Privacy Policy

This online Privacy Policy (the “Policy”) describes how Goodwood International Ltd and its affiliates and subsidiaries (collectively “Goodwood,” “we,” “us,” or “our”) collect, use, disclose, and secure the personal information we gather about you through our website, https://grrcamerica.com (the “Site”), when you use our app, and when you otherwise interact with us (collectively, the “Services”).

For purposes of this Policy, personal information means data that classifies as personal information, personal data, personally identifiable information, or similar terms under applicable data privacy and security laws and regulations. It does not include data excluded or exempted from those laws and regulations, such as aggregated, anonymized, or deidentified data. Nothing in this Policy will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Goodwood generally or in any specific context.

In providing our Services, Goodwood may collect personal information on behalf and as a service provider for third parties. This Policy does not govern any information we collect on behalf of third parties, and you should consult their privacy policies to become familiar with their data collection and usage practices.

Notice at Collection: At or before the time of collection, California residents have a right to receive notice of our practices, including the categories of personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how to opt-out of such uses, and how long such information is retained. You can find those details in this statement by clicking on the foregoing links.

By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Policy. If you do not agree to this Policy, you may not use the Services.

This Policy applies regardless of how the Services are accessed and will cover any technologies or devices by which we make the Services available to you.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

We collect information you voluntarily provide directly to us, information that we collect automatically when you interact with the Services, and information collected from third parties. The categories of personal information that we collect and the purposes for which we collect that information are described below.

a. Personal Information You Provide to Us

The following list describes the categories of personal information we may collect directly from you:

• Contact Information includes first name, last name, mailing address, phone number, and email address. We collect this information when you provide it directly to us, such as when you sign up for newsletters, request information about our Services, create an account, or fill out a form. We collect this information for providing the Services, administrative purposes, and marketing and advertising our products and services.
• Payment and Commercial Information includes first name, last name, billing address, phone number, third party payment service provider-related information, debit or credit card information, purchase and participation history, or other payment processing information. We collect this information for providing the Services and for administrative purposes.
• Press Information includes first name, last name, title, profession, email address, business phone number, mobile phone number, company name, password, coverage details. We collect this information for providing the Services, administrative purposes, and for marketing and advertising our products and services.
• Responses to Surveys and Questionnaires includes information you provide to us when you respond to marketing materials, promotions, contests, requests for feedback, or other surveys. We collect this information for administrative purposes and marketing and advertising our products and services.
• Social Media Information includes information that you post by sharing on a blog or another social media platform. We collect this information for administrative purposes and marketing and advertising our products and services. Please note that your comments will be visible to the public, so you should never share personal information that you would like to keep private.
• Text Message Opt-In Information includes your opt-in consent to receive marketing messages from us through short codes or similar means. We collect this information for providing the Services, marketing and advertising our products and services, and for administrative purposes.
• User-Generated Content includes information about you included in content you upload, comment, or otherwise submit on the Services, such as your name and email address and products you may have purchased. Be aware that as a default, any information you post on the Services, including without limitation reviews, comments, and text, may be available to and searchable by all users of the Services. We collect this information for providing the Services and administrative purposes.

The purposes for which we use your personal information are described in further detail in the “How We Use Personal Information We Collect” section below.

b. Personal Information Collected Automatically Through Cookies or Other Tracking Technologies

We may send one or more cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services. This information allows us to understand how you use the Services.

Cookies are small files created by websites, including our Services, that reside on your computer’s hard drive and that store information about your use of a particular website. Cookies have many different functions, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience or providing us information about how users navigate through our Services. To learn more about the cookies we utilize and their purposes, review our Cookie Policy.

You can manage your cookies preference as described in the “Your Privacy Options and Configurations” section below.

Mobile App Information. When you use our mobile app, we will collect certain information regarding your usage, the specifics of which will depend on how you use the application. We collect this information for the purposes of providing the services, analytics and research, and customer service.

Our mobile app may also use certain third party APIs, which will allow you additional functionality if you choose to use them. You should refer to the privacy policies of those third parties to determine how they may use your personal information.

c. Personal Information We Receive From Third Parties

We may receive additional information about you from third parties, such as parents, affiliates, subsidiaries, or marketing partners, and combine it with other information we have about you. We will always use that information only as described in this Policy.

