Your information privacy is important to us. We provide this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the Santa Lucia Preserve Company website (“Site”) and any Santa Lucia Preserve Company mobile application, other services offered by the Santa Lucia Preserve Company, and any other time you interact with the Santa Lucia Preserve Company (“Services”). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below). This Privacy Policy applies to all users of the Site and Services. The Site and Services are provided by the Santa Lucia Preserve Company (“Company” “we” “our” “us”). BY USING THE SITE OR SERVICES, YOU ARE CONSENTING TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.

Personal Information We Collect

We collect the following categories and types of “Personal Information”:

• Contact Information: your first and last name, mailing address, email address, and phone number;
• Other identifying information: IP address, family information, social media user names, passwords and other security information for authentication and access;
• Demographic information: gender, age, birthday, employment information and salary information;
• Geolocation data;
• Internet or other electronic activity: your browsing and click history, including information about how you navigate within our Site and Services and which elements of our Site and Services you use the most, social media comments and engagements;
• Commercial information: interests in property, services, or memberships;
• Audio and visual information: photos that you provide to us; and
• Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude.

How We Use Personal Information

We may use your Personal Information for the following categories of use:

• Transactional Purposes: We use your contact information and commercial information to: Receive, process, and track your property inquiries, membership requests and applications; and Communicate with you about your inquiries, requests, memberships or applications;
• Analytical Purposes: We use your other identifying information, internet activity and browsing history, commercial information, demographic information, and geolocation data to analyze preferences, trends and statistics.
• Marketing and Promotional Purposes: We use your contact information, commercial information, demographic information, internet or other electronic activity, geolocation data, and inferences to:
  • Inform you of our new services and offers;
  • Provide you with targeted advertising;
  • Provide you with other information from and about our Company, including personalized marketing communications.
• Maintenance and Improvement of the Site and Services: We use your contact information, commercial information, and internet activity and browsing history to:
  • Provide and maintain functionality on our website;
  • Handle your customer services requests;
  • Check website performance, both from a functionality standpoint, and effectiveness of attracting and retaining customer engagement; and
  • Help us diagnose technical and service problems and administer our websites and apps.
• Review and content creation purposes: We use your contact information, commercial information, and audio and visual information to enable reviews of our products and to display content that you have created and allowed us to display on our Site and Services and on social media.
• Security and Fraud Prevention: We use your contact information, other identifying information, commercial information, geolocation data, internet activity and browsing history, and inferences to protect the Site and Services, our Company, and others and to prevent fraud, theft and misconduct.

Sources of Personal Information

We collect Personal Information from the following sources:

• We collect information directly from you. We collect contact and demographic information directly from you.
• We collect information about you from third parties. We collect your Personal Information from third parties, such as real estate associations, social media sites and data co-ops. We may collect your identifying information from Facebook, in accordance with their terms of use and privacy policy. We purchase from and trade contact information, demographic information, commercial information, and internet and electronic activity with data co-ops and other third party data aggregators.
• We collect information from you passively. We collect Internet or other electronic activity passively using tools like browser cookies. This activity is further described in the Cookies and Advertising and Online Tracking sections below.

Categories of Third Parties

We Share Personal Information With

• Service Providers
  • From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
• Our Affiliates
  • We may share Personal Information with businesses controlling, controlled by, or under common control with our Company.
• Our Partners
  • We may share Personal Information with our realtor partners to provide you with real estate services.
• Our Members
  • We may share Personal Information with our current members in connection with your membership application.
• Corporate Transactions
  • If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.
• Compliance with Laws and Law Enforcement
  • We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law

Cookies

We use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other similar technologies to analyze use of and improve the Site and Services and as described in the Advertising and Online Tracking Section of this Privacy Policy. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers (defined below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf. We use Google Analytics on the Site and Services to analyze how users use the Site and Services, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

Advertising and Online Tracking

We may allow third-party companies to serve ads and collect certain information when you visit the Site and Services. These companies may use certain information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. Our systems do not recognize browser “Do Not Track” signals, but several of our Service Providers who utilize these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices. We also provide you with additional tools to opt out of marketing from us. You can learn about this in the “Managing Your Information Preferences” section of this Privacy Policy.

