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Internet Privacy Statement

Starwood Vacation Ownership, Inc., its subsidiary companies, and managed owners’ associations (together “SVO”) respects your privacy and is committed to protecting it through compliance with this Online Privacy Statement (“Policy”). This Policy describes the type of information SVO may collect from you or that you may provide when you visit any website owned or operated by SVO. The mission of SVO is to consistently exceed our visitors’ expectations in terms of the products and services we provide to our business and leisure travelers. SVO collects information about our visitors (both offline and online) so that we can provide an experience that is tailored to their preferences. Since the privacy of our visitors is of paramount importance to SVO, we wish to protect it and maintain the trust of our visitors while collecting the information necessary to do this. SVO is fully committed to providing information about the collection and use of personal information furnished by, or from, visitors while using our websites, products and services. We offer visitors the choice to decline (opt out) participation in certain services and promotional benefits provided by SVO and/or our carefully selected third parties. Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our websites. By accessing or using our websites, you agree to this Policy. This Policy may change from time to time. Your continued use of the websites after we make changes is deemed acceptance of those changes, so please check the Policy periodically for updates.

Note that the Starwood Hotels & Resorts Worldwide Inc. (“Starwood”) Privacy Statement governs the data collection and use in relation to Starwood operated websites and properties.

The following is an explanation of the information collected by SVO, its use, and why the use of this information will benefit our visitors’ experience.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83, provides certain privacy rights to individual customers who are California residents. If you are a California resident and have provided personal information to SVO, you may request information about our disclosures of certain categories of personal information to third parties, if such disclosures were for the direct marketing purposes of the recipient of that information. Because your privacy is important to us, SVO does not share your personal information with unaffiliated third parties for the third parties’ direct marketing purposes, except as stated below. SVO does share customer information among its subsidiary companies for the purpose of marketing the various SVO resorts, vacation products and services, and shares certain information about its vacation ownership interest owners with the external vacation exchange companies (Interval International and/or Resort Condominiums International) that are affiliated with the SVO resorts. If you would like to receive a list of such companies, please submit your request by writing to the addresses listed under Contact Us.

INFORMATION COLLECTED ON OUR WEBSITES
COOKIES AND INVISIBLE PIXELS
SOCIAL MEDIA
EMAIL
DIRECT MAIL / OUTBOUND TELEMARKETING
LINKS TO OTHER WEBSITES
ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION
CHILDREN UNDER THE AGE OF 13
SAFE HARBOR
SECURITY
PERIODIC REVIEW AND MODIFICATIONS
CONTACT US

INFORMATION COLLECTED ON OUR WEBSITES

The websites owned or controlled by SVO may ask for and collect personal information in order to provide a customized experience. The personal information we collect on or through our websites may include information that you provide by filling in forms on our websites, such as, name, postal address, e-mail address, and telephone number. Visitors are given notice of this request and they have the ability to choose the information they wish to share with us. Visitors will be informed about how SVO may use such information, including whether it will be shared with carefully selected third parties. In most cases, the information a visitor provides is added to our database in order for us to provide personally tailored messages which are delivered online and offline.

SVO may also collect information using automatic data collection technologies to collect certain information about your equipment and browsing activities and patterns. Our automatic data collection activities are further described in the Cookies and Invisible Pixels section of this Policy below.

SVO may contract with third-party service providers to deliver services and customer solutions. Service providers, which may change or be added from time to time, are required to keep confidential the information received on behalf of SVO and may not use it for any purpose other than to carry out the services they are performing for SVO. Situations in which SVO may disclose your information to others include:

  • When we have received your consent to do so;
  • In situations where sharing or disclosing your information is required in order to offer you products or services you requested (e.g., a vacation package);
  • When companies or services providers that perform business activities on behalf of SVO require such information (e.g., credit card processing, customer support services, market research administration or database management services);
  • When a hotel or other property leaves the Starwood system and access to your personal information is necessary to facilitate business operations or meet contractual obligations;
  • In the event SVO is merged or acquired by another company;
  • To comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena, to enforce the right of a lender, owners’ association, or foreclose on a property interest; and
  • In case of emergency such as to safeguard the life, health, or property of an individual.

If information is shared as mentioned above, we seek to limit the scope of information that is furnished to the amount necessary for the performance of the specific function. Unless otherwise precluded by legal process, we require third parties to protect your personal information and abide by applicable privacy laws and regulations.

If you are accessing the Policy through a website intended for owners of SVO products, such as MyStarCentral.com or StRegisResidenceClub.com (“Owner Only Websites”), please know that it is necessary for us to collect certain personal information to present you with your specific ownership information and allow you to perform various activities within these websites. If you do not wish to share your information, please do not register on any of the Owner Only Websites.

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COOKIES AND INVISIBLE PIXELS

The websites may collect personal information through behavioral tracking. As you navigate through and interact with our websites, SVO, its vendors, and marketing partners, may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns by using cookies, invisible pixels, and web beacons. These help us deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our websites according to your individual interests; and speed up your searches.

Web Beacons and Invisible Pixels. SVO uses invisible pixels and web beacons to count how many people visit certain web pages. Information collected from invisible pixels and web beacons is used and reported in the aggregate. SVO may use this information to improve marketing programs and content.

