The St. Joe Company Privacy Policy

Effective Date: September 25, 2020

This is the Privacy Policy of The St. Joe Company and its affiliates (“St. Joe,” “we,” “us,” or “our”) and governs the collection and use of information gathered from or provided by you through www.joe.com and each website provided by St. Joe that links to this Privacy Policy (collectively, the “Site”). The Privacy Policy applies to all “users” of the Site, including both users who simply visit the Site and users who submit information to us through the Site. Please review this Privacy Policy carefully because it contains important information concerning your use of the Site. If you do not want us to gather and use information about you as described in this Privacy Policy, please do not use the Site. Your use of the Site constitutes your acceptance of and agreement to this Privacy Policy. This Privacy Policy is a part of and governed by the St. Joe Terms of Use.

1. Our Privacy Policy is based upon respect. The purpose of this Privacy Policy is to identify for you the nature of information that may be collected about or from you in connection with your use of the Site and the way in which we may use and disclose this information.

2. Types of Information Collected. We may collect the following types of information from you:

(A)information that you actively choose to disclose when you submit an information request through the Site, sign up to receive one of our community e-newsletters , participate in an online survey or use the “Send to a Friend” feature on the Site, such as your name, address, telephone number, email address or other information by which you may be identified;

(B)information automatically collected when you visit the Site, such as your name, street or e-mail address, birthday information, IP address, mobile device ID, geolocation data, browser type and other software and hardware information, and information about what web pages you have visited, what queries you have run and advertisements you have viewed, and other information associated with you, such as your interests, job, family, personal characteristics, and preferences; and

(C)information that home builders, realtors, and other companies, and other people provide to us about you when they send you a property listing using the “Send to a Friend” feature on the Site.

3. Use of Information Provided. We do not sell or otherwise disclose information about you, except as described in this Privacy Policy. St. Joe may use and disclose information collected from you through the Site in the following circumstances:

To contact you. We may periodically send you information and promotional materials about our services, properties and products in which we believe you may be interested. If you want to stop receiving informational and promotional materials from us you can follow the unsubscribe instructions at the bottom of each email or contact us at marketing@joe.com.  To fulfill requests submitted by you. If you request information or services from us, or if we receive your email address because someone you know has sent a property listing to you through the “Send to a Friend” feature on the Site, we may use the information provided about you to fulfill the applicable request. If we receive your email address because someone you know has sent a property listing to you through the “Send to a Friend” feature on the Site, we will not use your email address for any reason other than to send you the property listing, and any related message, that is sent to you by that person to perform market research. We may use and disclose information collected through the Site for market research purposes, for project planning or for development of prospect lists for our communities. In addition, we may use your information in an aggregate manner with the information of others and may use and disclose such statistical information in connection with managing our business. To provide and manage the Site. We use the information we collect from and about users to measure and improve the services and features offered through the Site, to allow you to participate in contests or promotions, to enable you to communicate and share with other users, and to provide you with customer support and respond to inquiries.

4.  How We Share Your Information with Third Parties. We do not sell or rent user information we collect through the Site to any third parties for their own marketing purposes. In the event we want to sell or rent your information to third parties for their own marketing purposes in the future, we will notify you and you will have an opportunity to affirmatively opt-in to receiving these third party marketing communications. St. Joe does share your information with third parties in some circumstances as follows:

To allow third party service providers to assist us in connection with the Site. We may make your information available to certain third-party service providers, such as contractors, agents or sponsors, who help us manage the Site or provide services through the Site by, for example: developing or supporting products and features; conducting email marketing on our behalf; processing transactions; administering message boards; processing data or statistics; or assisting with the administration, judging and prize fulfillment aspects of contests, promotions and sweepstakes. These third-party service providers are required to protect the information we entrust to them and not use it for any purpose other than the specific service they are providing to us. In connection with business transfers. in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from users of the Site to third parties. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. We note that information submitted or collected after a transfer may be subject to a new privacy policy adopted by the successor company to protect users and in connection with law enforcement. In addition, we may use and disclose information that we have gathered from you or that you have provided to us if we believe that any law or regulation requires us to do so, to respond to a subpoena or governmental request, as we deem it advisable or necessary to protect our safety, rights or property, or that of our employees, agents, affiliates, users or others, and to respond to a possible violation of the St. Joe Terms of Use or this Privacy Policy. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law. We may share your information with third parties when we forward Digital Millennium Copyright Act (“DMCA”) notifications we receive in accordance with the St. Joe Terms of Use. DMCA notifications will be forwarded as submitted and we will not remove any personal information that may be included in the applicable notification.

5. St. Joe’s Use of Cookies and Web Beacons. We use “cookies” and other tracking technologies which are comprised of small bits of data that often include an anonymous, unique identifier. The Site sends this data to your browser when you first request a webpage and then stores the data on your computer so that the Site can access the information when you make subsequent requests for webpages from the Site. We use these technologies to help us provide a better user experience by measuring which Site areas are of greatest interest to you. Most browsers are initially set to accept cookies, however, you can choose to disable cookies in your browser. If you elect to disable cookies in your browser you should still be able to access most webpages on the Site.

