Privacy Policy

1. General
We know that your privacy is important to you, and we work hard to earn and keep your trust. This Privacy Policy addresses questions about the types of personal information we collect, the third parties with whom we might share such information, and how you can review or change the personal information you provide to us.

Mulligan Investors, LLC (collectively the “Company,” “Mulligan,” “we,” “us” and “our”), respect your privacy and are committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

This Policy describes:

The types of information we collect from you or that you may provide when you visit our website available at: https://www.bearsbestlv.com / (the “Website”), any websites and blogs directly owned by the Company where this Policy is linked, and in-person interactions when you provide information to the Company (“Offline” together with the Website and App, our “Platform”).
Our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies to your use as a user of the Platform, such as a visitor or registered user (“you”). This Policy applies to information we collect on the Platform or in emails and other electronic messages between you and the Platform, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy. This Policy does not apply to information collected by any other website operated by any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Platform (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not provide personal information to the Company Offline or use our Website. By using our Platform, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. Platform Terms of Use
This Policy should be read in conjunction with the Platform Terms of Use, into which this Policy is incorporated by reference.

3. What We Collect and How We Collect It
To ensure that we provide you with the best possible experience, we will store, use and share personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”). In particular, the Platform may collect the following categories of Personal Information from users of the Platform:

Category	Examples	Collected	Disclosed
Identifiers	First and last name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, telephone number, date of birth, and account name	YES	Mulligan and Affiliated Companies. Co-Sponsors and Service Providers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license or state identification card number, automobile insurance policy number, education, employment, employer information, bank account number, credit card number, debit card number, or any other financial information, and medical information that is necessary for special room, dining and other accommodations.	YES	Mulligan and Affiliated Companies. Co-Sponsors and Service Providers.
Protected classification characteristics.	Age, marital status, medical condition (for special room, dining and other accommodations), physical or mental disability (for special room, dining and other accommodations), sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status (for special programs and discounts when available).	YES	Mulligan and Affiliated Companies. Co-Sponsors and Service Providers.
Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	Mulligan and Affiliated Companies. Co-Sponsors and Service Providers.
Sensitive Personal Information.	Precise geolocation (when using a golf cart or the App), Social Security number, driver’s license, state identification card, account log-in, financial account, debit card, credit card number with security, or access code or password, and health and sexual orientation.	YES	Mulligan and Affiliated Companies. Service Providers.
Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO	N/A
Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES	Mulligan and Affiliated Companies. Co-Sponsors and Service Providers.
Geolocation data.	Physical location or movements (when using a golf cart).	YES	Mulligan and Affiliated Companies. Service Providers.
Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO	N/A
Professional or employment-related information.	Current or past job and education history, including information contained in a resume.	YES	Mulligan and Affiliated Companies. Service Providers.
Non-public education information.	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES	Mulligan and Affiliated Companies. Service Providers.
Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES	Mulligan and Affiliated Companies. Service Providers.

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, when you:
register yourself with the Website;
make reservations and tee times;
complete member applications and related forms;
participate in sweepstakes and surveys;
subscribe to one of our e-newsletters;
complete informational cards Offline to request more information from the Company and its clubs, and
communicate with us, such as request information via email or Website form.
Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
Directly and indirectly from activity on our Website. For example, from Website usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Username and Password; Other Sources. Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us.

Aggregated and De-Identified Data. We also collect, use and share Aggregated and De-Identified Data such as statistical or demographic data for any purpose. Aggregated and De-Identified Data could be derived from your Personal Information but is not considered Personal Information in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated or De-Identified Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Policy.

4. Automated Information Collection
Website. In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:

(1) session cookies, which do not stay on your device after you close your browser, and

(2) persistent cookies, which remain on your device until you delete them or they expire.

We may use the following categories of cookies on our Website.

Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items, cannot be provided.

Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.

Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.

Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.
Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

Google Analytics; Pixel. The Website sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance. We may also use pixels provided by Google to ensure that our ads are in line with your interests and do not have a nuisance effect. For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.

Meta Pixel. With the help of the Meta pixel, also known as the Facebook Pixel, Meta is able to determine the visitors of our Website as a target group for the presentation of advertisements. With the help of the Meta pixel, we want to make sure that our ads are in line with the potential interest of users and do not have a nuisance effect. Using the Meta pixel, we can also track the effectiveness of Meta or Facebook ads for statistical and market research purposes. Meta’s processing of the data is governed by Meta’s Data Usage Policy, which is available at https://www.facebook.com/policy.php. For specific information and details about the Meta pixel and how it works, please visit the Meta Business Help Center: https://www.facebook.com/business/help/651294705016616.

Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

App. In addition to the information you provide to us, we may also collect information about you during your use of the App. We collect this information using automated technology. This technology may collect information about your behavior and your device, such as your internet address (IP Address), the pages you have viewed, the actions you have taken while using the App, saved preferences, and log-in Session ID. This information is not personally identifiable or capable of being used to identify you in the scope of this Policy.

5. How We Use Your Information
The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

processing reservations and other transactions that you request;
communicating information regarding club news and operations
providing the information, products and services you request;
security, credit or fraud prevention purposes;
providing you with effective customer service;
providing you with a personalized experience when you use the Platform;
contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
contacting you with information and notices related to your use of the Platform;
inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
better understanding your needs and interests;
improving the content, functionality and usability of the Platform;
improving our products and services;
improving our marketing and promotional efforts;
other business purposes such as better understanding customer needs, enhancing relationships, or making appropriate offers; and
any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.
Duration. The length of time Company intends to retain Personal Information, including sensitive information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.

