YOUR PRIVACY IS IMPORTANT TO US.

Effective Date: June 13, 2016 - UPDATED

This Privacy Statement governs the online information collection practices of Kirkbrae Country Club ("KCC"). KCC and any and all entities that control, are controlled by, or are affiliated with Kirkbrae are collectively referred to herein as "we," "us" or "our". This Privacy Statement outlines the types of information that we gather about you while you are using Kirkbrae.com (the "Site") and other sites controlled or managed by KCC, and the ways in which we use and don't use this information. This Privacy Statement does not apply to information that we may collect offline or through other means (for example, at a live event, via telephone, or through the mail).

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY BEFORE USING THE SITE. DO NOT USE THE SITE OR PROVIDE INFORMATION (OR ALLOW OTHERS TO DO SO ON YOUR BEHALF) IF YOU (AND YOUR PRINCIPAL IF YOU ARE ACTING AS AGENT) DO NOT AGREE WITH THIS PRIVACY STATEMENT AND ANY APPLICABLE SUPPLEMENTAL PRIVACY STATEMENTS. By using the Site, you signify your agreement to this Privacy Statement. If you do not agree to this Privacy Statement, you may not use the Site.

1. CHANGES TO THE PRIVACY STATEMENT Please note that we may change this Privacy Statement from time to time by posting an updated version of the Privacy Statement to the Site. It is your obligation to review this Privacy Statement from time to time and to review updates that are posted on the Site. If we make a material change to the way in which we collect, use, or share your personal information, we will post the changes on this page. If the changes are significant, we will provide a more prominent notice. Please refer to this Privacy Statement regularly. Your use of the Site following any such notice will signify and constitute your assent to and acceptance of the revised Privacy Statement.

If we make a material change to the way in which we collect, use, and/or share your personal information, we will post the changes on this page. If the changes are significant, we will provide a more prominent notice. Please refer to this policy regularly. Your use of the Site following any such notice will signify and constitute your assent to and acceptance of the revised Privacy Statement.

2. THE INFORMATION WE GATHER AND HOW WE USE IT A. Information we collect: Non-personally identifiable information is information that does not identify an individual user of the Site. We may use non-personally identifiable information collected from you and other users to perform statistical analyses of user behavior and characteristics. These aggregated statistics may be used to improve the Site and for product development and marketing purposes generally. We also may provide such aggregated information to advertisers, sponsors, licensees, and other existing or potential KCC vendors for certain purposes, but such statistics contain no personally identifiable information and cannot be used to gather such information.

"Personally identifiable information" is identifiable information about an individual person, as more particularly described under applicable privacy laws, such as a name, email address, and age. The personally identifiable information you provide to us when using the Site may be used to provide KCC services to you, to enhance your experience at the Site, and, if applicable, to enhance your experience as a subscriber to KCC country club and services.

B. How we use information we collect: Our Site also collects information through a variety of technical methods, including without limitation, cookies, web beacons, and other technologies. Cookies are pieces of information that a Web site sends to your computer while you are viewing the Web site. Web beacons are small pieces of data that are embedded in images on the pages of Web sites. Cookies, web beacons, and other technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We use these technologies for a variety of purposes such as to improve your online experience, to manage Site traffic, to prevent, detect, and investigate fraud, to assess promotional effectiveness, to track information such as the total number of visitors, IP addresses and browser types, access times, pages viewed and referring website addresses. We may also employ these technologies so that we remember you when you return to the Site, and collect information about your activities on the Site. We may also deliver ads or make recommendations in the context of your current visit to our Site or a single search query in our Site.

We generally do not share information from "cookies" and the like with third parties other than our service providers and within the KCC organization, but reserve the right to do so. For example, we may share information from "cookies" or other technologies used on our Site with our service providers or within the KCC, on an aggregate basis or to facilitate our business or marketing purposes (or those of our affiliated entities). If we materially change the type of information we automatically collect or the ways in which we share it, we will notify you.

If you do not want to receive cookies, you may set your browser to reject them. However, if you turn cookies off, you may not have access to some of the Site's services and features. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access the Site.

KCC uses the personally identifiable information you provide to us (i) for our business purposes, such as establishing and managing your customer account, providing products and services you request (such as processing and shipping orders and sending order and shipping confirmations), processing and collecting payments; (ii) to provide customer support, and to send you important administrative communications regarding the Site; (iii) to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, and the Site; (iv) to perform data analyses, including market and consumer search, trend analysis, demographic analysis, and financial analysis; (v) to comply with applicable legal requirements, to enforce our policies and terms of service, and to protect you, the Site, and us, against error and fraud. In addition, we may use your personally identifiable information to contact you concerning offers and new products and to enhance our product offerings. You may also be asked on the Site whether you wish to receive information from third parties and upon your consent, KCC and such third parties may use the personally identifiable information you provide to contact you consistent with the consent you provided.

We may employ independent contractors, vendors, and suppliers (collectively, "Outside Contractors") to provide specific services and products related to KCC and the Site, including, without limitation, hosting and maintaining the Site, and developing applications for the Site. These Outside Contractors may receive access to information collected from you, including your personally identifiable information, in the course of providing products or services to us.

