Supplemental Privacy Notice for California Visitors

THE BREAKERS PALM BEACH, INC.

Last Updated: December 26, 2025

This Supplemental Privacy Notice for California Visitors (“Notice”) supplements our main Privacy Policy (“Policy”) and describes how The Breakers Palm Beach, Inc. and its affiliated companies, subsidiaries and properties (“The Breakers”) uses, shares, and retains the Personal Information that we maintain about our California guests, members, retail customers, restaurant patrons and visitors on our websites (thebreakers.com, johnwebstergolf.com, breakerswestclub.com and viaflagler.com),  (collectively, the “Services.”) This Notice also describes the rights afforded to California residents under the California Consumer Privacy Act (“CCPA”) and how a California resident can exercise these rights.

The term “Personal Information” means information that directly or indirectly identifies, relates to, describes or is reasonably capable of being associated with or linked to a particular consumer or household. In this Notice, we use the words “The Breakers,” “us,” “our,” or “we” to refer to The Breakers, and “you” and “your” to refer to our guests, retail customers, restaurant patrons and online visitors. The Policy and this Notice shall be collectively referred to as “The Breakers’ Policies.” If there is an inconsistency between this Notice and the Policy, this Notice will govern as to California residents.

By providing your Personal Information and other data to The Breakers, you agree that we may collect, use and disclose your Personal Information according to the terms of The Breakers’ Policies. If you do not agree with these terms, please do not provide any Personal Information to The Breakers or use our Services. However, please note that some of our Services can only be offered if you provide or allow us to collect your Personal Information.

You may click on the links below to jump to that section.

1. What Personal Information We Collect and How We Collect It
2. Why We Use Personal Information
3. Disclosures of Your Personal Information
4. Data Retention
5. Your Privacy Rights
6. Submitting Consumer Requests
7. Third Party Sites
8. Changes to This Policy
9. For More Information
 


WHAT PERSONAL INFORMATION WE COLLECT & HOW WE COLLECT IT

 

Personal Information We May Have Collected When You Use Our Websites, Apply for Membership or Communicate with Us

Currently and in the last twelve months, when you or your agent contact us, make reservations, apply for membership, or access our websites and mobile application, we may collect or have collected the following types of Personal Information:

Audio Information, such as: 

  • Audio recordings of your telephone conversation with our employees and call center staff for quality assurance and legal compliance

Characteristics of Protected Classifications, such as:

  • Gender, age, or national origin, and
  • Disability accommodations, but only if you voluntarily provide this information to us

Commercial Information, such as:

  • Dates of stay or other Services, accommodation requirements or preferences, reason for your stay or visit, names of those who may be staying or using the Services, and promotional specials selected

Customer Records Information, such as:

  • Travel history, purchase history with us, and
  • Medical information that you directly provide to us for allergy or disability accommodations

General Location Data that we collect through your use of the Services, such as:

  • Physical location of your device via your IP address (precise geolocation data is not collected without your consent)

Identifiers, such as:

  • Name, address, date of birth, e-mail address, membership number, and phone number, and
  • Unique cookie identifier or similar identifier or Internet Protocol (“IP”) address that is collected automatically through your use of the Services

Inferences, such as:

  • Your interests and hobbies that are drawn from the other categories of Personal Information

Internet Activity or Other Similar Network Activity that we collect automatically through your use of the Services, such as:

  • Type of internet connection, the equipment used to access our website(s), usage information, browsing history, search history or information relating to your interaction with our website(s) through the use of “cookies,” beacons, pixel tags, mobile ad identifiers, or similar technologies

Professional or Employment-Related Information, such as:

  • Job title, profession, income and employer information (e.g., company name, company address) provided for a membership application, in connection with your reservations, use of our Services or an event; and/or

Sensitive Information that you directly provide to us, such as:

  • Payment information used for reservations, membership, or other purchases made through the Services, and driver’s license or other government identification used for identity verification and security purposes; other Sensitive Information such as race/ethnicity, sexual orientation, religious or philosophical beliefs, health or medical information, citizenship or immigration status and/or union membership status are not actively collected through the Services, but we may infer such information through your accommodation and/or meal requests and/or you may voluntarily communicate or provide such Sensitive Information to us in any content or communications that you upload or make available to The Breakers while using our Services.
     

