Downstream Casino Resort Privacy Policy

LAST UPDATED: December 11, 2023.

Downstream Casino Resort, and its subsidiaries and affiliates (“referred to as “Downstream Casino” or “we”, “us” or “our”) know that privacy matters. We use information about you to improve and personalize the services we offer you to make your experience with us as rewarding as possible.

This Privacy Policy describes our practices and policies for collecting, using and sharing information collected online via websites operated by us, software applications made available by us, mobile betting applications, kiosks, retail services, social media pages that we control, and email messages that we send to you, as well as information collected in connection with our gaming and hotel systems, vacation booking services, loyalty programs such as the Q Club and your use of any other services, features, functionalities, applications, browser extensions, and other services provided by us (collectively, the "Services"). This Privacy Policy also governs the use of information we obtain about you from any third-party site or application where we post content or invite your feedback or participation. By visiting, accessing, or using, or providing information to us in connection with, the Services, you expressly consent to our collection, storage, use and sharing of your information as described in this Privacy Policy.
 

WHAT INFORMATION WE COLLECT

1. We collect and use information we believe is necessary to administer and promote our business, provide you with the products and services you request, and to provide a safe and healthy environment to our employees and other customers. We may collect and maintain both personal information and non-personal information needed for these purposes.

“Personal information” refers to any information by which you can be personally identified, such as your first name, last name, address, phone number, email address, credit card number, social security number, driver license number, passport number, license plate number, geolocation information, Q Club number, date of birth, purchase information, gaming activity information, biometric information and other similar information.

“Non-personal information” refers to information by which you cannot be personally identified. Your personal information and/or non-personal information will be referred as your “information” in this Privacy Policy. The information we collect may include:

• Name, contact information, and social media information. Name and contact information including: postal address (including billing and shipping addresses); email address; telephone number; social media account ID; and account numbers associated with our Services.
• Government issued IDs. Identifiers, such as name and government-issued identifier (e.g., Social Security number or driver’s license number).
• Pictures and recordings of you. Profile pictures; audio, electronic, visual, and similar information, such as call and video recordings.
• Financial information. Financial information including credit and debit card numbers, and commercial information, such as transaction information and purchase history.
• Sensitive personal information. Characteristics of protected classifications under California or federal law, such as age, gender, medical conditions, and marital status.
• Biometric data. Biometric information, such as fingerprints or facial recognition images and data.
• Inferences about you. Inferences drawn from any of the information listed above to create a profile or summary about, for example, your preferences and characteristics.
• Location, Gaming, and Transaction Information. When you use our Services that require you to register for an account, we and our third-party service providers may collect information about your precise physical location, your gaming activity, and all transactions associated with your account.
• Device Information. When you use our Services, we and our third-party service providers may use beacons and geofencing/geolocation services (“Verification Technologies”) to collect and analyze information about you, your device, and your activity. Information collected through Verification Technologies may include the type of device; mobile carrier you are using; your device identifiers; your (mobile) telephone number; your precise geographic location; and your activities within the Services including the links you click; the pages or screens you view; your session time; the number of times you click a page/screen or use a feature of the Services; the date and time you click on a page or use a feature; and the amount of time you spend on a page or using a feature. Information collected through Verification Technologies is stored in log files.
• Internet activity and Traffic Data. Internet or network activity information by cookies and other technologies as described in Section 2., and other information collected through our websites as described in Section 2.
• Aggregated Information. Aggregated information does not personally identify you (for example, we may aggregate telephone numbers to calculate the percentage of our users who have a particular area code).

HOW WE COLLECT YOUR INFORMATION

1. Information You Directly Provide to Us. You may provide information directly to us under a wide range of circumstances, such as when you submit information to us through our websites or mobile applications, use any gaming or non-gaming services at one of our properties, are videotaped or photographed in connection with a security incident or for other surveillance purposes, visit one of our properties, when you contact customer service, sign up to receive email or text messages from us, sign up to access Wi-Fi at one of our properties, install or use one of the mobile applications, sign up for our rewards program, promotions or offers, log in as a Q Club member, book a reservation for at one of our properties, enter an online promotion, request information from us, scan your ID at check-in kiosk, apply for casino credit or provide feedback in a survey.

Information Collected Through Our Websites. --Traffic Data. We automatically track and collect general log information when you visit our websites, including your: (A) Internet Protocol (IP) address, (B) domain server, (C) operating system, and (D) type of Web browser as well as the pages you visit on our websites (collectively “Traffic Data“). Traffic Data does not personally identify you, however, if you choose to provide us with personal information, we may store some items of your personal information and use it with the Traffic Data to better personalize your experience on our websites. We use the Traffic Data to report aggregated website activity and to better understand the needs of our users so we can make informed decisions regarding the content and design of the our websites.

