APPLICANT PRIVACY POLICY Updated: March 4, 2019 Thank you for your interest in a position with PGA TOUR Golf Course Properties, Inc. or one of its affiliate entities (“GCP” and sometimes referred to herein as “we”, “our”, or “us”). This privacy policy is applicable to the information you share with us through your application, which may be located on a site hosted by one of our third-party vendors, or any website which posts a link to this privacy policy (collectively, the “Site(s)”). Your privacy is important to us. To better protect your privacy, we provide this policy explaining our online information practices and the choices you can make about the way your information is collected and used. This policy explains: What information we collect during our application and recruitment process; How we use that information; Who we may share that information with; and How to access and update that information. THE INFORMATION WE COLLECT. (a) Your Personal Information. At the Sites, you may be able to register a profile and share information with us in connection with the application and recruitment process. Examples of the types of personally identifiable information that may be collected include: Your name, address, email address, telephone number and other contact information; Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, veteran status, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process; Information from interviews and phone-screenings you may have, if any; Details of the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences; Details of how you heard about the position you are applying for; Any sensitive and/or demographic information obtained during the application or recruitment process such as gender, information about your citizenship and/or nationality, disability status, medical or health information and/or your racial or ethnic origin; Information received from background checks (where applicable), including information provided by third parties; Information relating to any previous applications you may have made to GCP and/or any previous employment history with GCP; Information about your educational and professional background from publicly available sources, including online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn profile); and/or Information related to any assessment you may take as part of the interview screening process. Registering a profile and/or applying for a position is completely voluntary. Therefore, you have a choice whether or not to disclose this information. If you choose to apply, you hereby give consent for the collection of personal data as described herein. However, if you do not provide the information, we may not be able to process your application properly or at all. When you visit any of the Sites, we, and our service providers may collect various types of information about your device and your internet activity. A representative list of this type of information that we may collect include: IP address and type of browser you are using (e.g., Firefox, Internet Explorer) Type of operating system you are using, (e.g., Microsoft Windows or Mac OS) Internet service provider (e.g., Comcast, Verizon or AT&T) Web pages/Sites you have visited Type of mobile device used to view the Site & device identifier location information Site content you have accessed We store this data in log files that do not identify individual users. We use this information, to analyze trends, to administer the site, to track users’ movements around the Sites and to gather demographic information about our user base as a whole. (b) Others’ Personal Information. During the application and recruitment process, you may also be able to submit information about other people. For example, you might submit a person’s contact information as a reference or former employer. Examples of the types of personally identifiable information that may be collected about other people include: referrer’s name, address, e-mail address, and telephone number. It is your responsibility to obtain consent from references before providing their personally identifiable information to GCP. HOW WE USE THE INFORMATION. (a) Use of Your Information. Your information will be used by GCP for the purposes of carrying out its application and recruitment process which includes: Assessing your skills, qualifications and interests against our career opportunities; Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job; Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at the GCP such as promotions and transfer decisions; Creating and/or submitting reports as required under any local laws and/or regulations, where applicable; Where requested by you, assisting you with obtaining an immigration visa or work permit where required and providing verification of employment; Making improvements to GCP’s application and/or recruitment process including improving diversity in recruitment practices; and/or Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us. We will also use your information to protect the rights and property of GCP, our applicants, employees, membership, volunteers, customers, fans or the public as required or permitted by law. If you are offered and accept employment with GCP, the information collected during the application and recruitment process will become part of your employment record. (b) Use of Information about Others. We may use the information that you provide about others to contact them as references and learn more information about you, and for such other purposes as may be stated at the point where the information is collected. Any such individual may contact us if they no longer want us to use his or her information. (c) Automated Decision-Making. Recruitment processes at GCP are not based solely on automated decision-making. (d) Basis for Processing. We collect and process your information where it is necessary in order to take steps, at your request, prior to our potentially entering into a contract of employment with you. We may also seek your consent to process your personal information in specific circumstances or process it where necessary to comply with a legal obligation or for purposes connected to legal claims. If we use your information to improve our application or recruitment process, we do so on the basis that it is in our legitimate interests to ensure we recruit the best possible candidates. INFORMATION SHARING AND DISCLOSURE. (a) Legal Process. We may disclose personally identifiable information when legally obligated, such as in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request, or when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, to verify or enforce compliance with the policies governing our sites and applicable laws, or as otherwise required or permitted by law or consistent with legal requirements (b) Interested Affiliates and Connected Employees. Your information may be shared with PGA TOUR Golf Course Properties, Inc. affiliates, subsidiaries or joint ventures in the US and in other jurisdictions, in relation to the