal Data for use in Treviso Bay Golf's club directory that may, with your consent, be displayed to other Treviso Bay Golf members. While Treviso Bay Golf will retain any information that you provide to us through this method, you have the option to not have any information displayed to other Treviso Bay Golf members as part of this directory.

The second method is automated technologies or interactions through both our public site and members-only areas. As you interact with our website, Treviso Bay Golf may automatically collect Technical Data or Usage Data. We collect this personal data by using cookies, server logs, and other similar technologies. For information concerning our use of cookies, please refer to Section V.C, below.

Treviso Bay Golf will only use your Personal Data when the law allows us to do so. Typically, we will only use your Personal Data:

• Where it is necessary for our legitimate interests (or those of an Internal Third Party or an External Third Party as defined above) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal or regulatory obligation; or
• Where you have provided us with consent.

A. Legitimate Interests

Treviso Bay Golf may process the Personal Data described below for the following legitimate interests, where appropriate. Please note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data.

1. To manage our relationship with you, including notifying you about changes to our Privacy Policy, we may process your Contact Data, Identity Data, Marketing and Communications Data, Profile Data, or Transaction Data;
2. To administer and protect our businesses and this website, including troubleshooting, data analysis, testing system, maintenance, support, and reporting and hosting of data, we may process your Contact Data, Identity Data, Profile Data, Technical Data, or Usage Data;
3. To deliver relevant website content, we may process your Contact Data, Identity Data, Profile Data, Technical Data, and Usage Data; and
4. To provide you with services related to your membership or other contract or agreement with Treviso Bay Golf or to respond to your requests for information made through this website, we may process your Contact Data, Identity Data, and Profile Data.

Please contact our General Manager, Joseph Iafe at 9800 Treviso Bay Blvd, Naples, FL 34113, or [email protected].

B. Consent

In order to provide services and communicate in connection with your membership or other contract or agreement with Treviso Bay Golf, Treviso Bay Golf's website allows you to affirmatively provide Personal Data through on-line forms. By providing your Personal Data, you voluntarily consent to its processing for the purpose for which you provided said Personal Data. Treviso Bay Golf may share your Personal Data with Treviso Bay Property Owners Master Association, Inc. or PGA Tour Golf Course Properties, Inc., but will not otherwise sell, distribute, or lease your Personal Data to third parties unless we obtain your prior, affirmative consent.

Treviso Bay Golf will document your consent to the collection of your Personal Data. You have the right to withdraw this consent, as detailed below.

If you have provided us with consent, Treviso Bay Golf will only use the Personal Data in connection with the reasonable scope of that consent. If Treviso Bay Golf intends to use that information outside the scope of your consent, it will notify you to obtain such additional consent.

Please consider and balance any potential impact on you (both positive and negative) before consenting to our processing of your Personal Data.

C. Cookies

Treviso Bay Golf employs web traffic log cookies to identify which pages of this website are being used. This Usage Data helps us analyze our website's traffic for statistical analysis purposes, and assists us in better serving our customers' needs. Cookies allow us to provide our customers with a better website, and in no way gives us access to your computer or any Personal Data, other than the data that you share with us.

You may change your browser settings to not allow for cookies. If you do so, then you will still be able to visit the website, but you may not be able to use this website to its full potential.

Under certain circumstances, were you do not provide us with consent to track your Usage Data through cookies, Treviso Bay Golf may maintain a single cookie indicating that you did not provide consent.

D. Do Not Track

Treviso Bay Golf does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

E. No Automated Process for Profiling

Treviso Bay Golf does not use or employ any automated processes for profiling based on its collection of your Personal Data.

Treviso Bay Golf may disclose your Personal Data obtained through this website among and between Internal Third Parties and External Third Parties as defined in Section II for the Legitimate Interests outlined Section V.A. Similarly, Treviso Bay Golf may, from time to time, disclose your information to Treviso Bay Property Owners Master Association, Inc and GCP pursuant to agreements between Treviso Bay Golf and those two entities.

