Effective Date: October 24, 2022
Last Updated: October 24, 2022
Shore Club Property Owner LLC, a Delaware limited liability company (hereinafter “we,” “our,” or “us”) is committed to safeguarding and handling your Personal Information in a responsible and secure manner.
How to Revoke Your Consent or Request Information.
You may revoke your consent on a going forward basis and submit written requests and questions about your rights to us by contacting us at:
Regular Mail: Shore Club Property Owner LLC, c/o The Witkoff Group LLC, 233 Broadway, Suite 2305, New York, NY 10279, Attn: James Stomber
We may modify this Policy at any time, without prior notice, and changes may apply to any “Personal Information” (as defined below) we already hold about you, as well as any new Personal Information collected after the Policy is modified. If we make changes, we will notify you by revising the date at the top of this Policy. We will provide you with advance notice if we make any material changes to how we collect, use or disclose your Personal Information or that impact your rights under this Policy. If you continue to access or use the Site after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.
In addition, we may provide you with real time disclosures or additional information about the data handling practices of specific parts of the Site. Such notices may supplement this Policy or provide you with additional choices about how we process your Personal Information.
Section 1 – Information We Collect Through Your Use of the Site
Personal Information is any information that identifies you or makes you identifiable. We collect different types of Personal Information when you’re accessing or using the Site, including:
- Information You Provide to Us. In connection with the Site, you may voluntarily provide Personal Information about yourself including your name, phone number, e-mail address and/or physical address or other information you submit to us while using the Site.
- Usage Information Automatically Collected. When you use the Site, we automatically collect information regarding your usage of the Site as described below. We have a legitimate interest in understanding how you use and interact with the Site and communicating with you in response to your requests for information.
- Service Data: We collect information about your interactions with the Site, such as the pages or other content you view, and other actions you perform while using the Site.
- Log Data: We automatically collect log information when you use the Site. This might include your IP address, access times, hardware and software information, device information, device event information (e.g. crashes, browser type), the web page you’ve viewed or engaged with before or after using the Site, and other relevant information. We collect and monitor this data in order to keep track of the security and privacy of your information and analysis of use of the Site.
- Cookies and Similar Tracking Technologies: We may use various tracking technologies to collect and store information about your use of the Site. We use these tools to ensure that you receive a personalized experience, to provide you with certain functions on our Site and to improve and optimize the Site. Please refer to the “Cookies and Similar Tracking Technology” section below for more information.
Section 2 – How We Use Your information
Your Personal Information can be used for various purposes, including:
- To Provide You with Project-Related Communications. If you submit a request via the site to receive information about the Shore Club project, we will use your Personal information to send you project-related communications. You can manage your email preferences and opt out of communications.
- To Enforce our Terms, Agreements, or Policies. To maintain a safe, secure, and trusted environment for you when you use the Site, we use your Personal Information to make sure our terms, policies, and agreements with you and any third parties are enforced. We actively monitor, investigate, prevent, and mitigate any suspected or actual prohibited activities on the Site. We are required to process your Personal Information for this purpose to provide the Site.
- For Research and Development. We may process your Personal Information to improve, optimize, or expand the Site or features of the Site. We do so by processing information about your use of the Site, any information you provide to us, and by measuring, tracking, and analyzing trends and usage in connection to your use or the performance of the Site.
Section 3 – How We Share Your Information
We may share your Personal Information as follows:
- Third-Party Service Providers. We may use third parties to perform certain services on our behalf in connection with the Site such as: sending e-mail, removing repetitive information from prospect or customer lists, web site analysis, analyzing data, providing marketing assistance and providing customer service.
- Opt-in and Opt-out Programs: Throughout the Site you may be presented with opportunities to receive mailings from third parties or us. An opt-in/opt-out message may ask you if you would like your Personal Information to be shared. If you do choose to have your Personal Information shared, please be aware that we are not responsible for the privacy practices of these other companies, and you should review the privacy practices of such companies prior to providing your Personal Information. If you would not like your information to be shared to third parties, or if you would like to stop receiving mailings from third parties or us, you may follow the instructions in the opt-out section below.
