Effective Date: January 1, 2023
Treasure Island Community Development, LLC and its affiliated companies and subsidiaries, including UST Lennar HW Scala Joint Venture, Treasure Island Development Group, LLC, Treasure Island Series 1, LLC, Treasure Island Series 2, LLC, Treasure Island Series 3, LLC, Treasure Island Series 4, LLC, and Treasure Island Series 5, LLC, (collectively, “TI Group,” “we,” “us,” “our”) are committed to protecting the personal information we collect and use from members of the homebuying public, real estate brokers and their employees and associates, trade partners, and users of online services (“you,” “your”) who visit our website or use our mobile application (collectively “Online Services”) or communicate with us by mail, telephone, email. SMS text message, other electronic means, or in person, in connection with the Treasure Island Residential Development and its homes and related products and services.
THIS PRIVACY POLICY DESCRIBES:
• What information is collected about you;
• How we use and with whom we share this information;
• How you can access and update this information; and
• The choices you can make about how we collect, use and share your information.
If you have any questions regarding this Privacy Policy or our information collection and use practices, please contact us using the information in the “How to Contact Us” section below.
THE PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT
The term “personal information” as used in this Privacy Policy refers to information that identifies you as an individual or relates to you as an identifiable individual. We collect your personal information when, for example, you use our Online Services or communicate with TI Group by other means or in person, or communicate with unaffiliated companies with whom we collaborate in the development of the Treasure Island Residential Development (“Business Associates”), among other sources as explained below.
Categories of Personal Information We Collect
The categories of personal information we collected and used for our business and commercial purposes during the past 12 months are the following:
• Contact information (such as name, address, government-issued identification numbers, telephone number, and email address), purchasing preferences and other information you provide to us. We may also obtain this information from real estate agents and professional, publicly available databases; and joint marketing partners and event sponsors. Information about gender, employment, education, and information from other sources may be reflective of a person’s interests and preferences.
• Device and Usage Information. Like most online services, our Website collects standard technical, non-personal information when you use it, including internet protocol (IP) addresses, browser types, internet service providers (ISPs), the pages and content you view or interact with on our Website, the information you search for, and the dates and times that you visit our Website.
• Cookies and Other Technologies. Our Website and online platforms collect certain information through the use of “cookies” and other tracking technologies. Cookies are small files that your browser places on your computer. We may use session cookies, persistent cookies, and other tracking technologies to better understand how you interact with our Website, to monitor usage by our users and web traffic routing on our services, and to improve and personalize our Website. Many Internet browsers automatically accept cookies. You may be able to instruct your browser to stop accepting cookies or to prompt you before accepting cookies from the websites you visit. Google provides some additional privacy options relating to Google analytics, described at www.google.com/policies/privacy/partners/. We do not respond to “do not track” browser signals at this time. We may also use web beacons, which are transparent graphic images on a webpage or within the body of one of our marketing emails, to allow us to measure visitor actions and assess the effectiveness of our email marketing campaigns. For example, we use web beacons in our email marketing to track instances where a user clicks through a link in the email.
• Job applicant information. Application for employment requires submission of a resume and information regarding your education (including highest level attained) and employment history.
• Contact information. If you request information about products and services offered by TI Group-affiliated companies or Business Associates, we will collect your name, address, email address, telephone numbers and such other information necessary to fulfill your request.
• Business contacts with TI Group. Real estate brokers who request information on Treasure Island Residential Development communities will provide and we will collect the broker’s contact information.
• Additional information you provide may include information about personal matters, such as family, employment, education. However, we ask that you not send or disclose to us any sensitive or personal medical information to us.
Information We Collect from TI Group-Affiliated Companies, Business Associates, and Other Sources
• TI Group-affiliated company transaction information. We may receive and use personal information collected by a TI Group-affiliated company in your transaction with the TI Group-affiliated company (subject to your consent to share certain credit and other financial information). The disclosure of some of this information may be protected by the Fair Credit Reporting Act. Some TI Group-affiliated companies have posted their own privacy policies on their websites that explain how they collect, use and disclose personal information.
