Privacy Policy

Miramar Club Privacy Notice and Your Privacy Rights

Effective: January 1, 2023

Notice Last Updated: December 15, 2022

This Privacy Notice describes how Miramar Club, LLC and its affiliates (collectively “Club,” “we,” “us,” or
“our”) collects, uses, stores, and shares information about you.
We recommend you read this Privacy Notice carefully before you visit or use the Club facilities or
communicate with us in any manner. The practices described in this Privacy Notice are subject to applicable
laws.

BY VISITING THE CLUB FACILITIES, USING THE CLUB’S WEBSITE, OR COMMUNICATING WITH US IN ANY MANNER, YOU ARE ACCEPTING THE TERMS OF THIS PRIVACY NOTICE, WHICH MAY BE UPDATED AND AMENDED FROM TIME TO TIME.

What Information Do We Collect From Or About You?

Depending on how you interact with us, we may collect several types of information concerning you,
including:
➢ Information that you choose to provide in connection with a Club application, such as your name,
social security number, date of birth, contact information, prior addresses, club affiliations, personal
and financial references, names and other data relating to your spouse or domestic partner, names
and other data relating to your children, approximate income level, approximate net worth, education
history, and employment history.
➢ Information about your usage of our guest Wi-Fi network, such as your device type and Media Access
Control (“MAC”) address.
➢ Information that Club members may share about you in connection with a nomination for you to be
considered for Club membership, such as your name, occupation, company, contact information, and
the reasons for the nomination.
➢ Information that you may choose to share with us when you have a question, request, or concern.
➢ Payment information for your membership dues and your Club charges.
➢ Data that can help us deliver an excellent Club experience for you, such as information about your preferences when you visit the Club (for example, your favorite foods).
➢ Information about vehicles that you may use to travel to and from the Club, such as license plate numbers and vehicle type.
➢ Reservation information, including your name, the size of your party, and the date and time of your reservation.
➢ If you install the Miramar Club app, and depending on how you make use of it, we may collect data about your request for valet services, for reservations to attend a Club event, dining reservations, or feedback you provide on the Club.
➢ If you install the Miramar Club app on your phone and enable location services, we may collect information related to your arrival in the parking lot of the Club and regarding your location in the Clubhouse and your name and associated photograph may be transmitted to Club employees so that they can provide customized services during your visit to the Club.
➢ Information used for the safety, management, or administration of the Club facilities, such as data collected through the use of security cameras.

How Do We Collect Information?

We may collect this information from several categories of sources:
Directly from consumers when they communicate with us through email, our website, by text, by phone, or in person.
Examples:
➢ Information you provide by filling out an application form.
➢ Data you share about your preferred payment method.
➢ Text messages that you send requesting a service.
➢ Data that you input on our website’s membership inquiry form.

Automatically when consumers access or interact with our website, Wi-Fi network or a camera.
Examples:
➢ Your device’s MAC address when you use our Wi-Fi network.
➢ Through your use of the Miramar Club app if you choose to install it on your mobile device.
➢ Your image if you pass by a CCTV or security camera.

From third parties, including Club members, business partners, and affiliates.
Examples:
➢ A Club member recommends that you be considered for membership and provides your name, contact information, company, and reasons for your nomination.

How Do We Use Your Information?

We use the information described above for multiple purposes, including to:
➢ Evaluate membership applications and nominations;
➢ Manage reservations;
➢ Communicate with you regarding services that you have requested or that we believe you may be interested in;
➢ Create, manage, administer and communicate with you regarding your Club member account;
➢ Process and manage payment of membership dues and Club charges;
➢ Provide Wi-Fi service to you and to perform functions associated with the Wi-Fi service, such as access management, troubleshooting, data analysis, testing, research, and for statistical purposes;
➢ Respond to your requests, feedback, or inquiries;
➢ Comply with laws, regulations, and other legal requirements;
➢ Comply with relevant industry standards and our policies;
➢ Deliver services tailored to your preferences;
➢ Protect and enforce your rights and the rights of other users against unlawful activity, including identity theft and fraud;
➢ Protect and enforce our collective rights arising under any agreements entered into between you and us;
➢ Provide certain conveniences and efficiencies to our guests;
➢ Estimate our audience size and usage patterns;
➢ Provide security for the Club facilities, or protect our rights;
➢ Valet park your vehicle;
➢ Ensure appropriate use of Club parking facilities.

How Do We Share Your Personal Information?

We may share your information in several ways:

• With your consent. In certain circumstances, we may seek to share your information with a third-party with your consent.

• With service providers or contractors. We may share your information with service providers and contractor partners who complete transactions or perform services on our behalf. For example,
to process payment card transactions, we have to share information with payment card processing companies. To help us interact with you and manage our internal operations, we use online software systems, such as Jonas Club Software and Pacesetter Technology and share data with
those systems.
• With affiliated companies. We may share your information with affiliated companies in an effort to facilitate your use of the Club facilities or to provide you with services that may match your preferences.
• In a business transfer. We may share your information as part of a corporate business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be shared with third parties as a business asset in the transaction.
• For legal process and protection. We may share your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
• Enforce or apply agreements, or initiate, render, bill, and collect for services;
• Protect our rights or interests, property or safety or that of others;
• In connection with claims, disputes, or litigation – in court or elsewhere;
• Protect users of our services, and other carriers or providers from fraudulent, abusive, or unlawful use of, or subscription to, such services;
• Facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government; or
• In case of an emergency.

