Flagstone Property Group, LLC and its affiliated operating companies ("Flagstone" and/or "we") have a strong commitment to providing excellent service to all of their customers, owners and guests, which includes respecting their concerns about privacy. We understand that visitors to this website may have questions about whether and how this website collects and uses information. We have prepared this statement ("Statement") to inform you of the privacy principles that govern this website.

This Statement contains information about the steps we take to respect your privacy, the information we collect, how we use that information and for how long collected information is retained. We have organized the Statement by major topic areas, including region-specific details, so that you can quickly access and review the information of most interest to you.

If, after reviewing this Statement, you have any questions, privacy concerns or wish to adjust or update the contact information we have for you, please notify us via email at ngoulet@flagstonegroup.com or our postal address listed below. Our Privacy Officer also serves as our Grievance Officer and on behalf of our Privacy Department, as may be required under applicable countries' and other jurisdictions' regulations.

Flagstone Property Group, LLC
Attn: Privacy Officer
888 MacArthur Causeway
Miami, Florida 33132
United States of America

Also, if you do not want us to use your personally identifiable information for our direct marketing purposes, you may write to us at any time and we will cease using the information for such purposes at no charge to you. Please send your request to ngoulet@flagstonegroup.com

Meeting your needs and expectations form the foundation of everything we do - including protecting your privacy.

Information We Collect and Its Uses
When we need to collect personally identifiable information to execute the requested transaction or provide a particular service, we will ask you to voluntarily supply us with any additional information we need. For example, if you would like to request further information on our project, we will ask you for information such as name, address, telephone number and email address to process your request. We typically use your email address to send information and, if necessary, might use the other information to contact you for any questions.

On occasion, we use third parties to provide, confirm or supplement for us, other information given the information you provided to us directly. We would then use this information for market analysis and our direct marketing purposes. In addition, when you provide contact details for transaction requests, such as scheduling an appointment or requesting a proposal, we will use the contact information to keep you updated about our future offers or promotions.

In addition, you may be requested to provide personally identifiable information about others to us (for example, the name, address and contact details of your travel companion). In such cases, we rely on you to obtain that other persons' consent for disclosing their information to us and inform that other person about us, how we will use the information and our contact details for any queries.

Personally identifiable information will be retained only until it is reasonable to assume that the purpose for which that personally identifiable information was collected is no longer being served by its retention and the retention is no longer necessary for legal or business purposes.

We will maintain your personal information in whole, usable and up-to-date form. Please contact us as described above in the event you would like to review and adjust any of this information.

Creating an Account Profile
Owners of our products and programs may, at their choice, create a personal account profile online within our password-protected sites. Creating an account profile makes use of our sites more convenient for you by eliminating the need to repeatedly enter personal contact or preference information. The security of this information is addressed in the security section below. In the event that we have created a personal account profile option on our website, you will be able to access and review, update or deactivate the information in your account profile online.

We treat the information you provide to us as confidential; it is, accordingly, subject to our company's security procedures and corporate policies regarding protection and use of confidential information. Because laws applicable to personal information vary by country, additional measures that satisfy applicable legal requirements may be put in place. Please note that we will never send you an email requesting your user name, password, credit card, social security or national insurance numbers. If you receive an email that looks like it's from one of our companies, but asks you for your credit card number, social security or national insurance number, it is a fraudulent email or "phish."

If you believe "phishers" have obtained access to your personal or financial information, we recommend that you do the following:

Confidentiality of Identification Numbers
When collected, Social Security, National Insurance and other government-issued identification numbers are treated with great care, including our satisfaction of applicable Federal and State laws, as well as International regulations. Social Security, National Insurance and other government-issued identification numbers are collected and retained in order to comply with various Federal and State laws, as well as International regulations. For general information systems, we use customer numbers and employee identification numbers that are not derived from government-issued identification numbers. We use policies, procedures, training, technology and auditing to protect the confidentiality and privacy of Social Security, National Insurance other government-issued identification numbers and ensure that proper controls are in place concerning the collection, use and disclosure of this information.

