Tepetonka Privacy Policy

Introduction

This Privacy Policy ("Privacy Policy") describes the measures Tepetonka Club LLC, together with its affiliates, related Tepetonka properties and experiences, and any Tepetonka-branded mobile applications, Tepetonka Loopers, websites, reservation platforms, hospitality offerings, membership services, retail operations, events, lodging, and guest services (collectively, "Tepetonka," "we," "our," or "us"), takes with regard to collecting, using, protecting, and disclosing personally identifiable information that you voluntarily provide to us or that is provided to us by our business partners, service providers, affiliates, advertisers, clients, reservation providers, property operators, or other third parties that support Tepetonka services (collectively, "Business Partners").

For purposes of this Privacy Policy, "personal information" may include, without limitation, your name, address, telephone number, email address, payment information, reservation information, membership-related information, transaction history, inquiry details, and other information that identifies, relates to, describes, or can reasonably be associated with you. This Privacy Policy also describes our practices with respect to certain non-personal information, including tracking information collected as you navigate through our websites, applications, and digital services.

We and our Business Partners may use personal information subject to this Privacy Policy and applicable law. Our Business Partners may also collect and use personal information pursuant to their own privacy policies. We are not responsible for the policies or actions of Business Partners or third-party websites, platforms, or services with respect to personal information that you provide directly to them. Use of Tepetonka websites, applications, digital services, or other services constitutes your acceptance of this Privacy Policy.

Information Collection and Use

We collect personal information that you provide primarily to provide you with, administer, improve, or contact you about Tepetonka services, products, events, memberships, hospitality offerings, lodging, tee time or stay-and-play reservations, retail purchases, experiences, promotions, and other matters described on Tepetonka websites, applications, or the websites or platforms of our Business Partners.

We collect personal information that is voluntarily provided by you in connection with our services and products. Such information may include, for example, information about golf reservations, lodging reservations, membership inquiries, events, offers, contests, sweepstakes, surveys, dining and hospitality experiences, retail purchases, travel arrangements, guest services, and inquiries that require a response or coordination.

When you make a reservation, purchase, or attempt to make a purchase from us or our Business Partners through a Tepetonka website, application, reservation platform, point-of-sale system, or Business Partner site, we may collect certain information from you, including your name, billing address, shipping address, payment information, payment app details, email address, and phone number. We use this information generally to fulfill orders and reservations, process payments, provide invoices and confirmations, communicate with you, manage any account or membership program, screen for potential risk or fraud, and, consistent with your preferences, information provided, and web interactions, provide you with information or advertising relating to applicable products or services provided by Tepetonka or the relevant Business Partner.

We also collect personal information to enhance your visit to Tepetonka websites, applications, and Business Partner sites, and to deliver more individualized content, advertising, and offers. For example, we may use personal information to communicate with you regarding this Privacy Policy, surveys, sweepstakes, contests, special events, promotions, member or guest communications, and other matters.

We may combine information collected online with information we have collected through other means, including in-person interactions, reservations, purchases, events, membership communications, and customer service interactions.

Personal information may also be collected and used on our behalf by, or shared with, service providers who assist us in the administration, hosting, operation, maintenance, security, analytics, payment processing, reservation management, marketing, communications, technical support, or other functions related to Tepetonka websites, applications, services, or Business Partner platforms. We may also share personal information with third-party contractors retained to assist us or our Business Partners in the operation of our respective businesses.

We may also collect and aggregate non-personal information from users of Tepetonka websites, applications, and Business Partner sites to analyze website traffic, understand which pages or features are visited most frequently, determine what features are most attractive to users, improve our digital services, administer the sites, and support business operations.

At any time, if you do not wish to receive email from us or do not wish us to use your personal information for marketing purposes, you may opt out by following the instructions in our email or by contacting us as described below.

If you do not wish to receive email from Business Partners you have engaged with, you may opt out in the same manner. We will remove you from the marketing lists we maintain for the applicable Business Partner(s) and notify them where appropriate, but we are not responsible for their actions or inactions.

We may disclose personal information without notifying you in response to legal process; to establish, exercise, or defend legal rights; to investigate or prevent illegal activity, suspected fraud, safety threats, policy violations, or threats to rights or property; or in connection with a sale, purchase, merger, partnership, reorganization, or transfer of assets.

