We take seriously the issue of safeguarding the privacy of information. We have created this Privacy Policy in order to better familiarize you with the information we collect or obtain, and the way in which we use this information to better operate our business and serve the needs of our guests.

What is Personal Information?

The term “Personal Information” refers to any information that can be used to identify you as an individual or is about you as an individual. It can include, among other things, your name, address, age, gender, personal financial history and social security number.

How is Personal Information Collected?

1. Reviewing Our Website

While in the process of browsing our website, you also provide us with information that does not reveal your personal identity—what type of destination you're seeking information about, for example. We use this aggregated, anonymous data mainly for editorial purposes, but we do not connect it to any Personal Information, such as your name or address.

While you explore our website for the information that interests you, you may wish to put in a specific “Information Request” about one of our properties, or you may wish to participate in one of our online surveys or promotions. To respond to this request or to participate in our various programs, we may ask you for Personal Information, such as your name, zip code, email address and phone number.

In the event you choose to provide us with this information, we will use it for the purpose solicited as well as to enhance our ability to provide services to you. We will only email you where and when it is appropriate, and you can choose a number of alternate methods by which to receive a reply to a request. Your use and navigation of our website shall constitute your acknowledgement to the terms and conditions of this Privacy Policy generally, and your transmittal or provision of Personal Information shall constitute your acknowledgment of and agreement to the terms and conditions contained in this Privacy Policy with regard to Personal Information. If you are uncomfortable providing this information over the Internet, you can always call our offices and representatives.

If you wish, you may also submit your email address in order to be placed on a subscription list or to receive other information. You will be placed on these lists only when you indicate your desire to be included. In deciding whether or not to join such lists, please note that they are only used for internal purposes; we do not sell or rent our lists to anyone. In the event you choose to join one of our lists, you may ask to be removed from the list at any time as it is our desire to allow each visitor to have the ability to accept or decline any form of communication from us.

2. When Making a Reservation From Our Website

If you decide that you would like to make a reservation at The Lodge at Sea Island or The Cloister at Sea Island, you will be linked to our reservation service site, hubx.com. Visitors who elect to make reservations online will be required to complete a reservation profile the first time they make a reservation. When you create a reservation profile you will be asked to provide specific Personal Information, including your name, address and contact information, as well as certain guarantee and deposit information to secure your reservation, such as your credit card number. Your transmittal or provision of Personal Information shall reaffirm or constitute your acknowledgment and agreement to the terms and conditions contained in this Privacy Policy with regard to Personal Information.

At this point your credit card number and Personal Information will be verified using a checking sequence and our validation procedures. Once your Personal Information and reservation are validated and confirmed, we and/or the selected affiliate resort will be sent all of the appropriate information regarding the reservation information.

In order to better facilitate the security of the credit card number and like Personal Information that you provide us when making a reservation through our website, an electronic reservation system with transmission encryption is used. We also receive a copy of the reservation profile at our website excluding your credit card number that is connected to your ID number, which we use to create a log in our web site database.

We also occasionally combine information from a number of web visitors in a way that does not identify any user, in order to identify user patterns.

3. During Your Stay with Us

During your stay, we record certain information about things such as your itemized spending in order to properly assemble your folio, which sets out your room rate and other expenses billed to your room. We also record and may report this information to comply with legal and financial reporting requirements, including those imposed by our auditors and government regulators. Information particular to your stay may also be stored (e.g., health issues, payment difficulties). This stay-specific information is stored at the particular resort where you stayed and is combined with information from previous visits and other Personal Information. We may also collect certain information as required by local laws (e.g., passport number).

In addition, we may retain the content of any document (including comment cards, electronic documents such as emails and other similar forms of communication) that you send us before, during or following your stay. This information may be shared with associates of the resort on an as-needed basis only.

4. When Requested by or Made Available to Third Parties.

In order to better operate our business and provide the level and quality of service, and stay with us that we expect to provide you, we may request of, obtain from, or validate with third parties information, including Personal Information. For example, when a reservation is made, we may obtain Personal Information about you from a family member. Alternatively, when handling the reservation of a rental car, we may receive Personal Information about you from the rental car provider.

How Do We Store Information?

1. At Our Site

We regularly obtain and store information in both digital and physical form. In order to better facilitate the security for Personal Information, we endeavor to store Personal Information in a secure location, be it a database or filing cabinet. Furthermore, we take steps to limit and control access to this information.