Disclosure of Information to Third Parties
We do not sell or transfer personal information to other companies for their own use without your approval and without giving you the opportunity to opt-out. Flagstone and its operating companies may share your personally identifiable information among themselves. Personally identifiable information may be sent to non-affiliated companies when we have your consent to share the information, need to share your information to provide the product or service you have requested or need to send the information to companies who work on our behalf (e.g., mailhouses and technology service providers) to provide a product or service to you, for general recordkeeping, informational and/or analysis reports and to supplement your information. These companies do not have any right to use the information we provide to them for any purpose beyond what is necessary to assist us.

We share personally identifiable information with other companies, organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

Children's Privacy
This site is not intended for children and we do not knowingly solicit or collect personal information from children.

Cookies & Related Technologies
This website utilizes cookies and may use pixel tags, web beacons or similar technologies for web analytics. "Cookies" are small text files that a website stores on a user's computer. This website requires the use of cookies to store and utilize information you enter across multiple pages. This is a "session" cookie, which expires when you close your browser. We use "persistent" cookies to measure usage of various pages on our website, to help us make our information more pertinent and easy for you to access, and as part of the functionality that allows you to interact with a representative while you are on some of our websites. Persistent cookies will remain on your computer until they expire or are deleted by you. Further, cookies are either First Party Cookies (utilized by us) or Third Party Cookies (utilized by others), for the purposes described above. We do not use "super cookies", sometimes referred to as zombie, perma, or ever cookies, known for their ability to evade removal tactics. Cookies are never utilized on our sites to ascertain personal information about you beyond what you voluntarily provide to us in your dealings with us. You may set your browser to block cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use particular functionality and access certain content on our website. We only use cookies or related technologies as your browser permits.

Other Sites
This website may contain links to third party sites that might be of interest to you. We are only responsible for the privacy statement and content of this website. We are not responsible for the privacy practices or the use of cookies on other companies' websites that you have accessed prior to or after visiting our websites.

Region-Specific Website Privacy Elements

European Economic Area (EEA)
For residents of the European Economic Area (EEA), the following additional privacy elements apply to you:

When you request a page from our website, our servers log the IP address, the time of the request, the URL of your request and related information. By continuing to use our website, you agree to our placing cookies on your computer in order to analyze the way you use our website, provide you with enhancements and customized content and improve your browsing experience while on our website.

If you do not wish to accept cookies in connection with your use of this website, you must disable the acceptance of cookies within your browser or stop using our website. Note, if you disable the use and acceptance cookies within your browser, many features and benefits within this website, and other websites across the Internet, will no longer be available to you.

We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any matters related to the use and disclosure of personal information in accordance with the Safe Harbor Privacy Principles. In the unlikely event that we cannot satisfy your concerns, you may ask for details of the independent dispute resolution procedure we have available for those whose data has been transferred under the Safe Harbor framework.

Flagstone has selected the International Centre for Dispute Resolution (ICDR), a division of the American Arbitration Association (AAA), as the administrator of our independent recourse mechanism for the US-EU & US-SWISS SAFE HARBOR program.

Some parts of our website use third-party services, which may also use cookies as part of the services they provide.

Hong Kong
For residents of Hong Kong, the following additional privacy elements apply to you:

This website does not collect personally identifiable information from your computer when you browse and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your email address, or any other personally identifiable information. When you request a page from our website, our servers log the information provided in the HTTP request header including the Internet Protocol (IP) address, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our website function correctly and provide the functionality that you see on this website. We also use this information to understand how visitors use our website and to permit us to adjust its contents and functionality to meet their needs.

When you visit our websites, our server software records the domain name of your computer and its IP address. We may also track the pages you visit within our sites. We do these things so that we may measure website traffic, gauge the popularity of various parts of our website, gain some general knowledge about your preferences and compile aggregated statistics to improve the visitor's experience.

