PRIVACY POLICY – Kingsbury Club & Spa

Effective Date: September 23, 2026

Kingsbury Club and Spa (“Kingsbury,” “we,” “us,” or “our”) is committed to respecting and protecting the privacy of our members, guests, website visitors, program participants, and other individuals who interact with us.

This Privacy Policy describes how Kingsbury collects, uses, discloses, retains, and protects personal information in connection with our website, membership services, facilities, programs, events, activities, and other services.

By accessing our website, downloading, creating an account, using associated membership applications, or providing personal information to Kingsbury, you acknowledge that you have had an opportunity to review this Privacy Policy. If you do not agree with our policies and practices, do not access our website, download, create an account, or use any associated membership applications used in connection with Kingsbury’s services.

This policy may change from time to time. Your continued use of our website and membership applications after we revise this policy means you accept those changes, so please check the policy periodically for updates.

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information collected by or on behalf of Kingsbury through:

Our website, including kingsburyclub.com;
Membership applications and member accounts;
Club Automation and other membership-management systems;
Program, class, lesson, camp, and event registrations;
Reservations and purchases;
Communications with members, guests, and prospective members;
In-person interactions at the Club;
Telephone, email, and other communications;
Marketing and promotional activities; and
Other services and activities provided by Kingsbury.

This Privacy Policy does not necessarily apply to information collected by independent third parties that operate their own websites, applications, or services, even if those services are accessible through Kingsbury or our website.

2. INFORMATION WE COLLECT

Kingsbury may collect personal information that you voluntarily provide, information collected automatically when you interact with our website or services, and information received from third parties in connection with providing our services.

A. Information You Provide

Depending upon your relationship with Kingsbury, we may collect information including:

Full name;
Mailing address;
Email address;
Telephone number;
Date of birth;
Membership information;
Account information;
Family or household information;
Emergency contact information;
Program and activity registration information;
Reservation information;
Purchase and transaction information;
Information necessary to administer Club programs and activities;
Communications and correspondence with Kingsbury; and
Other information you voluntarily provide to us.

We request that you provide only information that is necessary and appropriate for the particular service or purpose.

You may also provide information for publication or display (“Posted”) on public areas of the app or our websites (collectively, “User Contributions”). our User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

B. Membership and Registration Information

Kingsbury uses Club Automation as a membership-management and registration platform.

Information provided in connection with membership applications, account administration, program registration, reservations, payments, communications, and other Club-related services may be collected, stored, and processed through Club Automation.

Information processed through Club Automation may include, depending upon the services you use:

Name and contact information;
Membership information;
Account information;
Registration information;
Reservation information;
Transaction history;
Program participation information; and
Other information necessary to administer your membership or participation in Club services.

Club Automation is a third-party service provider. Information processed through that platform may also be subject to Club Automation’s applicable privacy policy and terms.

C. Payment Information

When you make a payment or purchase, payment information may be collected and processed by Kingsbury and/or third-party payment processors.

Kingsbury generally does not retain complete credit or debit card numbers on its own systems.

D. Information Collected Automatically

When you access our website, certain information may be collected automatically, including:

Internet Protocol (“IP”) address;
Browser type;
Operating system;
Device type;
Referring webpage;
Pages viewed;
Date and time of access;
General website usage information; and
Other technical information.

We may use cookies, pixels, web beacons, analytics tools, and similar technologies to operate, maintain, secure, and improve our website.

E. Information Collected Through the Application

If you access Club services through Club Automation application, Kingsbury and Club Automation may also collect additional categories of information relating to your mobile device, including:

Device type, unique device identifiers, and mobile operating system;
Mobile network and carrier information;
Precise or approximate geological information, where enabled through your device settings;
Information accessed from files or data stored on your device, such as photographs that you choose to submit or upload through the application; and
Push-notification tokens and in-application usage data.

You may be able to limit collection of certain categories of information described in this Section 2(E) by adjusting your device’s privacy or permission settings; however, disabling certain permissions may limit or disable corresponding features of the application.