How We Gather Information

Log Files

As is true of most websites, we gather certain information automatically and store it in log files. This may include IP addresses, browser type, internet service provider, referring and exit pages, operating system, date and time stamps, and clickstream data. We use this information to analyze trends, administer digital services, track users' movements, and gather demographic information about our user base as a whole.

Cookies, Pixels, and Similar Technologies

We, along with Business Partners and service providers, use cookies and similar technologies such as pixel tags, web beacons, and clear GIFs. Cookies are small text files that help identify preferences, optimize your experience, maintain selections during reservations or transactions, and support site functionality. Pixel tags and similar technologies may help display customized advertising, measure browsing behavior, and evaluate campaign effectiveness.

Analytics and Behavioral Advertising

We may use third-party tracking services, such as Google Analytics, that use cookies and similar technologies to collect non-personally identifiable usage and volume statistics in the aggregate, understand how Tepetonka websites and Business Partner sites are used, and support advertising and marketing. By using Tepetonka digital services, you consent to the processing of data about you by Google and other analytics providers in the manner and for the purposes described in this Privacy Policy.

Behavioral Advertising

We may use your personal information, transaction information, and interaction information to provide targeted advertisements or marketing communications we believe may be of interest to you. You may opt out of targeted advertising through applicable platform settings, including Facebook, Google, Bing, the Digital Advertising Alliance opt-out portal, mobile device advertising controls, browser settings, and any cookie preference manager made available on Tepetonka websites.

Do Not Track Protocols

Because the Do Not Track standard has not been finalized, Tepetonka websites may not recognize or respond to Do Not Track browser signals. Where required by applicable law, we will process Global Privacy Control signals as described below.

Social Media Plugins

Tepetonka websites and digital services may include social media plugins or links that enable you to share content through social networks such as Instagram, X/Twitter, Facebook, LinkedIn, or similar services. We do not control the setting of cookies or other tracking technologies by these service providers. Please review the privacy policies of those providers for information about their data practices.

Links to Other Sites

Tepetonka websites, applications, or Business Partner sites may contain links to other sites that are not owned or controlled by Tepetonka. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy statements of every website that collects personal information.

Security

We follow generally accepted industry standards designed to protect the personal information we receive from unauthorized access or disclosure. We are not responsible for the security of personal information in the possession or control of Business Partners. No method of electronic transmission, storage, or security is 100% reliable.

Right to Access, Amend, Opt Out

If you would like to know what personal information we maintain about you, if your personal information changes, or if you no longer want us to use your personal information, including to opt out of electronic communications, please contact us by email at [privacy@tepetonka.com or privacy@kempersports.com] or by postal mail at:

Tepetonka Club LLC

1155 County Rd 40 NE

New London, MN 56273

Attn: Privacy Request

Except as required by applicable law, please allow up to 30 days for a response. We may ask for additional information to authenticate your identity or request. Unless otherwise required by law, our sole obligation shall be to exercise commercially reasonable efforts to comply with your request. Requests pertaining to any Business Partner should be directed to the applicable Business Partner.

International Users

Tepetonka websites and services are U.S.-focused and administered from the United States. The websites and services are not directed to users outside the United States. To the extent information is provided through Tepetonka websites, applications, or Business Partner sites, it may be uploaded to a cloud environment and/or transferred to the United States for processing. By providing information, you consent to the transfer to, processing, and use of the information in the United States and/or through a cloud environment.

Retention of Information

Tepetonka will retain personal information only for as long as necessary to fulfill the purposes for which it was collected and as required or permitted by applicable laws and regulations. The specific retention period may vary depending on the type of information and the purposes for which it was collected.

California Residents

If you are a California resident and would like to exercise your rights with respect to Tepetonka, you may do so by emailing us at [privacy@tepetonka.com or privacy@kempersports.com] or by contacting us at the mailing address above. We may seek additional personal information to verify your identity and your or your agent's rights to the data subject to your request.

California law provides residents a number of rights as they relate to personal information, including the right to know, right to delete, right to correct, right to opt out, and right to limit use and disclosure of sensitive personal information. Depending on the circumstances, Tepetonka may act as a business, controller, service provider, processor, or similar role for certain Business Partners.

