Effective Date: February 3, 2026
Last Updated: February 3, 2026

INTRODUCTION

Swan Hotel Associates d/b/a The Walt Disney World Swan Hotel (“Swan”) and Dolphin Hotel Associates d/b/a The Walt Disney World Dolphin Hotel (“Dolphin”) are separate hotels and separate general partnerships (the hotels and their service outlets are collectively the “Hotels”); however, they together provide the website www.swandolphin.com (“Site”). The Hotels are not owned by The Walt Disney Company (“Disney”). Likewise, the Hotels are not owned by “Marriott” (e.g., the Marriott Group, Marriott International, Inc., Starwood Hotels & Resorts Worldwide, LLC, Bonvoy, etc.), but the Hotels are Marriott-branded. In reviewing this privacy policy, we refer to the Hotels as “we,” “us,” or “our” and you, the website user or Hotel guest, as “you,” “your,” or “user.” In addition to this policy, use of the Site is also governed by the Terms & Conditions of Use which is found here.

This Privacy Policy describes how we collect, use, disclose, retain, and protect your personal information when you visit our Site or interact with our Hotels. We are committed to safeguarding your privacy and complying with applicable privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”), the Florida Digital Bill of Rights (“FDBR”), and other applicable state privacy laws. By using this Site or providing your personal information to us, you acknowledge that you have read and understand this Privacy Policy.

INFORMATION COLLECTED

Information You Provide Directly

When you interact with us or this Site, we may collect the following categories of personal information that you voluntarily provide:

• Identifiers: Name, postal address, email address, telephone number, account username and password, and similar identifiers.
• Communications: Correspondence, inquiries, feedback, and other communications you send to us.
• Preferences: Room preferences, dietary restrictions, accessibility needs, and other preferences you share with us.

Information Collected Automatically

To the extent you allow “cookies” in your settings for this Site or via your web browser, we collect website cookie information pertaining to website analytics. Cookie information may include:

• Your Internet Protocol address (IP address)
• Device type and device identifiers
• Browser types and language
• Referring and exit pages
• Platform type
• Version of software installed
• System type
• The content and pages that you access on the Site
• The number of clicks
• The amount of time spent on pages
• The dates and times that you visit the Site
• Other similar information

We use Google Analytics on this Site to monitor your interactions with the Site. For more information on what Google Analytics is and what it does, you may consult this webpage (which is not affiliated with us): https://en.wikipedia.org/wiki/Google_Analytics. To opt out of Google Analytics, you may install the Google Analytics Opt-Out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

Information from Other Sources

We may also collect information about you from the following sources:

• Other information about your physical use of the Hotels, sales information, purchase information, stay preferences, parking, room key use information, and similar information about your use of the Hotels and its amenities, as well as related sales information for purchases you make.
• We may receive information from Marriott/Bonvoy and third-party booking sites about your bookings, requests, preferences, and the like.
• Similar information may be obtained from The Walt Disney Company regarding your use of the parks.
• Publicly available information and information from data brokers and marketing partners.

Sensitive Personal Information

We do not intentionally collect “sensitive personal information” as defined under the CCPA/CPRA, including Social Security numbers, driver’s license numbers, financial account numbers, precise geolocation data, racial or ethnic origin, religious or philosophical beliefs, union membership, genetic data, biometric data for identification purposes, health information, or information concerning sex life or sexual orientation, except where strictly necessary to provide requested services (e.g., accessibility accommodations) or as otherwise permitted by law. To the extent we do collect any sensitive personal information, we use it only for the purposes disclosed at the time of collection or as otherwise permitted by applicable law.