F. On-Premises Device Detection and Data-Sharing

Kingsbury has an arrangement with a third-party technology provider (currently, Cell Dwell, which Kingsbury engages to amplify cellular signal reception throughout Kingsbury’s steel-structured facilities for the benefit of members, guests, and staff) under which that provider collects device-identification and/or location information from mobile devices present at Kingsbury’s facilities, including devices belonging to members and guests. Kingsbury receives compensation from this provider in connection with this arrangement. Because Kingsbury receives compensation in exchange for enabling this collection, Kingsbury treats this arrangement as a sale of personal information for purposes of this Privacy Policy. If you have questions about this arrangement, please contact Kingsbury using the information in Section 18.

3. HOW WE USE PERSONAL INFORMATION

Kingsbury may collect and use personal information for legitimate business and operational purposes, including to:

Establish, administer, and maintain memberships;
Create and maintain member accounts;
Process payments and transactions;
Register individuals for programs, classes, lessons, camps, events, and activities;
Manage reservations and Club services;
Communicate regarding memberships, accounts, programs, reservations, purchases, and Club operations;
Respond to questions, requests, and customer-service inquiries;
Provide information concerning Club programs, activities, services, and events;
Send promotional and marketing communications, where permitted by law;
Maintain Club safety and security;
Control and administer access to Club facilities;
Operate and improve our website, facilities, programs, and services;
Conduct business and operational analysis;
Detect, prevent, and investigate fraud, misuse, unauthorized access, or other improper activity;
Protect the rights, safety, and property of Kingsbury and others;
Comply with applicable laws, regulations, legal processes, and governmental requests;
Establish, exercise, or defend legal claims; and
Fulfill other purposes disclosed at the time information is collected or otherwise permitted by law.

4. DISCLOSURE OF PERSONAL INFORMATION

Kingsbury receives compensation from a third-party technology provider in exchange for enabling that provider to collect certain information from mobile devices present at Kingsbury’s facilities, as described in Section 2(F) below. Except for that arrangement, Kingsbury does not otherwise sell personal information for monetary payment.

We may disclose personal information when reasonably necessary to operate our business, provide services, administer memberships, or fulfill the purposes described in this Privacy Policy.

We may disclose information to the following categories of recipients:

A. Service Providers

We may provide personal information to companies and individuals that provide services on our behalf, including providers of:

Membership-management services;
Registration and reservation services;
Payment processing;
Website hosting;
Information technology;
Data storage;
Email and communications;
Marketing and promotional services;
Accounting and financial services;
Professional services; and
Other business and operational functions.

This includes Club Automation, which Kingsbury uses for membership management and related Club services.

B. Professional Advisers

We may disclose information to attorneys, accountants, auditors, insurance providers, consultants, and other professional advisers when reasonably necessary to obtain professional services or protect Kingsbury’s interests.

C. Legal and Safety Requirements

We may disclose personal information when we believe in good faith that disclosure is necessary to:

Comply with applicable law;
Respond to legal process;
Respond to governmental requests;
Enforce our agreements or policies;
Protect the rights or property of Kingsbury;
Protect the safety of members, guests, employees, or others; or
Detect or investigate fraud, security incidents, or other unlawful activity.

D. Business Transactions

If Kingsbury undergoes a merger, acquisition, restructuring, sale of assets, change in ownership, financing, bankruptcy, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

5. CLUB AUTOMATION

Kingsbury utilizes Club Automation as a third-party membership-management and registration platform.

Club Automation may process information on Kingsbury’s behalf to facilitate functions such as:

Membership administration;
Member account management;
Program and class registration;
Reservations;
Payment-related functions;
Account and transaction management;
Member communications; and
Other Club-related administrative functions.

Information submitted through Club Automation may be stored or processed by Club Automation or its service providers in accordance with the applicable agreements and privacy practices governing those services.

Kingsbury takes reasonable steps to use service providers that maintain appropriate safeguards for personal information. Nevertheless, Kingsbury does not control the independent privacy practices of third-party service providers.

Members and users should review the privacy policies and terms applicable to third-party services when appropriate.