- Our Subsidiaries and Affiliates: We may share your information (including, without limitation, Personal Information) with our affiliated companies.
- Merger, Bankruptcy, or Corporate Reorganization. We may disclose and transfer your Personal Information to a subsequent owner, co-owner, or operator of our company or the Site, or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets (i.e., a bankruptcy proceeding), or other corporate change.
- Legal Obligations and Safety. We may share your Personal Information if it is reasonably necessary to:
- Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);
- Comply with requests or investigations by public authorities;
- Comply with applicable laws or regulations;
- Enforce or apply our policies or policies of our business partners;
- Protect the security or integrity of the Site; or
- Protect our rights, property, or safety or that of our employees or users, partners and affiliates, or other natural persons.
Section 4 – Your Choices
- Voluntary Information. You may choose not to provide us with some of your Personal Information. You are not required to send us any Personal Information.
- Communication Preferences. If you do not want to receive emails from us, please adjust your communication preferences or click the unsubscribe link within the email you received from us.
Section 5 - Third-Party Services
Section 6 - Security
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your Personal Information from unauthorized access, use, or disclosure, we cannot guarantee the security of your Personal Information. In the event that we are required by law to inform you of a breach of security with respect to your Personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Section 7 – Cookies and Similar Tracking Technology
- A session Cookie expires when you close your browser and is used to make it easier for you to navigate our Services.
- A persistent Cookie remains on your hard drive for an extended period of time.
For example, if your Site has user log-in features, then when you sign in to our Site, we may record your user or member ID, which is your email address, and the name on your user or member account in the cookie file on your computer. We may store your unique member ID in a cookie for automatic sign-in. This cookie is removed when you sign-out. For security purposes, we will encrypt the unique member ID and any other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier.
We use the following types of cookies on our website:
- Strictly Necessary Cookies. These cookies enable you to move around and use the Site. This category of cookies is essential for our Site to work and they cannot be disabled.
- Performance or Analytics Cookies. These cookies collect usage information about how you use our Site. For example, the cookies will collect information about the pages you view or click on while using our Site or if you get an error message from certain pages. We use the information collected by such cookies to improve and optimize our Site. You can disable these cookies. Generally, we may use first-party and third-party cookies for the following purposes:
- To make our Site function properly;
- To provide a secure browsing experience during your use of our Site;
- To collect usage information about your use of our Site to help us improve and optimize our Site; and
- To remember your preferences for your convenience.
- Third Party Service Provider Cookie Use. We may allow our authorized service providers to serve cookies from our Site to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our Site, content and advertising. You can enable, disable, or delete cookies through the browser you are using to access our Site. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies parts of our Site may not work properly for you.
More information may be found for the following browsers here:
- Google Chrome:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en-GB
- Microsoft Edge:https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-25dc-1de753474879
- Internet Explorer:https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
- Mozilla Firefox:https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- Safari (Desktop):https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Android Browser:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en
- Opera: https://help.opera.com/en/latest/web-preferences/
Information regarding management of cookies from third party websites is also available at http://www.allaboutcookies.org/.
We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our Site visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on the user’s computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our Site from an online advertisement displayed on a third-party website.
Section 8 – Children’s Privacy
By using this Site, you represent that you are at least the eighteen (18) years old. The Site is not intended for persons under 18 years of age. No one under age 18 may provide any Personal Information to or on the Site. We do not knowingly collect Personal Information from anyone under 18. If you are under 18, do not use or provide any information on the Site or through any of its features, register on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from someone under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us using the information provided in the “Questions & Contact Information” section below.
