PRIVACY POLICY

Five Point Holdings, LLC and our affiliates and subsidiaries, including Five Point Operating Company, LP, Five Point Communities Management, Inc., Heritage Fields El Toro, LLC, The Shipyard Communities, LLC, and The Newhall Land & Farming Company (A California Limited Partnership) (collectively, "FivePoint", "we", "our", and/or "us") value the privacy of individuals who use the websites, apps, and affiliated services that we own and operate (collectively, the "Services"). This privacy policy (the "Privacy Policy") explains how we collect, use, and share information from or about users of our Services ("Users") or their devices. By using or accessing our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

Unless otherwise specified, FivePoint includes Five Point Holdings, LLC and all affiliated companies, including but not limited to: Five Point Operating Company, LP, Five Point Communities Management, Inc., Heritage Fields El Toro, LLC, The Shipyard Communities, LLC, and The Newhall Land & Farming Company (A California Limited Partnership). This Privacy Policy applies to all FivePoint Services, including fivepoint.com, greatparkneighborhoods.com, valencia.com, candlesticksf.com, tourgpn.com and any mobile application provided by or on behalf of FivePoint.

If you are a California resident, please visit our California Resident Privacy Notice for supplemental information and disclosures regarding rights of California residents. 

1. INFORMATION WE COLLECT

As part of the normal operation of the Services, we may collect a variety of information from or about you or your devices from various sources, as described below. 

If you do not provide your information when requested, you may not be able to use all the functionalities of our Services if that information is necessary to provide you with access to our Services or if we are legally required to collect it.

INFORMATION YOU PROVIDE TO US

If you create or update profiles on our Services, sign up for notifications or updates, log into your account, register for sweepstakes or contests, or participate in demos or surveys, we may ask for information about you including, but not limited to, your first and last name, home address, email address, cell phone number, home telephone number, work telephone number, fax number, and any other information we collect. If you sign up using a third-party social media account, we may also receive information from those third parties, such as your name, email address, gender, date of birth, profile photo, preferences, friends, and information that you agree to share with us at the time you give permission to link your accounts.

If you make purchases through our Services, a third-party service provider that handles payments for us will receive your payment card information.

If you contact us directly, we may receive additional information about you. For example, when you communicate with or transact business with us, request information or materials, request assistance to find a new home, or make inquiries concerning investor relations, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information that you choose to provide, including photos, videos, blog entries, interests, hobbies, lifestyle choices, and groups with which you are affiliated. If you sign up for updates, then we will collect certain information from you, such as your first and last name, home address, phone number, email address, neighborhoods of interest, and type of real estate of interest. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

When you make inquiries concerning career opportunities, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your highest level of education, employment experience, and information about the type of job you are seeking. You may also apply through LinkedIn. If you do so, we will collect the information you make available to us on LinkedIn.

INFORMATION WE COLLECT WHEN YOU USE OUR SERVICES

We receive information about the device and software you use to access our Services, including internet protocol ("IP") address, web browser type, operating system version, phone carrier and manufacturer, installed applications, device identifiers, mobile advertising identifiers, and push notification tokens.

To help us understand how you use our Services and to help us improve them, when you use our Services, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, pages you request, the websites you visited before using or accessing our Services, and the dates, times, and duration of your visits.

When you use our Services, if you allow us, we may receive your precise location information. We may also collect the precise location of your device when the app is running in the foreground or background. We use your location information to tell you about nearby restaurants, parks, shops, and activities that may be of interest to you, enable you to obtain directions and shuttle schedules, and allow you to request friends or relatives monitor your journey home and report suspicious activity in the community. We also infer the general physical location of your device and the geographic regions our Users come from. For example, your IP address may indicate your general geographic region.

If you permit us to access the address book on your device, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Privacy Policy or at the time of consent or collection. Additionally, this allows us to auto-populate fields for you in other features, such as “Walk Me Home.”

We and third-party partners may use cookies and other tracking devices on our Services. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Using cookies on our Services provides benefits to you, such as allowing you to maintain your account login information, if applicable, between visits. We may use third parties to serve our advertisements on other websites. In serving our advertisements, these companies may use cookies and other tracking devices to collect certain information about your visits to other websites (such as browser type, IP address, which page was visited, and time of day). This information may be used to evaluate our online advertising campaigns or to tailor promotions and other marketing messages to you. 

You may elect to refuse cookies. Please refer to your browser Help instructions to learn more about cookies and how to manage their use. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

To assist you in managing your home or office appliances and enable certain safety features, you may choose to link such appliances to our Services. We use home appliance information, including fuel consumption, heating or cooling history, utility resource consumption and usage information to enhance energy efficiency, provide maintenance tips, and facilitate service requests. We also may collect information about detection of smoke and carbon monoxide levels, garage door data, maintenance checklists, utility shut-off procedures, and emergency or non-emergency requests for internal analysis and to provide safety notifications to you.

INFORMATION WE RECEIVE FROM THIRD PARTIES 

We may use single sign-on services that allow you to sign into our Services using your third-party social networking login credentials. If you choose to link our Services to a third-party account, we may receive information about you, including your profile information, preferences and login information. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

We may receive additional information about you from third parties such as data or marketing partners and combine it with other information we have about you.

2. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect to provide, manage, operate, maintain, improve, and enhance our Services, to communicate with you, to respond to your requests for information or services, for general record-keeping purposes and to otherwise contact you about promotions and available products or services. We may use the information collected on our Services or on our behalf to conduct surveys and contests, facilitate transactions and payments, perform data management and analysis, personalize your experience on our Services, such as presenting tailored content, and for other customer service, marketing and promotional purposes. 

We may also use the information we collect to send you electronic and other messages about developments by and/or offerings from one of our subsidiaries or affiliated companies. Your use of our Services constitutes your permission to do so. 

We use the information we collect for compliance purposes, including to respond to subpoenas, court orders, or legal process, to establish or exercise our legal rights, to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service, or as otherwise may be required by applicable laws and regulations or requested by judicial process of governmental agency.

We also use the information for other purposes for which we provide specific notice at the time the information is collected. We may de-identify and aggregate information collected through the Services and use it for any lawful purpose.

3. SHARING INFORMATION COLLECTED ON OUR SERVICES

We may share or otherwise disclose information we collect from or about you as described below or otherwise disclosed to you at the time of collection.

We may share any information we receive with or among FivePoint’s subsidiaries and affiliates for any of the purposes described in this Privacy Policy. 

We may share any information we receive with vendors and service providers retained in connection with the provision of our Services. 

Our Services include social services such as discussion boards, bulletin boards, blogs, and referral functions in which you can find, enjoy and share content. Your name, username, and other profile information will always be viewable. The content you post to the Services will be displayed on the Services and viewable by others by default. When using social media resources, you should take into careful consideration what information you post and share with others.

If you connect a third-party application to our Services, we may share information such as sign-on information and user registration information with that third party.

We may also share information with select third parties who offer goods or services we think may be of interest to you. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout

We work with third party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative ( http://optout.networkadvertising.org/?c=1#!/) or Digital Advertising Alliance ( http://optout.aboutads.info/?c=2&lang=EN). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps. 

We may also access, preserve and disclose information about you when we believe doing so is appropriate to: (i) comply with law enforcement requests or a court order or other legal process; (ii) protect the rights, property or safety of FivePoint, the Services, our Users, or others; or (iii) enforce the Terms of Service [insert link to Terms of Service]. For the avoidance of doubt, the disclosure of information about you may occur if you post any objectionable content on or through the Services. Your use of any of the Services constitutes your permission for FivePoint to use and share the information collected from you as provided in the Privacy Policy.

We may disclose and transfer information about you to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.

We may also disclose information from or about you or your devices with your permission.

4. YOUR CHOICES

PUBLIC FORUMS

The Services may make chat rooms, message boards, news groups and other interactive areas available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use, and you should exercise caution when deciding to disclose any personal or any other information about yourself.

LOCATION INFORMATION

You can prevent your device from sharing precise location information at any time through your device’s operating system settings. However, location is core to some of our Services and without it, you may not be able to successfully use certain features in our Services such as the “Walk Me Home” feature.

CONTACTS

You may enable or disable the sharing of contacts information through the permission system used by your mobile operating system.

MARKETING COMMUNICATIONS

You can unsubscribe from any promotional messages we send at any time by following the instructions included within the message. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us. 

DO-NOT-TRACK SIGNALS

There is no accepted standard on how to respond to Do Not Track Signals, and our Services do not respond to such signals.

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

5. THIRD PARTIES

Hypertext or other computer "links" may appear on the Services that may be used to link to other websites, including websites operated by other parties. In most cases we have no control over the linked websites or the materials, site plans, building renderings, floor plans, neighborhood maps, aerial photos, neighborhood photos, and/or enhanced descriptions of neighborhoods, other illustrations and other information, goods or services available or contained on these linked websites, including their privacy practices and terms and conditions of use. We are not responsible for and do not endorse or warrant in any way any materials, information, goods or services available through such linked websites or any privacy or other practices of such websites. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them. If you decide to access any of the linked websites, you do so entirely at your own risk.

6. SECURITY

We employ reasonable administrative, technical and physical safeguards designed to protect the security, confidentiality, and integrity of information we maintain. However, we cannot guarantee the security of the information on and sent from the Services. Unfortunately, no data transmission over the Internet or on a computer can be guaranteed to be 100% secure. Any such transmission is done at your own risk.

7. CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@fivepoint.com

8. INTERNATIONAL VISITORS

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your information from the U.S. to other countries or regions in connection with storage and processing of information, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage and processing.

9.UPDATE YOUR INFORMATION OR POSE A QUESTION

You can update your profile information by contacting us. If you have questions about your privacy on the Services or this Privacy Policy, please contact us at privacy@fivepoint.com

10.NOTIFICATION OF PRIVACY POLICY CHANGES

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we make material changes to the ways in which we use or share information about you or your devices, we will provide notice of the change by posting a notice, through the Services, by email, or other communication.

11.CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@fivepoint.com or write to us at Five Point Holdings, LLC, 15131 Alton Parkway, 4  th Floor, Irvine, CA 92618, Attention: Privacy Group.

LAST UPDATED: January 1, 2020

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