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LAST UPDATED: 28 May 2020 Click to read the Special Notice for Collection of Personal Information Related to the COVID-19 Pandemic. A separate privacy notice applies to employees of Wyndham Destinations and its group of companies. Employees are to refer to the ‘Employee Privacy Notice’. |
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Wyndham (We, Us, or Our) cares about privacy issues and wants you to be familiar with how we collect, disclose, and otherwise use (Process) information about you. This privacy notice (Privacy Notice) describes our practices in connection with the information we collect through our websites (the Websites), social media pages that we control (Social Media Pages), and software applications that we make available for use on or through computers and mobile devices (the Apps), that include a link to this Privacy Notice, and through any of our offline activities, such as when you provide your information on the telephone via our call centers or in person (Offline Activities) (collectively, including the Websites, Apps, Social Media Pages, and Offline Activities, the Services).
NOTICE TO CLUB OWNERS/CUSTOMERS OF FINANCE BY WYNDHAM: You may receive a separate notice regarding “Your Financial Privacy” by mail. If a Service provides you the ability to access your account online, and you agree to receive annual notices online, we will provide you with annual notices through such Service. Further, if we provide you with updated notices online, we will require you to acknowledge receipt of the updated notice through such Service or another identified Service.
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements, such that our practices may be more limited in such jurisdictions.
Please read the following to learn more about our privacy practices.
We may collect Personal Information (information that identifies you or relates to you as an identifiable person) about you such as your:
We may collect information from you when you interact with us such as when you:
Other information we collect about you:
Cookies: Our Services may use “cookies” and similar technologies (collectively, “cookies”). Cookies are small text files this Website sends to your computer for recordkeeping purposes; this information is stored in a file on your computer’s hard drive. Cookies make web surfing and browsing easier for you by saving your preferences so we can use these to improve your next visit to our Website.
Pixels, Beacons: We or third party ad servers, including Facebook, may use cookies or invisible pixels or beacons on this Website to count how many users visit certain pages or take certain actions to collect or receive information from this Website and elsewhere on the Internet. We may use this information to improve our marketing programs and content, and to target advertisements at this Website and/or on other sites.
From Other Sources: We may receive your Personal Information from other sources, such as public databases, joint marketing partners, data firms, social media platforms, from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your Website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your public profile or your friends’ public profiles.
Mobile Devices: When you use or access our Services from a mobile device, we may collect information such as your unique device ID and your location. If you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number, as well as any other Personal Information specified by the App in its terms or notices.
Do Not Track Signals: At this time, we do not respond to browser ‘do not track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit our website. You can learn about how to exercise choice regarding the collection of information about your online activities over time and across third-party websites or online services by visiting www.aboutads.info and www.networkadvertising.org.
Google Analytics: We use Google Analytics to help us get a better understanding of how visitors use this Website and to facilitate interest based advertising associated with your Google Account and other devices you use. The information generated by the Google Analytics cookie about your use of this Website is transmitted to and stored by Google. If you do not want your activity on this Website to be tracked by Google Analytics, you may opt out by using this link: http://tools.google.com/dlpage/gaoptout?hl=en.
Internet Based Advertising: We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Services and other websites, apps or online services, based on information relating to your access and use of our Services and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit www.aboutads.info and www.networkadvertising.org to opt out in mobile apps. You may also opt out in Twitter by going to your account privacy settings and unchecking the box next to “Tailor ads based on information shared by ads partners.”
Other Non-Personal Information: In addition to any Personal Information or other information that you choose to provide to us on the Services, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain web site usage information whenever you visit or interact with the Services. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information. We may use this usage information for a variety of purposes, including to enhance or otherwise improve the Services. In addition, we may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively, referred to herein as a Device Identifier). A Device Identifier is a number that is automatically assigned to your device, and we may identify your device by its Device Identifier. When analyzed, usage information helps us determine how our Services are used, such as what types of visitors arrive at the Services, what type of content is most popular, what type of content you may find most relevant and what type of visitors are interested in particular kinds of content and advertising. We may associate your Device Identifier or web site usage information with the Personal Information you provide, but we will treat the combined information as Personal Information.
We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and to improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated companies and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may in turn use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.
As aggregated or anonymized information does not constitute Personal Information, we may use it for any purpose. If we combine anonymized or aggregated data with Personal Information, we will treat the combined information as Personal Information according to this Privacy Notice.
We may Process Personal Information in connection with any of the following:
We may disclose your information as follows:
Security of Your Information: We will take reasonable steps to protect the information you provide us from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure your information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of all information you provide to us via the Services.
