Privacy Policy

This Privacy Policy is a part of the Terms of Use, the Membership Terms, and any other agreements or policies enumerated therein and is hereby incorporated by reference. Capitalized terms utilized but not defined herein shall have the meaning assigned to such term in the Terms of Use or the Membership Terms, as applicable.

INTRODUCTION

The Lodge respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. As used in this Privacy Policy, “The Lodge,” “we” and “us” refers to Tempus Holdings, Inc., d/b/a The Lodge Card Club and each of its subsidiaries and affiliates.

This Privacy Policy (this “Privacy Policy”) describes the types of information we may collect from you in connection with the Services we provide, including but not limited to, your Membership, your access and use of the Facilities and/or other Membership Services, or that you may provide when you visit the website located at www.thelodgepokerclub.com, any of our social media websites, streaming networks, or any other online site hosted or managed by us (collectively, the “Websites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect in connection with the Services we provide, including but not limited to, your Membership, your access and use of the Facilities and/or other Membership Services, and on the Websites and in email, text, and other electronic messages between you and us offline or the Websites. It does not apply to information collected through any other means, including on any website operated by any third party or by any third party that may link to or be accessible from or on the Websites.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not use the Services or the Websites. By accessing or using the Services or the Websites, you agree to the terms of this Privacy Policy. This Privacy Policy may change from time to time as described below. Your continued Membership or use of the Services or the Websites after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

1. Information We Collect

We collect 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 consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records;

• Deidentified or aggregated consumer information;

• Information excluded from the scope of the California Consumer Privacy Act of 2018 (“CCPA”), like:

o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and

o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from our users within the last twelve (12) months:

Category	Common Examples
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number and other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, social security number, physical characteristics or description, address and telephone number. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability or sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).
D. Commercial information	Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Usage Data	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Geolocation data	Includes location information about a particular individual or device. For example, if you check into one of our Services.

H. Audio, Video and Electronic Data	Includes audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV footage (e.g., collected from visitors to our Services), photographs and images (e.g., that you provide us or post to your profile) and call recordings (e.g., of customer support calls).
I. Biometric Information	Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity. For example, if you chose to do so, we may use fingerprint scanners for fraud detection and authentication purposes when you enter our Services
J. Inferences	Includes inferences drawn from other personal information that we collect to create a profile reflecting an individual’s preferences, characteristics, predispositions, behavior, abilities or aptitudes. For example, we may analyze personal information in order to identify the offers and information that may be most relevant to customers, so that we can better reach them with relevant offers and ads.

We collect this information:

• When you apply for your Membership, either at The Lodge property or via the Stie or visit The Lodge property;

• When you check-in at The Lodge property;

• When you utilize the Game Management System (as defined below); • Register for or a reserve a spot in a tournament or other activity;

• Automatically as you navigate through the Websites, which information may include usage details, IP addresses, and other information collected through cookies, web beacons, and other tracking technologies;

• When you purchase, order, return, exchange or request information about our products and Services offline or while using the Websites;

• When you register for or otherwise participate in interactive features on the Websites;

• When you sign up for our e-mails, mobile messages, or social media notifications;

• When you enter a contest or sweepstakes, respond to one of our surveys, or participate in a focus group;

• When you provide us with comments, suggestions, or other input;

• Via CCTVs in the common area of the building and at the building entrance for security purposes and Livestream events;

• When you communicate with us or our team, audio or video is recorded, or details of communicating with us may be recorded by other means; and

• Directly from you when you otherwise provide it to us.

The types of personal information we collect depend on your level of engagement with the Websites. The higher the level, the more personal information we require to provide our Services.

Personal Information We Collect Across All Websites

From registered and unregistered users of the Websites, we automatically receive and record personal information whenever you interact with the Websites. This includes IP address data from our server logs, cookie information, the pages you request, and the URL of the site you visited before the Websites. Your IP address serves the same function if you are using our website.

Personal Information We Collect from Registered Lodge Account Users (including Registered App Users)

If you are registered for an account through the Websites, we are required to obtain your name and email address in order to allow you to access the full Websites. You give us this information when you create your account with The Lodge (“Lodge Account”). When you give us this information at one of our events, or upon request, we will create your Lodge Account for you and this Privacy Policy and our Terms of Use apply. In addition, when you are signed in to your Lodge Account and using it through Facebook, Twitter, YouTube or any other third-party authorization service, we may make use of the data that they provide us to further customize your experience through the Websites.