It enables us:

• to estimate our audience size and usage pattern;
• to learn what information is of most and least interest;
• to speed up your searches; and
• to learn of any possible website performance problems.

We, or our service providers, may also use Traffic Data to identify your physical location to confirm that you are in a jurisdiction where you can use our online gaming services. We may collect Traffic Data through various technologies including, but not limited to, cookies, IP addresses, and transparent GIFs (Graphics Interchange Format, a software technology also known as a pixel tag).

o  Data Collected Using Cookies and Other Technologies. We also automatically collect information from you using cookies and other technologies on our websites. Cookies are small text files offered to your computer by servers in order to keep track of your browser as you navigate our websites. Cookies may be stored on your hard drive in which case they remain on your hard drive until deleted, or in temporary memory in which case they are deleted when you shut down your browser or turn off your computer. We may use cookies and similar technologies to identify who you are and may use them when you visit our websites, click on our ads, or open our emails. Cookies also enable us to remember your user preferences for our websites. Cookies and other technologies may also be used for site maintenance and analysis, performing network communications, authenticating users, serving contextual advertisements, and protecting against fraud and theft. You can block or remove cookies using your Internet browser’s settings. If you block or remove cookies, your ability to perform certain transactions, use certain functionality, and access certain content on our websites may be affected. To find out more about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

o  Information Collected by Third Parties through Third Party Links and Content. Our websites and mobile applications may include links to other websites and other content from third party businesses. These third-party businesses may use cookies, web beacons or other similar technology to collect information about you. We do not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on our websites (see the Section below for additional information about Online Advertising).

o  Information Collected by Third Party Analytics Services. These analytics services may use cookies and other technologies to collect information about the content you view, what websites you visit immediately prior to and after visiting our websites, and your system information and geographic information.

o  Information You Share on Third Party Websites or through Social Media Services. Our websites may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services. We may also monitor sentiments regarding Downstream Casino Resort that you publicly post on social media services or customer review sites. We may reach out to you regarding these postings to address customer service issues and to otherwise help ensure that you have a positive customer experience.

o  Information You Post on Our Websites. If you post information on any public areas of our websites, that information may be collected and used by Downstream Casino Resort, other users of our websites, and the public generally. We strongly recommend that you do not post any information through our websites that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

o  Information Obtained from Other Sources, including from Service Providers, Third Party Services and Our Marketing Partners. We may obtain information about you from other sources, including service providers, third party services (such as data brokers or analytics firms), publicly available sources, government agencies or our marketing partners, and we may combine such information with information we have collected about you as described in this Privacy Policy. To the extent we combine such third party information with other personal information we have collected, we will treat the combined information as personal information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.

o  Information We Automatically Collect Through the Mobile Applications, including Location Information. If you install or use one of the mobile applications, we may collect and use information regarding your mobile device, including but not limited to technical information about your mobile device, system and application software, and peripherals, that is gathered periodically to facilitate any upgrades, product support and other services to you (if any) related to the mobile applications, and to provide services or technologies to you. In addition, if you install one of the mobile applications and allow your device to share location information with our mobile App, we may be able to automatically identify and collect the location of your mobile device, including GPS location, which is the real- time geographic location of your mobile device.

o  Information We Automatically Collect When You Use Our Wi-Fi Services. If you use Wi-Fi services that we make available at one of our properties, we might collect information about your use of our Wi-Fi services, including your IP address, Wi-Fi information (such as SSID), mobile carrier, the websites you visit, the type of device and browser you are using, your device identification number, bandwidth used and session time.

o  Information We Automatically Collect from Mobile Devices on Our Properties. If you have a mobile device, are located on at one of our properties and have your Wi-Fi or Bluetooth functionality enabled, we may collect information concerning your mobile device, including the type of device, device ID, and the precise physical location of your device within and around at one of our properties (including geolocation and beacon-based location), for analytics and non-marketing related purposes, such as enabling us to understand our customers’ preferences and use of our properties, including general traffic patterns. With your consent, we might also use your location information for marketing purposes, such as to provide you with real-time offers and personalized promotions. If you do not want information concerning your precise location to be collected on at one of our properties, you may adjust your mobile device location sharing settings and disable the Wi- Fi and Bluetooth functionality in your mobile device settings.

o  Other Information We Collect Relating to Your Gaming and Purchase History and Other Interactions with Us. When you use any of our gaming services or make a purchase at any of the at one of our properties, we may collect transactional information about these activities and store it with your customer account. We may use this information to determine your Q Club rewards eligibility and to make predictions about your preferences, and interests, future spending and gaming activity.