California Residents

If you are a California resident, you have additional rights when it comes to your personal information under the California Consumer Privacy Act as amended by California Privacy Rights Act (together, the “CCPA”),
including:
Right of access / disclosure. You have a right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting, selling, or sharing that personal information.
• The categories of third parties to whom we disclose that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or shared your personal information, the categories of personal information that each category of recipient purchased.
• If we disclosed your personal information for a business purpose, the categories of personal information that each category of recipient obtained.
To make such a request, you may either call 1-855-490-5500 or submit a request here: www.caruso.com/disclosure/. Please note that your request is subject to verification, and that we are not obligated to provide personal information in response to such a request if a consumer makes more than two requests in a 12-month period. In order to verify that you are the consumer to whom the personal information relates, we may request certain information from you. To obtain information about categories of personal information, we may request that you submit two data points that match data points that we maintain about you and that we determine are reliable for purposes of verifying your identity. To obtain specific pieces of information we may have about you, we may request that you submit at least three pieces of personal information that we can match to information we maintain along with a signed declaration under penalty of perjury.
Right of deletion. You have a right to request that we delete your personal information, and that we direct any service providers, contractors, or, unless impossible or involves disproportionate effort, third parties to whom we sold or shared your personal information to do the same. To make such a request, you may either call toll-free at 1-855-490-5500 or submit a request here: www.caruso.com/disclosure/. Please note that your request is subject to verification. The type of verification we may require will depend on the nature of the information that you seek to delete. We also reserve the right to deny your request if your personal information is required to:
• Complete the transaction for which the personal information was collected;
• Provide a product or service requested by you;
• Continue the ongoing business relationship with you within the reasonably anticipated context of that relationship;
• Perform a contract between you and the Club;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another California resident to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws;
• To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information;
• Comply with legal obligations.
•
Right to correct. If you are a California resident, you have the right to request that we correct inaccurate personal information about you that we maintain taking into account the nature of the personal information
and the purpose of the processing of the personal information. To make such a request, you may either call toll-free at 1-855-490-5500 or submit a request here: www.caruso.com/disclosure. Please note that your request is subject to verification, and our duty to correct the personal information is limited to commercially reasonable efforts. Please note that your request is subject to verification. The type of verification we may require will depend on the nature of the information that you seek to delete.

Right of non-discrimination. You have a right to exercise your rights under the CCPA without being subject to discrimination, including, but not limited to, by:
• Denying you goods or services;
• Charging you different prices or rates for goods or services;
• Providing you a different level or quality of goods or services;
• Suggesting you will receive a different price or rate for goods or services or a different level of quality of goods or services; or
• Retaliating against an employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.
This right does not prohibit us from charging a consumer a different price or rate, or from providing a different level or quality of goods or services, if that difference is reasonably related to the value provided
to the business by the consumer’s data. Further, this right does not prohibit us from offering loyalty, rewards, premium features, discounts, or other programs consistent with the CCPA. In certain instances,
we may need your information to provide you with a particular service. For example, if you decide to apply for membership, you will need to provide us with certain information about yourself. Similarly, if your membership application is approved, the Club will need to maintain certain information about you in order to validate that you are a member of the Club and to process your payment of membership dues and Club charges. If you request that we delete all of your information, we will honor that request to the extent required by law, but such a request obviously may interfere with your ability to be a Club member.
Personal Information Collected (By Categories Set Forth In CCPA). We may collect, and during the preceding 12 months, we have collected the following categories of personal information about California consumers (including, but not limited to, customers, job applicants and/or employees). The Club retains personal information for as long as it is necessary to fulfill the purposes described above, unless a long retention period is required or permitted by law. Generally, the Club considers the following criteria in determining how long to retain categories of customer personal information: the amount, nature, and sensitivity of personal information; the potential risk of harm from unauthorized use or disclosure of personal information; the purposes for which we process the personal information; available alternatives for satisfying those purposes; and legal requirements. We may delete or de-identify personal information sooner if we receive a verifiable deletion request that is not subject to an exemption from the duty to delete.
• Identifiers (including, for example, names, email addresses, and postal addresses);
• “Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers);
• Characteristics of protected classifications under California or federal law (for example, demographic data collected about employees or descriptions of subjects in connection with incident reports);
• Commercial information (such as records of services provided);
• Biometric information, defined in the CCPA to include an individual’s physiological, biological or behavioral characteristics that can be used singly or in combination with other identifying data, to establish individual identity (for example, images recorded on security video);
• Internet or other electronic network activity information (such as MAC address information collected in connection with use of our Wi-Fi network);

• Geolocation data (for example, information about when you visited the Club or the MAC address of a device that used our Wi-Fi network);
• Audio, electronic, visual, thermal, olfactory, or similar information (such as images recorded on security video);
• Professional or employment-related information (for example, you may provide your current or past positions if you apply for Club membership);
• Education information (for example, you may identify the schools you attended and your areas of study if you apply for Club membership);
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes (for example, your preferences regarding services offered by the Club);
• Sensitive Personal Information (as defined in CCPA). For more information, please see the next section.