Cookies. Cookies are used to:

  • Remember your user name and password for future visits so log-in is easier and faster;
  • Ensure you are provided with the appropriate frames and content;
  • Ensure you obtain all requested information; and
  • Help us deliver communications that are relevant and responsive to your interests and location.

SVO cookies assign your computer or other device with a unique identifier, which in turn, becomes your identification card whenever you return to a SVO or Starwood website. Cookies are small data files that most websites store, access, and maintain on the hard drive of your computer. Most browsers now automatically accept cookies by default but they can be set so that all or some cookies are rejected automatically or are accepted or rejected on a case-by-case basis at the user’s option.

Below we explain the different types of cookies that may be used on our websites. For a full list of the cookies we employ please see the section labeled Cookie Choices.

  • Essential Cookies. Essential cookies are necessary for our websites to work, and to enable you to navigate it and use its services and features. As disabling these cookies would make the services and features unavailable, we are not required to provide you with an opt-out consent mechanism.
  • Customization Cookies. Customization or preference cookies store your choices and preferences allowing us to remember language or other local settings and to customize our websites accordingly.
  • Analytics Cookies. Analytics cookies collect information about your use of SVO websites and enable us to identify problems, determine the efficacy of our advertising, and understand how aggregate traffic moves on and to our websites.
  • Advertising Cookies. Advertising cookies allow us to show you the most relevant products, offers, advertisements and personalized content and help us provide you with an online experience that’s tailored to your needs.

We may also work with vendors and marketing partners to help deliver advertisements and personalized content that we believe will be of interest to you. These vendors and other partners include advertisers, advertising agencies, advertising networks, audience segment providers, data exchanges, analytics providers, and other similar providers. Please click here for a current list of the agencies and providers with which we work. These partners and vendors use cookies and web beacons to collect information about your online activity (e.g., the sites and pages you have visited at Starwood and other third party websites) in order to help SVO and third party advertisers deliver personalized content and advertising to you while you are on SVO or other websites. For example, if you go to an SVO website to look at one of our properties or to book a hotel room, you may later see an advertisement from us when you visit another website. We may also engage one of these vendors to deliver our advertisements to consumers whose online behaviors on websites other than the SVO websites indicate that they may be interested in travel. In other instances, we engage in special arrangements with certain advertisers with which we think our website visitors would have an interest. We allow these advertisers to deliver co-branded messages (e.g., SVO and the advertiser) directly to consumers who have visited our websites. These types of co-branded advertisements may appear on SVO or on third party websites. In general, you can opt out of our vendors’ use of cookies to tailor personalized content or advertising to you by visiting:

http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices.

We also work with vendors to deliver our advertisements directly to those who are traveling or about to travel. For example, when you print your boarding pass online, one of our vendors may drop a cookie on your computer, identifying your computer with a unique identifier and a code indicating your destination. We use this vendor to deliver advertisements to you indicating our available properties in the destination indicated on your boarding pass.

Cookie Choices

You can disable cookies by setting your preferences at any time in the Cookie Consent Tool available at the small grey box on the bottom left-hand side corner on our website. To see a complete list of the companies that use these cookies and technologies and to tell us whether or not they can be used on your device please click here. However, you should also understand that rejecting cookies might affect your ability to perform certain transactions on our websites and our ability to recognize your browser from one visit to the next.

You may also adjust your Internet browser to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security.

To learn more about cookies, please visit the following site, which is not affiliated with SVO: http://www.allaboutcookies.org/.

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SOCIAL MEDIA

Profile
If you connect with a social media service, or log in through a social media service, we may collect information that is publicly available through that service and the basic account information that is automatically passed to us by the service. For example, on Facebook, this could include your name, profile pictures and URL, cover photos, username, user ID, your friends’ user IDs, network, gender, birthday, language, and current city.

Social Content
We may also collect content that you provide to be published on those social media services, such as your likes and your social media activities, like check-ins or tweets. We also collect such other information as you and the social media service provide to us, including information regarding or provided by your friends. This includes, for example, check-ins, events, travel wishes, interests, posts, locations, and photos (including photos you or your friends have been tagged in). If you have turned on your device’s location services, your location may be included in that content.

Social Media Content Sharing
The information collected from or about you by social media networks with which you connect are governed by the policies of those social media networks. Be aware that sharing content on to a social media service may lead to it being shared to your friends (or contacts on those networks). Please consult the privacy settings on these services to update any of your sharing settings.

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EMAIL

From time to time, SVO asks visitors for their email address in order to provide relevant information such as reservation confirmations and offers. Email addresses may be joined with other information provided at our website and may also be augmented with other data sources. By providing their email address to us, visitors may receive email messages from SVO. A visitor may opt-out of receiving email communication by following the directions posted in the email, or by following the directions at SVO’s website, or by contacting a SVO customer service representative to opt out of email communication.

Visitors may receive periodic offers and information from SVO about our products and services, as well as offers and information from SVO’s carefully selected marketing partners. Visitors may also receive offers and information directly from these selected third parties. Visitors who do not want to receive marketing information from SVO and/or these third parties in the future, have the option to contact us in order to decline such communication.

