St. Regis Residences

The Residences at The St. Regis Los Cabos are not owned, developed or sold by Marriott International, Inc. or its affiliates (“Marriott”). Impulsora del Golfo de Cortez SA de CV (“IGC”) uses the St. Regis marks under a license from Marriott, which has not confirmed the accuracy of any of the statements or representations made herein.

WHAT INFORMATION IS COLLECTED FROM ME?

Information You Give Us: Information collected from you will vary, depending on how you access, visit, use or otherwise take advantage of the website and what information you may choose to provide to us. It may be possible to browse various sections of the “Sites” without submitting any Personal Information. “Personal Information” means individually identifiable information about you that we collect online or otherwise through the Sites, including, but not limited to, your full name, email address, phone number, and physical address. Information in a form that is aggregated with other information, anonymized or otherwise processed so as not to be reasonably identifiable with you, and information in a form that otherwise is detached, combined, organized, segmented, modified or processed so as not to be reasonably capable of being associated with you, will not be considered Personal Information, and will not be restricted by this Privacy Policy as to use, sharing or otherwise. If you access, visit, use or otherwise take advantage of certain of our products and/or services, or certain of our tools, Sites or Site functionality, we may receive or you may be asked to provide Personal Information. Whenever we ask for Personal Information, we strive to provide a link to this Privacy Policy to help you understand how Personal Information will be used before you decide whether to disclose it. You can choose not to provide us with Personal Information, but then you may not be able to fully take advantage of certain offerings our website features and we may not be able to provide you with certain requested information, products and/or services.

Automatic Collection of Information: Like many websites or media on or using the Internet, we automatically track certain information about you as you access, visit, use or otherwise take advantage of our website; this is for various reasons, including to help us (1) better understand, offer, operate, improve and modify the Sites; (2) better understand how the Sites are used and experienced; and (3) enhance, or better understand how we can enhance, your or others’ overall experience on our website, including providing advertising and other information that is relevant to you. This tracked or automatically gathered information may include, among other things, your computer’s (as used in this Privacy Policy, meaning a computer, tablet, smartphone or other relevant device) IP address (Internet Protocol address), identification number or location, the URLs and Site pages you’ve visited, sections of or content on Site pages on which you click or in which you are interested, the number of times you visit each Site page, what downloads and/or search queries you have made, when emails are opened or links are clicked, how long you spent on particular sections of each Site and on each Site generally, and information about your computer, browser or operating system type. This automatically gathered data includes information provided through the use of “cookies” (which is described in more detail below) and other technology or methods and may also include information gathered in connection with your use of third-party websites and media (for example, through the use of “web beacons,” “clear GIFs” or “tracking pixels”). Although not restricted by this Privacy Policy, we may also gather and use information, generated ourselves or obtained from others, derived from or based on information you have provided or that is obtained by way of the collection means referred to in this Privacy Policy (e.g., automatically).

Information from Cookies: Cookies are small files that we or others send to and store on or with your computer so that your computer, browser, mobile app or other application can be recognized as unique the next time you access, visit, use or otherwise take advantage of the websites or other media. Cookies may also reflect demographic data pertaining to you or other data linked to information you submit. One use or consequence of cookies is to enable you to receive customized ads, alerts, content, services or information. You are always free to decline any cookies we use by adjusting the settings of your browser, as your browser may permit; however, some products, services or features might not be available or operate properly if cookies are not enabled. Some of our advertisers and third-party service providers may also utilize their own cookies. In addition, we, our service providers and others sometimes use “web beacons” or “clear GIFs.” These perform statistical and administrative functions, such as ascertaining and measuring site and page traffic, verifying advertising paths, better understanding user interests and activity, gathering related information (such as information relating to a particular browser, device or IP address) and positioning images, and typically do so without detracting from your online experience. Web beacons and clear GIFs are not necessarily designed to collect Personal Information. In addition, if you have provided your email address, we might use a nonhuman unreadable form (or “hash”) of your email address to deliver, or facilitate delivery of, relevant advertisements and information to you on or by way of the Sites or on or by way of other websites or media, including, for example, popular social media sites and features.

INFORMATION SHARING DISCLOSURE—HOW IS INFORMATION ABOUT ME USED AND SHARED?

The use of information about you depends on the context in which it is collected. Therefore, pay special attention to the categories below that relate to the features of the Sites that you wish to utilize.

PERSONAL INFORMATION

We may share the Personal Information we collect from you with your consent or under the following circumstances or understandings.