Personal Information We May Collect When You Visit The Breakers

Currently and in the last twelve months, when you stay with us, dine in our restaurants, or shop at our resort, we may collect or have collected the following types of Personal Information:

Characteristics of Protected Classifications, such as:

  • Gender, age or national origin and
  • Disability accommodations, but only if you voluntarily provide this information to us

Commercial Information, such as:

  • Dates of stay or visit, hobbies, interests, records and reasons for your stays or visits with us, products and services you purchased or considered, accommodation requirements or preferences, service issues, promotions used, activities or services used while staying with or visiting us, events attended, names of those who may be staying or using the Services

Customer Records Information, such as:

  • Travel history, purchase history with us, or medical information used for allergy or disability accommodations, incident reports with respect to any injuries, crimes or other disturbances that occur on The Breakers property, customer complaints contained in our log book, information regarding your activity on property

Identifiers, such as:

  • Name, address, phone number, date of birth, membership number, or email address

Inferences, such as:

  • Your hobbies and interests that are drawn from the other categories of Personal Information collected

Internet Activity or Other Similar Network Activity collected automatically through your use of our Guest WiFi and Services, such as:

  • The devices or equipment used to access our Guest WiFi or other networks at location, usage information, browsing history, search history or information relating to your interaction while using our network through the use of “cookies,” beacons, pixel tags, mobile ad identifiers, or similar technologies

Photographic and Video Information, such as:

  • Digital photographs you provide as identification during mobile check-in and video recordings from security cameras located throughout the premises

Professional or Employment-Related Information, such as:

  • Job title, profession, income and employer information (e.g., company name, company address) provided for a membership application, in connection with your reservations, use of our Services or an event, and/or

Sensitive Information that you directly provide to us, such as:

  • Payment information used for reservations, membership, or other purchases made through the Services, and driver’s license or other government identification used for identity verification and security purposes; other Sensitive Information such as race/ethnicity, sexual orientation, religious or philosophical beliefs, health or medical information, citizenship or immigration status and/or union membership status are not actively collected through the Services, but we may infer such information through your accommodation and/or meal requests and/or you may voluntarily communicate or provide such Sensitive Information to us in any content or communications that you upload or make available to The Breakers while using our Services

You hereby acknowledge and agree that any Sensitive Information you voluntarily provide to The Breakers may be processed as necessary to provide the Services in accordance with your instructions and The Breakers' Policies. 


Personal Information Collected by our Business Partners and Service Providers

Business Partners/Your Agents. We receive Personal Information from business partners, such as your travel agents, luxury tourism associations, and business or personal event planners so that we can process their customers’ registrations, provide Services, and be apprised of their customers’ accommodation needs and other preferences related to our Services.

We are not responsible for how these third parties collect, use, store, or otherwise process your Personal Information. You should review their privacy policies and practices before disclosing your Personal Information to them. If you have any questions about how they use your information, you should review their policies and contact them directly. Once we receive your Personal Information, we will process it in accordance with this Notice and our main Policy.

Cookies on our Websites. When you visit our websites, information is collected about you and your online activities automatically through the use of cookies, pixels and other automated tracking technologies by data analytics companies including Google Analytics and Meta. The Personal Information that is collected through these automated technologies can be found under the subsection titled “Personal Information We May Have Collect When You Use Our Websites, Apply for Membership or Communicate with Us.”

These analytics and social media service providers deliver statistical reports to us about how you and other people use our websites and demographics about our website visitors in an aggregated format. This aggregated data is stored in a format that generally cannot be used to identify you, but to the extent any of this aggregated data reasonably could be combined with other data so that it can be associated with you, we will treat it as Personal Information. Our analytics service providers have represented to us that they use the data collected on our websites for a limited number of lawful purposes, such as improving their product and providing analytics or advertising for us. These third-party analytics and social media providers may transfer the above described information to third parties, if required by law or if third parties process the information on their behalf.

Google. An overview of Google’s data privacy practices for Google Analytics may be available here. For more information on Google’s privacy practices generally, please review Google’s privacy policy here. To opt-out of being tracked by Google Analytics, you may be able to download and install the Google Analytics Opt-out Browser Add-on here. These Google services also may cause you to receive personalized ads based on your browsing behavior. You may be able to opt-out of receiving these personalized ads by using the settings here. See the section titled “How to Restrict Information Collected on our Website” in our main Policy for information about choices you may have regarding this cookie-related activity.

