Privacy Policy

Last Updated: October 30, 2025

Introduction

This Privacy Policy ("Policy") describes the data practices of the Hagadone Corporation and its subsidiaries
(“We” “Us” or “Our”). Our well-known subsidiaries include the Coeur d'Alene Resort (the “Resort”), the Coeur
d'Alene Resort Golf Course, and the Hagadone Marine Center. Through our publishing division, we also own and
issue numerous newspapers and tourism publications in Idaho, Montana, Washington, and Hawaii. Please see
Appendix A for a full list of subsidiaries and affiliates covered by this Policy.

Our business is hospitality. The essence of hospitality is customer service, which includes respecting your
privacy and protecting your personal information.

This Privacy Policy (“the Policy”) explains how we may collect, use, or disclose your personal information when
you use any of our products or services. By using our products or services, you understand and acknowledge that
we will collect and use personal information as described in this Policy.

This Policy applies when we collect your information:

• Through our websites, which include Hagadone.com, CDAResort.com, and other sites owned or operated by
  our management group, the Hagadone Corporation (collectively, our “Websites”).
• Through mobile or web-based applications that we make available to you, such as the CDA Resort App,
  other software tools offered for download, or chat functionalities (collectively, our “Apps”).
• Through the social media pages we control (collectively, our “Social Media Pages”).
• Through your communications with us in-person or online, whether through email, phone, text, or the
  Websites.
• When you visit or stay as a guest at one of our properties, book an experience with us, or otherwise
  interact with us offline (e.g., at our golf courses, marinas, restaurants, or spas) (collectively,
  “Offline Services”).

When we use the term “Online Services,” we are referring to our Websites, Apps, or Social Media Pages. When we
use the term “Services,” we are referring to Online Services together with Offline Services.

Please note that our Online Services may link to third-party websites or platforms that we do not control. The
collection or use of your personal information through those websites is not subject to this Policy. We
encourage you to review the privacy policies of every website you visit.

We similarly encourage you to review this Policy periodically for updates, as we may modify it from time to
time. We will publish a link to any materially revised Policy on the homepage of Hagadone.com. Your continued
engagement with our Services indicates your acceptance and consent to the information collection practices
described in the Policy then in effect. By using our Services, you also acknowledge and accept our Terms of Use.

Table of Contents

Introduction………………………………………………………………………………………..………1

Collection of Personal Information      3

What Personal Information Do We Collect?     3

How Do We Collect Personal Information about You?      4

Direct Interactions with Us      4

Tracking Technologies      4

Other Companies and People      6

Publicly Available Sources      6

How Do We Use Your Personal Information?      6

Disclosures of Personal Information      7

Your Privacy Choices and How to Exercise Them      9

Managing SMS Messages      9

Managing Promotional Emails      9

Direct Mail Opt-Out      9

Customizing App Notifications      9

Cookies and Tracking Technologies      9

Notice at Collection and State-Specific Privacy Rights Information      9

Exercising Your State-Specific Privacy Rights and Choices      12

Data Retention      13

Information Security      13

Children      13

Changes to this Privacy Policy      13

Communicating with Us about Our Privacy Policy      13

Appendix A: Subsidiaries and Affiliates Covered by this Policy      15

 

Collection of Personal Information

What Personal Information Do We Collect?

We collect your Personal Information in accordance with applicable law to provide you with exceptional
Services. Personal Information is information that identifies, relates to, or describes you as a unique
individual or links you, directly or indirectly, with an individual consumer or household. Personal Information
does not include information that is de-identified, aggregated, or anonymized. The Personal Information we
collect about you includes:

