UPDATED: January 1, 2020

Alterra Mountain Company is committed to the privacy of our customers and guests (“you” and “your”). The Alterra Mountain Company Privacy Policy (the “Policy”) applies to Personal Information that Alterra Mountain Company collects online, in person, and through its call centers or otherwise. “Personal Information” is information associated with an identifiable individual or household. Personal Information does not include information about a business or aggregated anonymous information that cannot be associated with a specific individual. “Alterra Mountain Company”, “we”, “us” or “our” refers to Alterra Mountain Company its subsidiaries and certain of its affiliates. We have an international presence and maintains offices and facilities in multiple jurisdictions throughout the United States and Canada. Except in circumstances where the privacy policy of an affiliate, third party, or partner applies, all of our business operations are subject to this policy. This Policy does not apply to information about Alterra Mountain Company’s employees or to information that is not Personal Information.

PERSONAL INFORMATION WE COLLECT AND HOW IT IS USED

Alterra Mountain Company collects Personal Information during the course of operating our mountain resort adventure, resort hospitality, and real estate businesses. We use this information in order to provide you with the best possible service and to meet our reasonable business needs.

(a) We collect your personal information when you purchase a product or service or enroll in a program.

When you purchase a product or service, make a reservation or enroll in a program, we collect personal information in order to process the transaction and administer the program. We may also send you information relating to your purchase, reservation or program. For example, if you make a reservation at one of our resort locations, we may send you information about the activities, events or offers taking place at the resort around the time of your visit. The information we may collect and use for these purposes includes but is not limited to your:

• name and contact information to identify and communicate with you
• payment card information to process transactions
• age and/or birth date to ensure appropriate product pricing and know more about who is enjoying our products and services
• gender to verify your identity, provide appropriate services, such as rental equipment, and know more about who is enjoying our products and services
• biometric data when this information is necessary in connection with the product, service, program or activity that you have requested (for example, we may need gender, height and weight to provide you with appropriate rental equipment)
• medical information, such as allergies or medical conditions that we need to be aware if you are participating in lessons or other programs, or if you have dietary restrictions
• facial photograph to identify you as a guest
• status as the parent or guardian of a minor guest, if applicable
• experience preferences (such as preferred lodging room type)
• geographic location to locate ski school participants or other guests who have elected to utilize on-mountain tracking technology while on our mountains, including our Apps that offer on-mountain tracking
• transaction history to manage your purchases and reservations and to learn more about how you interact with our products.

In some cases you may provide us with Personal Information relating to a family member or another individual. By providing us with Personal Information relating to an individual other than yourself, you represent that you have their consent to provide us with their Personal Information for the purposes described in this Policy.

(b) We collect your personal information when you visit our resorts, use our pass products and tickets, and download and use our web applications (“Apps”).

When you purchase or use our pass products and tickets, we may collect information regarding your geographic location, activities and purchases while you are at Alterra Mountain Company resorts. Our pass products and tickets use either handheld scanner or RFID (radio frequency identification) technology. Through the use of this technology, we may be able to collect limited information regarding your location at the resort, including the lifts that you ride, and depending on whether you have a payment card linked to your pass product, other commercial transactions that you complete at one of our retail or restaurant location. We use this information to understand how our guests use our resorts and to understand your personal preferences.

Depending on your marketing preferences, we may also use your Personal Information to send you offers, invitations or promotions relating to our resorts, products, services or programs that we believe may be of interest to you. For example, we may monitor your commercial transactions or browsing habits on our websites or at our resort destinations which may influence the personalized special offers and promotions that we send to you.

Some of our pass products grant you access to ski resorts that are not owned or operated by Alterra Mountain Company (each a “Pass Product Resort”). When you visit a Pass Product Resort, the Pass Product Resort will scan or otherwise record your attendance at that resort destination using RFID technology (radio frequency identification), handheld scanners, or another method which allows the Pass Product Resort and us to record your usage activity of the product. Both Alterra Mountain Company and the Pass Product Resort may collect additional information from you depending on your transaction activity at the resort destination. We may also share your Personal Information with a Pass Product Resort(s) to administer your pass product, better understand how you use our products, and learn about how we can improve the guest experience. Also, when you transact directly with a Pass Product Resort, that resort’s privacy policy will apply. For example, if you book lodging accommodations or a ski school lesson directly with a Pass Product Resort, that resort’s privacy policy will apply to that transaction.