Managing Your Information Preferences

You can review, correct, update, or change your Personal Information or opt out of receiving certain e-mails by changing the relevant settings in your account or by e-mailing us at communications@santaluciapreserve.com. You can also opt out of receiving marketing e-mails from us by following the link provided at the bottom of all marketing e-mails you receive from us. Members can also change email communication preferences in their profile. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account. If you have questions or concerns regarding this Privacy Policy, please e-mail us at that same address.

Be Careful When You Share Information with Others

Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

Security

We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

Links

Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

Children’s Privacy

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.

Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States. Notice to California Residents/Your California Privacy Rights To opt out of sharing your Personal Information with third parties for their direct marketing purposes, please e-mail us at communications@santaluciapreserve.com and clearly state your request, including your name, mailing address, e-mail address and phone number.

California Consumer Privacy Rights

If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This Section describes those rights and how you can exercise them with our Company.

CCPA Rights Requests

Right to Know

• You can request what Personal Information we have collected about you in the preceding 12 months.
• You can request the specific pieces of Personal Information we have collected about you.
• You can also request the following categories of information:
  • The categories of Personal Information we have collected about you.
  • The categories of sources from which the Personal Information was collected.
  • The business or commercial purpose for collecting or selling the Personal Information.
  • The categories of third parties with whom we shared Personal Information.

To submit a request to know, please send an email to communications@santaluciapreserve.com. You must use “California Request to Know Information” or “California Right to Know Categories” in the subject line of your email and provide us with your full name and email address. In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization containing your first name, last name, email address, and phone number to: Santa Lucia Preserve Attn: CCPA Request One Rancho San Carlos Road Carmel, CA 93923 You can also call us toll free at 833-620-6768 to submit your request by phone. You must provide us with all of the information set forth above in any such request.

Right to Deletion

You can also request that we delete your Personal Information. We may not delete all of your Personal Information if one of the following exceptions applies:

• Transactional: to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or perform a contract we have with you;
• Security: to detect data security incidents;
• Error Correction: to debug or repair any errors;
• Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
• Internal Use: to use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).

We will also maintain a record of your CCPA Rights requests. Please note that if we delete your Personal Information, many of our services will not work the same. For example, your previous opt out requests will not be saved and saved preferences and information will no longer be available. To submit a request to delete, please send an email to communications@santaluciapreserve.com. You must use “California Request to Delete” in the subject line of your email. You must provide us with your first name, last name, email address, and phone number. To verify your identity, we will match that information to the information we have on our systems. In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization containing your first name, last name, email address, and phone number to: Santa Lucia Preserve Attn: CCPA Request One Rancho San Carlos Road Carmel, CA 93923 You can also call us toll free at 833-620-6768 to submit your request by phone. You must provide us with all of the information set forth above in any such request.

Do Not Sell My Personal Information

Personal Information that We Sell We may “sell” (as sell is defined in CCPA) the following categories of Personal Information:

• Identifiers
• Characteristics of protected classifications under California and federal law;
• Internet/electronic activity;
• Commercial information; and
• Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, preferences, behavior and attitudes.

We “sell” your Personal Information to Select Partners and to digital advertising networks. We do not knowingly sell the Personal Information of minors under the age of 18. Right to Opt Out of Sale California residents have the right to opt out of the sale of your Personal Information to third parties, as “sale” is defined under CCPA. To submit a request to opt out of the sale of your Personal Information, please email us at communications@santaluciapreserve.com. You must use “California Opt Out from Sale” in the subject line of your email and provide us with your full name and email address. In order to designate an authorized agent to act on your behalf, you must send a signed, written authorization containing your first name, last name, email address, and phone number to: Santa Lucia Preserve Attn: CCPA Request One Rancho San Carlos Road Carmel, CA 93923 You can also call us toll free at 833-620-6768 to submit your request by phone. You must provide us with all of the information set forth above in any such request. We participate in digital advertising networks to deliver advertising that is tailored to your interests. The participation in certain ad networks can constitute a “sale” of Personal Information under CCPA. In order to opt out of this activity, please visit optout.aboutads.info and optout.networkadvertising.org. Non-Discrimination We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.

Privacy Policy Changes

We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you are consenting to the revised Privacy Policy.

Contact Us

If you have any questions or concerns, you may contact us at 833-620-6768. PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOUR RECORDS AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.