6. COOKIES AND WEBSITE TECHNOLOGIES

Kingsbury’s website may use cookies and similar technologies.

These technologies may be used to:

Enable website functionality;
Remember preferences;
Understand website traffic;
Analyze website usage;
Improve website performance;
Maintain security; and
Support communications or other website functions.

Some cookies or similar technologies may be provided by third-party service providers.

You may be able to control or disable cookies through your browser settings. Certain website features may not function properly if cookies are disabled.

7. WEBSITE ANALYTICS

Kingsbury may use third-party analytics services to help us understand how visitors use our website and to improve website functionality and performance.

Analytics providers may collect information such as IP address, device information, browser information, pages visited, and general usage information.

The information collected through these services may be subject to the applicable provider’s privacy policy.

To the extent the Club Automation mobile application incorporates analytics, crash-reporting, or similar software development kits provided by third parties, those third parties may automatically collect information about your device and your use of the application in the same manner described in this Section 7. Kingsbury does not control the data collection practices of these third-party providers and encourages you to review their privacy policies.

8. MARKETING AND PROMOTIONAL COMMUNICATIONS

Kingsbury may use personal information to communicate with members and guests regarding Club programs, events, activities, services, special offers, and other matters that may be of interest.

Communications may be delivered by:

Email;
Telephone;
Text message/SMS;
Postal mail; or
Other communication methods permitted by applicable law.

You may opt out of promotional email communications by following the unsubscribe instructions contained in the applicable communication.

If you receive promotional text messages from Kingsbury, you may opt out by following the instructions provided in the message, where applicable.

Please note that opting out of promotional communications does not necessarily prevent Kingsbury from sending administrative or transactional communications, including communications concerning:

Memberships;
Accounts;
Payments;
Reservations;
Program registrations;
Facility closures or changes;
Safety matters; or
Other important Club-related information.

9. PHOTOGRAPHS, VIDEO, AND OTHER MEDIA

Kingsbury may photograph or record activities, events, classes, facilities, or other Club activities for legitimate business, operational, promotional, marketing, or informational purposes.

Photographs or recordings may be used in Club communications, social media, websites, newsletters, advertisements, promotional materials, or other communications.

Where appropriate, Kingsbury may obtain consent or provide notice regarding the use of identifiable images, particularly in circumstances where specific consent is required by applicable law or Club policy.

If you have questions or concerns regarding the use of your image, please contact Kingsbury at [email protected].

10. SECURITY CAMERAS AND FACILITY SECURITY

For the safety and security of our members, guests, employees, and facilities, Kingsbury may use security cameras and other security systems in and around portions of our facilities.

Security recordings may be used for purposes including:

Safety and security;
Prevention and investigation of theft or property damage;
Investigation of incidents;
Protection of members, guests, and employees;
Enforcement of Club policies; and
Compliance with applicable law.

Security cameras are not intended to be placed in areas where individuals have a reasonable expectation of privacy, such as locker rooms, restrooms, or other similar areas.

Security recordings may be retained for a limited period of time and may be accessed or disclosed when reasonably necessary for security, legal, insurance, investigative, or other legitimate purposes.

11. CHILDREN’S INFORMATION

Kingsbury offers programs and activities that may be available to children.

We may collect information concerning children when such information is provided by a parent, legal guardian, or other authorized adult for purposes including:

Membership;
Program registration;
Class or activity participation;
Emergency contacts;
Safety;
Facility access; and
Administration of Club services.

Kingsbury does not knowingly collect personal information directly from children for purposes unrelated to providing Club services without appropriate authorization.

If Kingsbury learns that it has collected personal information directly from a child without the verification of parental or guardian consent required by applicable law, Kingsbury will take reasonable steps to delete that information.

Parents and legal guardians who have questions regarding information collected in connection with a child’s participation in Kingsbury programs may contact us using the information provided in Section 18 of this Privacy Policy.

12. DATA SECURITY

Kingsbury maintains reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, acquisition, use, disclosure, alteration, or destruction.