User-Requested Services and Information: Certain features, products or services on or of our Sites may seek or obtain Personal Information from or about you, which may be used in the following ways:

For information, features, products and services provided by the Sites, the information you submit is used by us to provide the information, feature, product or service you’ve requested. We may also share this information with others to fulfill your request or to facilitate your use of the information, features, products or services, or as otherwise outlined in this Privacy Policy. When sharing Personal Information in such a manner, we may also share your computer’s Internet Protocol (IP) address, identification number or location. In addition, we may use and share any registration information that you submit as set forth in the “Registration Information” section below.

We may use other companies and individuals (1) to perform supporting functions for the various tools, functionality, information, products and services offered through our Sites on our behalf; (2) to perform or support various tasks or initiatives instrumental to the business of, or related to operating or improving, the Sites; or (3) to assist us in testing, maintaining or improving the features, content or effectiveness of the Sites or in performing research or development. These service providers may be permitted to receive from us and use information collected from you but will not be authorized by us to use Personal Information for any purpose other than in connection with performing the support functions for The Residences at The St. Regis Los Cabos at Quivira or such other tasks, initiatives or assistance for or expressly permitted by The Residences at The St. Regis Los Cabos at Quivira.

For information, features, products and services marketed or offered to you jointly or on a coordinated basis by us and a third party, Personal Information may be shared with or independently gathered by the third party. In these situations, we will be free to use Personal Information to facilitate such information, features, products and services (or information about them) being made available to you and as otherwise outlined in this Privacy Policy, and you understand the third party may use the information in different ways. Although not always the case, you often can tell when information, features, products or services are marketed or offered jointly or in coordination with a third party because a page or area of the Sites often will be “co-branded” in such cases, will display the third party’s logo and/or name (whether or not along with our own), will describe or reference the relationship between The Residences at The St. Regis Los Cabos at Quivira and the third party, or will be set up so that you can contact or be linked to the third party or its website to initiate, complete or learn more about the transaction. Please be aware that each company we do business with has its own policies regarding its use, sharing and protection of information about you and that such policies may differ from those outlined in this Privacy Policy.

User-Initiated Communication: From time to time, portions of the Sites may enable you to send email and other types of messages to us or to third parties and to participate in bulletin boards and discussion groups. All such emails and messages, and all such postings to bulletin boards and discussion groups, become our property once you submit them. Your computer’s Internet Protocol (IP) address may be included in any email that you send, whether to us or to third parties. Whenever you choose to initiate these kinds of communication with us, or anyone else, you may be contacted in return. Also, remember that our bulletin boards and discussion groups are open to the public, and therefore, your postings can be seen by anyone and are not protected by us or any other entity. Please use your own discretion when deciding whether and what to post and whom to contact. We reserve the right, in our sole discretion, to edit or delete postings from our bulletin boards and discussion groups. This reservation of rights shall not under any circumstances obligate us to conduct such edits or deletions, nor shall it cause us to be liable for any such edits or deletions.

Leads and Referrals. If you participate in or inquire about any lead, referral or similar service we may offer:

We may use the information you submit, as well as other data we might have or obtain ourselves or from other sources (for example, based on or related to such information), to determine which of our participating Professional(s) may be willing, able and/or compatible to serve your needs or possible interests and to assist them or others in doing so. We may forward or share information relating to you, which may include such information as well as Personal Information obtained through our sign-up form or otherwise, to certain Professional(s), which may sometimes include multiple Professionals (such as in cases where a given Professional has a marketing or business relationship with one or more other Professionals and designates them to receive such information, or in cases where the nature of a product, service or feature offered on or through a Site is designed to involve participation by multiple Professionals). Those Professionals or their affiliates, contractors, advertisers, agents or other designees may use such information and contact you regarding your needs or possible interests, as may we ourselves. The following paragraph applies only to Professionals; others may not infer any commitments or assurances from the following paragraph.

Protection of Rights: We will release Personal Information or other information we collect from you if we believe that such action is appropriate to: (1) comply with legal process; (2) enforce the Terms of Use agreement for the applicable Site; (3) identify, contact or bring legal action against persons or entities who are or we believe have caused or might cause injury to us or a third party; (4) defend or respond to claims brought or threatened against The Residences at The St. Regis Los Cabos at Quivira, its employees, directors, suppliers or service providers, Site users or others or (5) otherwise protect or assert the rights, property, interests or personal safety of The Residences at The St. Regis Los Cabos at Quivira, its employees, directors, suppliers or service providers, Site users or others. Any such release decisions may be made by us in our sole discretion.

Asset Transfers: We continue to develop our business and in doing so might choose to buy or sell, or expand or otherwise restructure (e.g., by way of joint ventures) with respect to businesses or assets. Personal Information and other information we collect from you is generally one of the assets acquired, transferred otherwise shared or affected in connection with such transactions.

Registration Information: The Personal Information you provide when you become a registered user or customer of one of the Sites is used primarily to help us customize or enhance your or others’ online experience, increase the convenience of accessing new or existing tools, products and services, and, if applicable, provide the information, features, products and/or services you purchase or request. This Personal Information may also be shared among the Sites to make use of the Sites more convenient by, for example, limiting the number of times you have to register with us. Your email address serves as a unique identifier in our record system, and together with your password is designed to help us prevent unauthorized access to information you choose to store on the Sites. The data you give us about your personal preferences and demographics (e.g., your age, ZIP code, occupation or the like), as well as other information we might have or obtain ourselves or from other sources (for example, based on or related to such data), may be used to help us offer content, advertisements, products and services that we believe will be of interest to you. In addition, we may share this information, in aggregate or other protected form (see “Information You Give Us,” above) or under confidentiality terms, with our current and potential advertisers and service providers so that they, or we, can present and deliver advertisements more effectively. If you forget your password for any registered area of the Sites, we have an automated password recovery system, which can be accessed by clicking on the “Forgot Password?” link on the sign-in page.

Consumers: Unless you specify that you would prefer not to hear from us, we may use the email address and other information (including Personal Information) you provide at the time of registration to contact you for promotional or other purposes. You may have promotional email communications terminated at any time by opting out by clicking on any “unsubscribe” link contained in a promotional email. Please be aware that opting out on one of our Sites does not opt you out from any of our other Sites unless that option is specifically provided. If you would like to request to opt out with respect to all of the Sites please email cescobosa@olarena.com with your request.

SPECIAL MESSAGING CONSENT

By submitting a request or inquiry about (or a request or inquiry for information about), or a request or authorization to be contacted about, real estate-, moving-, neighborhood-, mortgage-, credit-, care- or home-related products, services, offerings, procedures, details or matters, you are providing to The Residences at The St. Regis Los Cabos at Quivira-associated advertisers, lead customers (e.g., lead or referral service customers), subscribers and Professionals (each, a “Provider”), and to The Residences at The St. Regis Los Cabos at Quivira, your consent to be contacted for marketing, informational and related purposes in connection with such request, authorization or inquiry by one or more Providers and by The Residences at The St. Regis Los Cabos at Quivira by telephone device (including, but not limited to, being contacted on a recorded line and potentially by use of automated dialing systems and artificial or prerecorded voice messaging), email, mail or otherwise, based on the phone number, email address and/or other data you have provided. This consent applies even if your phone number, email address or other data is on a corporate, federal, state, local or other do-not-contact type of list or directory (such as the U.S. National Do Not Call Registry). You are not required to consent to receiving auto-dialer calls, or to otherwise provide this consent, as a condition of purchasing any products or services from Providers or The Residences at The St. Regis Los Cabos at Quivira you agree that your submitted request, authorization or inquiry (as described above) acts as your electronic signature for this consent. You acknowledge that for text, SMS, calls and other electronic messages, message and data rates (for example, from your network provider) may apply.

When sharing Personal Information in accordance with this Privacy Policy, we may also share your computer’s Internet Protocol (IP) address, identification number or location.

You (whether you are a consumer, a Professional, a Provider or otherwise) consent to The Residences at The St. Regis Los Cabos at Quivira (including any designee of The Residences at The St. Regis Los Cabos at Quivira) contacting you in any manner consistent with information (including Personal Information) you have provided or we otherwise have pertaining to you or consistent with other instructions, requests, inquiries or consents that have been given by you or on your behalf (whether by way of this Privacy Policy or otherwise). If for a particular contact we determine we need consent from you we currently do not have (or are not sure we have), The Residences at The St. Regis Los Cabos at Quivira (including any designee of The Residences at The St. Regis Los Cabos at Quivira) may contact you by any available communication means to seek such consent.

The Residences at The St. Regis Los Cabos at Quivira is not restricted as to information, including Personal Information, except as described in this Privacy Policy.