Certain web pages on the Site may contain web beacons (also known as internet tags, pixel tags and clear GIFs). When you receive newsletters or promotional e-mail from us, or use the “Send to a Friend” feature on the Site, we may use web beacons, customized links or similar technologies to determine the date and time the e-mail was sent, whether the e-mail has been opened and which links you click in order to provide you with more focused communications and information.

6. Third Parties’ Use of Cookies and Web Beacons. The Site may include third-party advertising, links to other websites, and other content from third-party businesses. These third-parties may use cookies and web beacons to track the actions of users online over time and across different web sites or platforms to deliver targeted electronic advertisements to an individual user. For information about how tracking works for online advertising purposes you can visit http://www.aboutads.info/choices.

St. Joe does not have access to or control over web beacons or cookies that third party websites may use. We are not responsible for the privacy practices or the content of these third-party websites. You are encouraged to review the privacy policies of the different websites you visit. In addition, some third-party advertising companies may provide a mechanism to opt-out of their technology. For more information about the opt out process, you may visit the Network Advertising Initiative website, available at: http://www.networkadvertising.org/managing/opt_out.asp. In addition, your browser may allow you to adjust your browser settings so that “do not track” requests are sent to the websites that you visit. However, St. Joe will not disable tracking technology that may be active on the Site in response to any “do not track” requests that we receive from your browser.

7. Chat Rooms, Bulletin Boards and Interactive Forums. If you post information about yourself on bulletin boards or similar interactive portions of our Site, that information may be viewed and used by St. Joe, other users of the Site and the public generally. We strongly recommend that you do not post any information through the Site that allows strangers to identify or locate you.

8. Notice to Residents of Countries outside of the United States. St. Joe is headquartered in the U.S., the Site is hosted in the U.S. and the data you submit to the Site is stored in the U.S. The privacy and data protection laws in the U.S. may not be equivalent to similar laws in your country of residence. By using the Site, or by providing us with your information, you consent to the collection, transfer, storage, and processing of information to and in the U.S.

9. Securing Your Information. We use commercially reasonable administrative, technical and physical precautions to keep the information about you that we have gathered protected from unauthorized use or access. You should recognize, however, that no computer system is fully secure and that there are inherent risks associated with the Internet.

10. The Site Is Not Intended for Children Under 13 Years Old. The Site is not directed to children under the age of 13. We will not knowingly collect or use personal information from anyone under the age of 13. Minors who are 13 years old or over should secure the permission of their parent or guardian before providing any information on or through the Site. We ask parents to be particularly careful in supervising any children using the Site, especially the interactive portions.

11. Access to and Correction of Personal Information Maintained About You/Ability to Opt Out of Further Contacts.

·Access. In the event you wish to determine the nature of the information we have collected from or about you, please contact us.

(D)Updates and Corrections. In addition, if you have corrections or updates to the information we are maintaining about you (your address for example), please help us keep your information accurate by providing us with the corrected information.

(E)Opt Out. In the event that you do not wish to receive future marketing and similar materials from us (other than those we are required by law or by contract to provide to you), please contact us and notify us of your request. Our inadvertent failure to comply with this request shall not be a violation of this policy. Please note that we may have gathered information about you through other sites, sources, methods and means (including through our affiliates) and this opt out may not necessarily be applied to the information we have about you that has been provided by these other sources. In addition, if you opt out to receive certain information, you may not be able to utilize certain portions of the Site.

(F)Questions. If you have questions about the operation of this site or other matters, please direct them marketing@joe.com.

12. Updates to Our Privacy Policy. We reserve the right to change this Privacy Policy at any time in our discretion. If we make material changes to this Privacy Policy that expand our rights to use your personal information, we will notify you through a prominent posting on the Site or by email.

NOTICES AND RIGHTS FOR CALIFORNIA CONSUMERS
California Consumer Privacy Act
This section of our Privacy Policy supplements our Privacy Policy to provide additional information under the California Consumer Privacy Act of 2018, as amended, and applies only to consumers who reside in the State of California. This section does not apply to Community personnel or to California residents whose information we obtain in business to business interactions.

Notice of Collection of personal information
The personal information we collect about consumers and the business or commercial purposes for which it will be used is described in the following sections of our Privacy Policy:

• USE OF YOUR INFORMATION
• PERSONAL INFORMATION COLLECTION AND USE
• USAGE DATA
• TRACKING & COOKIES DATA
• USE OF DATA
• TRANSFER OF DATA
• DISCLOSURE OF DATA

No Sale of personal information
California consumers have the right to direct a business not to sell their personal information to others. We may participate in joint marketing programs that involve sharing personal information about customers and prospective customers with home builders, and other business partners that work with us, we believe may be of interest to our customers or complement our products and services. We do not consider these cooperative marketing arrangements to be a sale of your personal information, although we may receive reciprocal services or customer information as part of these arrangements.