Once a visitor has opted out, they can choose to opt-in again by changing their profile online or by contacting us in any of the ways outlined in our Contact Us section.

For Owner Only Websites, please know that e-mail addresses are required to provide confirmation of owner requests and activities within these websites. If you do not wish to provide your e-mail address or do not wish to receive confirmation e-mails from SVO, then SVO cannot accept any requests through the Owner Only Websites.

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DIRECT MAIL / OUTBOUND TELEMARKETING

As part of the service that SVO provides its visitors, SVO may mail or call its visitors to inform them of enhancements, changes in offerings, special events, or other relevant information responsive to the visitors’ interests. Visitors who supply SVO with their postal address or telephone number may receive periodic mailings or phone calls from us with information on new SVO products and services or upcoming SVO special offers/events. They may also receive mailings/calls from our carefully selected third parties.

SVO offers our visitors the option to decline these communications and we comply with all Federal and State “Do Not Call” legislation. Visitors may contact us to opt-out of such communications.

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LINKS TO OTHER WEBSITES

In order to anticipate your needs, SVO provides links to other web sites for your convenience and information. SVO is not responsible or liable for any content presented by or contained on any independent website, including, but not limited to, any advertising claims or marketing practices. Please note that while SVO will protect your information on SVO owned and operated websites, SVO cannot control and will not be responsible for the privacy policies of third party websites, including websites owned or controlled by independent owners’ associations, vendors, service providers, travel providers that may have a business relationship with SVO, or other websites not controlled or authorized by SVO. Third party websites that are accessed through links on our web sites have separate privacy and data collection practices and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their websites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any personal information. We recommend that you review the privacy statements and policies of linked websites to understand how those websites collect, use and store information.

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ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION

We respect our visitors’ privacy and maintain their profile information on a secure server. Personal information can be accessed and updated by the visitor with the assistance of an SVO customer service representative. Visitors have the opportunity to review the information they provide and update it by contacting SVO by the means below.
Occasionally, information that a visitor requests to be removed will be retained in certain files in order to properly resolve disputes or to troubleshoot problems. In addition, information is never completely removed from our databases due to technical and legal constraints, including stored “back up” systems. Therefore, visitors should not expect that all of their personal information will be completely removed from our databases in response to their requests.
Data collected by SVO is an asset. It is possible that SVO, its subsidiaries, affiliates, joint venture companies, or any combination of the foregoing, could merge with or be acquired by another legal entity. In such event, visitors should expect that SVO may share some or all of the data collected from its visitors with such other entity; provided, that such other entity will be notified of the practices which apply to personal information under SVO’s applicable privacy policy.

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CHILDREN UNDER THE AGE OF 13

Our websites are not intended for children under 13 years of age. No one under age 13 may provide any personal information on our websites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this or any other website owned or operated by SVO, do not use any of the interactive or public comment features, do not provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

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SAFE HARBOR

If you are located in the European Economic Area or Switzerland, we comply with applicable legal requirements providing adequate protection for the transfer of personally identifiable information to countries outside of the European Economic Area or Switzerland. SVO as part of Starwood is certified under the Safe Harbor privacy frameworks as set forth by the U.S. Department of Commerce, European Commission and Switzerland regarding the collection, storage, use, transfer and other processing of personally identifiable information transferred from the European Economic Area or Switzerland to the U.S. Click here to view our Safe Harbor Privacy Statement.

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SECURITY

SVO recognizes the importance of information security and is constantly reviewing and enhancing our technical, physical, and logical security rules and procedures. SVO owned web sites and servers utilize security measures to help protect your personal information against accidental loss, misuse, unlawful or unauthorized access, disclosure, and alteration while under our control. Any payment information transactions will be encrypted using SSL technology. We also strive to ensure our affiliates and service providers, with which we share your personal information, exercise reasonable efforts to maintain its confidentiality and security. Although “guaranteed security” does not exist either on or off the Internet, we safeguard your information using appropriate administrative, procedural and technical safeguards, including password controls, firewalls, and the use of encryption.

Where we have given you or where you have chosen a password for access to certain parts of our websites, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. We also urge you to be careful about giving out information while in public areas of our websites like message boards. The information you share in public areas may be viewed by any user of the websites.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security lf your personal information transmitted to our websites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our websites.

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PERIODIC REVIEW AND MODIFICATIONS

The effective date of this privacy policy is July 1, 2014. SVO recommends that visitors review this Policy periodically, as SVO may revise it from time to time. Updated versions will be posted to our web site and date stamped so that you are always aware of when the Privacy Statement was last updated.

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CONTACT US

SVO provides all visitors with the option to contact us with any further questions or concerns.

You can contact us these ways:

By email: privacyoffice@starwoodvo.com

By writing to us at:
Starwood Vacation Ownership, Inc.
Attention: Privacy Office
9002 San Marco Court
Orlando, Florida 32819

For Owner Only Websites with which you have a unique log in, you can also review and change your personal information by logging into that website and visiting your account profile. We may not be able to delete your personal information without deleting your account on the Owner Only Website.

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