Privacy Policy

Last Updated: [Date to be confirmed by client]

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It is part of Lake Buena Vista Commons' (collectively hereinafter "Lake Buena Vista Commons," "we," "us," or "our") culture and values to do the right thing and act with integrity, including respecting our guests' 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. Some state laws allow certain rights relating to personal data. If you live in the U.S. in one of the states below, please select your state of residency to review your state's rights and subject rights request processes.

For more information about our California privacy practices, click here. For more information about our Virginia privacy practices, click here. For more information about our Colorado privacy practices, click here. For more information about our Connecticut privacy practices, click here. For more information about our Nevada privacy practices, click here. For more information about our Texas privacy practices, click here. For more information about our Montana privacy practices, click here. For more information about our Oregon 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.

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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.

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PERSONAL DATA WE COLLECT

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 Lake Buena Vista Commons, 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 Lake Buena Vista Commons properties, 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. Images and video and audio data via: (a) security cameras located in public areas, such as hallways and lobbies, in our properties; and (b) body-worn cameras carried by our loss prevention officers and other security personnel.

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.

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PAYMENT PROCESSING INFORMATION

When you make a payment in connection with purchasing any of the Services, Lake Buena Vista Commons may obtain credit card or other payment information.

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NOTICE OF FINANCIAL INCENTIVES

Lake Buena Vista Commons may offer various and different loyalty or promotional programs that provide certain benefits to our guests. For example, we may provide special offers or discounts to our guests as part of certain programs, promotional campaigns, subscriptions, or other offerings. We may also provide discounts when guests sign up to receive marketing messages or when guests claim a specific offer. In this Notice of Financial Incentives, we refer to these various programs and offerings as the "Programs."

In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, internet or other electronic network activity information, geolocation data, or similar information, and inferences drawn from the above. For additional details on the types of information we may collect, please see "Personal Data We Collect" in our Privacy Policy. If you have any questions or require assistance, please contact us at [email to be provided by client].

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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, 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:

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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.

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.

We use both Session and Persistent cookies for the purposes set out below:

• Necessary / Essential Cookies — Session Cookies: These cookies are essential to provide you with the Services. They help to authenticate users and prevent fraudulent use of user accounts.
• Cookies Policy / Notice Acceptance Cookies — Persistent Cookies: These cookies identify if users have accepted the use of cookies on the website.
• Functionality Cookies — Persistent Cookies: These cookies allow us to remember choices you make when you use our website, such as remembering your login details or language preference.
• Tracking and Performance Cookies — Persistent Cookies, administered by third parties: These cookies are used to track information about traffic to the website and how it is used.
• Targeting and Advertising Cookies — Persistent Cookies, administered by third parties: These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you.

Log files are deleted after 120 days. Session cookies expire and are deleted at the end of your browser session. Persistent cookies may be set to expire from 30 days to 1 year depending on the function of the cookie.

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. 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.

In addition to cookies, we also use Web Beacons and Embedded Script. Web Beacons help us better manage content on our Services by informing us of what content is effective. Embedded Script is a programming code that collects information about your interactions with the Services, such as the links you click on.

We also collect data through Google Analytics, which uses cookies and technologies to collect and analyze data about use of the Services. 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.

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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 and registration as a user of the Service.
• For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with us through the Service.
• To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products, or contracted services.
• To provide you with news, special offers, and general information about other goods, services, and events which we offer.
• To manage your requests to us.
• To tailor content, recommendations, and offers we display to you on the Services and elsewhere online.
• To improve the Services and our products, including asking you to participate in surveys and for other internal business purposes.

Our goal is to provide you with the highest level of hospitality and to assist us with doing so, we share personal and other data with the following parties:

• Owners: We disclose data, including personal data, and other information to owners of Lake Buena Vista Commons properties for the purposes described in this Privacy Policy.
• Strategic Business Partners: We disclose data, including personal data, and other information with select strategic business partners who provide goods, services, and offers that enhance your experience at our properties.
• Service Providers: We disclose data, including personal data, and other information to third-party service providers for the purposes described in this Privacy Policy.
• Corporate Reorganization/Business Transfers: We may disclose or transfer your personal data and other information to a third party in the event of any reorganization, merger, sale of our assets, financing, joint venture, assignment, transfer, or other disposition of all or any portion of the Lake Buena Vista Commons business, assets, or stock.
• Sweepstakes, Contests, and Promotions: We may work with third parties that sponsor or offer sweepstakes, contests, and other promotions.
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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, resolve disputes, and enforce our legal agreements and policies.

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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.

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CONSENT TO TRANSFER

Lake Buena Vista Commons is operated in the United States. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using our website or the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States.

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INFORMATION SECURITY

The security of your data is important to us, and Lake Buena Vista Commons 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.

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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, we will delete it in accordance with applicable law.

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CALIFORNIA PRIVACY

California residents have additional rights regarding our use of your personal data and are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year.

California residents under the age of 18 who are registered users of online sites, services, or applications also have the right under California law to request and obtain removal of content or information they have publicly posted. If you are a California resident and wish to request removal of such data, please contact us using the contact information provided below.

For additional details on your California Privacy rights, see our California Privacy notice.

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VIRGINIA PRIVACY

Under the Virginia Consumer Data Protection Act (CDPA), you have the following rights with respect to your personal data:

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling

We have not sold any personal data to third parties for business or commercial purposes. We will not sell personal data in the future belonging to website visitors, users, and other consumers.

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YOUR RIGHTS RELATED TO THE FOLLOWING STATES: COLORADO, CONNECTICUT, NEVADA, TEXAS, MONTANA, OREGON

The state-level legislation grants you specific rights in and to your personal information, including:

• Right of Access to Collected Information and Data Portability
• Right of Access to Information Sold or Disclosed for a Business Purpose
• Right to Request Deletion
• Right to Opt-Out of the Sale of Your Personal Information
• Right of Non-Discrimination

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EMAIL MARKETING

We may use the email address that you provide to us in order to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt-out of receiving any or all of these communications by following the unsubscribe link or instructions provided in any email we send or by contacting us directly.

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BEHAVIORAL REMARKETING

We use remarketing services to advertise on third party websites to you after you have visited one of our websites. In the course of doing so, we use cookies and non-cookie technologies to inform, optimize, and serve ads based on your past visits to our Service.

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CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

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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 or through other means. You are encouraged to review this Privacy Policy periodically for any changes.

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CONTACT US

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

By email: [email to be provided by client]

By mail: Lake Buena Vista Commons 8040 Palm Parkway Orlando, FL 32836

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EUROPEAN UNION PRIVACY

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

We may process your personal data pursuant to one of the following conditions: Consent, Performance of a contract, Legal obligations, Vital interests, or Legitimate interests.

You have the right under this Privacy Policy, and by law if you are within the EU, to request access to, correction of, objection to processing of, erasure of, and transfer of your personal data, as well as the right to withdraw your consent.

To exercise your GDPR rights, please contact us at [email to be provided by client].

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CALIFORNIA PRIVACY NOTICE

This California Privacy Notice supplements the Lake Buena Vista Commons Privacy Policy and applies specifically to visitors and users who are California residents. This Notice details Lake Buena Vista Commons' compliance with, and the rights of consumers under, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CPRA).

To exercise your California privacy rights, you can submit a verifiable request by:

Email: [email to be provided by client]

Mail: Lake Buena Vista Commons 8040 Palm Parkway Orlando, FL 32836

Lake Buena Vista Commons uses commercially reasonable efforts to respond to any verifiable consumer request within 45 days of our receipt of such request.

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