Personal Information We Collect For Membership

When you submit a membership application, we will ask for your name, address, email, driver’s license or other accepted form of identification, and other information pertinent to the Services. We will also ask some questions so that our front desk staff can verify your identity. When you arrive at The Lodge property, the front desk staff will ask you to verify your identity, and may even ask for a photo ID. At this point, your relationship with us is not just online.

2. How We Use Your Personal Information

We use your personal information to communicate with you about your Membership or our Services. You may also subscribe to Alert Emails with respect to the Services. If you opt-in to also receive marketing email messages, we may send you The Lodge-related news, surveys or promotions. If you do not want to receive alerts or marketing email from us, please click the unsubscribe link in the bottom of the unwanted email.

We also use personal information that we collect about you or that you provide to us, including any personal information, to:

• Set up your Membership;

• Process payments for the Services and your Membership (including credit card, debit card and bank account debit (ACH) transactions;

• Process and analyze any other benefits associated with The Lodge’s business operations, such as for setting up and managing accounts, delivering marketing communications and educational activities, research, preparing statistics, surveying, researching and developing products and services, improving services, preparing and delivering marketing or advertising information with The Lodge or its Affiliates or for relevant targets including content delivery, advertising and public relations, activities and promotions as well as providing appropriate advice in order to customize services to meet your interests, personalize business content, or user experiences, prevent fraud as well as complying with the law and internal audit requirements

• Contact you via social media network, telephone, SMS, e-mail, postal mail, or through any other channel for inquiries or informing you of or checking and verifying your membership account information or feedback survey or informing you of information related to our services to the necessary extent;

• Ensure that the Services are used in an orderly manner and in accordance with the applicable laws, rules and regulations including for compliance with legal obligations and rules relating or applicable to The Lodge both now in force and those to be amended or added in the future;

• Fulfill and manage purchases, orders, payments and requests for information;

• Deliver newsletters, emails and mobile messages including, for example, by push notification or other mobile communications;

• Send marketing communications and other information regarding products, services and promotions;

• Improve the effectiveness of the Websites, website, stores, mobile experience and marketing efforts;

• Develop products and services and increase efficiency in providing services to you; • Conduct research and analysis, audits, including focus groups and surveys; • Administer sweepstakes and contests;

• Track your use of The Lodge Services;

• Make reservations and monitor status and availability of games via the Game Management System (as defined below).

• To prevent or avoid any danger to your life, body or health including your property or where it is necessary for us to perform our duties for the public interest or for exercising the power of the state given to us or our employees or representatives or to comply with the law;

• For security monitoring for our members, staff and contractors;

• Prevent fraudulent transactions and monitor against illegal activity and fraud;

• Assist law enforcement, respond to subpoenas, and to comply will all applicable governmental regulations and adhere to The Lodge compliance standards in connection with applicable laws, regulations, standards and best practices mandated or recommended arising out of The Lodge’s business or provision of the Services; and

• For any other purpose with your consent.

In addition, we may use the User-ID feature of Google Analytics to help us enhance your user experience. User-ID would let us associate a persistent ID for you with your engagement data from one or more sessions initiated from one or more devices. This ability to connect your contacts with us into a single thread would also provide us with a more unified, holistic story about your relationship with our business. We would use information received through our use of User-ID in the manner described above. If you would like to opt-out of our use of this service, you may do so by following the instructions found under “Updating Personal Information” below.

3. Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

• To our personnel in the normal course of business;

• To our affiliates, in which case we will require our affiliates to honor this Privacy Policy;

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Websites’ users is among the assets transferred;

• To third parties for purposes of marketing our products or services that may be of interest to you, in which case we may combine the information that you give us and information about your site usage with other personally identifiable information (such as demographic information and past purchase history) available from our records and other sources and, when we disclose your information to these third parties, they are not allowed to use your information for any purpose other than supporting and promoting our Services and Websites;

• With certain business partners to provide requested services that we do not provide directly, including but not limited to, our vendor Overlay Gaming Corporation which provides online real-time game status, player waitlists, run tournaments, and other information accessed through pokeratlas.com and updates thereto (the “Game Management System”);

• To fulfill the purpose for which you provide it; and

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, regulation, banking requirement, beneficial owner/affiliate/business associate inquiry, standard, or legal process, including to respond to any government or regulatory request;

• To enforce or apply our Terms of Use and the Membership Terms (including any Club Policies); and

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers or others.

