PRIVACY POLICY

Updated January 9, 2025

This Privacy Policy for CTH Ivins LLC, a Delaware limited liability company, which manages the Black Desert Resort in Ivins, Utah (“we,” “us,” or “our”), describes how and why we might access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”) including when you (1) visit our website at https://www.blackdesertresort.com/, (2) any website of ours that links to this Privacy Policy, (3) use our services, and (4) engage with us in other ways, such as through sales, management services, marketing, or participating in events.

Reading this Privacy Policy will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at reservations@bdresort.com or by postal mail at Black Desert Resort, Attn: Privacy Request, 1500 E Black Desert Drive, Irvins, UT84738].

INFORMATION WE COLLECT

Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities involving the Services, or otherwise when you contact or transact business with us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and services you use. The personal information we collect may include the following:
• names
• phone numbers
• email addresses
• mailing addresses
• contact preferences

Sensitive Information. We may process sensitive information that you provide to us, such as Social security or passport number, driver’s license or state ID information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you our Services, and other technical information. This information is primarily needed to maintain the security and operation of our operation of our Services, and for our internal analytics and reporting purposes.

HOW WE PROCESS YOUR INFORMATIONWe process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send business information to you. We may process your information to send you details about our products, services and opportunities and those of our affiliates, changes to our terms and policies, and other similar information.

To fulfill and manage contractual commitments. We may process your information can fulfill and manage contractual commitments, such as work orders, payments, and transactions, made through the Services.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

LEGAL BASIS WE RELY ON TO PROCESS YOUR INFORMATION
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., a legal basis) to do so under applicable law, such as with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

SHARING YOUR PERSONAL INFORMATION
We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company, and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us. Affiliates also includes third parties involved in any of the foregoing transactions, but only if they have agreed to honor and comply with the obligations contained in this Privacy Policy.

Third Parties. We may share your personal information with third parties who provide services to us or to you in connection with your business relationship with us, such as audio/visual service providers, engineering, security and maintenance services providers, and entertainment and event services providers.

Google Analytics
We may share your information with Google Analytics to track and generalized of the Services. To opt out of being tracked by Google Analytics across the Services, please visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page at https://policies.google.com/privacy.

DURATION WE KEEP YOUR INFORMATION
We will only keep your personal information for as long as you have a business relationship with us and when it is necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, regulatory compliance, or other legal requirements). [If you have been a guest at [Location Name], for the purposes of providing you with information about our products, services and opportunities, we consider our business relationship with you to continue indefinitely after your stay. You can end that business relationship at any time by submitting a deletion request via postal mail at Black Desert Resort, Attn: Privacy Request, 1500E Black Desert Dr., Irvins, UT 84738.

If we otherwise have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is reasonably possible.

PROTECTION OF YOUR INFORMATION
We have implemented technical and organizational security measures that we believe have been reasonably designed to protect the security of the personal information that we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will try to protect your personal information, transmission of personal information to and from us is at your own risk. You should only access the Services within a secure environment.

COLLECTION OF INFORMATION FROM MINORS
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependents’ use of the Services. If we learn that personal information from users under the age of 18 years has been collected, we will deactivate any account that was created with us, and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at reservations@bdresort.com for Property-Level Privacy Officer.

YOUR PRIVACY RIGHTS
In some jurisdictions you have certain rights under applicable data protection laws. These may include the right (1) to request access and obtain a copy of your personal information, (2) to request rectification, correction or erasure (which may include de-identification), (3) to restrict the processing of your personal information, (4) if applicable, provide data portability, and (5) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in this section titled “How You Can Contact Us About this Policy” below.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent.
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section titled “How You Can Contact Us About this Policy” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

DO NOT TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a “do not track (“DNT”) feature or 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. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at time.

UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect


We may also collect other personal information outside of these categories through instances where you interact with us in person, online, by phone, mail, or email in the context of (1) receiving help through our customer support channels, (2) participation in customer surveys or contests, and (3) facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information
The sources of personal information that we collect are described in the section titled “Information We Collect".

How We Use and Share Personal Information
How we use your personal information is described in the section titled “How We Process Your Information".

Sharing Your Information
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. How we disclose personal information is described in the section titled “Sharing Your Personal Information”.

We may use your personal information for our own business purposes, such as completing business transactions with you and third parties, for undertaking internal research, and for development and marketing of new offerings and services. Such uses are not considered to be “selling” or "sharing” of your personal information.

We have not sold or shared any personal information to third parties fora business or commercial purpose unrelated to a business transaction with you in the preceding 12 months. We may have disclosed personal information to third parties for a business or commercial purpose that is specifically related to a business transaction with you in the preceding 12 months, such as to make and complete a reservation, to use systems, computers, equipment or facilities in a guest room or elsewhere at Black Desert Resort, or to complete a sale of merchandise, food, beverages or services at Black Desert Resort. We will not sell or share personal information in the future belonging to website visitors, users, or other consumers.

Your Rights
You have rights under certain U.S. state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• The right to know whether or not we are processing your personal data.
• The right to access your personal data.
• The right to correct inaccuracies in your personal data.
• The right to request the deletion of your personal data.
• The right to obtain a copy of the personal data you have previously shared with us, if it is still accessible.
• The right to nondiscrimination for exercising your rights.
• The right to opt out of the processing of your personal data if it is used for targeted advertising (or “sharing” as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

Depending upon the state where you live, you may also have the following rights:
• The right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law).
• The right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law).
• The right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law).
• The right to review, understand, question and correct how personal data has been profiled (as permitted by applicable law including Minnesota’s privacy law).
• The right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law).
• The right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law including Florida’s privacy law).

How to exercise your rights
To exercise these rights, you can contact us by submitting your request by postal mail at Black Desert Resort Name, Attn: Privacy Request, 1500 E Black Desert Dr. Irvins, UT 84738. Under certain U.S. state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification
Upon receiving a request, we will need to verify your identity to determine if you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission statement from you to submit this request on your behalf.

Appeals
Under certain US state data protection laws, if we declined to take action regarding your request, you may appeal our decision by emailing us at reservations@bdresort.com for Property-Level Privacy Officer or contacting us by postal mail at Black Desert Resort, Attn: Privacy Request, 1500 E Black Desert Dr. Irvins, UT 84738. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If the appeal is denied, you may submit a complaint to the applicable state officials (e.g., the state attorney general) in accordance with your state’s laws.

California “Shine The Light” Law
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) we have disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section titled “How You Can Contact Us About this Policy”.

UPDATES TO THIS POLICY
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

HOW YOU CAN CONTACT US ABOUT THIS POLICY
If you have questions or comments about the sentence, you may email us at reservations@bdresort.com for Property-Level Privacy Officer or contact us by postal mail at Black Desert Resort, Attn: Privacy Request, 1500 E Black Desert Dr. Irvins, UT 84738.

HOW YOU CAN REVIEW, UPDATE, OR DELETE DATA THAT WE COLLECT FROM YOU
Based on the applicable laws of your state of residence in the U.S., you may have the right to request access to the personal information that we collect from you, details about how we have processed it, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. Request to review, update, or delete your personal information, please visit the website at reservations@bdresort.com for Property-Level Privacy Officer or contact us by postal mail at Black Desert Resort, Attn: Privacy Request, 1500 E Black Desert Dr. Irvins, UT 84738.