Business Associates and Marketing Information
We may receive personal information from Business Associates and other companies (not owned or controlled by TI Group) for marketing programs and prospective customer lead generation as you may authorize. Such information includes without limitation:
• Information from publicly available and commercial databases, including marketing research and data analytics resources. We may, for example, receive demographic information (age, sex, household income, job industry, and job title) from these sources.
• Information from social-media platforms or other third-party services. If you choose to link your social-media account or other third-party accounts to our Online Services, you may be authorizing those third parties to send us certain information about you, and you are authorizing us to collect, store, and use the information they transmit to us in accordance with this Privacy Policy.
• Aggregated information. We may combine information gathered through our Online Services with information collected from other online and offline sources. For example, we may aggregate information to correlate IP addresses to zip codes to assess the performance of a marketing campaign.
• Information Collected about Your Online Activities.
Information from our Online Services
When you visit our Online Services, we automatically collect and store data using cookies and other online technologies. These data include:
• Identification – prior visits to any of the Online Services, your user name and password if any.
• Device – your IP address, browser type, operating system and other usage information about the use of our Online Services.
• Usage – browsing history, search history, and information regarding your interactions with our Websites and other websites, applications, or advertisements.
• Location information – your IP address or mobile device identification transmits general information about your geolocation and you may allow us to obtain more specific geolocation information.
Although the data points collected this way may not specifically identify you, they can be combined with other information about your internet activities to identify your interests and preferences. The information from many separate websites is aggregated by third parties such as Google Analytics and Google Ads and used for data analytics, marketing, and interest-based advertising. For more information about these technologies, how they function, why we use them, and how you can restrict them, see the section titled “How We Use and How You Can Limit Cookies and Interest-Based Advertising.”
Linking to Other Websites and Social Network Access
Our Online Services may provide links to the websites of companies providing products and services that may be of interest to you. Each of these companies has its own privacy policy that may differ from TI Group’s Privacy Policy. If you click on the link, you will be transferred to that company’s website, and any personal information you share on that website will be subject to the privacy policy or practices of the website owner and will not be subject to TI Group’s Privacy Policy. TI Group does not have any control over, or responsibility for, the privacy practices or website content of any Business Associate. The use of such websites is at your own risk.
Some of our Online Services allow you sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, YouTube, Instagram, and Pinterest with your user account. By using this functionality, you give TI Group permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with us and other connected applications and to manage the data that is shared through your account, including information about your activities using our sites. If you would like to disconnect a social media account from TI Group, refer to the settings of that social media account and its provider..
HOW WE USE PERSONAL INFORMATION
TI Group collects and uses your personal information for the business and commercial purposes summarized below, but our use of your information is subject to the following limitations:
• The terms of this Privacy Policy;
• Any specific terms applicable to the services or products you request;
• Your instructions to us that limit the use of certain information when you exercise an “opt-in” or “opt-out” or “unsubscribe” option we provide; and
• The requirements of applicable law.
Subject to those limitations, TI Group may use your personal information in the
following ways:
• To Contact You. We may use your email address or other information we collect to contact you for administrative purposes such as customer service or to send communications, including marketing or promotional communications relating to the Treasure Island Residential Development.
• Establish, maintain and service our customer accounts, provide customer service, process and or fulfill requests for information, verify customer information, engage in advertising, marketing, and online analytic services.
• Build long-term customer relationships by communicating and working closely throughout the contracting, planning, financing, and completion of a project, requesting feedback on the customer’s experience, and offering products and services in the future.
• Maintain records of our customers’ needs, preferences and interests so that we may assist customers to identify properties and services provided by TI Group-affiliated companies or Business Associates and letting them know about services or promotions that may be of interest to them, including by email, mail, telephone, or SMS text message. These are marketing messages and you are able to control whether you receive them. To learn how you can choose to stop receiving some or all of these messages, see the section titled “Opt-In/Opt-Out Procedures.”
• Present customers’ home buying experiences (with their permission) on our Online Services and in marketing materials.
• Undertake activities to maintain the quality of TI Group products and services and to improve, upgrade, and enhance those products and services including research and development.
• Manage our Online Services to maintain functionality, customize the user experience to display information pertinent to a user’s interest, assess our users’ feedback so that we present information on your computer or mobile device in a user-friendly way, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity and take appropriate action if needed.