Meta. To learn more about Meta’s privacy practices please see Meta’s Privacy Policy and Cookie Policy. To opt out of tracking through Facebook please go to interest based ads settings or the Meta privacy center. To opt out of tracking through Instagram, please go to privacy settings or the Meta privacy center.

Other Service Providers. We also receive information from other vendors. Specifically, call center management and customer service providers such as Revinate to manage and operate our call center, and digital advertising vendors such as Cendyn to provide marketing services.

The Personal Information that we receive from Revinate can be found under the subsection titled “Personal Information We May Collect When You Use Our Websites, Apply for Membership or Communicate with Us.” For more information with respect to how Revinate may collect and handle Personal Information, please see the Revinate privacy policy here.

We may also collect the following types of Personal Information from Cendyn in order to provide you with opportunities and information suited to your interests (for more information regarding how Cendyn handles any Personal Information it collects from you, please refer to Cendyn’s privacy policy here):

Characteristics of Protected Classifications, such as:

  • Gender, age, or national origin

Commercial Information, such as:

  • Hobbies, interests, and products and services you purchased or considered

Customer Records Information, such as:

  • Travel history or purchase history

Identifiers, such as:

  • Name, address, date of birth, e-mail address, or phone number

Inferences, such as:

  • Your interests and hobbies that are drawn from the other categories of Personal Information we collect and/or

Professional or Employment-Related Information, such as:

  • Education level, job title, profession, income and employer information (e.g., company name, company address)

WHY WE USE PERSONAL INFORMATION

We only use or disclose your Personal Information, including your Sensitive Personal Information, as described in The Breakers' Policies and as permitted or required by applicable law.

Services and Identification. We use Audio Information, Characteristics of Protected Classifications, Commercial Information, Customer Records Information, Identifiers, Photographic Information and Sensitive Information to:

  • Perform our contractual obligations, including providing you with any requested Services, necessary notices, confirmations or communications regarding your stay, event, or other use of our Services
  • Verify the information that you provide to us
  • Respond to requests that you make
  • Charge and bill for services or products; and/or
  • Protect the physical security and safety of the premises

Enhancing Your Visit. We use Commercial Information, Customer Records Information, Identifiers and Inferences to anticipate and fulfill your preferences and requirements, and to provide the accommodations and services for which we are known.

Long-term Relationship. To help build a long-term relationship, we may use Characteristics of Protected Classifications, Commercial Information, Customer Records Information, Geolocation Data, Identifiers, Inferences, Internet Activity and Professional or Employment-Related Information to:

  • Provide you with promotional materials suited to your interests; and
  • Send you emails, digital newsletters, personalized offers or other communications about our products and services.

Optimizing Website and Mobile Interaction. We use Commercial Information, Customer Records Information, Geolocation Data, Identifiers, and Internet Activity to:

  • Analyze usage of our websites, the number of visits from different locations, and your online browsing activities so that we better understand the interests and demographics of the visitors to our websites and improve performance and effectiveness
  • Customize the content you see on our websites and deliver our advertisements to you when you visit other websites
  • Monitor and control the use of our websites in order to protect the security and integrity of our Services; and/or
  • De-identify and aggregate data about usage of our websites that we use or share for statistical or analytical purposes (noting that de-identified data is not Personal Information subject to The Breakers' Policies)

Membership Applications. For club membership applicants, we use Characteristics of Protected Classifications, Commercial Information, Customer Records Information, Identifiers, Professional or Employment-Related Information and Sensitive Information to verify eligibility and security requirements related to membership.

DISCLOSURES OF YOUR PERSONAL INFORMATION

Currently and in the last twelve months, we may have shared your Personal Information with the vendors, business partners, professional or legal advisors, acquiring or merging entities, and providers of fraud protection or security services as set forth in the “WHEN AND WHY WE DISCLOSE PERSONAL INFORMATION” section of our main Policy.

Selling / Sharing Personal Information

Currently and over the last twelve months, we have not engaged in any direct sale of your Personal Information as a way to generate revenue, but we use certain third-party analytics and social media providers which may have access to some of your data to help provide Services on our behalf as described in our main Policy. The Breakers’ use of these third-party providers may cause you to receive targeted advertising based on your browsing behavior on our Services and elsewhere online.

To opt-out of the sharing of your Personal Information for targeted advertising purposes, please see the “Right to Opt-Out of the ‘Sale’ or 'Sharing' of Personal Information” section, below, for further information.

Over the past 12 months, we did not knowingly “sell” or “share” the Personal Information of minors under the age of 16 years old, as those terms are defined under the CCPA.

Other Disclosures

In the past twelve months we did not:

  • Use your Sensitive Information to infer characteristics about you for a purpose that would grant you a right to limit such sharing;
  • Conduct profiling activities about you based on your Personal Information for a purpose that would grant you the right to opt out of such processing activities;
  • Process your Personal Information using “automated decision making technology” to make a “significant decision” (e.g., financial, housing, education, employment, or health-based decisions) about you, as such terms are defined under the CCPA; or
  • Provide any financial incentives with respect to the collection of your Personal Information.

DATA RETENTION

Currently and in the past twelve months, The Breakers have retained Personal Information in accordance with the “HOW LONG WE KEEP PERSONAL INFORMATION” section of the Policy.

YOUR PRIVACY RIGHTS

In connection with The Breakers’ collection and use of your Personal Information, you may be able to submit certain requests when exercising your rights under California law, which are further described below.

Right to Know

As a California resident, you have the right to confirm that we have accessed and processed your Personal Information and request that we disclose certain information to you about our collection and use of your Personal Information. You may submit a verifiable request (see “Submitting Consumer Requests” below) that the following be disclosed to you:

  • The categories and sources of Personal Information that we collected about you;
  • Whether we sold, shared, or disclosed your Personal Information;
  • Our business or commercial purpose(s) for collecting, selling, or sharing your Personal Information; • The categories of recipients of your Personal Information; or
  • The specific pieces of Personal Information that we collected about you in a portable format (also called a data portability request), unless prohibited by law.

Right to Delete

As a California resident, you have the right to request that we delete all or some of the Personal Information that we collected about you, subject to certain exceptions. You may submit a verifiable request (see “Submitting Consumer Requests” below) that may result in:

  • The permanent and complete erasing of your Personal Information on our existing systems, and our vendor’s existing systems, with the exception of archived or back-up systems;
  • De-identifying your Personal Information so that it is no longer reasonably capable of being linked to you; or
  • Aggregating your Personal Information with other information so that it is no longer reasonably capable of being linked to you.

If you choose to request that we delete your Personal Information, it may affect your ability to use certain features of our websites or to receive other Services.

Right to Correct Inaccurate Personal Information

As a California resident, and subject to certain exceptions, you have the right to request that we correct inaccurate Personal Information that we have collected and maintain about you. In determining whether your Personal Information is inaccurate, we will consider the nature of the information (for instance, whether it is objective information or subjective information), the source of the information, and available documentation relating to the accuracy of the information. If the information is inaccurate, we may also delete that information.

Right to Opt-Out of the “Sale” or “Sharing” of Personal Information

As a California resident, you may have the right to opt-out of any such “sale” or “sharing” of Personal Information through targeted advertising. You may exercise this opt out right by clicking the “Your CA Privacy Choices” link that is available through our Services and filling out our interactive request form. Other ways you may be able to opt-out of targeted advertising are described in the “Security and ‘Do Not Track’ Signals” section, below.

Right to Non-Discrimination

As a California resident, you have a right not to be subject to discriminatory treatment as a result of exercising the rights conferred upon you by the CCPA. In other words, the quality and price of the goods and services we offer will not be modified because you exercised your rights as described in this Notice.

Right to Appeal and Submit a Complaint

If we reject your privacy request, you have the right to submit an appeal to us and you can also submit a complaint to the California Privacy Protection Agency.

Other Privacy Rights

The CCPA also provides other privacy rights; however, such rights do not apply to our processing activities as described under this Notice.

SUBMITTING CONSUMER REQUESTS

To exercise your privacy rights as described above, please submit a verifiable request to us by:

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Each verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information, or an authorized representative of such person; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

For requests to correct inaccurate information, we may ask you to provide documentation that demonstrates why or how the existing information is inaccurate.

