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California Privacy Notice

IMPORTANT PRIVACY NOTICE FOR CALIFORNIA CONSUMERS

Last Updated: April 28, 2020

This Privacy Notice for California Consumers is provided by Vacation Village Resorts and any Vacation Village Resorts affiliate or subsidiary that links to this Notice (collectively “Vacation Village Resorts”  “Company” “we”, “us”, or “our”). This Notice supplements and is expressly made part of the information contained in the Company’s Privacy Policy and applies solely to those who are Consumers (“you”) as defined in Section 1798.140(g) of the California Consumer Privacy Act of 2018. We adopt this Notice in compliance with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this Notice.

As a Consumer, you have certain rights regarding your Personal Information (“information”), as defined in the CCPA. The Company respects and will honor the rights bestowed upon you by the CCPA. This Notice provides you with information on how the Company collects, uses and shares personal information. It also outlines the rights you have regarding personal information that we collect from you and describes how you can exercise those rights.

Collection and Use of Personal Information

Vacation Village Resorts recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Vacation Village Resorts has collected the following categories of personal information from consumers within the last twelve (12) months:

CategoryExamplesCollected
A. Identifiers.  A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.  YES  
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).  A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.  YES  
C. Protected classification characteristics under California or federal law.  Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).  YES
D. Commercial information.  Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.  YES  
E. Biometric information.  Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.  NO  
F. Internet or other similar network activity.  Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.  YES  
G. Geolocation data.  Physical location or movements.  YES  
H. Sensory data.  Audio, electronic, visual, thermal, olfactory, or similar information.  NO  
I. Professional or employment-related information.  Current or past job history or performance evaluations.  NO  
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).  Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.  NO  
K. Inferences drawn from other personal information.  Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.  YES

Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information otherwise excluded from the CCPA’s scope, such as information collected pursuant to the Gramm-Leach-Bliley Act (“GLBA”) or the Fair Credit Reporting Act (“FCRA”). Any personal information or category of personal information collected pursuant to the GLBA or FCRA would not be considered “personal information” under the CCPA.

We have obtained the categories of personal information listed above from the following categories of sources

  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our Websites.
  • From third-party business partners such as social media sites, ad networks, and analytics providers.

We use this information to

  • to respond to your inquiry and fulfill your requests;
  • personalize your experience to better respond to your individual needs;
  • to inform you about important information regarding the Site, products or services for which you apply or in which you are enrolled, changes to terms, conditions, and policies and/or other administrative information;
  • to verify your identity and/or location (or the identity or location of your representative or agent) in order to allow access to your services, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of your Personal Information;
  • to allow you to participate in surveys and other forms of market research, sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which may contain additional information about how Personal Information is used and shared;
  • to send you e-mails regarding system downtime and/or changes to this Privacy Policy or the Terms and Conditions of Use;
  • collected through our social media pages and other online interactions with you to assist in verifying your identity and account status. We may combine this online information with information collected from offline sources or information we already have;
  • for business purposes, including data analysis, audits, developing and improving products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns; and
  • for risk control, for fraud detection and prevention, to comply with laws and regulations, and to comply with other legal process and law enforcement requirements.
  • to improve our website based on the information and feedback we may receive from you;
  • to improve customer service; to administer a promotion, survey or other site feature; and
  • to deliver marketing communications that we believe may be of interest to you via telephone, email, direct mail or in other ways.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Sharing Personal Information:

In response to a California law, we will automatically treat accounts with California billing addresses as if you requested us to not share your information with nonaffiliated third parties except as permitted by the applicable California law. We will also limit the sharing of information about you with our affiliates to comply with California privacy laws that apply to us.

That said, we may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contractual arrangement that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contracts.

We have shared personal information with the following categories of third parties:

  • Affiliates.
  • Service providers.
  • Data aggregators.

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category D. Commercial information.
  • Category G. Geolocation data.

Sale of Personal Information.

The CCPA similarly requires Vacation Village Resorts to provide you with a statement on its personal information sales. In the preceding twelve (12) months, Vacation Village Resorts had not sold your personal information. Vacation Village Resorts does not and will not sell the personal information of California consumers. Notice Regarding Your Rights

Access & Data Portability Rights

You have a right to request that the Company disclose what personal information we collect, use, and disclose. If we receive and confirm your consumer request as verifiable (see Exercising Access, Data Portability, and Deletion Rights) and no exception applies, we will provide you with:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two s list disclosing:
    • Sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable, unless an exception applies we will delete (and direct our service providers to delete) your personal information from our records.

The CCPA provides a number a reasons why a deletion request may be denied. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  2. Debug products to identify and repair errors that impair existing intended functionality.
  3. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Vacation Village Resorts by either:

Only you, or a person registered with the California Secretary of State and legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify either: (A) your identity; or (B) authority to make the request. Making a verifiable consumer request does not require you to create an account with us, but we must also be able to confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We will confirm receipt of your request within 10 days of receiving the request. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights described above. Unless permitted by the CCPA, 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.

California Do Not Track Disclosures

How do we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services?

We currently do not respond to DNT signals in browsers because we do not track individual users across the web.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit our Sites?

No.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the Websites and update the Notice’s effective date. Your continued use of our Websites following the posting of changes constitutes your acceptance of such changes.

Contact Information You can contact us by writing or email us at the address below.

Vacation Village Resorts
Privacy Policy Dept.

2626 E. Oakland Park Boulevard,

Fort Lauderdale, FL 33306

privacy@vacationvillageresorts.com.

Please print and retain a copy of this privacy policy for your records.