2. In Our Guest Database Systems

In order to serve you better, we specifically store certain guest and visitor information in our guest database systems.

Primarily, the information stored on our guest database systems includes what is needed in order to facilitate the provision of our services and to improve the efficiency of your visit. Guest name, address, phone numbers and credit card number are recorded and made available as needed when you make a reservation at a one of our resorts or properties. We also store other transaction information in our guest database systems such as the number of stays you have had at properties managed by us and the number of nights of each stay.

What Information Is Not Secure?

It is important to note that there is always risk associated with disclosing any information and in particular with regard to method of disclosure used. For example, email communication can not be guaranteed as secure, so there is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by email (for example, from the Contact Us section of our web site). We recommend that you do not include any confidential information (e.g., credit card information) when using email. For your protection, our email responses to you will not include any confidential information.

Finally, we cannot and do not warrant the operation of the reservation website and/or matters relating to its security as it is not our site nor does it, to the maximum extent permitted by law, warrant or guarantee privacy. To be prudent, please be sure to always close your browsers when you are done using the reservation site. Although the session will terminate after a short period of inactivity, it is best to close your browsers immediately upon completion as it can be easier for someone to attempt to get access to your profile and Personal Information while you are logged on.

If I Have Created a Guest Profile, How Is My Personal Information Treated?

If you are invited and elect to create a Guest Profile on our website, you will be asked to furnish specific Personal Information. You will also be asked to provide a password for use each time you log in. Once you have created a Guest Profile, online session data and other Personal Information may be added to your Guest Profile on subsequent visits to our website. Whenever you provide information, including revised information to your Guest Profile, be aware that we may use it to update other databases and records maintained by us.

Your transmitting or providing information as a part of your Guest Profile shall constitute your acknowledgment of and consent to the application of the Privacy Policy to such Personal Information.

Why Is Personal Information collected?

1. To Provide Superior Customer Service

Personal Information is collected to (i) assist us with making your reservation, by accommodating billing, and by knowing which services to provide at our properties in order to facilitate meeting your needs while you are staying with us and (ii) allow us to contact you in relation to matters that may have arisen during your stay with us. Furthermore, by keeping certain Personal Information on file, such as information regarding guest history and itemized spending, former guests of ours have the ability to confirm prior transactions and reconcile statements or invoices.

2. To Keep Our Guests Informed

We may also use Personal Information to advise you of promotions or to inform you of offers or other information that may be of interest to you. In order to do this, your information may be shared with a third party, including a customer relationship management company and/or a marketing and communications company. These companies are typically under contract with or obligation to us and understand that guest information should never be sold, rented, exchanged or in any way transferred without consent.

If you would prefer not to receive marketing information directly from us, you may advise our resort directly or send an email to: [email protected].

3. For Marketing Research

We occasionally combine information from a number of guests to better understand trends and expectations of our guests. Where this occurs, personal identifiers are typically removed so that the aggregate information cannot be linked to specific guests. This information is then used by us to study, understand and operate our business.

4. Legal and Financial Compliance

Certain laws, legal actions, financial reporting requirements and other government or third party considerations require us to collect, process and/or provided certain information that may included Personal Information.

What Information May Be Exchanged Between Our Resorts and Properties?

Information is shared between personnel at individual affiliated resorts and properties in certain limited circumstances, particularly where service, health or safety concerns have arisen in the past.

Further, if a guest does not pay the outstanding account on time, or acts in an unlawful or inappropriate manner, this information may be shared among accounting, security, collection and law enforcement personnel.

What Information May Be Provided to Others?

Agents, contractors or third party service providers of ours may receive your Personal Information in the course of providing services to us to better serve the needs of our guests. Using contractual or other arrangements, we strive to have such parties protect your Personal Information in a manner consistent with the principles articulated in this Privacy Policy.

Other than when (a) it is required or authorized by law or regulation (for example, in response to a legal subpoena); (b) it is required to provide you with services that you have requested, in which case your request is acknowledged by you as your consent (e.g., car rental or guest services); (c) your stay has been paid for by a third party and we need to provide billing information to the paying party; (d) if you have failed to pay amounts owed or we need to take action to enforce or defend our rights and interests; or (e) we suspect any unlawful activity is taking place, we will only share Personal Information about you outside of our operations with your consent.

If we suspect any unlawful activity is taking place or if we need to enforce or defend our rights, we may investigate and/or take action that we deem appropriate, including to report findings or suspicions to the police or other relevant law enforcement agency.