• Identifiers and contact information, such as your name, postal or billing address, personal email address, or
  telephone number.
• Demographic information, which may include characteristics of protected classifications under state or federal
  law, such as age, gender, and household income.
• Device information, including information about the desktop or mobile device you use to interact with our
  Online Services, such as your Internet Protocol (IP) address, device identification number, model, and
  manufacturer, operating system, browser type and version, Internet service provider, or mobile carrier.
• Electronic communications, such as the content of messages you send to us or that we exchange through email,
  SMS/text messaging, or online chat features or forms on our Websites.
• Audio and visual recordings or similar information, including recordings of telephone calls with our customer
  experience and other support teams for quality assurance and videos or other footage of activities that occur in
  public areas throughout our properties. Please note that we do not use security cameras or similar devices where
  guests and visitors have a reasonable expectation of privacy (e.g., in bathrooms or guest rooms).
• Geolocation data, which is collected by our App for purposes of issuing guests weather-related
  notifications.
• Commercial information, such as your purchase history with us or other details regarding the Services that you
  prefer or have considered.
• Internet or electronic network activity, such as your browsing history, search history, or details about your
  interactions with our Online Services or advertisements.
• Inferences drawn from your prior stays or interactions with our Services, such as goods and experiences booked,
  travel itineraries, special accommodation or amenities requests, employer details (for corporate/business
  bookings), webpages you visit when you engage with our Websites, interactions with our advertisements, or
  information collected through cookies, pixels, beacons, and other website technologies. For more information
  about the website technologies our Websites use, please see the Tracking Technologies [hyperlink to section]
  section below or our Cookie Policy [hyperlink to section].
• Sensitive Personal Information, including
  • Financial Information, such as your credit, debit, or other payment card data in combination with any access
    codes or other credentials that permit access to an account. Please note that we partner with a third-party
    processor for payment card transactions. When you provide your payment card information to receive our Services,
    that information is stored with our third-party payment processor, authorize.net.
  • Precise Geolocation, which is collected by our App for purposes of issuing guests weather-related
    notifications.
  • Personal Information concerning your health, such as information used to book accommodations.

If we collect information that is not linkable to you on its own but combine it with other information such
that the combined information identifies you, we treat the combined information as Personal Information.

How Do We Collect Personal Information about You?

We collect your personal information in different ways. Most often, we will collect your information in one of
four ways: (1) when you interact directly with our Services (Direct Interactions with Us); (2) automatically
through the website technologies that we use to improve our Online Services (Tracking Technologies); (3) from
other companies we partner with and people who may refer you to us (Other Companies and People), and (4) from
Publicly Available Sources. Each collection source is described in further detail below.

Direct Interactions with Us

You may give us your information when you:

• Use the Online Services to browse, make a reservation, communicate with us (via AI-assisted technologies or
  Social Media Pages), participate in a survey, sign up for a newsletter, or for other similar activities.
• Make a reservation with us over the phone or otherwise communicate with our Concierge online or in person. We
  may record those communications for training and quality assurance. Please also note that the interactive chat
  feature on the Resort’s website (i.e., the CDA Resort Room Reservations Specialist) is powered and hosted by a
  third party.
• Express an interest in our Services.
• Check in at one of our properties, book a package, or other experience.
• Complete interest forms or surveys, provide ratings or reviews, or submit other feedback to us regarding your
  experience.
• Subscribe to any of our newspapers or our tourism publications.
• Connect a device to the Resort’s Wi-Fi or use other internet-connected devices available throughout our
  properties.
• Report an issue or problem with our Services.

Tracking Technologies

When you interact with our Online Services, we may use cookies, pixels, web beacons, or other website
technologies (collectively “tracking technologies”) to collect information about the:

• Desktop or mobile device used to access the Services.
• Your browsing activities, patterns, events, and interactions with our Services, including web pages you viewed
  and links you clicked, to maintain your preferences.

We do this primarily through cookies, which are pieces of data stored directly on the computer or mobile device
that you are using. The data collected by tracking technologies does not identify you by name. However, these
technologies may identify the device you are using, via IP address or other device identifier, and those device
identifiers may allow us to identify you when our systems correlate them with other Personal Information you
provided to us directly.

We use the data collected through tracking technologies to customize and enhance your customer experience. We
also use the data for analytics purposes and to maintain the security and functionality of our Websites.

When you interact with our Online Services, we and our advertising partners may use tracking technologies that
collect information about your activities over time and across other websites or online services. This allows us
to better understand your interests so that we can present you with relevant messages and offers that are most
likely to appeal to you. The types of information collected through tracking technologies may include device
information, internet or electronic network activity, and certain preferences as described above in the What
Personal Information Do We Collect?