HOW WE USE YOUR INFORMATION

1. We use your Information for legitimate business purposes:

o Communications. To contact you in response to your inquiries, comments and suggestions; to notify you about promotions and special offers regarding products and services provided by us or our affiliates or other associated third parties; and to contact you otherwise when necessary.

o Purchases. To complete and fulfill your purchase, for example: processing your payments, confirming your reservation, communicating with you regarding a reservation or purchase, and providing you with related customer service.

o Mobile features. To help you engage with our mobile applications and our online services.

o Marketing. To enhance our marketing efforts and to send you marketing communications that we believe may be of interest to you. o Personalized experiences. To personalize your experience by presenting products and offers tailored to you, as well as personalizing, advertising, and marketing our products and services.

o Contests. To allow you to participate in sweepstakes, contests, and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use or disclose your personal information. We suggest you read these additional rules carefully.

o Other business purposes. To provide our products and services and to otherwise accomplish our legitimate business purposes. These purposes included, for example, developing, improving, and maintaining our properties, products, and services and otherwise operating and expanding our business. In addition: conducting audits and internal investigations, research, analytics, and data analysis, accounting, maintaining our facilities and infrastructure, undertaking quality and safety assurance measures, determining the effectiveness of our promotional campaigns, performing identity verification, and maintaining records.

o Legal compliance & fraud prevention. As we believe to be necessary or appropriate: (a) to comply with laws or with legal process served on us as well as with our internal policies; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; and (d) for fraud monitoring, detection, and prevention and otherwise to protect and defend the rights, privacy, property, safety, or operations of us, you, or our affiliates (including through surveillance).

HOW YOUR INFORMATION MAY BE SHARED

1. Your Information may be shared with: o Affiliates. With our affiliates for the purposes described in this Privacy Policy.

o Service providers. With our third-party service providers who provide services, such as: website hosting, data analysis, payment processing, order fulfillment, show and event ticketing, reservation management, credit and other bank account authorization, information technology, customer service, email delivery, auditing, and other services. o Third-party marketers. With third parties to permit them to send you marketing communications, consistent with your choices.

o Promotion sponsors. With third-party sponsors of sweepstakes, contests, and similar promotions. o Social media account providers. With your friends associated with your social media account, with other website users and with your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to a Service account or log into your account on the Service through your social media account. By connecting your account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy

.

o Aggregate Information. We may share your information with affiliated or non-affiliated third parties on an anonymous, aggregate basis. While this information will not identify you personally, in some instances these third parties may be able to combine this aggregate information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally.

o Third parties in connection with any reorganization, merger, sale, etc. With third parties in connection with any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

o Public, government, or public safety authorities or other legal-matter entities. As we believe to be necessary or appropriate: (a) to comply with laws or with legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; and (d) to protect and defend the rights, privacy, safety, property, or operations of us, you, our affiliates, or others.

HOW TO ACCESS AND CONTROL YOUR INFORMATION

1. If you have any questions about this Privacy Policy or how Downstream Casino Resort handles the information collected from and about you please contact us:
1. Email:info@downstreamcasino.com
2. Telephone: 918-919-6000
3. Mailing address: 69300 E Nee Rd, Quapaw, OK 74363
Please note that we may need to retain certain information to meet legal obligations, for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change (e.g., when you make a reservation or enter a promotion, you may not be able to change the information you provided until after the completion of such reservation or promotion).

ONLINE ADVERTISING; TRACKING

1. Online Advertising. Downstream Casino Resort and third parties may use the information collected through the our websites or mobile applications using cookies, web beacons, and other similar technologies to help manage online advertising programs. This information may enable advertising services to track the actions of users online over time and across different web sites or platforms to measure statistics relating to marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience. For information about how tracking works for online advertising purposes, and what happens when you elect a do- not-track option, visithttp://optout.aboutads.info. For more information about the Network Advertising Initiative opt-out process, you may visit the Network Advertising Initiative website, available at:http://optout.networkadvertising.org.

Do Not Track. Your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, at the present time we do not disable tracking technology that may be active on our websites in response to any “do not track” requests that we receive from your browser.

2. SECURITY We maintain physical, electronic and organizational safeguards that reasonably and appropriately protect against the loss, misuse and alteration of the information under our control. With regard to information that you transfer to us through one of our websites or mobile applications, please be aware that no data transmission over the Internet or a wireless network can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit on or through our websites or mobile applications and you do so at your own risk.

3. UNDERAGE PERSONS The Services are for use by persons who are of age, pursuant to applicable law and regulations. If you are underage, pursuant to applicable law and regulations, you may not access, attempt to access, or use the Services. We do not knowingly collect or allow the collection of personal information via the Services from persons underage, pursuant to applicable law and regulations. We do not knowingly collect or allow the collection of personal information via the Services from persons under the age of 13. If we learn that we have collected the personal information of someone underage, pursuant to applicable law and regulations, we will take the appropriate steps to protect this information. If you are a parent or guardian and discover that your child has submitted personal information, you may alert us at info@downstreamcasino.com

4. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION The Services are controlled and operated by us from the United States. Information may be stored and processed in any country where we have facilities or in which we engage service providers. By using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

5. ADDITIONAL INFORMATION REGARDING NEVADA We do not sell Covered Information as defined under Nevada law. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. If you are a Nevada resident and have any questions about this, please contact us:info@downstreamcasino.com

6. ADDITIONAL INFORMATION REGARDING CALIFORNIA The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with additional information regarding how we collect, use, and share your personal information.

Information We Collect. We have collected (or not collected, if stated below) the categories of personal information noted in the table below within the last twelve (12) months. Please note that because this list is comprehensive, it may refer to types of personal information that we collect and share about people other than yourself.

Category	Examples	Collected
Collected Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
Personal information categories listed in the California Customer Records statute (Cal.Civ. Code § 1798.80(e))	.A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	YES
Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
Geolocation data.	Physical location or movements.	YES
Sensory data.	udio, electronic, visual, thermal, olfactory, or similar information.	YES
Professional or employment-related information.	Current or past job history or performance evaluations.	YES
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g,34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We obtain the categories of personal information listed above from the following categories of sources:

o Directly from you. For example, you may give us your personal information by filling in forms or by corresponding with us by mail, phone, fax, email or in-person.

o Indirectly from you. For example, from observing your actions on our Website or mobile applications.

o Other parties or publicly available sources. For example, from publicly availably sources, from third parties that interact with us in connection with the services we perform or products we provide, and from our affiliates. Use of Personal Information. We may use or disclose the personal information we collect for one or more of the following purposes:

o To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

o To provide, support, personalize, and develop our Website, products, and services.

o To create, maintain, customize, and secure any of your accounts with us.

o To process your requests, purchases, transactions, and payments and prevent transactional fraud.

o To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

o To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

 

>o To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business

o For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

o To respond to law enforcement requests and as otherwise required by applicable law, court order, or governmental regulations.

o To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.

Sharing Personal Information. We may disclose your personal information to a third party for a business purpose. We disclose your personal information for a business purpose to the following categories of third parties:

o Service providers.
o Our affiliates.
o Governmental authorities and parties to judicial and administrative proceedings.
o Purchasers or acquirers of some or all of our assets.
o Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Disclosures of Personal Information for a Business Purpose. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category Collected Identifiers.	YES
Personal information categories listed in the California Customer Records statute (Cal.Civ. Code § 1798.80(e)).	YES
Protected classification characteristics under California or federal law.	YES
Commercial information.	YES
Biometric information.	NO
Internet or other similar network activity.	YES
Geolocation data.	YES
Sensory data.	YES
Professional or employment-related information.	YES
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g,34 C.F.R. Part 99)).	NO
Inferences drawn from other personal information.	YES
Sales of Personal Information.	In the preceding twelve (12) months, we have not sold personal information.

 

Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see How to Exercise Your Rights below), we will disclose to you, based on what you request:

o The categories of personal information we collected about you.
o The categories of sources for the personal information we collected about you.
o Our business or commercial purpose for collecting or selling that personal information.
o The categories of third parties with whom we share that personal information.
o The specific pieces of personal information we collected about you (also called a data portability request).
o If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (1) sales, identifying the personal information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained Deletion Request Rights.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer (see How to Exercise Your Rights below),, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. An exception may exist, and we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation. 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

How to Exercise Your Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

o Calling us at: (870)-686-9001.
o Emailing us at info@downstreamcasino.com
o Sending mail to: 69300 E Nee Rd, Quapaw, OK 74363

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
o Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

o Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination. We do not discriminate against California residents who exercise any of their rights described in this Addendum.

7. UPDATES TO THIS PRIVACY POLICY We may update this Privacy Policy. The “Last Updated” date at the top of this page indicates when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when the updated Privacy Policy is posted.

References to mobile applications in this policy include the Q Club mobile app.