Treviso Bay Golf may also disclose your Personal Data to third parties to which we may choose to sell, transfer, or merge parts of our business or our assets, including this website. If a change happens to our business, then the new owners may use your Personal Data existing with Treviso Bay Golf at the time that the new owners take control in the same way as set out in this Policy.

Treviso Bay Golf will not sell, distribute, or lease your Personal Data to third parties without your prior consent where the only basis for processing that Personal Data was your consent. Moreover, Treviso Bay Golf will disclose your Personal Data where required to do so by the laws of the applicable jurisdiction.

For individuals that are citizens of the European Economic Area ("EEA"), after May 25, 2018, all processing of Personal Data is made in accordance with the Regulations ("EU") 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation ("GDPR"), and Treviso Bay Golf processing of Personal Data will take place in accordance with the GDPR. Similarly, to the extent that the Personal Data is transferred from a data controller outside the EU and/or EEA, Treviso Bay Golf will adhere to the requirements of the GDPR. Treviso Bay Golf will promptly notify you in the event of any known unauthorized access to, or use of, your Personal Data in accordance with all applicable legal requirements.

For individuals who are citizens of states outside the EEA, Treviso Bay Golf has implemented reasonable physical, technical and organizational safeguards that comply with applicable governing laws, statutes, and regulations.

Treviso Bay Golf has implemented and maintains appropriate security measures to prevent your Personal Data from being accidentally lost, processed, or accessed in an unauthorized way, or altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors Internal Third Parties, and External Third Parties who have a legitimate business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Treviso Bay Golf has procedures to address any suspected personal data breach or unauthorized disclosure and will notify you and any applicable regulator of a breach where we are legally required to do so. Security for this website is managed by a third party.

Treviso Bay Golf will not retain Personal Data for any period of time longer than to fulfill the purpose for which the information was obtained, or as dictated by any applicable law, statute, or regulation, not to exceed seven years. In determining the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, accounting, and reporting requirements.

Please be aware that when visiting this website, you may follow links to external websites that are not affiliated with Treviso Bay Golf. Treviso Bay Golf is not responsible, nor makes any representation of responsibility, for the privacy policies of those third parties. When you leave our website, we encourage you to read the privacy notice of every website you visit.

With respect to the Personal Data that Treviso Bay Golf holds, if any, you have the following seven rights:

Right to request access to your personal data. This right allows you to request to receive a copy of the Personal Data that Treviso Bay Golf holds about you and to check that we are lawfully processing it.
Right to request correction of the Personal Data. This right allows you to request to have any incomplete or inaccurate data that Treviso Bay Golf holds about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to request erasure of your Personal Data. This right allows you to request that Treviso Bay Golf delete or remove Personal Data where there is no legitimate reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object to processing of your Personal Data. This right allows you to object to Treviso Bay Golf's processing of your Personal Data where we are relying on a Legitimate Interest (or those of an Internal Third Party or an External Third Party as defined above) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to request restriction of processing of your Personal Data. This right allows you to request that Treviso Bay Golf suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request the transfer of your Personal Data to you or to a third party. This right allows you to request that Treviso Bay Golf provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use.
Right to withdraw consent. This right allows you to withdraw your consent to Treviso Bay Golf's processing of your Personal Data at any time where we are relying solely on your consent to process your Personal Data. However, this right does not affect the lawfulness of any processing carried out before you withdraw your consent. If you do withdraw your consent, then we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

In connection with any request pursuant to these rights, we may request additional information to confirm your identity and to ensure your right to access the Personal Data requested. Any request for additional information is part of Treviso Bay Golf's security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You may exercise any or all of these rights at no cost to you. You have the right to receive equal service and pricing from Treviso Bay Golf, even if you exercise any of the aforementioned privacy rights. Where practical and not subject to statutory exemption, Treviso Bay Golf will try to respond to all legitimate requests within 30 days of said request. Occasionally it may take us longer than these 30 days to respond if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You also have the right to make a complaint at any time to a regulatory body concerning our processing of your Personal Data. While you have that right, we would appreciate if you first contacted us and afforded us the opportunity to address your concerns before you approach any regulatory body.

For further information concerning your Personal Data, please contact our General Manager, Joseph Iafe, at the information stated in Section I, above.