• Develop demographic information for statistical and market research for new communities and product development, project planning, development of prospect lists, and other strategic marketing purposes.
• Permit third party advertisers and ad servers to deliver TI Group advertisements to you on other websites you visit as explained herein. This includes, for example, verifying positioning and quality of ad impressions, and auditing compliance with marketing specifications and standards. If you prefer not to receive this form of advertising, see “How We Use and How You Can Limit Use of Cookies and Interest-Based Advertising.”
• Manage our contractual relations, protect our business interests, enforce our terms and conditions and comply with applicable law by monitoring, investigating, and taking other actions to detect and prevent illegal or fraudulent activities and risks to the personal safety of any individual (see our terms and conditions).
• Significant Business Transactions. Your information, including personal information, may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• Compliance with Laws and Law Enforcement; Protection of Our Rights. We may disclose your information (including your personal information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of our Website or Services, (d) to protect the property, rights, and safety of TI Group, our users or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.
• We may make certain aggregated non-personal information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, usage patterns, and borrowing and loan origination trends.
Except as otherwise specifically provided in this Privacy Policy or as required by law, any communication or material you provide to us, whether received online, electronically, in person or otherwise collected by or submitted to us, including any data, questions, comments, suggestions or the like, is, and will be treated as, non-proprietary and may be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, market research, development of prospect lists, project planning, broadcast, posting and marketing, among other things.
How and Why We Share Personal Information
Business Purposes. To carry out many business operations for which you engage TI Group or a TI Group-affiliated company, we disclose or provide access to personal information to TI Group-affiliated companies and non-affiliated service providers so that they may perform a business function on our behalf (“Service Providers”). Information we disclose to Service Providers may be used only for TI Group’s business purposes and Service Providers are not permitted to use the personal information for their own direct marketing or other commercial purposes. We may also sell or exchange for value some categories of personal information to TI Group-affiliated companies, Business Associates, and selected non-affiliated third parties (collectively, “Third Parties”). When information is sold or exchanged for value, the Third Parties may use the personal information for their own direct marketing or other commercial purposes.
Please note that Third Parties have their own policies and practices for collecting, using and disclosing personal information. TI Group does not have any control over, or responsibility for, the content or operation of the website of any Third Party or its privacy practices. You may access the privacy policy of a Third Party by visiting its website or requesting a copy.
You may be able to restrict access by these Third Parties to your personal information. See the section of this Privacy Policy titled “Opt-in/Opt-out Procedures”.
The chart below shows the categories of personal information TI Group disclosed for a business purpose to Service Providers or TI Group-affiliated companies or sold/exchanged to other Third Parties during the past 12 months.
| Categories of Personal Information Collected in Past 12 Months | Disclosed to a Service Provider or TI Group- affiliated company for a business purpose | Possibly sold or exchanged for value with a Third Party or TI Group-affiliated companies |
| Personal identifiers | ||
| Name, postal address, email address, and telephone number, if provided by customer or available from public or commercial sources. | Yes | Yes, to TI Group-affiliated companies and Business Associates, Third Parties for customer lead generation, direct marketing; market research services |
| Social security number, government-issued identification number, driver’s license and passport number, if provided by customer. | Yes | No |
| Internet protocol address, online identifier obtained from TI Group website usage data. | Yes | Data available to web analytics; online advertising providers; market research services |
| Consumer information: Credit/debit card and bank or other financial account numbers, if provided by customer to complete a transaction. | Yes | No |
| Internet and other electronic network activity, Data input by users, location/community of interest for new home, chat messages. Usage data, website pages visited; internet browsing history, search history, and interactions with TI Group’s and other websites, applications, and advertisements | Yes | Data available to Third Party digital marketing, website analytics and online advertising services |
| Geolocation data: General location derived from IP addresses and mobile device data. Note that locations and communities of interest selected by website visitors are not retained unless the visitor submits a request for information | Yes | Yes, to TI Group-affiliated companies and Business Associates for lead generation, direct marketing and market research services. |
| Yes, to TI Group-affiliated companies and Business Associates for lead generation, direct marketing and market research services. | Yes | Yes, to TI Group-affiliated companies and Business Associates for lead generation, direct marketing and market research services. |
Other Reasons for Sharing Personal Information
Except as otherwise provided in this Privacy Policy, we may share or disclose personal information for the following reasons:
• To TI Group-affiliated companies and third parties to whom you or authorize us to disclose your personal information.