Sensitive Personal Information Collected (By Categories Set Forth In CCPA). We may collect, and during the preceding 12 months, we may have collected the following categories of Sensitive Personal Information about certain types of California consumers: specifically, member applicants, Club members, job applicants, and/or employees.
• Social Security numbers;
• Driver’s license numbers;
• Racial or ethnic origin;
• Health data; and
• Religious affiliation.

We collect and/or use these categories of Sensitive Personal Information for various purposes associated with performing our roles as a provider of Miramar Club, including:
• Improving guest services such as dietary restrictions;
• Verifying employment or member eligibility;
• Performing background checks;
• Administering health benefits;
• Health and safety;
• Paying applicable employment taxes and making necessary withholdings;
• The promotion of diversity, equity, and inclusion;
• Complying with legal obligations, satisfying document retention requirements, or defending against legal claims.

Personal Information Sold or Shared (By Categories Set Forth In CCPA). Our current practice is to not sell or share consumers’ personal information or sensitive personal information for monetary or other
valuable consideration, and we have not done so during the preceding 12 months. We do not have actual knowledge that we sell or share personal information of consumers under 16 years of age. Because we do
not sell or share personal information, our current practice is to not respond to Global Privacy Control Signals, which are designed to assist consumers in opting out of sales and sharing of personal information.

Our website also does not respond to Do Not Track signals.

Personal Information Disclosed For A Business Purpose (By Categories Set Forth In CCPA). We generally do not disclose the personal information of Club Members or applicants for Club Membership to
third parties, as that phrase is defined in the CCPA. We may disclose such information to service providers or contractors who assist us with our operations. With respect to employees, during the preceding 12
months, we have disclosed the following categories of personal information about employees and/or job applicants to third parties:
• Identifiers (including, for example, names, email addresses, and postal addresses) Categories of Third Parties Disclosed To: Government agencies;
• “Personal Information” as defined in California Civil Code section 1798.80, subsection (e) (such as names, address, and telephone numbers)
Categories of Third Parties Disclosed To: Government agencies;
• Characteristics of protected classifications under California or federal law (for example, demographic data collected about employees or descriptions of subjects in connection with incident reports)
Categories of Third Parties Disclosed To: Government agencies;
•
• Professional or employment-related information (for example, you may provide your current or past positions if you apply for Club membership)
Categories of Third Parties Disclosed To: Government agencies;
•
• Biometric information defined in the CCPA to include an individual’s physiological, biological or behavioral characteristics that can be used singly or in combination with other identifying data, to establish individual identity (for example, images recorded on security video)
Categories of Third Parties Disclosed To: Government Entities;
• Education information (for example, if you choose to apply for employment with us)

Categories of Third Parties Disclosed To: Government Entities.

Use or Disclosure of Sensitive Personal Information. Other than the use or disclosure of Sensitive Personal Information to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services, to perform the services set forth in California Civil Code § 1798.140(e)(2), (4), (5), or (8), or as otherwise authorized by regulations adopted pursuant to Civil Code § 1798.185(a)(19)(C), we do not use or disclose Sensitive Personal Information.

How We Store And Protect Your Personal Information

We have established reasonable organizational, technical and physical safeguards designed to limit who has access to your personal information, and to protect your personal information from unauthorized alteration, access, loss, theft, use or disclosure. These safeguards include, but are not limited to, access controls that are intended to restrict access to your personal information to authorized employees and contractors only.
We also rely on you to protect your personal information. Where we have provided you, or you have chosen, a password for access to certain online services associated with the Club, you are responsible for ensuring
that password is kept confidential. We ask that you do not share your password with others. We may act on any activity undertaken under your password.
No system can guarantee complete security of your personal information. We therefore cannot ensure or warrant that your personal information is secure from unauthorized third parties. Your use and access of the Club and its services, and your communications with us, are at your own risk.

International Jurisdictions

The Club is located in the United States of America (US), and is subject to US state and federal law. If you communicate with us or use Club services from other countries, please be advised that you are transferring
your personal information into the US, and by doing so you consent to that transfer and use of your personal information in accordance with this Privacy Notice. You also agree to abide by the applicable laws of the
US, including state and federal law and your agreements with us. Any persons using the Club or its services from any jurisdiction with laws or regulations, including laws or regulations regarding personal data
collection, use and disclosure, different from those of the jurisdictions mentioned above may only use the the Club and its services in a manner lawful in their jurisdiction. If your use of the Club and its services would be unlawful in your jurisdiction, you may not use them.

Changes To Our Privacy Policy

We may change this Privacy Notice from time to time. Any and all changes to this Privacy Notice will be reflected on the Club’s website.
Your continued use, access, or interaction with the Club or its services or your continued communication with us after the updated Privacy Notice has been disseminated to Club members will constitute your acceptance of the updated Privacy Notice.

Contact Us
info@caruso.com
1-855-490-5500