The tracking technologies we use include:

• Necessary cookies to help us deliver our Online Services without disruption, enable the basic features of our
  Websites (e.g., online reservations, etc.), and understand how the Online Services are performing.
• Functional cookies to retain user preferences, display content more effectively, or otherwise personalize your
  experience.
• Analytics technologies to collect, understand, report, and improve features and content for our Online
  Services, including how the Online Services are used and the content that users view most frequently.
• Location technologies (including your general location based on your IP address or your precise location
  through our Apps) to verify your location, communicate with you, prevent fraud, and provide Services
  personalized to you based on your location.
• Security technologies to detect activity that might violate our Terms of Use [hyperlink]; prevent fraud,
  unauthorized access or activity, or other misuse of our Services; and to protect our business.
• Communication technologies to determine whether you have opened, viewed, or otherwise interacted with the
  emails or other online correspondence we send to you.
• Marketing and targeted behavioral advertising technologies to provide you with personalized advertisements,
  communications, and other information about our Services that aligns with your interests.

Choices Related to Advertising and Cookies 

There are several ways to opt out of cookies. When you visit our Websites, you will be given the option to
opt-out of third-party cookies. If you choose to opt out, your ability to perform certain activities while using
the Online Services may be disrupted or otherwise affected. For example, we may not be able to recognize your
device, and you may need to log in every time you visit. You will not receive certain advertising or other
offers from us that are customized to your interests.

You may learn more about cookies here: https://allaboutcookies.org/how-to-manage-cookies.

Many companies that are engaged in marketing and advertising participate in the Digital Advertising Alliance
(“DAA”) You can learn more about the DAA AdChoices Program opt-out program for website browsers at
https://www.youradchoices.com/ and mobile apps at https://www.aboutads.info/appchoices.

We partner with third parties to provide advertising services that are targeted based on your online activities
across websites, mobile apps, and devices over time (commonly referred to as “interest-based advertising”). Our
advertising partners may collect information about your engagement with our Services on your device and combine
it with information about your activities on other websites, mobile apps, and devices. They may collect such
information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Facebook
cookies or Google's Advertising ID), cross-device linking, and similar technologies. For example, our
advertising partners may use the fact that you visited our website to target advertising to you on other
websites and mobile apps on your current device or on other devices you use. They may match your browsers or
devices if you log into the same online service on multiple devices or if your devices share similar attributes
that support an inference that they are used by the same person or household. This means that information about
your activity on websites or apps on your current browser or device may be combined and used with information
collected from your other browsers or devices. You can opt out of interest-based advertising in web browsers and
mobile apps on your current browser or device by following the instructions below.

• Web Browser Opt-Out. To opt out in web browsers, please visit http://optout.aboutads.info/ and
  http://optout.networkadvertising.org. To help preserve the choices that you make in the DAA's WebChoices page,
  you can install the DAA's “Protect My Choices” extension that is available at
  http://www.aboutads.info/PMC.
• Mobile Application Opt-Out. To opt out in mobile apps, you can adjust the advertising preferences on your
  mobile device (for example, in iOS, visit Settings > Privacy & Security > Tracking, and in Android,
  visit Settings > Google > Ads > Opt out of interest-based ads). You can also opt out for companies that
  participate in the Digital Advertising Alliance's AppChoices tool by downloading the app and following the
  instructions. For more information about opting out on mobile devices, please see here.

Other Companies and People

We collect some Personal Information about you from other external sources, including authorized licensees,
travel agencies, joint marketing partners, and event planners. Authorized licensees are companies with whom we
enter into a license or similar agreement to sell goods and services under the Hagadone Corporation name or an
affiliated brand. We may also collect your Personal Information from golf, spa, restaurant, health club,
concierge, and other outlets at our properties.

We collect Personal Information from third parties who may provide marketing, advertising, or promotions to
you. We may combine data collected from those marketing and advertising partners with data collected from you
directly or about you through Tracking Technologies. We may use the combined data consistent with this Policy
and applicable law.

Publicly Available Sources

We may collect Personal Information from public databases or guest reviews of our Services. The latter
includes, for example, reviews of our Services that you publish on Social Media Pages. or other third-party
platforms.

How Do We Use Your Personal Information?