• To TI Group-affiliated companies and third parties as reasonably necessary to complete the transaction for which you engage TI Group and/or the TI Group-affiliated companies.
• To enforce our contracts and the Terms and Conditions applicable to the use of the Websites.
• To fulfill your requests including connecting with your social media accounts.
• To comply with laws or valid legal process and in response to appropriate governmental requests.
• As we deem reasonably necessary to investigate, prevent or take other appropriate action in connection with potential illegal or fraudulent activities or potential risk to the personal safety of any individual or the security of your personal information.
• As we deem reasonably necessary to in connection with a major business transaction subject to appropriate confidentiality protections.
YOUR PRIVACY RIGHTS
Information Sharing with TI Group-affiliated companies – Your Privacy Rights under the Fair Credit Reporting Act.
Under Federal law, we are permitted to share information about our own transactions and experiences with you with TI Group-affiliated companies. However, federal law gives you the right to limit our ability to share information about your creditworthiness or for marketing purposes with TI Group-affiliated companies.
Notice of Your Choice to Limit Marketing by TI Group-affiliated companies.
You may limit TI Group-affiliated companies from marketing their products or services to you based on personal information that we collect from you and share with them. You can limit marketing offers from TI Group-affiliated companies, by visiting the Communications Preferences page of this Website, or by contacting us by e-mail at: privacy@tisf.com.
Opt-In / Opt-Out Procedures
In the process of purchasing a home in the Treasure Island Residential Development, you may be interested in receiving information about a variety of related products and services including, but not limited to, home loan, title and homeowner’s insurance, security and telecom services, and local merchants. When you provide us with your contact information, you will be asked to consent to authorize us to share your personal information with TI Group-affiliated companies and/or Business Associates to market services relating to the purchase of a home in the Treasure Island Residential Development. If, after you authorize any such sharing of personal information, you determine that you prefer that we not disclose your personal information to such entities, you may change your election at any time by visiting the Communications Preferences page of this Website.
If you would like to restrict the automated collection of your personal information while using our Online Services, see the section titled, “How We Use and How You Can Limit Cookies and Interest-Based Advertising.”
If you are a California resident, please review the information regarding your Right to Opt-Out provided in section titled “Rights of California Residents – Right to Opt-Out of the Sale of Personal Information.”
How We Use and How You Can Limit Cookies and Interest-Based Advertising
Data analytics. We use cookies and similar technologies on our Online Services to obtain information about how our Online Services are used and to analyze visiting patterns. These technologies support some of the features of our Online Services. The use of cookies and similar technologies for mobile applications also allows us to recognize your IP address or mobile application identifier, measure activity and usage such as the time and length of your visit, the pages you look at, the sites you browse before and after you visit our site, and the name of your internet service provider.
We obtain usage and activity data from TI Group-affiliated companies that operate separate websites and from third parties that host or manage certain features of our Online Services. Each of these companies has its own policies on the collection and use of data collected using cookies and other internet technologies.
We may engage third parties, such as Google Analytics, to collect activity and usage data. TI Group may disclose identifying personal information to a third-party data analytics provider. The provider may monitor a user’s interactions with our Online Services and combine this data with data from other websites monitored by the same service provider and then use these findings for its own business and commercial purposes. The provider may have means of correlating data from our Website to an identifiable individual, in which case the processing of personal information will be the responsibility of the service provider.
To learn more about how Google collects and processes data and the choices Google may offer to control these activities, you may visit http://www.google.com/intl/en/policies/privacy/partners/
Interest-Based Advertising
We may use third-party advertising companies to serve ads when you visit our Online Services. These companies may collect information about your visits to our Online Services and other websites and/or apps in order to provide advertisements about goods and services of interest to you. We also partner with ad networks and other companies that serve ads on behalf of us and others on non-affiliated digital properties. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information these ad networks collect about your visits to our Online Services and other non-affiliated websites or apps over time.