HOW WE USE YOUR INFORMATION

We use the information we collect about you for the following business and commercial purposes:

• Service Provision: To provide services to you, administer transactions with you, provide further information regarding your transactions, fulfill reservations, and respond to your inquiries and requests.
• Safety and Security: To monitor your physical interactions with the Hotels in an effort to keep you and others safe and to protect our property.
• Service Improvement: To improve the services that we provide to you and to develop new products and services.
• Administrative Communications: To communicate with you for administrative purposes, including confirmations, updates, and service-related notices.
• Marketing Communications: When you expressly consent, to send promotional and marketing communications and to target marketing materials and information to you.
• Cookie and Analytics Use: We use cookie information as permitted by your cookie preferences via your web browser settings and a web plug-in, and to monitor Site use metrics.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Enforcement: To enforce our Terms & Conditions of Use, this Privacy Policy, and other agreements.
• Protection of Rights: To protect the rights, property, safety, or security of the Hotels, our guests, employees, or the public.
• Business Operations: For internal business purposes, including auditing, data analysis, and research.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

HOW WE DISCLOSE YOUR INFORMATION

We disclose your information as follows:

• Marriott and Booking Partners: We may provide some or all of the information that you provide to us to Marriott for its business administration purposes (e.g., affinity programs, stay information, and the like). We may do likewise with other third-party booking sites and with Disney regarding your use of the parks. When you expressly consent, we may also provide some or all of the information that you provide to us to Marriott for its marketing purposes. We may do likewise with other third-party booking sites and with Disney regarding your use of the parks.
• With Your Consent: When you expressly give us permission to provide that information to third parties for administrative, marketing, or promotional purposes. For instance, certain restaurants at the Hotels are not under our ownership or control (e.g., Il Mulino or The Blue Zoo), and we may provide information to them if you ask us to make a reservation for you. Likewise, we may provide your information via our concierge to restaurants or area attractions if, for example, you ask us to make a reservation for you or ask us to solicit a vendor on your behalf.
• Aggregate Information: We may send automatically collected aggregate information and other aggregate information to third parties to analyze usage, demographics, and functionality of the Site, usually for the ultimate purpose of marketing.
• Affiliates: The Hotels may provide personal and non-personal information to affiliates that are under common ownership and/or control for administrative purposes.
• Service Providers: We provide information to companies that provide products and services to us in order to operate, improve, and innovate with respect to the Site (for instance, hosting services). Likewise for companies that provide services to us regarding the operation of the Hotels; however, these transmissions of information are not for marketing purposes. Rather, such third parties receive such information pursuant to written contracts that specify how the information may be used (which does not include marketing).
• Legal Requirements: The Hotels disclose information in order to comply with legal requirements, including those of law enforcement, court orders, subpoenas, and governmental requests.
• Protection of Rights and Interests: The Hotels also reserve the right, but do not undertake the obligation, to disclose information when necessary to protect the Hotels’ interests and/or those of third parties, or to prevent or investigate fraud, security breaches, or other potentially illegal activities.

SALE AND SHARING OF PERSONAL INFORMATION

Under the CCPA/CPRA, a “sale” of personal information includes disclosing personal information for monetary or other valuable consideration, and “sharing” includes cross-context behavioral advertising. To the extent the Hotels engage in activities that may be characterized as “sales” or “sharing” of personal information under applicable law, users have the right to opt out of such sales or sharing as described below in the “Your Privacy Rights” section.

In the preceding twelve (12) months, we may have “shared” (as that term is defined by the CCPA/CPRA) the following categories of personal information: identifiers, internet or other electronic network activity information, and inferences drawn from the foregoing categories.

DATA RETENTION

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, comply with our legal obligations, resolve disputes, and enforce our agreements. The retention period may vary depending on the context of the processing and our legal obligations. When personal information is no longer needed for these purposes, we will securely delete or anonymize it, unless a longer retention period is required or permitted by law.