Data that we collect is used only for the purposes indicated within this Internet Privacy Statement or as stated within materials you receive requesting your consent. We utilize your personal information for purposes, which include, but are not limited to:

Personal information will not be disclosed to any third party except as noted below:

If you wish to opt-out of our direct marketing communications you receive, please send an email to ngoulet@flagstonegroup.com or send a letter to the postal address within the Introduction section of this Privacy Policy.

Singapore
For residents of Singapore, the following additional privacy elements apply to you:

This website does not collect personally identifiable information from your computer when you browse and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your email address, or any other personally identifiable information. When you request a page from our website, our servers log the information provided in the HTTP request header including the Internet Protocol (IP) address, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our website function correctly and provide the functionality that you see on this website. We also use this information to better understand how visitors use our website and to permit us to adjust its contents and functionality to meet your needs.

Your providing personal information shall be deemed to be your consent to our collection, use and transfer of such information as described in this Privacy Policy.

By continuing to use our website, you agree to our placing cookies on your computer in order to analyze the way you use our website, provide you with enhancements and customized content and improve your browsing experience while on our website.

If you do not wish to accept cookies in connection with your use of this website, you must disable the acceptance of cookies within your browser or stop using our website. Note, if you disable the use and acceptance cookies within your browser, many features and benefits within this website, and other websites across the Internet, will no longer be available to you.

If you have any questions relating to Flagstone's collection, use or disclosure of personal data, privacy concerns or would like to make corrections to personal data you have shared with us, please send an email to ngoulet@flagstonegroup.com or send a letter to the postal address within the Introduction section of this Privacy Policy.

People's Republic of China (PRC)
We do not collect personal sensitive information directly from people with limited capacity for civil conduct and those with incapacity for civil conduct, such as minors under the age of 16. If indeed necessary, personal sensitive information of such subjects shall be collected after acquiring expressed consent from the legal custodian of the said people.

You consent and allow Flagstone and its successors to collect and maintain data, including your personal details (provided by you voluntarily on a Flagstone website), such as name, address, telephone and facsimile numbers, email address(es), occupation, government issued ID number, nationality and passport number, in databases controlled by Flagstone and/or any service providers and third parties (including auditors) engaged by Flagstone, its affiliates or any successors, in Singapore, Hong Kong, the United States or elsewhere, and consent to the processing, use, transfer and disclosure of such data by Flagstone to and/or by its affiliates world-wide and to their agents and partner companies, to: verify your identification; send commercial messages (to your address, email, telephone number or otherwise); advise you of other offers and information; carry out general record keeping; create informational or analysis reports; supplement your disclosed information; carry out verifications, mailhouse, planning or other legitimate business needs, the provision of related services and the management thereof; respond to queries by you or others who have been identified by you as your authorized representative or proxy; and such other purposes as permitted by applicable law. Flagstone, its affiliates and its successors shall permit third parties to have, process, use and disclose your data only for purposes as necessary to assist Flagstone, its affiliates and its successors to achieve the foregoing. Flagstone will protect your details in accordance with applicable data protection laws. The use and transfer of this information may result in personal data being transferred outside of the location in which it is collected to the United States, Singapore and other jurisdictions. Flagstone will protect your details in accordance with applicable data protection laws and shall take steps to ensure any transferees do the same.

United States
For residents of the United States, the following additional privacy elements apply to you:
If you receive an email that looks like it's from one of our companies, but asks you for your credit card or social security number, it is a fraudulent email or "phish." We recommend that you do the following:

At this time, we do not respond to browser 'do not track' signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different Web sites, including when you visit our website.

If you are a customer who resides in the State of California, you have the right to request, from us, a list of third parties with whom we shared personally identifiable information about you for their own direct marketing purposes during the previous calendar year. However, we do not permit personally identifiable information that is shared with third parties to be utilized for their marketing activities. Any third party with which your personal information is shared is required to maintain adequate policies and controls in order to protect such information.

If you have any questions or privacy concerns, please send an email to ngoulet@flagstonegroup.com or send a letter to the postal address within the Introduction section of this Privacy Policy.

Privacy Statement Changes
In the future, we may need to change our privacy statement. All changes will be made here so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. This statement was last updated on July 6, 2015.