You may visit www.aboutads.info/choices to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to restrict interest based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that application onto your device and exercise your choice. AppChoices is available at the links below:
DAA AppChoices iOS – https://itunes.apple.com/us/app/appchoices/id894822870?mt=8
DAA AppChoices Android – https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en
Ad Privacy Manager iOS – https://itunes.apple.com/WebObjects/MZStore.woa/wa/viewSoftware?id=551047372&mt=8
Ad Privacy Manager Android – https://support.google.com/android/answer/9431959?hl=en
You may also be able to limit data collection by using your browser or mobile device settings. Please note that electing to limit interest-based advertising will not stop all advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests. Additionally, please note that if you use a different browser or erase cookies from your browser, or use a different device, you may need to renew your setting selections.
Protection of Collected Information; Retention Policy
TI Group maintains administrative, technical and physical safeguards to protect the security, confidentiality, and integrity of your personal information appropriate to the nature of the personal information we collect. While the measures we implement are intended to reduce the likelihood of security problems, we cannot guarantee that these measures will prevent unauthorized access to your personal information. In particular, information transmitted over the Internet may find its way to recipients to whom it is not intended or persons you may not want to have such information. Under certain circumstances, this may be beyond the control of TI Group, and you are advised that such transmission may not be secure.
We retain personal information for as long as we reasonably require it for legal or business purposes. When we no longer have a legitimate business interest in keeping your personal information, we will delete or destroy it. If you submit a request for information about the Treasure Island Residential Development, we will retain your contact and preferences information and consider our relationship to remain active for marketing purposes after fulfilling any request you submit and until we take note that you no longer show interest in our products or services.
PRIVACY RIGHTS FOR NEVADA RESIDENTS
Nevada residents have the right to direct us not to sell certain personally identifiable information that we collect about you on our Websites or other online services by emailing us at by sending a request to privacy@tisf.com. This information includes: your first name or first initial and last name in combination with your social security number; driver’s license number, driver authorization card number or identification card number; account number, credit card number or debit card number, in combination with any required security code, access code or password that would permit access to your financial account; medical identification number or a health insurance identification number; user name, unique identifier or electronic mail address in combination with a password, access code or security question and answer that would permit access to an online account. Additionally, you may review and request that we change the personally identifiable information that we collect about you on our websites or other online services by emailing us at privacy@tisf.com.
Our service providers and other third parties may collect personally identifiable information about your online activities over time and across different internet websites or online services when you use our Websites or online services.
NOTICES AND RIGHTS FOR CALIFORNIA RESIDENTS
California Consumer Privacy Act
This section of our Privacy Policy supplements our Privacy Policy to provide additional information under the California Consumer Privacy Act of 2018, as amended, and applies only to consumers who reside in the State of California. This section does not apply to TI Group personnel, job applicants, or California residents whose information we obtain in business- to-business transactions.
Notice of Collection of Personal Information
The categories and sources of personal information we collect about consumers, the purposes for which it may be used, and the categories of third parties with whom we may share personal information are described in the following sections of our Privacy Policy:
• Personal Information We Collect;
• How We Use Your Personal Information; and
• How and Why We Share Personal Information.
Notice of Right to Opt-Out of the Sale of Personal Information
Right to Opt-Out. California consumers have the right to direct a business not to sell their personal information to others (“Right to Opt-Out”). You can exercise your Right to Opt-Out by visiting the Communications Preferences page of this Website. You may also exercise your Right to Opt-Out by submitting your request as explained below under “How to Make a California Consumer Request.”
As explained in the section of this Privacy Policy titled, “How and Why We Share Personal Information,” TI Group provides personal information about customers and prospective customers to TI Group-affiliated companies and Business Associates and may receive reciprocal services or customer information from them. In some instances, we may receive a monetary payment for referring a prospective customer. If you elect to opt-out of all sales of your Personal Information, we will act as soon as feasible to implement your request. We will also instruct any TI Group-affiliated company or Business Associate to whom we sold your personal information within 90 days prior to receiving your opt-out request to not make further sales of your personal information.