How Do I Access My Personal Information?

We understand that you may like to know what Personal Information we hold about you, and we welcome facilitating your request whenever appropriate to do so. To protect your Personal Information, however, we require that you prove your identity to us at the time your request is made.

When you make a request in person, we will require you to produce some form of valid and reliable photo identification such as a passport or a driver’s license and you will be asked to sign a request form.

Where you make a request by other means, we require the request be made in writing via facsimile or letter including a copy of a government issued identification and signature. We also may require other appropriate confirming information such as your home and business addresses and/or telephone numbers so that we can verify such submitted information with what is in our files to satisfy us as to your identity.

The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Information.

We reserve the right to decline access to your Personal Information under certain circumstances. When your Personal Information will not be disclosed, you will be provided with the reasons for this nondisclosure.

How Do I Revise My Personal Information?

If at any time you wish to update your Personal Information, you can do so by contacting our E-Channel Manager:

- via email: [email protected]
- via fax: 912.638.5897
- via letter: Attention: E-Channel Manager

     Sea Island Company
     P.O. Box 30351
     Sea Island, GA 31561

In all instances it will be your responsibility to maintain the accuracy and currency of your Personal Information with us. We will only make changes requested by you to your Personal Information in those instances when we have received an appropriate written request from you. That written request must also include adequate and appropriate proof of your identity.

For How Long Is My Personal Information Retained?

Information generally, including Personal Information, will be retained for the period of time required to fulfill our business purpose and comply with applicable law and record retention requirements. This may mean that it will be stored indefinitely or for as long as there is a business purpose for doing so. Notwithstanding, we may delete information, including your Personal Information, from time to time as we deem appropriate.

Changes To, and Uses Outside of, This Policy?

Please be aware that we reserve the right to change at any time without notice to you the Privacy Policy as well as our practices, policies, procedures and operations. If we decide to change our Privacy Policy, we will post those changes with our Privacy Policy, which can currently be found on our website at seaisland.com. Except as permitted or required by law, changes to the Privacy Policy will not apply retroactively without your consent to Personal Information for which you have given explicit consent and that was acquired before the change to the Privacy Policy.

If at any point we decide to use Personal Information in a manner different from that stated in this Privacy Policy, we will either contact you or send a notice to you by letter or email at last known address. You will then have up to fifteen days for the sending of such notice to object to such new use if you do not agree with the different way we intend to use Personal Information. To object, you may contact us in writing within those fifteen days with your request that we not use your Personal Information in such different way. If you do not object or your objection is not timely received by us, you will be deemed to have consented to the use of your Personal Information in the changed manner.

How Is Personal Information Affected by Business Transfers?

We manage properties on behalf of third party owners. Guest information required for the business transaction between the guest and the property, including Personal Information, is shared with the property owners'. We consider the information that it collects and retains, including Personal Information to be proprietary to it and not the property owners. If we cease to manage a particular property, such information is expected to remain with us. Certain guest information that is historically obtained by or shared with the property owner, may be retained by the property owner on an as-needed basis. In the event that we merge, consolidate, combine, partner, sell, liquidate, shut down or dispose of all or a part of our business or any of our assets, any and all information, data and material of ours, including Personal Information, may be assigned, transferred, licensed, conveyed, quitclaimed or sold accordingly.

What Laws Apply to this Policy?

We do business in Georgia and worldwide, servicing customers, visitors and others wherever we do business. As such, the laws of the United Sates of America (U.S.) and the State of Georgia apply as do the laws of other jurisdictions provided appropriate nexus exists between you, us and such other location. If you have additional questions regarding the law or if you feel we have not treated your Personal Information appropriately, please contact our Chief Privacy Officer as provided below and share the details of your concern. For additional information about applicable U.S. federal law, you may contact the Federal Trade Commission through its website at www.ftc.gov.

To Whom Do I Direct Questions or Concerns Regarding this Policy?

Questions or concerns regarding this privacy policy should be directed to the E-Channel Manager:

- via email: [email protected]
- via fax: 912.638.5897
- via letter: Attention: E-Channel Manager

     Sea Island Company
     P.O. Box 30351
     Sea Island, GA 31561

Who Provided the Photos of Davis Love III and Jonathan Byrd?

Photo of Davis Love III and Jonathan were provided by Anders Overgaard for Polo Golf