Section 9--Governing Law and Jurisdiction
All matters relating to this Site and Policy and any dispute or claim arising therefrom or related thereto, shall be governed by and construed in accordance with the internal laws of the State of Florida without giving effect to any choice or conflict of law provision or rule (whether of the State of Florida or any other jurisdiction). This Site is operated from the United States. By using this Site from outside the United States you consent to have any Personal Information you provide through this Site transferred to and processed in the United States, and allow us to use and collect your Personal Information in accordance with this Policy. Text on this Site may be published in languages other than English, in which event the English language version of any text, including this Policy shall control.
Section 10 – Retention
We generally retain your Personal Information as long as necessary to fulfill the purposes of collection or to comply with applicable law. Otherwise we will try to delete your Personal Information upon your request or when we no longer need it for the purposes it was originally collected.
Section 11--Access To Your Personal Information
You may request access to your Personal Information by contacting us at the address provided in the “Questions & Contact Information” section below. If required by law, upon request, we will grant you reasonable access to the Personal Information that we have about you.
Section 12--Changes To Your Personal Information
We rely on you to update and correct your Personal Information. If the Site does not permit you to update or correct Personal Information, you should contact us at the address provided in the “Questions & Contact Information” section below in order to request that your Personal Information by modified. Note that we may keep historical information in our backup files as permitted by law.
Section 13--Deletion Of Your Personal Information
You may request information about how long we keep a specific type of information, or request that we delete your Personal Information by contacting us at the address provided in the “Questions & Contact Information” section below. If required by law we will grant a request to delete Personal Information, but you should note that in many situations we must keep your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
Section 14--Objection to Certain Processing; Revocation of Consent
You may object to our use or disclosure of your Personal Information by contacting us at the address provided in the “Questions & Contact Information” section below. If you revoke your consent for the processing of Personal Information then we may no longer be able to provide you information or other services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address provided in the “Questions & Contact Information” section below. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
Section 15 – Information for California Residents-Your California Privacy Rights.
Under California law, “Personal Information” means information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household, and may include:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Any categories of Personal Information described in subdivision (e) of Section 1798.80.
- Characteristics of protected classifications under California or federal law.
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Biometric information.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information.
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).
- Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
“Personal information” does not include publicly available information. For purposes of this paragraph, “publicly available” means information that is lawfully made available from federal, state, or local government records. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. “Personal information” also does not include consumer information that is deidentified or aggregate consumer information.
California Information Sharing Disclosure
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of Personal Information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law).
We do not “sell” your Personal Information. We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
The table below indicates the categories of Personal Information we may collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself.
Category A. Identifiers.
Examples A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Data analytics providers, Internet service providers, Operating systems and platforms, Other Service Providers, Our Brand Licensor, Financial institutions
Category B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Other Service Providers, Our Brand Licensor, Financial institutions
Category C. Protected classification characteristics under California or federal law.
Examples Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Data analytics providers, Other Service Providers
Category D. Commercial information.
Examples Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Data analytics providers, Other Service Providers, Financial institutions
Category E. Biometric information.
Examples Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
To Whom We Disclose Personal Information for a Business Purpose
Category F. Internet or other similar network activity.
Examples Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Other Service Providers, Internet Service Providers
Category G. Geolocation data.
Examples Physical location or movements.
To Whom We Disclose Personal Information for a Business Purpose
Category H. Sensory data.
Examples Audio, electronic, visual, thermal, olfactory, or similar information.
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Other Service Providers
Category I. Professional or employment-related information.
Examples Current or past job history or performance evaluations.
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Other Service Providers
Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
To Whom We Disclose Personal Information for a Business Purpose Affiliates, Other Service Providers
Category K. Inferences drawn from other Personal Information.
Examples Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
To Whom We Disclose Personal Information for a Business Purpose
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from contact forms you complete on the Site or information you otherwise provide to us other than via the Site.
- Indirectly from you. For example, from observing your actions on our Site.
Personal Information collected other than via the Site may include sensitive Personal Information such as social security number, driver’s license, state ID card or passport number, or financial account, debit card, credit card or other account information or credentials, geolocation information, racial or ethnic origin, union membership, contents of mail, email or text messages, genetic data, biometric information, which would only be shared with a third party for a business purpose, such as if/to the extent necessary to provide our services to you and our clients or as required by law.