We may use Personal Information for one or more of the following purposes:

• To fulfill the purpose for which you provided the information. For example, if you provide your Personal
  Information to make a reservation for our Services, we will use your information to book the reservation and
  process your payment. We may also save your information to facilitate communications between Us and you,
  accommodations related to your stay, or future reservations.
• To provide, support, personalize, and develop our Services.
• To register you for or administer loyalty programs or other authenticated, account-based services.
• To process your requests, purchases, transactions, and payments, and prevent transactional fraud.
• To make arrangements with third-party providers on your behalf (e.g., shuttle services, tour guides, other
  entertainment-related requests).
• To provide you with support and to respond to your inquiries, including through AI-enabled chat functions
  offered on our Websites. We may use the information you provide via automated chatbots or other messaging forums
  to address your concerns and improve our responses.
• To personalize your experience with our Services and deliver content relevant to your interests, including
  targeted offers and advertisements served to you through our Websites, third-party sites, Social Media Pages,
  and via email, direct mail, or text message (with your consent, where required by law).
• To ensure appropriate incident response and prevention, and help maintain the safety, security, and integrity
  of our properties, Services, and technology assets.
• For testing, research, analysis, and product development, including developing and improving our
  Services.
• To respond to law enforcement requests, inquiries from regulatory authorities, and as required or permitted by
  applicable laws, court orders, or regulations.
• As described in our Notice at Collection provided in accordance with the California Consumer Privacy Act
  (“CCPA”) and other comprehensive US state consumer data privacy laws.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or
  transfer 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 our customers is among the assets transferred.
• For other uses as may be permitted or required by applicable law.

Disclosures of Personal Information

We may disclose your Personal Information to:

• Other companies within Hagadone Corporation for the purposes described in this Privacy Policy
• Owners of Hagadone Corporation and its companies for the purposes described in this Privacy Policy
•  Service providers, vendors, partners, subcontractors, and third parties who perform functions in support of our
  Services, such as companies that provide:
  • Payment processing
  • Website hosting
  • Online Services development and customer service, including automated chat or other AI-assisted
    technologies
  • Consulting and business services
  • Marketing and advertising services, including promotional communications
  • Auditing and other professional services
  • Research and data analytics services
  • Breach and fraud detection, prevention, and response services
  • Information technology and security
  • Social media advertising
• Other people, such as an authorized representative when you direct that person to submit a Personal Information
  rights request on your behalf
• Individuals or entities who need access to Personal Information for safety, security, and other legal purposes,
  such as law enforcement agencies or government authorities, including those outside your country of residence to
  meet national security or comply with applicable legal requirements.
• Third parties to obtain more information about our website visitors and reach out to them with promotional
  messaging through other channels, such as email and/or direct mail.
• Third parties to market their products or services to you if you have consented to or not opted out of such
  disclosures. For more information, see Your Privacy Choices and How to Exercise Them and
  State-Specific Privacy Rights Information.
• For any other purposes of which we provide notice when collecting your information.
• With your consent.

We may also disclose your Personal Information to external recipients:

• If we sell any business or assets, in which case we may disclose your Personal Information to the buyer of such
  business or assets if your Personal Information is part of the asset sale.
• To a buyer or other successor in the event of 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, where one of the transferred assets is the Personal Information we
  hold.
• To comply with any court order, law, or legal process, including responding to any government or regulatory
  request.
• To enforce or apply our Terms of Use and other agreements.
• To protect the rights, property, or safety of our business, our employees, our customers, or others. This
  includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud
  protection, and credit risk reduction.

Your Privacy Choices and How to Exercise Them

We believe all customers should have choices with respect to their data. We therefore provide all customers
with the following choices for data management. The next section, State-Specific Privacy Rights Information,
applies additionally to consumers who reside in certain U.S. states where comprehensive consumer data privacy
legislation is effective.

Managing SMS Messages

To stop receiving text messages, reply STOP to any of the text messages you receive from us. After texting
STOP, you will receive one additional message confirming that your request has been processed.

Managing Promotional Emails

You can opt-out of promotional communications sent via email by clicking the “unsubscribe” link that is
included at the end of each email. Please note that even if you opt-out of promotional emails, we may still need
to send you emails about your account and transactions (e.g., reservations or associated bookings, including
confirmation and pre-arrival emails).

Direct Mail Opt-Out

You may request that we stop sending you postal mail by submitting a request to info@cdaresort.com.

Customizing App Notifications

You may customize notifications you receive from our App in your mobile phone settings. You may not opt out of
emergency notifications for safety purposes.

Cookies and Tracking Technologies

For information on your choices, please see section on Tracking Technologies above.

Notice at Collection and State-Specific Privacy Rights Information

This chart describes our Personal Information collection practices over the last 12 months: