Privacy Policy

Last Revised: July 8, 2019 

The Howard Hughes Corporation (“us”, “we”, or “our”) respects your privacy. This Privacy Policy applies to all Howard Hughes Corporation websites that link to it, including www.summerlin.com (collectively, the “Website”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Website.

We use your Personal Information only for answering press and potential member inquiries. By using the Website, you agree to the collection and use of information in accordance with this policy.

Information We Collect

While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name, email address, demographic information, and any personal information that you provide in response to surveys we provide (collectively, “Personal Information”). We may also receive information about you from our parent company, affiliates, service providers, business partners, and other third parties.

When you use the Website, we may collect certain information by automated means, such as through the use of cookies. “Cookies” are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. We may also use third-party analytics tools (such as Google Analytics) that collect information about use of the Website and user traffic. The information we may collect by automated means may include, but is not limited to:

· Information about the devices you use to access the Website (such as the IP address and the type of device, operating system, and web browser);

· Dates, times, and duration of use of the Website (including whether you are a repeat or first-time visitor); and

· Information on actions taken when using the Website (such as page views and website navigation patterns).

The information we collect automatically helps us to improve and personalize our Website, including by enabling us to identify and authenticate users. To the extent that we pair any anonymous or nonpersonal information with a user’s personal information, we will treat such information in accordance with the terms of this Privacy Policy.

How We Respond to Do Not Track Signals

Your web browser may let you choose your preference as to whether you want to allow the collection of information about your online activities over time and across different websites or online services. At this time, the Website does not respond to the preferences you may have set in your web browser regarding such collection of your information, and the Website may continue to collect information in the manner described in this Privacy Policy. 

How We Use Your Personal Information

We may use the Personal Information we collect to:

· Complete transactions you have requested using the Website;

· Send you information or materials you request;

· Maintain a record of your transactions using the Website;

· Respond to your questions and comments and provide customer or member support;

· Communicate with you about our products, services, offers, promotions, and loyalty program;

· Operate, evaluate, and improve our business and the products and services we offer;

· Analyze and enhance our marketing communications and strategies;

· Analyze trends and statistics regarding use of the Website and transactions conducted using the Website;

· Protect against and prevent fraud, unauthorized transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;

· Enforce our Terms of Use [https://www.summerlin.com/terms.html] and other agreements; and

· Comply with applicable legal requirements and industry standards.

We also may use the information we obtain about you in other ways for which we will provide specific notice at the time of collection.

How We Disclose Your Personal Information

We may disclose aggregated information about our users, and information that does not identify any individual user, without restriction. We may disclose Personal Information about you:

· To our affiliates and subsidiaries;

· To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;

· To comply with any court order, law, or legal process, including to respond to any government or regulatory request;

· To enforce or apply our Terms of Use [https://www.summerlin.com/terms.html] and other agreements;

· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Howard Hughes Corporation, users of the Website, or others; and

· With your consent.

We also reserve the right to transfer your personal information to a buyer or other transferee in the event of a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of some or all of our assets.  Should such a sale, merger, or transfer occur, we will use reasonable efforts to direct the transferee to use your personal information in a manner that is consistent with our Privacy Policy.

Your Choices

We offer you the following choices about the information we collect from you and how we communicate with you: 

Cookies

Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of the features of the Website. 

Promotional Communications

If you have received a promotional email from us, you can also opt out of receiving future promotional emails from us by following the unsubscribe instructions contained in such email. You may also update your communication preferences by logging into your account and visiting your account profile page.

Third-Party Analytics

You may opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics by installing Google’s browser extension, here: https://tools.google.com/dlpage/gaoptout.

Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of Personal Information is at your own risk.

Children Under the Age of 13

The Website is not directed to, and we do not knowingly collect or solicit personal information from, children under the age of 13. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at summerlin@howardhughes.com.

Changes to this Privacy Policy

This Privacy Policy is effective as of July 8th, 2019 and will remain in effect except with respect to any changes in its provisions in the future. We reserve the right to update or change our Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our Website. In the event we make a material change to this Privacy Policy that affects how we handle your Personal Information, we will also provide you with an opportunity to opt out of such new or different use.

The date this Privacy Policy was last revised is at the top of this page. We encourage you to review this Privacy Policy periodically to check for any updates or changes.

Data Transfers

We are based in the State of Texas in the United States. When we obtain information about you, we may transfer, process, and store such information outside of the country in which you reside, including in the United States. By using the Website, you consent to the transfer to and processing and storage of your information in countries outside of your country of residence, which may have different data protection laws than those in the country where you reside.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at summerlin@howardhughes.com or info@downtownsummerlin.com, or write to us at:

The Howard Hughes Corporation

Attention: Marketing Director

1650 South Pavilion Center Dr., Suite 160

Las Vegas, Nevada  89135

Summerlin Social Media Policy

Last Revised: July 8, 2019

Summerlin welcomes honest and open conversation on Summerlin and Downtown Summerlin social media pages (the “Summerlin Pages”); however, we reserve the right to remove comments or discussion posts at our discretion.

We encourage comments that:

· Are on topic, brief, and have a constructive tone;

· Are open to being discussed or even contradicted by other commenters; or

· Might disagree with the content in the post or update.

We discourage comments that:

· Are repeatedly off topic;

· Are excessively long or negative in tone;

· Are considered likely to disrupt, provoke, attack, or offend others, including personal conversations better suited for private messaging; or

· Advertise products or services for profit or gain.

We reserve the right to remove comments that:

· Are racist, sexist, sexually explicit, abusive or otherwise objectionable;

· Contain swear words or other language likely to offend;

· Could break the law or condone or encourage unlawful activity (this includes breach of copyright, defamation and contempt of court);

· Are seen to impersonate someone else;

· Are factually inaccurate or libelous and thus could mislead or misinform readers/followers;

· Share personal information including phone numbers, social security numbers, or addresses;

· Describe or encourage activities which could endanger the safety or well-being of others;

· Are considered to be ‘spam’ (posts containing the same message posted multiple times or multiple, excessive comments that are not relevant or related to existing content), marketing, or advertisement;

· Contain personal or offensive comments about individual social media users or people who work for Summerlin, which may be considered harassment.

By commenting on the Summerlin Pages, you are indicating that you have read, understand, and agree to abide by the guidelines laid out above. People who are continually abusive and offensive to others on the Summerlin Pages risk being permanently removed as commenters.

Disclaimer
Comments posted on the Summerlin Pages do not necessarily reflect the opinions of Summerlin and Downtown Summerlin, and shared information does not constitute an endorsement of any kind. All content and posts are bound by the terms and conditions of Facebook, Twitter, Instagram, Yelp, Trip Advisor, or such other social media platforms, as applicable.

If you have any questions about this Social Media Policy, please contact us at summerlin@howardhughes.com or info@downtownsummerlin.com.