Several of our resorts use GPS tracking technology in connection with their ski and ride school programs in order to track and locate students on the mountain. The GPS tracking technology is owned and operated by a third-party service provider which may be provided certain information to provide the tracking service and to operate the websites on which you and/or your family members can track their day on the mountain.

Some of our resorts and products have Apps available for download to your mobile device. The download, installation and use of our Apps will allow you convenient access to great experiences our resorts have to offer, including the ability to purchase pass products, lift tickets, track and share your performance, create a profile, create social groups with whom you can share information, access mountain wayfinding, weather and lift info, and receive in-App notifications (collectively, the “Apps Services”). If you access our Apps, we may be able to collect your Personal Information, including your geographic location, activities, and purchase history. We may also associate the information collected through your use of the Apps to your customer profile, including your pass product and pass scan data.

The Apps automatically collect detailed location and navigation information, in the form of GPS signals from the mobile device on which you have installed and activated the App (“App Location Information”). Whenever you open, use or interact with the App Services, we use your App Location Information (e.g., latitude and longitude) to tailor the App Services experience to your current location. We also use your App Location Information to provide certain App Services, including to send you notifications of friends, events, or other relevant information that are near to you. If you have ‘background location’ turned on, the Apps may, from time to time, tell us about your device’s location even if you are not directly interacting with the App. We may use various technologies to determine your App Location Information, such as location services of the applicable operating system or browser, GPS, Bluetooth, i-Beacon, RFID, and sensor data from your devices, along with nearby Wi-Fi access points and cell towers, and other technologies to determine your mobile devices’ approximate location.

The Apps may also share your App Location Information on a map or by communicating your distance and general direction to other users. You should only share your App Location Information with those that you trust. You understand that the nature of location-based services is such that your App Location Information is available to you and other users, and that we cannot control what you or other users, who receive this information when using the App or the App Services, will do with it.

If you do not wish for the Apps to track your App Location Information, you should turn off the App Location Information tracking feature in the App settings menu. If you turn off the App Location Information feature, some features of the App and App Services cannot be provided without using this standard technology. For example, the App Services use your location and route information to create a detailed location history of your journeys made when using the App and App Services. The Apps use this history to offer the App Services to you, to improve the quality of the App Services it offers to you and to all of its users and to improve the accuracy of its mapping and navigation data.

You may be able to take part in certain activities within our App Services that let you communicate or share information not just with us, but also with other users. These include:

• sending private or group messages or content to other users
• chatting with other users
• sharing performance metrics, such as your total days skied, vertical feet skied, and number of chairlift rides
• sharing your skill-level, home mountain, and/or personal preferences
• sharing photos or drawings with other users.

We record and store archives of this data on servers to provide these features as well as to protect our rights and property in connection with our App Services and you acknowledge and agree to our storage of this data.

At certain of our resort destinations we may use video surveillance for the safety and security of our guests, employees and property. We will retain video recordings for as long as reasonably necessary for these purposes. Our resorts may also use live stream webcams in outdoor public areas either on mountain or in the base village area. These live web cam feeds can be accessed by anyone via an internet connection.

(c) We collect your Personal Information when you submit an inquiry, complete a guest survey, or provide feedback

We may collect your name, contact information and comments or questions when you submit an inquiry or comment, or otherwise provide us with feedback about our business. We may also collection information related to your experience at one of our mountain destinations or using our products or services in a guest satisfaction survey. These surveys may include optional questions regarding your income, race/ethnicity, or gender which, if answered, help us to learn more about our customers and how we can improve our business and public engagement in snow sports. We may use this information to respond to your question and to improve our business, products, services and programs.

(d) We collect your Personal Information when you participate in a marketing initiative or create an online account

If you choose to create an online account profile, we may collect your name, contact information, age, gender, birth date, personal image, username and password and other information that you choose to provide (such as your preferences).

We may also collect your name, contact information, age and/or date of birth if you decide to participate in a marketing initiative such as a contest, sweepstakes or other promotion. In some cases we may also ask you specific questions about your preferences or for feedback on our business, products, services and programs. We use this information to administer the promotion, including contacting and announcing winners (where applicable), to improve our business, products, services and programs, and for marketing initiatives, such as offers or promotions relating to our resorts, products, services, or programs that we believe may be of interest to you, depending on your marketing preferences.