You may grant an authorized agent written permission to submit requests on your behalf. We may request proof of your written permission before responding to any requests made by a purported authorized agent and may deny those requests if we are unable to verify your identity, or if you cannot provide proof that you authorized the agent to act on your behalf. You may also make a verifiable consumer request on behalf of your minor child. The Breakers may deny authorized agent requests if we are unable to verify your identity directly as the subject of the Personal Information at issue.

The Breakers is required to verify the identity of any person or entity that requests the disclosure, correction or deletion of Personal Information. If you have a password-protected account with us, we will use our existing authentication procedures to verify your identity. For most other requests from individuals who do not have a password-protected account with us, we will ask for information that matches at least two pieces of Personal Information we store about you before responding to your request. If you would like to request specific pieces of your Personal Information that the Breakers has collected, or if you would like us to delete Sensitive Information, you will need to provide information that matches at least three pieces of information that we store about you, and you must provide a signed declaration under penalty of perjury that you are the consumer, or agent for the consumer, whose Personal Information you are requesting.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information that relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify identity or authority to make the request.

Security and “Do Not Track” Signals

We understand that the privacy and security of your Personal Information is important to you. In keeping with this understanding, and with our legal obligations, we utilize appropriate administrative, technical and physical safeguards designed to protect your Personal Information.

If you do not want your internet activity or similar information tracked or collected through the use of cookies, you should review your web browser settings. Most web browsers allow a user to restrict these functions; however, you should note that disabling cookies may prevent certain website features from functioning properly. More information on our use of “cookies” can be found in our main Policy.

“Do Not Track” (“DNT”) is a preference you may be able to activate in your web browser to inform websites that you do not want to be tracked. You may be able to enable or disable DNT or other automated signals by using the settings of your web browser. Our website is not currently configured to respond to DNT or similar automated privacy controls. However, you can still exercise your opt out rights by clicking on the “Your CA Privacy Choices” link that is available through our Services.

To learn more about ways to opt-out of certain kinds of tracking that occur when you browse the internet generally and may lead to targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific, and there is no guarantee that these industry-provided opt-out tools will prevent all targeted advertising. As noted elsewhere in The Breakers’ Policies, it is possible that certain third parties may collect or receive information from you when you use our Services, such as analytics providers. Since some of these third parties may respond differently than The Breakers to DNT and similar automated requests, you should consult the applicable privacy policies of those third parties for that information.

THIRD PARTY SITES

The Breakers is not responsible for Personal Information you provide to third parties, such as social media platforms or sites where you may be redirected for payment. Our websites include features that interact with social media platforms, such as Instagram and Facebook. These features may collect your IP address, which page you are visiting on our websites, and may set a cookie to enable the feature to function properly. The Breakers also maintains an online presence on these social media platforms.

When you interact with our pages on these social media platforms, including by sending us direct messages or submitting other information, your information is subject to the data practices of these platforms. Your interactions with these features are governed by the privacy policy of the company providing the features. We are not responsible for the privacy policies and practices of any of these third parties. You should review the privacy policies and practices of such third parties prior to disclosing your Personal Information to them. If you have any questions about how these third parties use your information, you should review their policies and contact them directly.

CHANGES TO THIS POLICY

We reserve the right to modify this Notice at any time. When we make changes to this Notice, we will post the updated Notice on this website and contact you as required by law. You are responsible for periodically reviewing this Notice. The Notice posted at any time on this website shall be deemed the Notice then in effect. Your continued use of our Services following the posting of changes constitutes your acceptance of the updated Notice.

Please note that we will not collect new types of Personal Information without providing you notice prior to collecting such Personal Information. We will not use your Personal Information for an unexpected purpose without first obtaining your consent in accordance with applicable law.

FOR MORE INFORMATION

In the event that you have any questions about this Notice, or if you have reason to believe that we may have failed to adhere to this Notice, please contact The Breakers using the following information.

BY MAIL:
The Breakers
Attention: Privacy Officer
One South County Road,
Palm Beach, FL 33480

BY EMAIL: 
[email protected]

BY PHONE:
(844) 683-1439