In the preceding twelve months, we are not aware of any sales of personal information for monetary or other consideration and have no present plans to do so.

Right to Know about personal information We Collect, Disclose, or Sell
California consumers have the right to request any of the following information from us about personal information collected about the consumer or the consumer’s household during the last 12 months (“Right to Know”):

• The categories of personal information collected.
• The categories of sources from which the personal information is collected.
• The business or commercial purpose for collecting or selling personal information.
• For personal information sold or exchanged for value with a third party: categories of personal information and categories of third parties.
• For personal information disclosed to a third party for a business purpose: categories of personal information; and categories of third parties.
• The specific pieces of personal information collected about you (except for very sensitive personally identifiable information, which we will describe but not transmit).

The process by which we verify and respond to your requests is explained below under “How to Make a Verifiable California Consumer Request” and “How We Will Respond to a California Consumer Request.”
You may submit a Right to Know request here. marketing@joe.com

Right to Deletion of personal information
California consumers have the right to request that we delete any personal information about the consumer which we have collected from you, subject to a range of exclusions permitted by law (“Right to Delete”). For example, we are not required to delete personal information if it is necessary to complete a transaction, reasonably used for an ongoing business relationship, or used internally in a lawful manner that is compatible with the context in which the consumer provided the information.
Once we receive a request for deletion, and separately confirm that request, we will take reasonable steps to verify the identity and authority of the person submitting the request. If the Right to Delete request is confirmed and verified, we will delete the personal information from our records (and direct our service providers to do the same without any liability for such service providers failure to delete), unless an exclusion applies. If we are unable to fulfill all or part of your request, we will let you know why (for example, if we have a permitted reason to retain certain information if the identity of the requesting person cannot be verified).
The process by which we verify and respond to Right to Delete requests is described below under “How to Make a Verifiable California Consumer Request” and “How We Will Respond to a California Consumer Request.”
You may submit a Right to Delete request here.marketing@joe.com

Right to Designate an Authorized Agent
California consumers have the right to designate an authorized agent to act on their behalf to submit a Right to Know or Right to Delete request, or a request to opt-out from our sale of their personal information (if applicable). An authorized agent may be a natural person or a business entity registered with the Secretary of State. An authorized agent must also submit to us written proof of their authorization to act on the consumer’s behalf.

How to Make a Verifiable California Consumer Request
California consumers may submit a request to exercise any of their rights described above using any of the following methods:

• By phone: CCPA Notification at 888-769-6002; and
• Right to Know – Contact: marketing@joe.com
• Right to Delete – Contact: marketing@joe.com

Please note that in order for a request to be verifiable (including verification of your identity and your California residency), you may be required to confirm information that we have on file for you; including e-mail address, phone number, full name, address and other personal information.  We reserve the right to deny a consumer request if the identity or authority of the requesting party cannot be confirmed.

How We Will Respond to a California Consumer Request
We will confirm receipt of a Right to Know or Right to Delete request within 10 days and may request additional information necessary to verify that you are permitted to make the request. We will endeavor to respond to a verifiable consumer request within 45 days of receiving it, subject to delays and exclusions permitted by law. If we require more time to respond, we will let you know the reason why and extension period in writing. Please provide either your e-mail address or U.S. Postal address, at your option, so that we may communicate with you.

For a Right to Know request, our response will cover the 12 month period preceding our receipt of the request. If we cannot comply with all or part of your request, we will explain the reasons why. For data portability requests, we will select a format to provide your personal information that is useable and should allow you to transmit the information readily from one entity to another entity.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or clearly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Protection from Discrimination for Exercising California Consumer Rights
We will not discriminate against a California consumer for exercising any of the rights described in this section. This means that except as legally permitted we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Financial Incentive Programs
We are permitted to offer certain financial or service incentives to encourage consumers to provide certain financial information. If we offer a financial or service benefit program to you, we will provide a written description of the material terms of the program to you in a written Notice of Financial Incentive, and you will only be enrolled as a participant if you affirmatively opt-in to the program. You may revoke your opt-in consent at any time. The Notice of Financial Incentive will explain the process for opting-in to participate and withdrawing from the program (opting-out).

California “Shine the Light” Law
Under California Civil Code Section § 1798.83, California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. You may request this information by contacting us as explained in the section of the Privacy Policy titled “Contact Us” and indicating “Request for California Privacy Information.” Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

YOUR RIGHTS IF YOU ARE A RESIDENT OF THE EUROPEAN ECONOMIC AREA (“EEA”)
If you are a resident of the European Union, we will process your personal information in compliance with the EU General Data Protection Regulation (“GDPR”).  For information submitted, we are the data controller, as defined under GDPR.  In accordance with GDPR, as a data subject you will be accorded with any applicable rights, which may include the following:

• right of confirmation;
• right of access;
• right to rectification;
• right to erasure;
• right of restriction of processing;
• right to data portability;
• right to object;
• right to withdraw data protection consent; and
• the right to lodge a complaint with a supervisory authority.