We may also disclose aggregated information about our users and members, and information that does not identify any individual, without restriction.

In the preceding twelve (12) months, we have disclosed personal information to our third party vendor, Overlay Gaming Corporation to process in accordance with the system integration with the Game Management System The Lodge reserves the right to, any you agree that The Lodge and its affiliates may release your detail to system administrators at other sites in order to provide vendor services and to law enforcement agencies in order to assist them in resolving security incidents and violations of the law.

When you access internet available in our Services via wireless hotspots, such in-club wireless access is provided by third parties and not by The Lodge, and we do not collect any information in relation to your use of the in-club wireless access. We are not responsible for your data security transmitted over such in-club wireless internet or such third party’s privacy, information or other practices.

4. Our Use of Tracking Technology

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Website or access online subscription materials. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to any website used as part of the Website.

• Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Managing Your Personal Information” below.

• Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

When you use the Website, we may, after receiving your express consent, place one or more cookies in your browser. These are required to enable to hold session information as you navigate from page to page within the Website. In addition, we use cookies through the Website to understand visitor and user preferences, improve their experience, and track and analyze usage, navigational, and other statistical information.

Because we respect your right to privacy, you can choose not to allow some types of cookies by changing your web browser default settings to remove cookies and to reject cookies. However, if you choose to remove cookies or reject cookies, this could affect certain features of our Website and the Services.

5. Our Retention of Your Information

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. Payment Transactions

You acknowledge and agree that any credit and debit card transactions conducted through the Website will be processed using a Third-Party Processor and, in connection with such payment transactions, your personal information including personal information relating to your credit or debit card account will be transmitted to such Third-Party Processor. By submitting your credit or debit card information in connection with a payment transaction, you authorize such Third-Party Processor to charge your credit card for the amount and frequency indicated and agreed upon. We require that any Third-Party Processor processing payments is compliant with FERPA and the GLB Act.

7. Our Protection of Your Information

We store the information we collect from you in the United States. If you are located outside the United States and choose to use our Services or Websites, we may store and process the information you provide to us in the United States. We take appropriate administrative, physical and electronic measures designed to protect the information that we collect from or about you from unauthorized access, use or disclosure. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will attempt to protect your personal information, transmission of personal information to and from the Websites is at your own risk. You should only access the Websites within a secure environment.

8. Children

The Websites are intended for use by adults. The Websites are not designed nor intended to collect personal information from children under the age of thirteen. So that we may comply with the Children’s Online Privacy Protection Act, we ask that children under the age of thirteen not provide any personal information on the Site. If a child under the age of thirteen has provided us with personal information, we ask that a parent or guardian contact us at the email address provided below. Please mark your inquiries “COPPA Information Request.”

Parents should always supervise their children while online.

9. Managing Your Personal Information

You may manage your personal information by making certain choices. You have the right to (a) access, review and correct your personal information we have on file, (b) request that we delete your personal information we have on file, (c) object to any information that we may collect related to your personal information we have on file, and (d) withdraw your consent given to us to gather your personal information. You may also have additional rights detailed below depending on where you live. If you wish to enforce any of the foregoing rights, please submit a written request to info@thelodgecardclub.com. Upon receiving such written request, we will take commercially reasonable steps to provide you with an opportunity to access, delete, object to, or withdraw your consent to the gathering of your personal information.

10. Do Not Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do­Not­Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice

in a revised version of this Privacy Policy.

