PRIVACY POLICY

Last updated: October 14, 2020

It is part of Pioneering Resorts LLC (hereinafter “we,” “us,” or “our”) culture and values to do the right thing and act with integrity, including respecting our guest’s concerns about privacy. We know that you care how your information is used, and we appreciate your trust that we will use it carefully and sensibly. This Privacy Policy details how we handle and maintain the information collected when you visit or use one of our websites, when you access one of the mobile applications made available by us in connection with our Services, when you access or use the social media pages that we administer and control, via any of our email marketing campaigns, as well as through the managed relationships necessary for the provision of our hospitality services (collectively, the “Services”). This policy describes our disclosure policies, as well as the choices that you have regarding use, access, and correction of your information. This policy does not describe the information collection policies or practices of any third party(s), including those with whom we may contract for the provision of Services or which may be linked to or integrated within any of our websites.

For more information about our European Union privacy practices, click here.

We encourage you to review this Privacy Policy periodically. Your use of our Services constitutes consent to the terms contained herein. If you do not agree with the practices described in this Privacy Policy, you should not use our Services. We may update this Privacy Policy periodically, and any changes will be reflected here. If the changes are significant, we will provide a more prominent notice, and at our discretion may email you a direct notification.

Collecting Data

We collect data and information about our guests and other visitors in order to better provide our Services. The data collected is provided by you, either directly or via your use of the Services.

Personal Data

Personal data applies to any data that can identify you as an individual or relate to an identifiable individual. At various points during your stay and experience with Pioneering Resorts LLC we collect certain Personal Data such as:

• Contact information: First and last name, Email address, Phone number, Address, State, Province, ZIP/Postal code, City, etc.
• Demographic information: Age, gender, date of birth, anniversary, primary language, etc.
• Reservation/Visit: Date of arrival and departure, special requests, goods, and services purchased and consumed, etc.
• Interests and Preferences: Regarding past, current and future stays at our property, such as your interests, activities, hobbies, food, and beverage choices, etc.

In more limited circumstances, we also may collect:

Data about family members and companions, such as ages of children. If you submit any Personal Data about other people to us (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Policy.

Payment Processing Information

When you make a payment in connection with purchasing any of the Services, Pioneering Resorts LLC may obtain credit card or other payment information.

Usage Data

Usage Data is collected automatically when you use the Service.

Usage Data may include information such as your device's Internet Protocol address (e.g. IP address), browser type (for example: Chrome, Firefox, Internet Explorer or Safari), browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may likewise collect certain information automatically, including, but not limited to, the type of mobile device you use, the unique ID or IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you access the Service by or through a mobile device.

Usage data is collected via tracking technologies, including:

Cookies

A cookie is a small data file which resides on your computer, and which allows us to recognize you as a user when you return using the same computer and web browser. Cookie data is used to customize your experience when you use the Services. When you visit our website, you are notified of the use of cookies for tracking and analysis and asked to provide your express consent. The notice refers to the detailed explanations in this Privacy Policy.

Cookies can be "Persistent" or "Session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while Session cookies are deleted as soon as you close your web browser.

You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Most modern internet browsers allow individuals to change the settings in the ‘options’ or ‘preferences’ menu to avoid or limit cookie storage. In addition, third party cookies generated by certain advertisers may be turned off by making a request with the Network Advertising Initiative. Please visit http://optout.networkadvertising.org for more information.

We also collect data through Google Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy and opt out by downloading the Google Analytics opt out browser add-on, available at tools.google.com. You can learn more about Adobe and opt out by visiting https://www.adobe.com/privacy/policy.html.

Using and Disclosing Data

The data and other information that we collect is used and disclosed in the following manner(s) and for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage your account: to manage your registration as a user of the Service. The information you provide can give you access to different functionalities of the Service that are available only to a registered user.
• To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage your requests: To attend and manage your requests to us.
• To tailor content, recommendations and offers we display to you on the Services and elsewhere online.
• Improve the Services and our products, including asking you to participate in surveys, and for other internal business purposes.

Retention of Data

We will retain data, including personal data, and other information for the purposes set out in this Privacy Policy. We will retain and use such data and information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes.

Third-Party Links

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Information Security

The security of your data is important to us, and Pioneering Resorts LLC takes commercially reasonable security and backup measures to protect the information submitted to us. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee its absolute security. We encourage our customers and partners to retain copies of all uploaded information on their own systems.

Children’s Privacy

The Services are general audience services and are not intended for individuals younger than the age of 13. We do not knowingly collect personal data from individuals younger than the age of 13 without parental consent. If we discover that a child under the age of 13 has provided us with personal data, or that we have otherwise inadvertently collected personal data from anyone younger than the age of 13, we will delete it in accordance with applicable law.

European Union Privacy

We comply with the provisions of the European Union’s General Data Protection Regulation (“GDPR”) as to any information in its possession regarding EU-based persons (“data subjects”). Accordingly, we only process personal information on data subjects where we has a lawful basis to do so, which may include the consent of each person (especially in the case of website visitors who provide their information) or compliance with a legal obligation. For additional details on your European Union Privacy rights, please see our European Union Privacy notice.

Changes to this Privacy Policy

We may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your personal data, we will display a notice on our website(s), or through other means. You are encouraged to review this Privacy Policy periodically for any changes. Continued use of our website(s) or our Services after any update will constitute your agreement to the new policy.

Contact Us

If you have any questions about this Privacy Policy, the practices, or use of the website(s) or Services, you can contact us:

• By email: [email protected]
• By phone: 727.564.0822
• By mail: Pioneering Resorts LLC ATTN: Internet Dept. 10575 49th St N Clearwater, FL 33762

European Union Privacy

If you are a resident of the European Union (the “EU”) or reside in the European Economic Area (the “EEA”) and we collect personal data relating to you in the context of the offering the Services, your personal data will be subject to Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”).

Legal Basis for Processing Personal Data under GDPR

We may process your personal data pursuant to one of the following conditions:

• Consent: You have given your consent for processing personal data for one or more specific purposes.
• Performance of a contract: Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing personal data is necessary for compliance with a legal obligation to which we are subject.
• Vital interests: Processing personal data is necessary in order to protect your vital interests or those of another natural person.
• Legitimate interests: Processing personal data is necessary for the purposes of the legitimate interests of Pioneering Resorts LLC.

In any case, upon reasonable request we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR Pioneering Resorts LLC undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EU, to:

• Request access to your personal data. You can access, update or request deletion of your personal data, please contact us and we will attempt to assist you as possible. You also have a right upon request to receive a copy of the personal data we hold about you.
• Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
• Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation which makes you want to object to our processing. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request erasure of your personal data. You have the right to ask us to delete or remove personal data from further processing.
• Request the transfer of your personal data. We will provide to you, or to 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 or where we used the information to perform a contract with you.
• Withdraw your consent. You have the right to withdraw your consent on using your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us via email [email protected] or via phone at 727.564.0822. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information please contact your local data protection authority in the EEA.