Retention Period. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
If you believe that Wyndham is holding personal information about you and you wish to access or correct it, please send a written request to Wyndham at the address indicated below. There may be a small charge if the information you requested takes time for us to provide to you. While Wyndham is happy to assist you within a reasonable period, Wyndham has the right to deny your request if it falls within one of the grounds stated in Principle 12 of the Australian Privacy Principles..
If you wish to have your personal information amended or to not receive direct marketing communications from Wyndham’s database, or wish to have your personal information removed from the database and you are not an Owner in the WorldMark South Pacific Club, you may do so by making a written request to Wyndham, except. Wyndham also has an obligation that all information collected is accurate, complete, up to date and relevant.
If you believe that there may have been possible breaches of your privacy, please write to Wyndham at the address indicated below, and Wyndham will endeavour to respond to you within 14 days of receipt of your complaint.
Contact Information: If after reviewing this Privacy Notice, you have any questions, complaints or privacy concerns, or would like to make any requests in relation to your Personal Information, or obtain further information on safeguards used for international transfers please send an email to customerteam@wyn.com or send a letter to:
The Privacy Officer
C/- Customer Care Team
PO Box 7493
Gold Coast MC 9726, Queensland, Australia
If you have a complaint or concern about how we are Processing your Personal Information then we will work to address such concern(s). You may also direct your complaint/concern to the applicable data protection authority.
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Your Nevada Privacy Rights
Notice to Nevada Residents: If you are a resident of Nevada, under certain circumstances, Nevada Civil Code Section NRS 603A.340 allows you to request operators of websites not to sell your Personal Information. To make such a request, please send an email to our Legal Services-Privacy Department at customerteam@wyn.com or send a letter to: The Privacy Officer C/- Customer Care Team PO Box 7493 Gold Coast MC 9726, Queensland, Australia
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Your California Privacy Rights
1. Shine the Light Law: If you are a resident of California, California Civil Code Section 1798.83 allows you to request information regarding the Personal Information we collected and third parties to whom we disclosed your Personal Information for the third parties' direct marketing purposes during the preceding calendar year. To send this request, you may contact us using one of the methods in the “How Can You Contact Us?” section of this Privacy Notice.
2. California Consumer Privacy Act (“CCPA”): This section 2 is intended to satisfy the requirements of the California Consumer Privacy Act (“CCPA”). The rights of the CCPA are in addition to any other rights applicable to you in this Privacy Notice.
a) Personal Information Definition: For the CCPA, “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
b) Exclusions: Some Personal Information is not subject to the CCPA such as consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, and any other Personal Information exempt from the CCPA. This CCPA section does not apply to Our employees. A separate privacy notice applies to Our employees.
c) The Categories of Personal Information We Collect and Why We Collect Them. Generally, where applicable, we may collect the following categories of Personal Information (as set forth in the CCPA) about you for the following purposes:
OTHER PURPOSES FOR COLLECTING AND USING YOUR PERSONAL INFORMATION: Generally, we may use all of the above categories of personal information for the following purposes where applicable:
· Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including: o Monitoring for, preventing investigating, and responding to security and privacy incidents o Providing and managing access to physical and technical access controls o Monitoring activities, access and use to ensure the security and functioning of our systems and assets o Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring · Auditing, reporting corporate governance, and internal operations. We process Personal Information for the purposes of performing audits of our business operations, performing security reviews, ensuring we are meeting legal obligations, managing your business record, and other auditing functions. · M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions. · Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties. · Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations.
d) WHERE DO WE GET YOUR personal information?: We may collect all of the Personal Information categories above primarily from you such as when you fill out a form, contact us, submit documents to us, use our websites or mobile apps, apply for a loan, and interact with us in other ways. We may collect it from our Affiliates, third party partners or data management companies. We may collect it from social media accounts such as when you connect to our websites through such an account. We may collect it from travel agents who provide it to us on your behalf or other persons who provide your information.
e) To Whom do we disclose your personal information?: We disclose Personal Information to Affiliates, vendors and service providers, legal and regulatory agencies under certain circumstances, third party product and service providers, third party partners, and others under certain circumstances. Please see the “When We Disclose Your Information” section for more.
f) selling your Personal Information: Under some circumstances as described below, we may sell or license your Personal Information.
g) California Rights:
*Wyndham, may include one or more of the following companies: Wyndham Destinations Asia Pacific Pty Ltd ACN 090 083 613, Wyndham Vacation Clubs South Pacific Ltd ACN 090 503 923, Finance by Wyndham Pty Ltd ACN 091 790 993, Travel by Wyndham Pty Ltd ACN 090 106 077, Resort Management by Wyndham Pty Ltd 099 634 830, Resort Hospitality by Wyndham Pty Ltd ACN 104 243 209.Gold Coast MC 9726, Queensland, Australia
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