11. NOTICE OF FINANCIAL INCENTIVE

We may offer Promotions (as defined in the Terms of Use) and other programs, benefits, and offerings to consumers related to the collection, retention, or sale of personal information that may be deemed a “Financial Incentive” or “price or service difference” under the CCPA. These offerings may involve collecting the following categories of personal information from customers who participate: identifiers; customer records; protected class and demographic information; commercial information and preferences; internet or other electronic network activity information and device information; audio, electronic, visual, or other sensory information; and inferences. We are providing you with this information so that you may make an informed decision on whether to participate in our Promotions and other programs, benefits and offerings. Examples of the programs we offer include:

• Loyalty Programs or Memberships: From time to time, we may offer one or more reward/loyalty programs or memberships where customers may be able to earn rewards, accumulate points on purchases, access exclusive promos, and be the first to know about new products and limited releases. Such members or participants may also receive promotional offers, such as free products, discounts, coupons, and opportunities to participate in other promotions. As part of such programs or memberships, we may collect personal information, such as your name, email address, phone number, and date of birth. We will post the material terms of the program for your review which will be linked in any sign-up pages on the Website for your review. You may cancel your membership or participation at any time by contacting us at info@thelodgecardclub.com Our good-faith estimate of the value of your personal information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.

• Surveys: We may also offer our customers opportunities to participate in surveys. In exchange for participation, you may be offered financial incentive, such as a discount or coupon. As part of these surveys, we may collect personal information, such as your name, preferences, experiences, beliefs, opinions, and other responses to the survey questions. Participation in surveys is governed by the applicable terms and conditions for the survey, which will also describe any financial incentives associated with that survey and how to participate. You can terminate participation at any time as will be explained in the survey terms. Our good-faith estimate of the value of your personal information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.

• Limited-Time Promotions or Sweepstakes: From time to time, we may offer incentives limited to a specific time period, such as limited-time sweepstakes, contests, and other promotions. In exchange for your participation in these

promotions, you may be offered a financial incentive, such as a prize. As part of these limited-time promotions or sweepstakes, we may collect your personal information, such as your name, email address, and phone number. Participation in a limited-time offer or promotion is governed by the applicable terms and conditions for the program (e.g., Promotion Official Rules and Prize Acceptance Agreements), which will also describe any financial incentives associated with the program and how to participate. You can terminate participation at any time as will be explained in the program terms. The value of your personal information will be disclosed in the applicable promotions terms and conditions.

• One-Time Promotions: In addition to the programs identified above, we may also offer you a one-time percentage off coupons, discounts, or other promotions from time to time, such as when you provide us your email address and agree to receive marketing emails in exchange for a one-time coupon. Such offers may not be available at all times. The amount and terms of such offers will be presented to you at the time of the offer. You can terminate participation at any time by contacting us at info@thelodgecardclub.com. Our good-faith estimate of the value of your personal information is the value of the benefit we offer to you. We have calculated such value by using the expense related to the benefit.

Each financial incentive or price or service difference related to submission and use of customer personal information is based upon our reasonable but sole determination of the estimated value of such information, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under the CCPA.

By participating in any of the above Promotions and other programs, you agree that the benefits are reasonably related to the value of the personal information collected and retained.

Participation in our Promotions and other programs is always optional, and you can terminate participation at any time as explained in the applicable Promotion or program terms. You can also contact us at info@thelodgecardclub.com to unsubscribe or cancel your participation in any Promotion or other program.

12. Notices for California Residents

This Section 12 applies to applies to all users who reside in the State of California and is adopted to comply with the CCPA. This Section does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:

• The categories of personal information we collected about you;

• The categories of sources for the personal information we collected about you;

• Our business or commercial purpose for collecting or selling that personal information;

• The categories of third parties with whom we share that personal information;

• The specific pieces of personal information we collected about you (also called a data portability request);

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o sales, identifying the personal information categories that each category of recipient purchased; and

o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written

warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);

• Debug products to identify and repair errors that impair existing intended functionality;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

• Comply with a legal obligation; or

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us an email at info@thelodgecardclub.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent please e-mail us at the email address provided below and provide your name and phone number as well as the authorized agents’ name and contact information (phone number or email address) and let us know what the scope of the authorized agents’ rights are to act on your behalf. If your authorized agent requests sensitive information about you then we may ask you to provide us with a sworn declaration to further verify your identity.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your full name, email address, phone number and zip code.

• Describe your request with sufficient detail that allows us to properly understand,

evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more than ninety (90) days, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12)-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unreasonable. 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.