We also expect service providers who process information on our behalf to maintain reasonable security measures appropriate to the nature of the information they process.

Where Kingsbury or Club Automation has issued you, or you have chosen, a username or password to access your member account through the Club Automation application or website, you are responsible for maintaining the confidentiality of that username and password and for all activity that occurs under your account. Please notify Kingsbury promptly using the contact information in Section 18 if you suspect any unauthorized use of your account.

Despite these measures, no electronic transmission or storage system can be guaranteed to be completely secure.

Accordingly, Kingsbury cannot guarantee that personal information will never be accessed, disclosed, altered, or destroyed in an unauthorized manner.

13. DATA RETENTION

Kingsbury retains personal information for as long as reasonably necessary to:

Provide and administer services;
Maintain memberships and accounts;
Complete transactions;
Maintain appropriate business and financial records;
Comply with legal and regulatory obligations;
Resolve disputes;
Enforce agreements;
Protect our legal rights; and
Fulfill legitimate business purposes.

Retention periods may vary depending upon the type of information, the purpose for which it was collected, and applicable legal requirements.

Information maintained by third-party service providers, including Club Automation, may be retained in accordance with applicable contractual arrangements and the provider’s policies.

14. YOUR PRIVACY RIGHTS AND CHOICES

Depending upon your state of residence and applicable law, you may have certain rights concerning your personal information.

These rights may include the right to:

Request access to personal information we maintain about you;
Request correction of inaccurate personal information;
Request deletion of certain personal information;
Request information concerning our collection or use of personal information;
Opt out of certain marketing communications; and
Exercise other rights provided by applicable law.

To exercise a privacy right, please contact us using the information in Section 18.

We may take reasonable steps to verify your identity before responding to certain requests.

Not all privacy rights apply in all circumstances. Kingsbury may retain or use information when permitted or required by applicable law, including information necessary to comply with legal obligations, complete transactions, resolve disputes, maintain records, or protect our rights.

15. MASSACHUSETTS PRIVACY

Kingsbury is located in Massachusetts and takes reasonable measures to comply with applicable Massachusetts privacy and data-security requirements.

Massachusetts residents may have rights concerning personal information under applicable Massachusetts law, including applicable consumer privacy and data-security laws.

Kingsbury will respond to valid requests concerning personal information in accordance with applicable law.

16. THIRD-PARTY WEBSITES AND SERVICES

Our website and communications may contain links to websites, applications, social-media platforms, or other services operated by third parties.

These third parties may collect information independently and may have privacy policies that differ from Kingsbury’s.

Kingsbury does not control and is not responsible for the privacy practices, security, content, or policies of third-party websites or services. This Section does not apply to Club Automation or other service providers acting on Kingsbury’s behalf, which are addressed in Sections 2(B), 2(F), and 5 above.

We encourage you to review the privacy policies applicable to any third-party service before providing personal information.

17. CHANGES TO THIS PRIVACY POLICY

Kingsbury reserves the right to modify this Privacy Policy from time to time.

If Kingsbury makes a material change to this Privacy Policy, Kingsbury will provide notice by posting a notice within the Club Automation application, by email to the address associated with your membership account, or by other reasonable means, in addition to updating the Effective Date below.

Changes may be made to reflect changes in:

Our business practices;
Services we provide;
Technology;
Third-party service providers;
Applicable laws or regulations; or
Other circumstances affecting the manner in which we collect or use personal information.

When we make material changes, we will update the Effective Date at the beginning of this Privacy Policy.

We encourage you to periodically review this Privacy Policy to remain informed about how Kingsbury collects, uses, and protects personal information.

18. CONTACT INFORMATION

Questions, concerns, or requests regarding this Privacy Policy or Kingsbury’s privacy practices may be directed to:

Kingsbury Club and Spa
Attn: Privacy Officer / General Manager
186 Summer Street
Kingston, MA 02364
United States

Telephone: 781-585-3883
Email: [email protected]
Website: kingsburyclub.com

Privacy Policy: kingsburyclub.com/privacy

Effective Date: September 23, 2026
Last Updated: September 23, 2026