YOUR PRIVACY RIGHTS

Rights for All Users

You may contact the Hotels using the contact information provided below in order to:

• Request to Know: Request to know any or all of the following for the twelve (12) months preceding our receipt of the request: (a) the specific pieces of personal information we have collected about you; (b) the categories of personal information we have collected about you; (c) the categories of sources from which we collected personal information; (d) the categories of personal information that we sold or disclosed for a business purpose about you; (e) the categories of third parties to whom we sold or disclosed personal information for a business purpose; and (f) the business or commercial purpose for collecting, selling, or sharing personal information.
• Request to Delete: Request that the Hotels delete the personal information they possess about you (i.e., “right to be forgotten”). The Hotels’ ability to delete the information may be limited by technical and/or legal requirements such that the Hotels will try to honor such a request but will not guarantee that they reasonably can.
• Request to Correct: Request that the Hotels correct inaccurate personal information that they have about you.
• Request to Opt Out of Sale or Sharing: Request to opt out of sale or sharing of personal information.
• Request to Limit Use of Sensitive Personal Information: Request to limit the use and disclosure of sensitive personal information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer.
• Request to Stop Processing: Request that the Hotels stop using the information they have about you in a particular way (i.e., to stop and/or not process the data). The Hotels will not always be able to accommodate this request due to technical and/or legal requirements.
• Request to Add Information: Request that the Hotels add to the information that they have about you.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by applicable law, we will not deny you goods or services, charge you different prices or rates, provide you a different level or quality of goods or services, or suggest that you may receive a different price or rate or different level or quality of goods or services.

EXERCISING YOUR RIGHTS

Quickest Method to Change: You may be able to add to, delete, and/or change the information you have input into the Concierge System and Group Reservation System (if you have accounts in those systems) by logging in and accessing your account.

Verification: Should you choose to exercise your rights under this section, we may require you to reasonably prove your identity to us. Such verification may include an email to and from a known email account, proof via identification card, answering questions that only you may know, or similar means.

Authorized Agents: You may designate an authorized agent to act on your behalf regarding the above, but we may require reasonable proof that an agent has actual authority to act for you.

Specific Information We Will Not Provide: Should you contact us, we will not respond to you with your Social Security Number, driver’s license or other government identification number, financial account number, health insurance or medical identification number, an account password, or security questions and answers.

Record of Requests: We will maintain a record of your requests for information, to delete, make changes, and the like.

Refusal to Comply: Should we be unable to or not required to delete information that you request to be deleted, we will notify you of that fact. We will delete that information that we are required and able to delete. If we are unable to delete the information for technical reasons, we will not use the information we were not able to delete. We are permitted to comply with a request to delete by deleting the personal information, de-identifying the personal information, or aggregating the personal information and thus rendering it non-identifiable to you.

California Residents

If you are a California resident, you have additional rights under the CCPA/CPRA, including: (a) the right to know what personal information is being collected about you; (b) the right to know whether your personal information is sold or disclosed and to whom; (c) the right to say no to the sale or sharing of personal information; (d) the right to delete personal information; (e) the right to correct inaccurate personal information; (f) the right to limit use and disclosure of sensitive personal information; (g) the right to access personal information; and (h) the right to equal service and price, even if you exercise your privacy rights. California residents may submit requests by using the contact methods below.

Do Not Sell or Share My Personal Information: California residents may opt out of the “sale” or “sharing” of their personal information by contacting us at [email protected] with the subject line “Do Not Sell or Share My Personal Information.”

Shine the Light: California Civil Code Section 1798.83 permits California residents to request information regarding the disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the information below.

ANALYTICS AND TECHNICAL ADVERTISING TOOLS

The Hotels routinely employ third-party web analytics on the Site such as Google Analytics. The purposes of such analytics are website improvement, marketing analysis, and the like.

The Hotels may allow third-party advertisers to transmit advertising directly to you on the Hotel website. When clicking on these third-party advertisements, you will connect to a website that is controlled by a third party and not the Hotels. When using such websites, your use is governed by that particular website’s terms of service and privacy policy.

The Hotels and third-party advertising may be tailored to you based on the information the Hotels collect about you, your interests, and demographics.

