Privacy Policy

This Privacy Notice informs you about the types of personal information collected
through Santa Rosa Golf & Beach Club (“we, our or us”) website (“Web Site”), and how we use, share
and protect that information.

Applicability of this Privacy Notice.

This Privacy Notice applies to the personal information we collect on this Web Site
(at and not to any information that we collect through other
methods or services, including websites owned or operated by our affiliates,
vendors or partners.

Information You Provide to Us.

We may collect and store personal information that you choose to voluntarily
provide to us when you contact us, such as when you contact us for business
purposes or in relation to a job application. Personal information may include your
name, email address, telephone number, and your resume. We use the information you
provide to respond to your request or question or to process your application for
employment. We may also use the information to communicate with you about other
topics that we think may be of interest to you.

Information We Collect by Automated Means.

We are committed to making your online experience with our Web Site informative and
relevant. To achieve this, we collect certain information by automated means when
you visit this Web Site, such as your IP address, the type of internet browser you
are using, operating system, referring URLs, information on actions taken on the
Web Site, how many users visited our Web Site and dates and times of Web Site
visits. By collecting this information, we learn how to best tailor this Web Site
to our visitors. We collect this information by various means, as explained below.


Cookies are bits of text that are placed on your computer’s hard drive or Internet-
connected device when you visit certain websites. Cookie technology hold
information a site may need to personalize a visitor’s experience. Cookies may also
be used for security purposes and to gather website statistical data, such as which
pages are visited, what is downloaded, and the paths taken by visitors to our
website as they move from page to page.
You do have control over cookies, and can refuse the use of cookies by selecting
the appropriate settings on your browser. Note, however, that by not accepting or
deleting the use of cookies, you may affect your website experience and you may not
be able to take full advantage of all features on this Web Site. Most browsers will
tell you how to stop accepting new cookies, how to be notified when you receive a
new cookie, and how to disable existing cookies. Please consult the “Help” section
of your browser for more information.

Google Analytics.

We may also use third-party web analytics services on this Web Site, such as Google
Analytics. Google Analytics uses technologies such as cookies to help analyze how
users use this website. The information generated by the cookie about your use of
this Web Site (such as your IP address, the URL visited, the date and time the page
was viewed) will be transmitted and stored by Google on servers in the United
States. Google will use this information to monitor your use of this Web Site,
compiling reports on website activity for website operators and providing other

services related to website activity and internet usage. Google may transfer this
information to third parties where required by law, or where such third parties
process information on Google’s behalf. For more information about Google’s privacy
policy in respect of Google Analytics, please refer to You may opt out of Google
Analytics by visiting

How We Use the Information We Collect.

We may use the information we obtain about you both to further our relationship
with you and for other purposes, including to:
process, evaluate and respond to your requests and inquiries;
verify your identity to ensure security for the other purposes listed here;
operate, evaluate and improve our business (including developing new services;
managing our communications; learning about our visitors, analyzing our services
and website; and facilitating the functionality of our website);
process applications for employment;
perform data analyses (including anonymisation of personal information);
enforce our Terms of Use
comply with applicable legal requirements and industry standards and our policies
We may use personal information for other additional purposes. We will identify
these additional purposes at the time of collection.

Sharing Information.

We do not sell or otherwise disclose personal information we collect about you,
except as described herein or otherwise disclose to you at the time the data is
We also may share information provided by our visitors to this Web Site with
service providers we have retained to perform services on our behalf, including
without limitation, hosting or operating this Web Site, carrying out your requests,
responding to your inquiries, and analyzing data. We require these service
providers by contract to appropriately safeguard the privacy and security of
personal information they process on our behalf.
We may disclose information about you as compelled or required by law, to law
enforcement authorities or other government officials, to protect or defend our
legal rights, or in order to investigate, prevent or take action regarding illegal
activities, suspected fraud, or violations for our Terms and conditions for using
this Web Site or other applicable policies.
We also reserve the right to transfer personal information we have about you in the
event that we sell or transfer all or a portion of our business assets.

Data Transfer.

We may transfer the personal information we collect on this website to other
countries other than in which the information was originally collected. Those
countries may not have the same data protection laws as your country of residence.
Currently, job applicant data may, in certain circumstances, be hosted by our
service provider located in the United States and who has certified compliance to
the Department of Commerce’s US/EU and US/Swiss Safe Harbor Frameworks. Your job
application and any additional information you provide to us when applying for a
position will be used for the purpose of processing your application for employment
and possibly to determine whether you would be suitable for other positions within
Company. Company may share job applicant data with its affiliated agencies in
around the world. Your job application and any additional information you provide

to us when applying for a position will be used for the purpose of processing your
application for employment and possibly to determine whether you would be suitable
for other positions within Company. Company may share job applicant data with its
affiliated agencies in around the world. By submitting your personal data, you
consent to this transfer. When we transfer your personal information to other
countries, we will protect it as described in this Privacy Notice.


The security of information is important to us, and we are committed to using
reasonable measures to protect the personal information we may collect. However,
due to the inherent open nature of the Internet, we cannot guarantee that
communications between you and us or the information stored on this Web Site is
absolutely secure.

Links to Other Websites.

This Web Site may provide links to other websites for your convenience and
information. These websites may operate independently from us. Linked sites may
have their own privacy notices or policies, which we strongly encourage you to
review to better understand their procedures for collecting, using and disclosing
personal information. We are not responsible for the content of the linked
websites, any use of these sites, or the privacy practices of these sites.


This Web Site is not intended for children and we do not knowingly solicit personal
data from or communicate with children under the age of 13. Further, this Web Site
is not intended for incapacitated persons, and we do not knowingly solicit personal
data from individuals who are incapacitated. If you become aware that your child,
any child under your care, or a person otherwise not able to provide valid consent
has provided us with information without a parent or guardian’s consent, please
contact us as described below.

Access, Updates and Your Choices.

You can tell us at any time not to send you marketing communications by email by
clicking on the unsubscribe link within the marketing emails you receive from us or
by contacting us as indicated below.
If you have provided us with personal information, you may request that it be
updated, modified or deleted. You may do this by sending your request to the
following addresses:
For inquiries relating to our London office:
For inquiries relating to our Rio office:
For inquiries relating to our U.S. offices:
For inquiries relating to our Singapore office:
By using this Web Site, you consent to the processing of your personal information
as described in this Privacy Notice.

Contacting Us.

If you have any questions about this Privacy Notice or our privacy practices,
please feel free to email us at or write to us at:

45 Main Street
Suite 220
Brooklyn, NY 11201
Attn: Rebecca Guthrie

Changes to this Privacy Notice.

We reserve the right to change or add to this Privacy Notice from time to time and
will post any revisions on this Web Site. We will indicate at the bottom of the
Privacy Notice when it was most recently updated. We encourage you to check back
often to review the latest version.
Privacy Notice Effective Date: June 1, 2016