Personal Information Sales Opt-Out Rights

If you are sixteen (16) years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than sixteen (16) years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between thirteen (13) and sixteen (16) years of age, or the parent or guardian of a consumer less than thirteen (13) years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by sending an email to info@thelodgecardclub.com with the title “Do Not Sell My Personal Information”.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us at info@thelodgecardclub.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you 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.

“Shine the Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

13. ADDITIONAL NOTICE TO CERTAIN OTHER U.S. RESIDENTS

If you are a resident of certain U.S. States, you may have some or all of the following rights. Specifically, these states include Nevada, Virginia, Colorado, Connecticut, Utah and Iowa. These rights are based on verifiable residency status, and we reserve the right to honor your request to exercise these rights based on your residency. You may have the right to request the following: (i) that we disclose and provide a copy of what personal information we collect, use, disclose and sell; (ii) that we delete your personal information, subject to certain exceptions; (iii) that we correct inaccurate or incomplete personal information; (iv) opt-out of the sale of personal information; (v) opt-out of targeted advertising; (vi) opt out of profiling in furtherance of decisions that produce legal or other similarly significant effects about you; and (vii) not receive discriminatory treatment by us for exercising these rights.

To make such a request, please submit a verifiable consumer request to us by sending us an email at info@thelodgecardclub.com.

14. ADDITIONAL NOTICE TO CANADA RESIDENTS

We may use service providers located outside of Canada, including, without limitation, in the United States of America, to process personal information, and may transfer your personal information to such service providers for this purpose. When your personal information is processed outside of Canada, it will be subject to the laws of the countries where the information is processed and may be accessible to law enforcement and national security authorities of those countries in accordance with their laws.

You may contact us by sending us an email at info@thelodgecardclub.com to obtain information about our policies and practices regarding the use of service providers located outside of Canada.

If you live in Canada, in addition to the other rights you may have hereunder, you may have the right to (i) request access to, review and to correct inaccuracies or omissions in your personal information; (ii) to withdraw consent for collection, use or disclosure of, or to request deletion of, your personal information (provided that, if you do so, we may no longer be able to provide services to you that rely on such personal information); (iii) to ask questions about our policies and practices, and to lodge complaints about our compliance with them with us or with regulatory authorities; and (iv) for Quebec residents, to request an electronic copy of the personal information you have provided to us in a structured and commonly used technological format.

To make such a request, please submit a verifiable consumer request to us by sending us an email at info@thelodgecardclub.com.

15. ADDITIONAL NOTICE TO EUROPEAN ECONOMIC AREA (“EEA”) AND UNITED KINGDOM RESIDENTS

If you are visiting the Website or are using the Services from within the EEA or United Kingdom for your own personal purposes, your data controller for the purpose of the UK General Data Protection Regulation (the “UK GDPR”) and the EU General Data Protection Regulation (the “EU GPDR” and together with the UK GDPR, the “GDPR”) is us, Tempus Holdings, Inc.

If you are visiting the Website or are using the Services in connection with your employment from within the EEA or United Kingdom, your employer is your data controller for the purposes of the GDPR, and we are the data processor collecting and using that data only to provide the Services to your employer. Your employer may have their own privacy notices that will apply to your use of the Services, and will have access to your usage information.

For the avoidance of doubt, the term “process” for the purposes of this Privacy Policy shall have the same meaning as it is given in the GDPR.

Grounds for Collecting Personal Information

We rely on the following lawful bases to process your personal information for these non exhaustive purposes:

Consent: We may obtain your consent to process your personal information in certain circumstances, which may include when we send you relevant marketing, when you elect to receive information from us, or when you contact us to register an interest in the Services or our The Lodge. We may also rely upon our legitimate interest in developing our business as a basis for sending you marketing information and information about the Services (see below).

Performance of a Contract: We rely on this lawful processing ground when we process your personal information to perform a contract which we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection with the provision of the Services to you and the management of our relationships with third parties.

Compliance with a Legal Obligation: We rely on this lawful processing ground when we process your personal information to meet legal and regulatory obligations which apply to us.

Legitimate Interests: We rely on this lawful processing ground when we process your personal information to provide the Services, to respond to specific requests, to manage our business operations, to manage our relationships with you and with third parties in connection with our business, and when we provide you with marketing information or other information in relation to the Services which we believe may interest you.