Right to Know and Data Portability.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information (the “right to know”). Once we receive your request and confirm your identity (see “Exercising Your Rights to Know, Delete or Correct”), we will disclose to you:
- 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 or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
Right to Delete.
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see “Exercising Your Rights to Know, Delete or Correct”), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform a contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- 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, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right to Correct.
You can request correction of your Personal Information if it is inaccurate. We will use commercially reasonable efforts to correct such information if we receive a verifiable request from you in accordance with the procedures provided below.
Exercising Your Rights to Know, Delete or Correct.
To exercise your rights to know, delete or correct described above, please submit a request by either:
- Emailing us at: email@example.com;
- Writing to us by regular mail at: Shore Club Property Owner LLC, c/o The Witkoff Group LLC, 233 Broadway, Suite 2305, New York, NY 10279, Attn: James Stomber; or
- Calling us at: 212-672-4700.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.
Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the following information to the request:
- A completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf.
- If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
For instructions on exercising your sale opt-out or opt-in rights, see “Personal Information Sales Opt-Out and Opt-In Rights” below.
Response Timing and Format.
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten (10) day timeframe, please contact us using one of the contact methods noted in the “Our Contact Information” below.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of your request unless otherwise required by law. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by email.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales or Sensitive Personal Information Sharing or Use Opt-Out and Opt-In Rights.
You have the right to direct us to not sell or share or use your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of any users. We may share and/or use your Personal Information, including sensitive Personal Information such as social security number, driver’s license, state ID card or passport number, or financial account, debit card, credit card or other account information or credentials, geolocation information, racial or ethnic origin, union membership, contents of mail, email or text messages, genetic data, biometric information for a business purpose related to the purpose for which it was provided to us or as otherwise required by applicable law. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract.
We will not discriminate against you for exercising any of your rights. Unless permitted by applicable law, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by California law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Other California Privacy Rights.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
If you would like to opt-out and/or limit our sharing of your Personal Information, you can contact us by email, phone or regular mail using the information provided below under “Our Contact Information.” You can opt out of our sharing of your Personal Information disclosed to third parties including affiliates and nonaffiliates for such third parties’ marketing use. Please understand if you opt out of receiving promotional correspondence from us or our affiliates or third parties, you may not be able to use some or all of our services, and we may still contact you in connection with your account with us and your use of our services.
Section 16 – Do Not Track Signals
Currently, we do not monitor or take any action with respect to Do Not Track signals or other mechanisms, which means that we collect information about your online activity both while you are using the Site and after you leave the Site.
We reserve the right to modify this Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. To the extent that our policy changes in a material way, the Policy that was in place at the time that you submitted Personal Information to us will generally govern that information unless we receive your consent to the new Policy. Our Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.
Section 18 –Cross-Border Transfer
Your Personal Information may be stored and processed in any country where we our Site-related service providers have facilities, and by using the Site you consent to the transfer of your Personal Information to countries outside of your country of residence, including the United States, which may have different data protection rules than those in your country. As a result your Personal Information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat Personal Information using the same privacy principles that apply pursuant to the law of the country in which we first received your Personal Information. By submitting your Personal Information to us you agree to the transfer, storage and processing of your Personal Information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information provided in the “Questions & Contact Information” section below.
Section 19--Sensitive Information
Do not send us, and do not disclose, any sensitive information (e.g., social security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership), or other information you consider to be confidential, on or through the Site or otherwise to us.
Section 20--Questions & Contact Information
If you would like to access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply want more information contact us by email at email@example.com or by phone at 212-672-4700 or by regular mail at Shore Club Property Owner LLC, c/o The Witkoff Group LLC, 233 Broadway, Suite 2305, New York, NY 10279, Attn: James Stomber.
Last updated: October 24, 2022