THIRD-PARTY WEBSITES

When using the Site, there are certain functions that may require you to visit a website other than this one (e.g., reservations via Marriott, reservations for signature dining, etc.). Such referral sites are usually, but not always, visually distinct. When using such websites, your use is governed by that particular website’s terms of service and privacy policy. The Hotels are not responsible for the privacy practices or content of third-party websites.

SECURITY

The Hotels take reasonable security precautions with respect to the information and data they possess and collect. These measures include, but are not limited to, technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, use, alteration, and disclosure. However, the Hotels cannot guarantee that any security measure they employ will guarantee absolute security, and no method of transmission over the Internet or method of electronic storage is 100% secure. You transmit information to us at your own risk.

CHILDREN’S PRIVACY

The Site is not directed to, and we do not knowingly collect personal information from, children under the age of sixteen (16). If you are under the age of eighteen (18) and wish to use the Site, then your parent or legal guardian must contact the Hotels using the below contact information in order to complete a consent form. The Hotels do not otherwise authorize anyone under eighteen (18) to use or access the Site, as the Hotels do not engage in commerce with persons under eighteen (18) years of age. If we learn that we have collected personal information from a child under sixteen (16) without parental consent, we will delete that information as quickly as possible. If you believe that we might have information from or about a child under sixteen (16), please contact us at [email protected].

Contact Information and Timing of Response

To exercise your rights, ask questions, or provide comments regarding this Privacy Policy, you may contact the Hotels via:

• Email: [email protected]
• Phone: 407-934-4248 and ask for the Privacy Supervisor
• Mail: Marshall Kelberman, 1500 Epcot Resorts Blvd., Lake Buena Vista, FL 32830

If you request to exercise your rights under this Privacy Policy to know, delete, or correct, we will acknowledge receipt promptly, but in no event more than ten (10) business days from the receipt of your request. We will then respond to your request within forty-five (45) days. In some circumstances, we may provide notice to you that we require an additional forty-five (45) days and the reason why. If you do not promptly provide information we need to identify you or act on your request, then your request may take longer.

AMERICANS WITH DISABILITIES ACT

Should you need assistance with this Site, including questions or someone to read the website to you, please email [email protected] or contact us at (407) 934-5783.

CHANGES AND UPDATES TO THIS PRIVACY POLICY

The Hotels reserve the right to change this Privacy Policy at any time. Should a change in the Privacy Policy require us to seek your express consent prior to taking an action, then we shall seek that consent first. If we make material changes to this Privacy Policy, we will notify you by posting the revised policy on this Site with a new “Last Updated” date. We encourage you to review this Privacy Policy periodically. Your continued use of the Site or our services after any changes to this Privacy Policy indicates your acceptance of the revised policy.

APPLICATION OF FLORIDA LAW

By using the Site, you are advised and understand that this Site is owned and operated by an American company. The Hotels were established, owned, and run under the laws of the United States of America, and our primary business functions are located in Orlando, Florida. You agree and stipulate that any transaction you have with respect to the Site and any information that you transmit is “present in” and “occurs in” Orlando, and no other location, as if you were physically located in Orlando, State of Florida, even if you are actually somewhere else or not even in the United States.

As such, the Hotels expect and intend any interaction with this website and the actual Hotels to be governed exclusively by American law and, in particular, exclusively the law of Florida, without application of Florida’s choice-of-law rules, law, or doctrines, and you agree and stipulate to such. Likewise, you agree to discontinue any suit that is not filed in Orlando, Florida, in the United States, if such suit arises from or relates to the Site or the Hotels. Any suit will be exclusively decided in a court located in Orlando, Florida, and nowhere else.

You waive any arguments of forum non conveniens (i.e., that Florida is not a convenient forum/place to litigate) and stipulate to venue being in Orlando, Florida. You are likewise advised that American law, and that of Florida in particular, does not afford the same level of protection and/or rights regarding your data/information as may exist in other states or countries. You stipulate and agree that each part of this section applies to any and all claims against any parent, owner, or affiliate of the Hotels arising from or related to the Site or the Hotels, and likewise that this Privacy Policy applies to such claims.