(e) We collect your Personal Information when you call our call center or we call you

We may record calls into and out of our call centers for the purposes of maintaining accurate records and for quality assurance and training purposes. We will retain call recordings for as long as reasonably necessary for these purposes.

(f) We collect your Personal Information from third parties

If you are a resident of the U.S., Alterra Mountain Company may also supplement the Personal Information that you provide to us with information that we obtain from third parties.

OUR COLLECTION OF INFORMATION THROUGH COOKIES AND OTHER TRACKING TECHNOLOGIES

When you visit one of our websites or use one of our Apps, your web browser sends us certain information depending on the browser you use and your security settings. This information may include your IP address, the name and version of your operating system, the name and version of your web browser, other technical data information, whether you accessed our website from a computer or a mobile device, when you open emails we send you, the date, time, and duration of your visit, and geolocation data. This web browser data helps with system administration, traffic reposting, and auditing. It also helps us better understand who our guests are, how they use our services, and what we can do to improve the user experience. We may use this information to offer you products and services and to create aggregate statistics. This helps us improve your experience both online and at our resorts.

We also use “cookies” to customize your website user experience by tailoring online content to align with your browsing habits. Cookies are small pieces of data, stored on your hard drive that send us information about your online browsing habits, including login and browsing history, button impressions, and personal preferences. Cookies also tell us under which account a user is logged in to one of our websites and this information helps us protect your information by making sure your personal preferences are only displayed when you are actually logged in. If you tell an Alterra Mountain Company website to “Remember Me” or save your preferences, this information is stored using a cookie. Some cookies are also required to support the functionality of your transaction (e.g. putting items in your shopping cart).

We may work with advertising networks (such as Google AdWords and Facebook Ads) that use cookies and similar technologies to track your use of our websites and other websites so that they can provide advertising about products and services tailored to your inferred interests. This advertising may appear on our website(s) or on other websites. Some of our advertising network’s technology uses separate cookies or other tracking technologies that may be delivered to your device when you visit our websites, use our Apps, or open emails from us. These advertising technologies are governed by the individual third-party advertising network’s privacy policy, and you must contact them directly to opt out. Please contact us for this information. Some of these third-party ad networks may be members of the Network Advertising Initiative (NAI). If they are members of NAI, then you have the option to “opt out”. Additional information on NAI members and how to opt out, can be found athttp://www.networkadvertising.org/optout_nonppii.asp

We may also use services, such as Google and Adobe Analytics and Facebook, that also use cookies and similar technologies, to provide us with information on how you interact with the content on our websites. For example, the webpage content that you click on, the duration of your visit to our website, and what website you visited prior to ours.

We may also allow social plug-ins with social media platforms, such as Facebook, Twitter, Instagram and Pinterest. When you visit a page on our websites or our Apps that contains a social plug-in, your web browser sends information to that social plug-in and the social plug-in sends content directly to your web browser which enables it to gain information that you have accessed a page on one of our websites or Apps. For information regarding the third party’s use of social plug-ins and how it may impact your privacy, you should refer to the third party’s privacy policy.

A Web Beacon is a tiny graphic with a unique identifier which is placed in the code of a web page. We use Web Beacons to count visitors to its websites and to monitor the traffic patterns within and between our websites, to deliver or communicate with cookies, to understand how you have come to our site, and to improve site performance. Web Beacons help us to measure the effectiveness of our content and other offerings.

You can choose to disable cookies using your web browser’s preferences menu. By turning off cookies, we will still be able to track your browsing history during a single visit to one of our websites however, we will not be able to link your browsing history during each of these visits to you, as you will be considered a new visitor each time you visit one of our websites. Web Beacons will no longer be able to track your activity on our websites however, the Web Beacon may be able to continue to track activity based on your IP address. Be aware that turning off cookies may disable certain functions on the website and cause it not to function properly.

To better understand your interaction with our websites across multiple devices and to effectively deliver tailored promotions to you, we participate in the Adobe Marketing Cloud Device Co-op. Go tohttps://cross-device-privacy.adobe.com/ to learn more about how Adobe does this and to manage your choices relating to the linking of your devices.

We may include links to third party sites on our websites. When you click on those third-party links, you leave our website. This Policy does not apply to third party sites or any information that you provide on those sites.

WHEN WE MAY COMBINE YOUR PERSONAL INFORMATION

We may combine the Personal Information you provide, or that we collect, in order to better understand your needs, requirements, and personal preferences so that we may improve our business, products, services and programs and optimize your experience when you visit our resort destinations, or when you are dealing with one of our team members, a call center representative, agents or other authorized third party.