Right to Know

You may request that Tepetonka provide the specific pieces of personal information we have about you; the categories of personal information collected; the categories of sources from which personal information is collected; the categories of personal information disclosed for a business purpose; the categories of third parties to whom personal information was disclosed; and the business or commercial purpose for collecting personal information.

Right to Delete

California law gives residents a limited right to request deletion of personal information. This right is subject to exceptions. If Tepetonka has a permissible need to retain personal information, we may not be obligated to delete it, even when requested. We may retain personal information to complete transactions, provide requested goods or services, perform contracts, detect security incidents, protect against malicious or fraudulent activity, comply with legal obligations, enable internal uses reasonably aligned with your expectations, or otherwise use personal information internally in a lawful manner compatible with the context in which you provided it.

Right to Opt Out

You may choose to opt out of the sale or sharing of your personal information, as those terms are defined by applicable law, or the use of personal information for targeted advertising, by submitting a request through the contact methods above or by using available opt-out tools. Tepetonka does not believe that it sells personal information as the term is commonly understood; however, certain advertising, analytics, or cookie-related practices may be considered a sale, sharing, or targeted advertising under some privacy laws.

Right to Correct

Subject to certain conditions and exceptions, you may request that Tepetonka correct inaccurate personal information that we maintain about you, taking into account the nature and purposes of the processing.

Right to Limit Use and Disclosure

Subject to certain conditions and exceptions, you may have the right to limit the use and disclosure of sensitive personal information. Tepetonka does not use or disclose sensitive personal information for purposes except as described in this Privacy Policy and as permitted by applicable law.

Authorized Agents and Non-Discrimination

California residents may designate an authorized agent to manage privacy requests. We may require proof of authorization and may also require the consumer to verify their identity directly. Tepetonka will not discriminate against you because you exercised privacy rights, including by denying goods or services, charging different prices or rates, providing a different level or quality of service, or suggesting that you may receive a different price, rate, level, or quality of service.

Global Privacy Control and Cookie Opt-Out

Tepetonka websites will honor Global Privacy Control signals where required by applicable law. If we detect that your browser is transmitting a GPC signal, we will process it as a request to opt out in accordance with applicable law. Residents may also opt out of cookie and pixel-related sales, sharing, or targeted advertising by adjusting cookie privacy preferences through any cookie preference manager available on Tepetonka websites. Preferences may need to be set separately for each browser and device.

Mobile Device Settings and Request Verification

To limit mobile tracking technologies, you may adjust your mobile device settings. Android users can visit Google settings and go to Ads to reset or adjust the advertising ID. Apple users can navigate to Privacy & Security settings and disable tracking to restrict apps from tracking activity across apps and websites for targeted advertising.

To verify a request, we will take reasonable steps to match the information you provide with information in our records. Please provide enough information to verify your identity and describe your request with sufficient detail. If an authorized agent submits a request, we may require evidence of authorization and may ask the relevant consumer to verify identity and confirm the agent's authority. If we collected information as a service provider for a Business Partner, we may direct you to that Business Partner.

Children

Tepetonka websites and the websites of our Business Partners may provide opportunities for parents or guardians to register children for activities such as camps, clinics, lessons, junior golf, or family events. Tepetonka does not knowingly collect or solicit personal information from any child under 16 years of age. If you believe that a child under 16 has provided us with personal information, please contact us using the contact information above so that we may take appropriate action.

Careers

Information about potential employment opportunities with Tepetonka and related properties may be accessible from Tepetonka websites, KemperSports career resources, or other career platforms. Tepetonka is an equal opportunity employer. Information provided through career resources will be used to process employment applications, including assessing qualifications, verifying information, and conducting reference or other employment-related checks. Applicants may exercise their rights under this Privacy Policy in the same manner set forth above.

Changes to this Privacy Policy

Tepetonka reserves the right to change this Privacy Policy at any time by posting revisions on Tepetonka websites or otherwise making an updated version available. Please check this page periodically for changes. Your continued use of Tepetonka websites, applications, or services following the posting of changes means that you accept those changes.

Contact Information

Tepetonka Club LLC

1155 County Rd 40 NE

New London, MN 56273

[Phone number]

[privacy@tepetonka.com or privacy@kempersports.com]

Revised June 3, 2026.