Selecting Your Preferences. Our Communications Preferences page provides several options. You may opt-out of all sales of your personal information regardless of the purpose or category of third party involved. Or, you may opt-in to allow only sales to TI Group-affiliated companies and/or Business Associates to permit them to market their products and services to you.
Changing Your Preferences. You may change your mind and opt-in to allowing sales of your personal information at any time by visiting the Communications Preferences page of this Website or by sending us a message. However, once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
Right to Know About Personal Information Collected, Disclosed, or Sold
California consumers have the right to request any of the following information from TI Group regarding personal information collected about the consumer or the consumer’s household during the last twelve (12) months:
• Categories of personal information collected about you;
• Categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting or selling personal information;
• Categories of personal information sold or disclosed for a business purpose;
• Categories of third parties whom personal information was sold or disclosed for a business purpose;
• The specific pieces of personal information collected about you (except for very
sensitive personally identifiable information, which we will describe but not transmit).
The process by which we verify and respond to your requests is explained below under “How to Make a Verifiable California Consumer Request” and “How We Will Respond to a California Consumer Request.” You may submit a Right to Know request to: privacy@tisf.com.
Right to Deletion of Personal Information
California consumers have the right to request that TI Group delete any personal information about the consumer which TI Group has collected from the consumer, subject to a range of exclusions permitted by law. For example, TI Group is not required to delete personal information if it is necessary to complete a transaction, reasonably used for an ongoing business relationship, or used internally in a lawful manner that is compatible with the context in which the consumer provided the information. Within ten business days we will confirm that we received your request and follow appropriate procedures to verify your identity and, if applicable, authority to submit the request. If the consumer request is confirmed and verified, we will delete (and direct our service providers to delete) your personal information from our records, unless an exclusion applies.
You may request deletion of your personal information by contacting us via email at privacy@tisf.com. Please include the necessary information (e.g. name, email address, etc.) to help verify your identity and we may request additional information necessary to verify that you are authorized to make the request.
Selecting Your Preferences. Our Communications Preferences page provides several options. You may opt-out of all sales of your personal information regardless of the purpose or category of third party involved. Or, you may opt-in to allow only sales to TI Group-affiliated companies and/or Business Associates to permit them to market their products and services to you.
Changing Your Preferences. You may change your mind and opt back in to personal information sales at any time by using the link below or sending us a message. However, once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales unless you reinitiate contact with one of our associates.
Right to Designate an Authorized Agent
California consumers have the right to designate an authorized agent to act on their behalf to submit a Right to know, Right to Delete, or Right to Opt-Out from the Company’s sale of their Personal Information. An authorized agent may be a natural person or a business entity registered with the Secretary of State. An authorized agent must also submit to the Company written proof of their authorization to act on the consumer’s behalf.
How to Make a Verifiable California Consumer Request
California consumers may submit a request to exercise any of their rights describe above using any of the following methods:
• By phone: 1-800-532-6993
• Online by visiting the Communications Preferences page of this Website.
• By contacting us by e-mail at: privacy@tisf.com.
• By postal mail: One Avenue of the Palms, Suite 212, San Francisco, CA 94130 (Attn: Privacy Assurance)
Please note that in order for a request to be verifiable (including verification of your identity and your California residency), you may be required to confirm information that we have on file for you; including email address, phone numbers, full names, addresses and other personal information. We reserve the right to deny a consumer request if the identity or authority of the requesting party cannot be confirmed.
How We Will Respond to a California Consumer Request
We will respond to a verifiable consumer request within forty-five (45) calendar days of receiving it, subject to delays and exclusions permitted by law. If we require more time to respond, we will let you know the reason why and extension period in writing. If you have a Treasure Island Account, we will respond via your Treasure Island Account. If you do not have a Treasure Island Account, please provide either your email address or U.S. Postal address, at your option. Our response will cover the twelve (12) month period preceding our receipt of the request. If we cannot comply with all or part of your request, we will explain the reasons why. 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 readily from one entity to another entity.
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.
Protection from Discrimination for Exercising California Consumer Rights
We will not discriminate against a California consumer for exercising any of the rights described in this section. This means that except as legally permitted we will not:
• Deny you goods or services.
• Charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
California Rights under “Shine the Light” Law
If you are a California resident, you may request a list of the types of customer information we provided to third parties for their direct marketing purposes and the names and addresses of all third parties with which we have shared such information during the past calendar year. We will provide the information to you free of charge within 30 days of your request. To request that we provide you with such information, please send a written request to privacy@tisf.com. Within thirty (30) days of receiving your request, we will provide you with the information at the address you designate in your request, which may be an email address or physical address.
For European Economic Area (EEA) and Other International Visitors
TI Group operates in the United States and follows the information and consumer protection laws of the United States and its individual states. If you reside or are located in a different country, the data protection laws of that country may differ as to what, and how, personal information is protected. We want you to understand that when you provide your personal information to us, or we obtain your information through our Online Services or other communications with us, you are giving us your express consent to the transferring your personal information and processing your information in the United States, subject to U.S. laws and the terms of this Privacy Policy.
Please contact us to make the following requests regarding your personal information. We may require verification of your identity before acting on your request:
• Restrict our use of your personal information and transfer of your personal information to TI Group-affiliated companies or non-affiliated third parties (including profiling to the extent that it is related to our marketing activities) as described above in “Opt-in/Opt-out Procedure.” You may submit your instructions using the Opt-In/Opt-Out form or by visiting the Communications Preferences page of this Website.
• Withdraw your consent to the processing of your personal information (after receiving your notice of withdrawal of consent) for any purpose other than implementation of pre-contractual measures or performance of a contract currently underway by notifying us at privacy@tisf.com, or by mail to TI Group at the address below (Attn: Privacy Assurance)
• Request access to your personal information and request that we provide you with your personal information in machine readable form;
• Request that we correct or update personal information that we may hold; or
• Request us to delete personal information; and we will make reasonable efforts to do so.
Privacy Rights In Other Jurisdictions
You may have rights, under applicable data privacy laws, to request information about or access to the personal information that we hold about you, to require that information be corrected if it is inaccurate or, in some circumstances, to object to our processing of your personal information. If you wish to exercise those rights, please send a written request to privacy@tisf.com.
Privacy Rights of Minors
Our Online Services are not directed to persons under 18 years of age and we do not knowingly collect or sell personal information from persons under 18 years of age without appropriate parent or other consent. If we learn that personal information from individuals less than 18 years of age has been collected without appropriate consent, we will take reasonable measures to promptly delete such data from our records. If you become aware of any personal information we have collected from children under age 18, please contact us as explained below under “How to Contact Us.”
Privacy Policies of Linked Sites and Advertisers
Our Website may contain links to other sites, as well as advertisements from companies linking to their own sites. We are not responsible for the privacy practices or the content of such sites. If you have any questions about how these other sites use your information, you should contact them directly.
How to Contact Us:
If you have any questions about this Privacy Policy, or you want to obtain more information about TI Group’s privacy practices, please contact us:
By email: privacy@tisf.com
By U.S. Postal Mail: One Avenue of the Palms, Suite 212, San Francisco, CA 94130
Changes to Our Privacy Policy
TI Group may at any time and without prior notice revise this Privacy Policy, its Terms and Conditions, or it Legal Disclaimers, by updating the applicable information and posting it on our Online Services. By using any Online Service, you are bound by all such revisions and should therefore periodically visit our Online Services to review the current terms and conditions, privacy policy and legal disclaimers to which you are bound.
This Privacy Policy, the Terms and Conditions, and the Legal Disclaimers posted on this Website do not apply to any TI Group-affiliated company that posts different terms and conditions, privacy policy, or legal disclaimers on its own websites. Such different privacy policy, terms and conditions, and legal disclaimers shall control for purposes of the TI Group-affiliated company in the event of any conflict with this Privacy Policy or the Terms and Conditions or Legal Disclaimers on this Website.
By using our Online Services or providing your personal information to us after receiving a copy of this Privacy Policy, you are giving your consent to the provisions of this Privacy Policy.
Copyright © 2023 Treasure Island Community Development Group, LLC. All rights reserved.
Void where prohibited by law.
The Treasure Island logo is a registered service mark of Treasure Island Community Development, LLC, or a subsidiary.
Copyright © 2023 Treasure Island Community Development Group, LLC.
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