Depending on your marketing preferences, we may also use this information to send you offers, invitations or promotions relating to our locations, products, services or programs that we believe may be of interest to you. For example, we may monitor your commercial transactions or browsing habits on our websites or at our resort destinations which may influence the personalized special offers and promotions that we send to you.

WHEN WE SHARE PERSONAL INFORMATION

We will not sell your Personal Information for monetary value. We may, however, provide your Personal Information with third party service providers in the following circumstances:

• Vendors – We may share your Personal Information with vendors (including affiliates acting in this capacity) who provide services on our behalf such as payment card processors, call center administrators, web-site hosting, data management, identity verification (for example, in order to confirm your eligibility for special offers, such as military discounts), market analyses, marketing, advertising, and contest administration, or your personal information may be collected by such service providers on our behalf.
• Partners – We may disclose your Personal Information to third-party partners in situations where the disclosure is necessary in order to complete or provide the service, product, or information that you have purchased or requested. For example, we may disclose your Personal Information to a third-party tour operator if you purchased a tour from the third-party tour operator using one of our resort’s websites.
• Other Entities in the Alterra Mountain Company Group of Companies – Personal Information relating to Alterra Mountain Company customers is maintained in a database that is accessible to the Alterra Mountain Company group companies. This means that Personal Information collected by one of our subsidiaries may be accessible by another subsidiary or businesses within the our group of companies. The purpose of this sharing is to facilitate customer bookings and reservations across all our mountain destinations and, depending on your marketing preferences, allow our businesses to better understand your preferences and send you information about our locations, products, services and programs.
• Corporate Transactions – We may disclose your Personal Information to another entity, if necessary, in the event of an actual or proposed merger, sale, re-organization, including as part of insolvency or bankruptcy proceedings, or for the purposes of evaluating and/or performing such transaction.
• Special Circumstances – We may consider it necessary or may be required by law to disclose your Personal Information with our attorneys, or with others who are legally authorized in certain emergencies where the health, safety, or well-being of a person is at imminent risk, or if required in order to comply with a court order, or as otherwise required to comply with the law.

YOUR CONSENT

We collect, use and disclose your Personal Information as outlined in this Policy and with your consent, except where permitted or required otherwise by law. We may be required or permitted under statute or regulation to collect, use or disclose Personal Information without your consent, for example to comply with a court order, to collect a debt owed to us or if there is an imminent threat to an individual’s health, safety, or well-being.

Your consent may be express (for example, oral, written, or electronic) or your consent may be reasonably inferred or implied from something that you do (for example, use of our websites, implies consent to the collection, use and disclosure of your Personal Information as described in this Policy). In some instances, an authorized representative may consent on your behalf. In the case of minor children, a parent or legal guardian may consent to our collection, use and disclosure of a minor’s Personal Information.

You may withdraw your consent at any time, subject to legal or contractual restraints by contacting us at the locations listed in the Access section of this Policy. However, your withdrawal of consent might affect your experience and our ability to provide products or services to you, or quick and accurate service to you either online or through our service agents.

If you do not consent to the collection, use and disclosure of your Personal Information online as described in this Policy, do not use our websites or Apps.

HOW TO MANAGE YOUR MARKETING PREFERENCES

If you no longer want us to use your Personal Information for marketing purposes, including to send you promotional communications, you may contact us (see “Contact Us” section below) and ask to be removed from our mailing and/or contact lists. We may ask you for more information where required in order to identify you correctly.

You may also manage your email subscriptions by clicking on “Unsubscribe” to stop receiving future promotional communications from us, or by clicking on “Manage My Email Preferences” found at the bottom of any of our emails you receive in order to manage your email subscriptions.

If you wish to stop receiving text messages from us, please either reply “STOP” to the text message, contact the front desk of the relevant property, or contact us with your request (see “Contact Us” section below).

Children Under 13: We do not knowingly collect Personal Information from children under the age of thirteen, without prior consent of the child’s parent or legal guardian. Alterra Mountain Company’s websites and social media pages available online are not directed to users under the age of thirteen. If you believe that your child under the age of thirteen may have provided us with Personal Information online please contact us atyourprivacy@alterramtnco.com and we will take appropriate action.