purposes described above. If you have been referred for a job at the GCP by a current GCP employee, with your consent, we may inform that employee about the progress of your application and let the GCP employee know the outcome of the process. In some cases, if it is identified that you have attended the same university/school or shared the same previous employer during the same period as a current GCP employee we may consult with that employee for feedback on you. (c) Business Transfer. We may transfer personally identifiable information about you if we, or one of our business units, are acquired by, sold to, merged with or otherwise transferred to another entity (d) Services Providers. We may also disclose your personally identifiable information to our affiliates, agents and contractors who are involved in assisting us with any of the activities identified in this privacy policy (e.g., verification / background checks), but we will require them to protect this information in a manner that is consistent with this privacy policy, and they are not authorized to use the information for any purpose other than to carry out the services they are performing for us. These service providers may be located outside the country in which you live or the country where the position you have applied for is located. (d) Certain Third Parties. We will also share your personally identifiable information with certain third parties if we have your consent (e.g., you gave us permission to contact your references) or to detect, prevent or otherwise address fraud, security or technical issues, or to protect against harm to the rights, property or safety of GCP, our applicants, employees, membership, volunteers, customers, fans or the public as required or permitted by law. COOKIES & DATA ANALYTICS. (a) Cookies and Their Function. To enhance the application experience, we use “cookies” or similar technologies. Cookies are text files placed in your computer’s browser to store your preferences. Cookies do not contain personally identifiable information; however, once you choose to furnish a site with personally identifiable information, this information may be linked to the data stored in the cookie. We use cookies to understand Site and Internet usage and to improve or customize the Site experiences. For example, we may use cookies to personalize your experience at our Sites (e.g., to recognize you by name when you return to a Site), save your password in password-protected areas, and enable you to use shopping carts on our sites. (b) Data Analytics. We also use the services of reputable third parties to provide us with data collection, reporting, and site analytics. These third parties may view, edit or set their own cookies. We and our third-party service providers may also place web beacons for these third parties. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this privacy policy. (c) Privacy Preferences. You can change your privacy preferences regarding the use of cookies and similar technologies through your browser. You may set your browser to accept all cookies, block certain cookies, require your consent before a cookie is placed in your browser, or block all cookies. Blocking all cookies will affect your online experience and may prevent you from enjoying the full features offered on the Sites. Please consult the “Help” section of your browser for more information. INTERNATIONAL TRANSFER. GCP operates globally, which means your information may be stored and processed outside of the country or region where it was originally collected including in the United States. In some of these countries, you may have fewer rights in respect of your information than you do in your country of residence. Please be assured that we take reasonable steps to ensure that your privacy is protected. By using the Sites, you consent to your information being collected, used, transferred and stored as set forth in this privacy policy. OUR COMMITMENT TO SECURITY. The security of your personal information is important to us. We have put in place reasonable physical, technical, and managerial procedures to safeguard and help prevent unauthorized access, to maintain data security, and to use correctly the information that is collected, processed, and stored as part of the application and recruitment process. In addition, we exercise special precautions in dealing with applicant personal data defined as sensitive by law. For example, when satisfactory completion of a medical examination is a condition for being hired, no medical information, apart from overall suitability or unsuitability for employment, is provided to hiring managers or stored in a new employee’s personnel file. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Sites, you can contact us at contacttpcnetwork@pgatourhq.com RETENTION & DELETION OF YOUR INFORMATION. If you apply for a job at GCP and your application is unsuccessful (or you withdraw from the process or decline our offer), GCP will retain your information for a period after your application. We retain this information for various reasons, including in case we face a legal challenge in respect of a recruitment decision, to consider you for other current or future jobs at GCP and to help us better understand, analyze and improve our recruitment processes. If you do not want us to retain your information for consideration for other roles, or want us to update it, please contact contacttpcnetwork@pgatourhq.com. Please note, however, that we may retain some information if required by law or as necessary to protect ourselves from legal claims. HOW YOU CAN ACCESS OR CORRECT INFORMATION. Access to personally identifiable information that is collected on the Sites and that we maintain may be available to you. For example, if you created a password-protected account within our Site, you can access that account to review the information you provided. You may also send an e-mail or letter to the following e-mail or street address requesting access to, deletion of, correction of or transfer of your personally identifiable information. For verification purposes please include your first name, last name, and e-mail address you use for such service. We will endeavor to respond to your request to access within 30 days. The PGA TOUR Golf Course Properties, Inc –13000 Sawgrass Village Circle Ponte Vedra Beach, FL 32082 email: contacttpcnetwork@pgatourhq.com HOW TO CONTACT US. If you have any questions or concerns about the online privacy policy for this Site or its implementation you may contact us at contacttpcnetwork@pgatourhq.com UPDATES & EFFECTIVE DATE. From time to time, we may update this privacy policy. We will notify you about material changes in the way we treat personally identifiable information by placing a notice on our site prior to making changes. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and to whom we disclose it. YOUR CHOICE REGARDING COOKIES ON THIS SITE This website uses cookies to optimize site functionality and give you the best possible experience. Learn More ALLOW COOKIESDECLINE