We may disclose your personal information to third parties in connection with a corporate transaction, where all or a portion of our business or assets (including our associated customer lists containing your personal information) are sold or transferred. We may also disclose your personal information if disclosure is required by law or pursuant to judicial or governmental investigations or proceedings.

In addition to the foregoing uses, if you submit, post, email or otherwise send us information, content or materials, including, without limitation, photographs, remarks, suggestions, ideas or comments (collectively, "Submissions"), we (and our licensees, distributors, agents, representatives and other authorized users) shall be entitled to unrestricted use of such information. To the extent Submissions contain any personal information, we cannot protect such information as confidential, and third parties may collect and use such information. We do not pay or provide other consideration for any Submissions (including but not limited to those regarding business or restaurant processes or procedures, product ideas, marketing or advertising slogans, or improvement of products, the Site or content thereon), graphics, or other information communicated through this Site.

You should be aware that if you voluntarily disclose personally identifiable information in an e-mail or other communications with third parties listed on the Site or in other materials, that information, along with any other information disclosed in your communication, can be collected and correlated and used by such third parties and may result in your receiving unsolicited messages from other persons. Such collection, correlation, use, and messages are beyond our control.

This Privacy Statement applies to KCC’s treatment of personally identifiable information collected by or on behalf of KCC through the Site and does not necessarily reflect practices with respect to information gathered through other sites that we operate or through other off-line means. The Privacy Statement does not apply to practices of companies whose sites may be linked to the Site. For access to the privacy policies of those linked sites, please refer to the policies and practices provided by those sites at their home pages.

3. SPECIAL NOTE FOR PARENTS CONCERNING PRIVACY The Site is considered a general audience site and is not directed to children. KCC does not currently knowingly collect any personal information from children under the age of thirteen on the Site. If you are under 18, you may use the Site only with the involvement of a parent or legal guardian. If in the future, we collect personally identifiable information from children, we will do so in compliance with the Children's Online Privacy Protection Act of 1998 (15 U.S.C. 6501 et seq.) including, without limitation, obtaining necessary parental consent.

4. USE OF COOKIES KCC uses cookies to enhance the interactive nature of your Internet experience and to provide a convenient feature to save you time. "Cookies" are small text files that your web browser leaves on your hard drive to recognize you as a repeat user of our Site, track your use of our Site and target advertising. Cookies enable KCC to quickly retrieve specific information from previous visits and to recall features that you may have customized on your browser. You can disable Cookies using your Internet browser settings. Note that if you disable Cookies, certain features of our Site may not function properly.

5. SECURITY KCC employs what we believe are commercially reasonable efforts to provide reasonable procedural and technical safeguards for your personally identifiable information against loss, theft, alteration, and unauthorized access, use and disclosure where we are legally required to protect it, but this is not a promise that your information will never be disclosed except as provided herein. However, the nature of the Internet is such that information may be transmitted over networks without appropriate security measures and may be accessed, deleted, altered, used or disclosed by unauthorized persons. WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION OR OTHER INFORMATION IN ANY FORM. Information can sometimes be intercepted or accessed in violation of law, contract, or policy, and technologies do not always work as anticipated.

Because of the international nature of the services and products provided by this Site and the nature of KCC’s business, your personally identifiable information may, subject to applicable law, be transferred internationally throughout KCC worldwide for the purposes described above. This may mean that personally identifiable information is transferred to countries which do not have laws or regulations which protect personally identifiable information, such as the United States, where the server for this Site is located.

6. OPT-OUT If you supply KCC with your email address, you may receive periodic electronic mailings from us regarding news, products, services, or upcoming events. If you ever wish to stop receiving such emails, please e-mail us at membership@kirkbrae.com with the phrase "REMOVE ME FROM MAILINGS" in the subject line. Please know that such a decision will not stop advertising or content that is generated prior to the time when we can accomplish the removal of your personally identifiable information.

7. QUESTIONS, ACCESS, CONTACT INFORMATION, CHOICE, AND CORRECTION If you have any questions or concerns about our Privacy Statement, email us at membership@kirkbrae.com with the phrase "KIRKBRAE.COM PRIVACY STATEMENT" in the subject line, call 401-333-1300, or send your questions or concerns in writing to:

Kirkbrae Country Club 197 Old River Road Lincoln, RI 02865-1113

No person (of any age) is required to provide us with the personally identifiable information we request. If you do not wish to provide your personally identifiable information, you are free not to do so. Your provision of requested personally identifiable to us through our Site or other means is presumed by us to be voluntary and with your consent to the uses described herein. However, in some cases, only persons who provide the requested personally identifiable information will be able to participate in the Site activities and offerings.

If you request, we will provide you with the opportunity to object to and correct any inaccurate information we maintain about you collected by the Site, subject to verification, as well as to require us to delete your personally identifiable information if you no longer want us to process it. Any such request may be added to your data file and forwarded to data recipients where appropriate or requested by you. You may also request that your data not be shared with any third parties. Such requests may be made by contacting us in How We Use Information Collected in Apps section above).