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Providing Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

• Facilitating stays and experiences;
• Hosting and running events;
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased or used;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Improving, upgrading, or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing personal information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” section below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

We may collect, use, or disclose personal information for a variety of business purposes, including the following:

• To Business Partners and Affiliates. We may disclose personal information to our business partners and affiliates; advisors such as legal advisors and financial advisors; related entities, parent companies, investors, subsidiaries, joint ventures, or other companies under common control; and other third parties.
• As Part of Business Transactions or Mergers. We reserve the right to disclose your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence. If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
• As Part of Bankruptcy or Insolvency. In the event of bankruptcy, insolvency, or dissolution proceedings, we may disclose your personal information with third parties as part of the sale or reorganization process.
• To Service Providers. We use service providers to perform various functions on our behalf. We may also receive personal information from service providers.
• Marketing Partners. We may use certain cookies or pixels that collect personal information so that it can be used in connection with the marketing efforts of third parties. In those instances, your personal information may be used for third parties to serve unsolicited information, services, or products to you.
• As Required by Law, for Legal Purposes, and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with regulatory, administrative, or law enforcement requests and legal process, such as a court order or subpoena, or the requests of governmental or regulatory agencies (whether domestic or foreign); (b) respond to your requests, the requests of others, or to lessen the burden of anticipated or formal legal requests; or (c) protect your, our, or others’ rights, property or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Under certain international and U.S. state privacy laws, you may be entitled to various privacy rights. Although they may not all apply to us, Goodwood values your privacy, and we therefore afford privacy rights to all individuals regardless of their residency. The chart below explains these rights, although some exceptions may apply:

Sensitive Data. We will process sensitive data (as the term or its equivalent is defined by applicable privacy laws) in accordance with any applicable privacy laws. In some instances, that means we will not collect sensitive data without first obtaining your consent or providing you with the right to opt out.

Exercising Your Rights. To exercise your rights to know/access, to correct, to delete, to restrict, or portability (“Verifiable Requests”), as applicable, please email us at DataPrivacy@Goodwood.com or at +44 1243 755055. To exercise your right to opt-out of sales or sharing of your personal information for targeted advertising please visit our “Cookies” page and click “Manage Settings”.

Verification. To ensure the protection of your personal information, we may need to verify that the individual submitting a request is the consumer to whom the request relates prior to processing the Verifiable Request, or an Authorized Agent. To verify a consumer’s identity, we may request up to three pieces of personal information about you to compare against our records when you make a request.

Making a Verifiable Request does not require you to create an account with us. However, we may require that you access a previously existing account where necessary to submit the request.

We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of consumers where we have reason to believe a Verifiable Request is fraudulent.

You may choose a person or business that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.

Depending on the device(s) you use to access the Services, you may be able to select certain privacy choices or configuration, which are further described below:

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Use or this Policy).
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device.
• Do Not Track (“DNT”). DNT is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals. At this time, our Site responds to the Global Privacy Control (“GPC”). You can visit the GPC official site at https://globalprivacycontrol.org/#about to learn how to configure your device to send such signals. We will honor and process the opt-out preference signal accordingly.
• Cookies and Personalized Advertising. You may stop or restrict the placement of cookies and tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions provided by Android or iOS. You can find out more about cookies and how to manage them by visiting https://ico.org.uk/for-the-public/online/cookies/.

This section supplements our Policy and only applies to our processing of personal information that is subject to California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. as amended by the California Privacy Rights Act and implementing regulations (collectively “CCPA”).

A. Collection of Personal Information

In the preceding 12 months, we have collected personal information from the following categories identified in Section 2, which are described using the terms identified under the CCPA: identifiers, personal information, protected classifications, commercial information, biometric information, sensory data, internet or other similar network activity, professional or employment related information, and inferences. We have collected these categories of information for administrative purposes, providing the Services, and marketing and advertising our products and services.