NON-PERSONAL INFORMATION

Automatically Gathered Information: Information that is automatically, electronically or otherwise gathered, including through the use of cookies and other technology, may be shared among the Sites. It may also be shared with other third parties, including listing providers, advertisers, service providers and others, so that we may better understand how the Sites are used, to enhance the overall experience on the Sites and otherwise in connection with our operation of the Sites and conducting related business. But when so shared with third parties, any Personal Information will be included for such purpose(s) only if first put in aggregated, de-identified or other protected form (see “Information You Give Us,” above) or the third party will be contractually or otherwise restricted as to the use of such Personal Information (for example, restricted to use only in connection with the purpose for which it was shared by The Residences at The St. Regis Los Cabos at Quivira).

Children’s Privacy: Our Sites are general audience websites and media. If you are under the age of 13 you should not register or provide information on our Sites. We do not collect Personal Information from any person we actually know is a child under the age of 13. If you have knowledge that a child under the age of 13 has submitted Personal Information to us, please email The Residences at The St. Regis Los Cabos at Quivira at cescobosa@olarena.com

The Residences at The St. Regis Los Cabos at Quivira is not restricted as to non-Personal Information except as described in this Privacy Policy.

HOW CAN I REQUEST TO REMOVE MY PERSONAL INFORMATION?

Consumers: If you would like us to no longer use or share with our affiliates, partners or other service providers Personal Information we may gather from you to market information to you, please send a request to The Residences at The St. Regis Los Cabos at Quivira at cescobosa@olarena.com

HOW IS PERSONAL INFORMATION PROTECTED?

Of course, we appreciate your help in safeguarding the integrity of your own and others’ privacy. We hope you’ll use common sense whenever you disclose Personal Information over the Internet. Just as important, we encourage you to let us know immediately if you suspect that Personal Information you share with us is being used in any way contrary to this Privacy Policy. Finally, unfortunately no data transmission over the Internet nor any storage of information on servers or other media can be guaranteed or made to be 100% secure; and while we strive to protect Personal Information, as outlined in this Privacy Policy, we cannot promise, guarantee or warrant the complete security of information. To contact us, please send an email to cescobosa@olarena.com

SCOPE OF THIS PRIVACY POLICY: OUTSIDE LINKS

Be aware that our Sites link to other websites and media that may collect Personal Information. This Privacy Policy applies only to the Sites, and we are not responsible for the privacy practices, nor the content, associated with any linked websites. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, security, use and disclosure policies.

INTEREST-BASED ADVERTISING

On our sites, apps and/or emails we and our third-party service providers may obtain information about your activities to provide you with advertising about products and services tailored to your individual interests. We and our third-party service providers also may obtain information for this purpose from third-party websites and apps. This section of our Privacy Policy provides details and explains how to exercise your choices.

We engage third-party advertising networks to help us target our messaging to visitors through interest-based and contextual means. Through these ad networks, we can track your online activities over time and across third-party websites and apps by obtaining information through automated means, as described above. This is sometimes called “interest-based” or “online behavioral” advertising. The networks use this information to show you advertisements on our Services or other third-party websites and apps that may be tailored to your individual interests. The information our ad networks may obtain on our behalf includes data about your visits to websites and use of apps that serve our advertisements, such as the pages or ads you view and the actions you take on those websites or apps. This data collection takes place both on our sites, apps and emails, and on third-party websites and apps that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, go to http://www.aboutads.info/choices or http://www.networkadvertising.org/choices/ in the U.S.

EFFECTIVE DATE AND MODIFICATIONS

This Privacy Policy is effective as of the 2020-10-15 (the “Recited Date”) and may be updated and modified from time to time by us in our sole discretion. If we choose to update or modify this Privacy Policy, such updated or modified policy shall become effective on the date that is five (5) days after its posting on the applicable Site(s) (the “Modification Effective Date”); this is true even if it were to happen that the Recited Date (as also modified) is a date earlier than the Modification Effective Date, in which case this Privacy Policy, as updated or modified, is effective as of the Modification Effective Date. We encourage you, therefore, to periodically review this Privacy Policy and the Sites in order to keep apprised of our current privacy practices. If you do not agree to any provision of this Privacy Policy, or any update or modification of it, please do not use the Sites.

Contacting Us

If you have concerns about this Privacy Policy or our privacy practices in general, contact us at cescobosa@olarena.com

DISCLAIMER

The St. Regis trademarks are owned by Marriott International, Inc. or its affiliate. The Residences at The St. Regis Los Cabos at Quivira are not owned, developed or sold by Marriott. CLK Estrategia SAPI del CV uses the St. Regis marks under license from Marriott, which has not confirmed the accuracy of any of the statements or representations made about this project. If the license is terminated or expires, The Residences will no longer be associated with the St. Regis brand and will cease all use of the St. Regis trademarks.