6. How We Disclose Your Information
We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information for a business purpose to the following categories of third parties:

Mulligan and Affiliated Companies.
Generally, such information is limited to a member’s name, email address, phone number, home club name and any instructions regarding disability accommodations or special requests.
Co-Sponsors. From time to time, we may contract with other companies to provide co-sponsored or co-branded promotions, products and services and may share your information with our co-sponsor. For example, we may co-sponsor some sweepstakes or contests on our Platform with other companies or we may provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your personal information with our co-sponsor or the third-party sponsor.
Service Providers. We rely on service providers to help us offer products and services, including but not limited to, delivery of products and services, fulfilling travel and hospitality packages, communicating news and delivering promotional materials via text, email and direct mail, generating periodic account statements, processing ACH, debit card and credit card payments, administering sweepstakes and surveys, and marketing our products and services to you and others through third party websites and apps.
Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

Legal Reasons.
We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena or court order;
To respond to duly authorized information requests from law enforcement or other governmental authorities;
To enforce our agreements, policies or the Terms of Use;
To investigate and prevent security threats, fraud or other malicious activity; or
To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.
Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

7. Your Choices and Selecting Your Privacy Preferences
We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

If you would like to update your information, modify your communication preferences, or to stop receiving marketing communications from the Company in the future, you can contact the Company in writing by email or postal mail. You may also follow the “opt-out” procedures outlined in the email communication you received. We will process your request as quickly as possible, but you may continue to receive additional promotional communications until your request is fully processed. Please allow up to 10 business days to process your opt-out request.

Despite your request to “opt out” of receiving promotional offers from us or from third parties, we may continue to communicate with you by email, letter or other means to provide general information or service-oriented messages as described above from time to time.

8. Text Messaging
You may have the opportunity to receive SMS or “text” messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

9. Accuracy and Access to Your Personal Information
We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always verify your identity, such as asking you for a username and password, to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

10. Information of Minors
We do not intentionally seek to gather information from individuals under the age of 16. We will only obtain the Personal Information of individuals under the age of 16 from a parent or legal guardian. By providing information of an individual under the age of 16, the parent or legal guardian represents to the Company that such person is doing so knowingly and in accordance with all lawful consents and authorizations under applicable law. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the Internet. If we are aware of any Personal Information that we have collected from minors, we will take steps to securely remove it from our systems.

11. Submissions
We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, ideas, materials, comments or other information you provide to us (collectively, “Submissions”) will be treated as non-proprietary and non-confidential. Your Submissions on or through the Platform are available to others who visit the Platform. In addition, we may use your Submissions in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Submissions for such purposes. Therefore, you should have no expectation of privacy with respect to your Submissions on or through the Platform. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Submissions comply with our Terms of Use or other applicable agreements. All terms and conditions of our Terms of Use apply to Submissions on or through the Platform. In particular, your Submissions must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Submission.

12. Third-party Websites
This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website and App may link to third-party websites and services, including partners, advertisers, and sponsors. For example, if you click on an advertisement on the Platform, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

13. Your Rights Under State Law
California

Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

Do Not Track Signals. Other than as disclosed in this Policy, the Website and App does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Website and App does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.

WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.

Your Consumer Rights.

Some states in the United States provide consumers with additional rights with respect to their Personal Information, as that term is defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018 (the “CCPA”) as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your Personal Information, you may exercise each of your rights as identified below, subject to our verification of your identity.

Access. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Correction. You can correct what Personal Information our Platform database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any Personal Information that you have provided to us.

Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information. In your request, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information. When such prohibitions are not possible to provide our services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.

Portability. Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.

Deletion. You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.

Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.

Non-Discrimination. If a data subject exercises his or her rights under applicable state law, including but not limited to the CCPA, CPA, and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.

Exercising your rights. If you are a data subject that has rights under applicable state law, including but not limited to the CCPA, CPA and VCDPA, who chooses to exercise the rights listed above, you can:

Submit a request at the following address:
Mulligan
1111 W. Flamingo Road
Las Vegas, NV 89135
Attn: Legal Department/Consumer Privacy

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within 45 days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

14. Location of Services
Our Platform is designed for use by individuals in the United States, Mexico and Canada. We do not warrant or represent that this Policy or the Platform’s use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

15. Safeguarding the Information We Collect
We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us of any actual or suspected unauthorized use.

16. Employment at Mulligan
We use private and third-party databases and tools hosted by third parties on their websites to collect information from individuals that provide information to be considered for potential employment. Information you provide to us via these private label services is accessible toMulligan. We will not use the information you provide for any purpose other than to allow you to conduct automated job searches or determine your qualifications for potential employment with Mulligan except as otherwise permitted by this Policy.

17. Changes to this Policy
This Policy describes our current policies and practices with regard to the information we collect through the Platform. We are continually improving and adding to the features and functionality of the Platform along with the products and services we offer through the Platform. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

18. How to Contact Us
We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at:

Mulligan Investors, LLC
1111 W. Flamingo Road
Las Vegas, NV 89135

Attn: Legal Department/Consumer Privacy

Revised July 2024