If you wish to have more information regarding the legitimate interests assessments we have conducted in order to reach these conclusions, please contact us at info@thelodgecardclub.com.

For information about how users based in the EEA and United Kingdom can object to our automated decision-making, see “Managing Your Personal Information” above. For more information, please contact us at info@thelodgecardclub.com.

Disclosure of Personal Information to Third Parties

We share your information with a number of third parties, described below, that process and store data related to how you interact with the Website and utilize the Services. Use of such third-party services is governed by such parties’ respective terms of use and privacy policies as described below. We will not submit your data to any third parties except as described in this Privacy Policy.

We use: (1) cloud storage providers, including AWS, located in the United States to store the personal information you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you; and (2) service providers, such as our

Third-Party Payment Processor, to process payments for the Services and Membership and Overlay Gaming Corporation to manage the Game Management System. The privacy policy of AWS can be found at https://aws.amazon.com/privacy/. The privacy policy of Overlay Gaming Corporation d/b/a PokerAtlas can be found at https://pokeratlas.com/info/privacy.

Safety Measures for Data Transfers and Storage

If we transfer personal information out of the EEA, please be advised that we will take such measures as are necessary to ensure that the transfer is in compliance with the GDPR, which may include but not limited to transferring personal information to a recipient in a country that the European Commission has decided provides adequate protection for personal information, to a recipient in the United States that has certified its compliance with the EU

US Privacy Shield, or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission.

In storing and processing the data, we will implement the technical and organizational measures reasonably necessary to protect the personal information from accidental or unlawful destruction and loss, alteration, unauthorized disclosure of or access to the personal information. We will disclose personal information only to employees and permitted subcontractors as reasonably necessary to accomplish the permitted purpose and shall ensure that any employees having access to the personal information have undergone data protection training and are required to protect the personal information in accordance with these requirements. If we share data with subcontractors, we will require any subcontractor we appoint to protect the personal information in accordance with the GDPR and we will assume liability for any GDPR compliance failure of the subcontractor arising from any act or omission by the subcontractor.

Exercising Your Rights

If you live in the EEA or United Kingdom, you may have the right to (i) request access to, rectification, or erasure of your personal information or restrict the processing of your personal information; (ii) object to processing such personal information; (iii) data portability (receive and transfer your personal information; (iv) lodge a complaint with a supervisory authority; and (v) where processing of your personal information is based on consent, withdraw your consent at any time without affecting the lawfulness of the processing of personal information that occurred before you withdraw consent.

To make such a request, please submit a verifiable consumer request to us by sending us an email at info@thelodgecardclub.com. For more information about how users based in the EEA and United Kingdom can object to our automated decision-making, see “Managing Your Personal Information” above.

16. Updates to This Privacy Policy

We may update this Privacy Policy at any time and from time to time. The updated version will be indicated by an updated “Last updated” date below and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

17. Contacting Us

If you have questions regarding this Privacy Policy or wish to obtain additional information, please send an e-mail to info@thelodgecardclub.com. You can also write to us at: 1401 S. IH-35, Suite 210, Round Rock, Texas 78664.

18. Acceptance of Privacy Policy.

Your access to and use of The Lodge property, the Services, and the Site is subject to this Privacy Policy and all applicable laws. Your use of the Services or access to The Lodge property or the Websites are further subject to the rules set forth in any membership agreement that you sign with us and any rules that are posted on The Lodge property or the Websites, and your use of Services and Website is further subject to the Terms of Use and the Membership Terms. By accessing and using the Services or browsing the Websites, you accept, without limitation or qualification, this Privacy Policy. The Lodge reserves the right to at any time revise this Privacy Policy without prior notice. If The Lodge changes its privacy practices, an updated Privacy Policy will be posted to reflect those changes and the effective date of the revised Privacy Policy (i.e., the “Last Updated” date below) will be set forth therein. You are bound by any such revisions and should therefore periodically visit this Privacy Policy. If you have questions about our privacy practices, or if you would like to request to opt out of future communications from The Lodge business or a particular program, please contact us by clicking on the “Contact” link on our Websites.

Last Updated: November 15, 2023