B. Disclosure of Personal Information

In the preceding 12 months, we have disclosed personal information in the following categories: identifiers, personal information, protected classifications, commercial information, biometric information, sensory data, internet or other similar network activity, and inferences with service providers. We have collected these categories of information for administrative purposes and providing the Services. We disclose content posted on our social media platforms (e.g., if a consumer “comments” on a story) with other consumers. Such posts may include information in the category of personal information and identifiers, but the content depends on the individual posts.

C. Sharing of Personal Information

In the preceding 12 months, we have shared for cross-contextual behavioral advertising personal information in the following categories: personal information, identifiers, protected classifications, commercial information, and internet or similar networking activity with advertising partners. We have shared this information for the purpose of marketing and advertising our products and services.

D. Sales of Personal Information

In the preceding 12 months, we have not sold the personal information of any consumer for monetary consideration. However, our use of cookies and other tracking technologies may be considered a sale of personal information under the CCPA. Categories of personal information that we have sold under the CCPA include the following: identifiers, personal information, commercial information, internet or similar network activities, and inferences. Categories of third parties to whom we have sold personal information under the CCPA include data analytics providers and advertising and marketing providers, for the purpose of marketing and advertising

E. Collection of Personal Information from Children under 16

We do not knowingly collect or process personal information pertaining to children under the age of 16.

F. Sensitive Personal Information

If we process sensitive personal information as defined by California law, we will only do so for the purposes specifically authorized by California law and in a manner that is necessary and proportionate for those purposes. As such, we do not perform any processing for which a Right to Limit request is available.

You may be entitled to know our legal basis for processing your personal information pursuant to applicable law. Our processing of your personal information is supported by the following legal bases:

• For Performance of a Contract. We may process your information where required to provide you with our Services. For example, we may need to process your information to respond to your inquiries or requests.
• When We Have a Legitimate Interest. We may process your information where we or a third party have a legitimate interest in processing your information. Those legitimate interest include, but are not limited to, fraud preventions, network security, identifying usage trends, determining the effectiveness of promotional campaigns, expanding our business activities, and improving the Services and the content and functionality of our Services.
• With Your Consent. We may process your information where you have consented to certain processing of your information.
• For Compliance with Our Legal Obligations. We may process your information where we have a legal obligation to do so. For example, we may process your information to comply with tax, labor, and accounting obligations.

The specific legal bases corresponding to the purposes for which we process your personal information is set forth in the chart below:

Goodwood is the controller for all personal information subject to this Policy that is collected from residents of the EEA, UK, and Switzerland. We process personal information on our servers in the United States, which does not have an adequacy decision, and may do so in other countries. If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.

Personal information you provide while in another country, including an EEA member state, the UK, or Switzerland may be transferred to the United States. Applicable data protection laws may permit such transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the applicable data protection laws in the EEA, UK, and Switzerland or the laws of other jurisdictions where you may be located. If we transfer personal information from the EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.

For more information, please contact us using the information provided in the “Contact Us” section below.

We determine how long to retain your personal information by taking into account various criteria, such as the type of Services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and our obligations under applicable law.

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, and unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Policy or under applicable law, contract, or regulation.

The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

However, we cannot and do not guarantee complete security, as it does not exist on the internet.

Our Services may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. It is important to note that this Policy only applies to our Services. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

Our Services are not directed at children (as defined under applicable law). We do not knowingly collect or otherwise process personal information from children. If you believe a child has provided us with information, you can alert us by contacting us as set forth in the “Contact Us” section below.

This Policy may change from time to time. If we need to change this Policy at some point in the future, we will post any changes on this page. If we make a significant or material change to this Policy we will notify you as required by applicable law. You should check these terms when you use the Services. Your continued use of the Services constitutes acceptance of the most current version of this Policy.

If you are a California resident and have an established business relationship with us, Goodwood has not disclosed personal information to third parties, for those third parties’ direct marketing purposes during the preceding calendar year.

If you have any questions about this Policy, please contact us by email at DataPrivacy@Goodwood.com, via phone at +44 01243 755000, or at Goodwood International Limited, Goodwood House, Goodwood, Chichester, West Sussex PO18 0PX.