# Privacy Policy

Last updated: November 21, 2025

This privacy policy ("Privacy Policy") covers the treatment of personally identifiable information ("PII") collected by or submitted to Exclusive Resorts, LLC and its affiliates, including Exclusive Resorts Club Management, LLC, FDL Event Management, LLC, Three Leaf Villas, LLC and Gateway Luxury, LLC (collectively, the "ER Group"). PII is defined herein. We understand and respect your desire for privacy and will make reasonable efforts to use PII in accordance with this Privacy Policy. This Privacy Policy is subject to change.

This Privacy Policy governs our use of information obtained from our customers and prospective customers, including information obtained through our Websites, including exclusiveresorts.com, by telephone, mail, applications, social media webpages, and other websites owned or controlled by the ER Group.

## CONTACT INFORMATION

You may contact us at the following:

Exclusive Resorts Club Management, LLC  
1601 19th Street  
Suite 500  
Denver, CO 80202  
800-447-8988  
[privacy@exclusiveresorts.com](mailto:privacy@exclusiveresorts.com)

## INFORMATION COLLECTION

We collect PII that you provide to us, including:  
- Your name, gender identity, home and work contact details, date of birth, and nationality;  
- Personal interests relating to travel, dining, and activity preferences;  
- Your occupation and background information;  
- Financial information, such as credit card numbers;  
- Online user account details, including profile or password;  
- Content of chat messages between a member and an ER Group representative, provided you have consented;  
- Any other information specific to you.

### Information Collected through Third Parties

We may collect PII through direct interaction, Licensees, third parties, and from Data Sources. This may include information from our airline, credit card, and social media partners.

### Cookies and IP Addresses

ER Group may use cookies to collect information about website usage to improve our services. Cookies are text files stored on a user's computer that contain information.

### Log Files

We use log files to track the IP addresses, browser type, ISP, referring/exit pages, platform type, date/time stamp, and number of clicks.

### Clear GIFs (Web Beacons/Web Bugs)

We use clear GIFs to manage content and track the online movements of users.

### Do Not Track Signals

We currently do not recognize DNT signals. You can set your browser to reject cookies and/or DNT signals, but this may limit your access to certain features.

## USE OF PII

We use PII to provide services, maintain membership accounts, conduct customer satisfaction research, comply with legal obligations, and provide marketing communications. We may aggregate your PII with third-party sources.

## SHARING OF INFORMATION

We may share PII within the ER Group, with service providers, in response to legal requests, or during business transactions such as mergers. We will not share PII with third-party entities not discussed unless disclosed to you.

## INTERNATIONAL TRANSFER OF INFORMATION

By submitting information through this website, you consent to the transfer of your PII to the U.S. where it will be subject to U.S. law.

## DATA INTEGRITY

We take measures to ensure that your PII is accurate and used for its intended purposes.

## CALIFORNIA RESIDENTS

California residents have the right to request a list of third parties with whom we share PII for direct marketing purposes. If you would like to request this information, send an email to [privacy@exclusiveresorts.com](mailto:privacy@exclusiveresorts.com).

## MODIFYING OR DELETING PII

You have the opportunity to review or correct your PII. To do so, please contact us via email at [dporequest@exclusiveresorts.com](mailto:dporequest@exclusiveresorts.com).

## NOTIFICATION OF CHANGES

We may revise this Privacy Policy at any time, and will revise the "last updated" date. Please check periodically for the most current version.

## MINORS

Our Websites are not directed toward individuals under twenty-three years old nor do we knowingly collect information from Minors.

## ADDITIONAL CONTACT INFORMATION

For any questions or comments, please contact us using the information provided above.