LIMITATION OF LIABILITY

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE HOTELS, THEIR AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, PARTNERS, AND LICENSORS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING WITHOUT LIMITATION, LOSS OF PROFITS, DATA, USE, GOODWILL, OR OTHER INTANGIBLE LOSSES, RESULTING FROM (A) YOUR ACCESS TO OR USE OF OR INABILITY TO ACCESS OR USE THE SITE; (B) ANY CONDUCT OR CONTENT OF ANY THIRD PARTY ON THE SITE; (C) ANY CONTENT OBTAINED FROM THE SITE; (D) UNAUTHORIZED ACCESS, USE, OR ALTERATION OF YOUR TRANSMISSIONS OR CONTENT; OR (E) ANY BREACH OF THIS PRIVACY POLICY OR ANY DATA BREACH. IN NO EVENT SHALL THE HOTELS’ TOTAL LIABILITY TO YOU FOR ALL DAMAGES EXCEED THE AMOUNT OF ONE HUNDRED DOLLARS ($100.00) OR THE AMOUNT YOU HAVE PAID TO THE HOTELS IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM, WHICHEVER IS GREATER.

WAIVER OF CLASS ACTION AND JURY TRIAL

In any action arising from or related to the Site or the Hotels, you waive any right to assert any claims against us in any class or representative action, except where such waiver is prohibited by Florida or applicable federal law. To the extent you are permitted by law or a court of law to proceed with a class or representative action against us (either or both entities), you agree that: (i) you shall not be entitled to recover or be awarded an amount for serving as a class representative or your legal fees and costs; and (ii) you will not submit a claim or otherwise participate in any recovery secured through the class or representative action. Finally, in any action arising related to the Site or the Hotels, you agree to WAIVE ANY RIGHT TO A JURY TRIAL AND INSTEAD CONSENT TO A BENCH TRIAL TO RESOLVE ANY AND ALL DISPUTES.

MERGER, SALE, AND/OR BANKRUPTCY

The Hotels reserve the right to sell, transfer, or otherwise disclose your data/information without notice to you, or consent by you, in the event of the Hotels’ merger, acquisition, sale of assets, reorganization, and/or bankruptcy. In such an event, your personal information may be one of the assets transferred.

SEVERABILITY

If any provision of this Privacy Policy is found to be unenforceable or invalid, that provision will be limited or eliminated to the minimum extent necessary so that this Privacy Policy will otherwise remain in full force and effect and enforceable.

ENTIRE AGREEMENT

This Privacy Policy, together with our Terms & Conditions of Use, constitutes the entire agreement between you and the Hotels with respect to the subject matter hereof and supersedes all prior or contemporaneous communications and proposals, whether electronic, oral, or written, between you and the Hotels with respect to this Site.

Should we decide that we are going to begin taking an action regarding your information that requires your consent under applicable law, we will first seek your express consent before so doing.

ASSIGNMENT

You may not assign, transfer, or sublicense any of your rights or obligations under this Privacy Policy without Hotel’s prior written consent. Hotel may assign, transfer, or sublicense any or all of its rights or obligations under this Privacy Policy without restriction and without notice to you.

FORCE MAJEURE

Hotel shall not be liable for any failure or delay in performing its obligations under this Privacy Policy if such failure or delay results from circumstances beyond Hotel’s reasonable control, including but not limited to acts of God, natural disasters, war, terrorism, riots, embargoes, acts of civil or military authorities, fire, floods, epidemics, pandemics, strikes, or shortages of transportation, facilities, fuel, energy, labor, or materials.

SURVIVAL

The provisions of This Privacy Policy that by their nature should survive termination shall survive termination, including but not limited to the following Sections: Application of Florida Law; Limitation of Liability; Waiver of Class Action and Jury Trial; and Severability.