Privacy Policy

For The Villages Website and Mobile Application

Last modified: May 1, 2022

Introduction

Holding Company of The Villages, Inc. together with its affiliates (collectively “The Villages Companies” or “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website thevillages.com and thevillages.net and any other website that includes a link to this policy on its home page or about us page, (collectively our “Websites”) or use our mobile application (“The Villages App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On our Websites or through The Villages App.
• In email, text, and other electronic messages between you and The Villages Companies.
• Through any other mobile and desktop applications you download from our Websites.
• Telephone and in-person communications with us.

It does not apply to information collected by:

• Any Community Development District (a “CDD”), any Lifestyle Group or club, or any website or software provided or managed by them; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website; or
• Information collected by other means not listed above.

Please read this 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, your choice is not to use our Websites or The Villages App. By accessing or using the Websites or The Villages App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of our Websites or The Villages App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. If you do not agree to any such change, you may stop use of the Websites and The Villages App.

Specific Policies

If you purchase or lease a property in the community, or do business with a company in the community, you may be subject to a more specific privacy policy or more specific terms relating to collection and use of your information (collectively “Specific Policies”). For example, when closing on a property, you may be given a Specific Policy in connection with the purchase, an insurance policy, or a loan. This policy is intended to address information that is not otherwise subject to a Specific Policy. If you agreed to, or were notified of, a Specific Policy at the time you provided or updated personal information, then that Specific Policy controls the collection and use of the information you provide or update at that time, and nothing in this policy will modify, limit or be subject to any of the terms and conditions of that Specific Policy. Similarly, nothing in any Specific Policy will modify or limit the terms and conditions of this policy. Stated differently, this policy only applies to information collected (i) by our Websites, (ii) by The Villages App, or (iii) in interactions with us where a Specific Policy does not otherwise apply.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us by mail at:

The Villages Office of the General Counsel
3619 Kiessel Rd.
The Villages, FL 32163

or by email at legal@thevillages.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Websites and The Villages App, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
• That is about you but individually does not identify you, such as your preferred activities; and/or
• About your internet connection, the equipment you use to access our Websites and facilities, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through our Websites or The Villages App. Information collected automatically may include usage details, IP addresses, and information collected through cookies. In certain situations, The Villages App may also collect your location within the community.
• From third parties, for example, our business partners or local businesses or CDDs.

Information You Provide to Us

The information we collect on or through our Websites and The Villages App may include:

• Information that you provide by filling in forms on our Websites or in The Villages App. This includes information provided at the time of registering to use our Websites or installing and configuring The Villages App, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you participate in an event or enter a contest or promotion sponsored by us, and when you report a problem to us.
• Records and copies of your correspondence (including email addresses), if you contact us or choose to do business with us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Websites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on our Websites or submitted to The Villages App.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Websites, or transmitted to other users of the Websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we reserve the right to limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our Websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Examples of User Contributions include, but are not limited to, any reviews or comments you post to any of our Websites, and any photos or videos you choose to upload to those Websites.

Information We Collect Through Automatic Data Collection Technologies

Like most other websites you visit, as you navigate through and interact with our Websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Websites and The Villages App, and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Websites and content according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

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

• Cookies (or browser cookies). A cookie is a small file placed on your computer or mobile device. 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 our Websites or The Villages App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites, or use features of The Villages App that display in a web browser.
• Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Websites. 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 Choices About How We Use and Disclose Your Information.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our websites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. Nor do we control if or how they collect information about you. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

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

• To present The Villages App and our Websites and content to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it (for example, reserving a tee time).
• To provide you with notices about the community and its facilities and events.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To notify you about changes to our Websites or any products or services we offer or provide.
• To enable third parties to provide you with information about events and services available in the community.
• To allow you to participate in interactive features on our Websites.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please follow the opt-out instructions included with our communication. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may also use the information we have collected from you to allow third parties (for example utilities and other service providers) to contact you with information about their services.

Disclosure of Your Information

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

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

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• 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 The Villages companies (by way of a sale of assets), whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users or The Villages App users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see below for Choices About How We Use and Disclose Your Information.
• To fulfill the purpose for which you provide it.
• For safety and law enforcement purposes,
• To assist the The Villages Companies in improving their products and services.
• For any other purpose disclosed by us when you provide the information.
• Otherwise with your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including to investigate potential breaches or violations by you.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Villages Companies or its affiliates or business providers, our customers, residents of the community and visitors to it, or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising.You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites or access to The Villages App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our Websites, if any. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we use commercially reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information transmitted to or from our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Websites or The Villages App.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. You should revisit this page periodically to see if the date of the policy has changed and, if so, you should review the updates carefully before continuing to use our Websites or The Villages App. If we make material changes to how we treat our users' personal information, we may notify you by email or by posting a notice on one or more of our Websites. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us by mail at:

The Villages Office of the General Counsel
3619 Kiessel Rd.
The Villages, FL 32163

Or by email at legal@thevillages.com.

To register a complaint or concern, please email us at legal@thevillages.com. Please provide a detailed description of your concern, and information as to how we may contact you. While we take all complaints and concerns seriously, we reserve the right not to provide a specific response if we believe such action is warranted by the situation. All complaints and concerns emailed to us may be used for any purpose consistent with law, including without limitation, referring them to CDDs, law enforcement or other agencies or organizations that we determine are better suited to respond.