We require the consent of the child’s parent or guardian for a child under the age of 13 to open an account or create profile related to an App. Parents and guardians understand the App may collect information about their child, such as photos, chat sessions, location information and the lifts that the child has skied or boarded. We collect this information for the limited purpose of providing the App Services. We do not collect or use this information in order to market products or services to children, and we will not sell this information. To disable your child’s account, request a copy of the information, or ask a question about the App and your child’s data, parents and guardians should contact our Chief Privacy Officer atyourprivacy@alterramtnco.com.

HOW WE PROTECT YOUR INFORMATION

We will generally keep your Personal Information on file for a reasonable period of time in order to meet our needs as described herein and as applicable, the needs of the parties to whom we disclose it. This file will be maintained on our servers or those of our service providers and will be accessible by our authorized employees, service providers and representatives. We maintain reasonable and systematic controls, schedules, and practices to retain and destroy Personal Information.

Internal Protections: We protect Personal Information by security safeguards appropriate to the sensitivity of the information. We have policies and practices to protect against loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. While we make efforts to protect your Personal Information we are not in a position to guarantee that your Personal Information will always be secure. There may be factors beyond our control which may result in loss or theft, or unauthorized access, use or disclosure of your Personal Information. As a consequence, we disclaim any warranties or representation on non-disclosure of your Personal Information. We also employ a Chief Privacy Officer to be accountable for our compliance with these policies and whom you may contact at the address below with any question, concern or complaint.

External Protections: To protect information disclosed to service providers, we use contractual or other means to provide a similar level of protection so that service providers treat the information confidentiality, implement appropriate security measures and only use and disclose the information for the purposes of providing the applicable services.

Please be aware that your Personal Information may be transferred to, stored and processed by us and its affiliates in Canada and the United States where Alterra Mountain Company, or its affiliates or service providers operate and maintain data. While outside of Canada, your Personal Information will be subject to applicable foreign laws, which may permit foreign government, regulatory or national security authorities to have access to your Personal Information in certain circumstances. By providing us with your Personal Information, you understand that your information may be transferred to our facilities and those third party service providers with whom we share it as described in this Policy.

ACCESS AND CORRECTION

Request a Copy: To obtain access to, or a copy of, your Personal Information that we have on file for little or no cost contactyourprivacy@alterramtnco.com or send a written request to 3501 Wazee St., Suite 400, Denver, CO 80216 Attention: Chief Privacy Officer. Access to this information may be denied if you are unable to verify that you are the subject of the request. Information may also not be provided when giving you access to the information would threaten someone’s life or security, reveal third-party Personal Information, breach confidentiality, violate attorney/solicitor-client privilege, disrupt a formal dispute resolution, or impede a law enforcement investigation.

Accuracy: We endeavor to ensure that your Personal Information is as accurate, complete, and as up to date as necessary for the purposes for which it will be used or shared. If you would like to request correction of your Personal Information that we have on file you may write to us atyourprivacy@alterramtnco.com or 3501 Wazee St., Suite 400, Denver, CO 80216 Attention: Chief Privacy Officer.

Contact Us: If you have any questions, you may contact us at:

California Customers:

California Consumer Privacy Act (CCPA)

In addition to your rights specified in this Policy, California citizens and households may request the deletion of or access to their Personal Information in accordance with the CCPA. To submit a request to delete or a request to access your Personal Information, please contact our Chief Privacy Officer at 877-477-6777 or visit the Contact Us page on our website to submit a webform. You must include sufficient detail in your request, such as your first and last name, date of birth, email and postal addresses. We may ask you for more information where required in order to identify you correctly. We will attempt to provide you with the requested information within forty-five (45) days of receipt. We do not discriminate against customers who submit requests to access or delete their Personal Information.

Shine the Light

Under California Civil Code Section 1798.83, California citizens may request certain information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties for their own direct marketing purposes. To make such a request, please contact us at the address listed above. You must include sufficient detail in your request, such as your first and last name, date of birth, email and postal addresses. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one set out in this policy.

SUBJECT TO CHANGE

This Policy is subject to change and may be supplemented or modified at any time. You should check this site regularly to stay up to date about changes to this Policy. If material changes are made, we will notify you by placing a notice on our websitehttps://www.alterramtnco.com/privacy-policy.

Copyright 2018 Alterra Mountain Company, 3501 Wazee St., Suite 400, Denver, CO 80216, (303) 749-8200