Effective Date: 7/1/2020
At Global Exchange Vacation Club (“GEVC”), we understand that the handling of your privacy and personal information is especially important to you. Being transparent to consumers about our information handling is a crucial and fundamental part of our business practices. This Privacy Statement details what personal information we may collect through your use of our websites, applications, social media, and other online services (collectively, “Services”). This Privacy Statement applies to Global Exchange Vacation Club and all of its affiliates and subsidiaries.
If you have received a financial product or service from GEVC, please see the separate privacy notice provided to you, which describes how we protect and use your non-public personal financial information.
Information We Collect
Information About You. The information that you provide directly to us and that we obtain from others is what we need to serve you, our affiliates and business customers. This information may include your contact details (such as name, postal and email addresses, phone number, social media handles and other online aliases); information specific to the Service you request (such as financial information when you apply for credit); details about your products and business transactions; contact information of individuals with whom you would like to share GEVC content; social media information; demographic and household information; your responses and engagement with our Services; and other information you may choose to share with us by interacting with our Services or with our affiliates, business customers, suppliers or other businesses that share information with us.
Information About Your Device. The information we collect by automated means also helps us, our affiliates, and our business customers to provide and tailor various products and services. Examples of information we collect by automated means include the following:
Reputable Third Parties. We use Google Analytics, to collect information through Data Technologies. This data is collected on an anonymized basis and in the aggregate, but may include or be associated with other non-personally identifiable information or with personally identifiable information that users have voluntarily submitted. Our primary goal in collecting user information is to enhance your experience on our site. Google Analytics is a web analytics tool provided by Google, Inc. (“Google”) that helps website owners understand how visitors engage with their website. We can view a variety of reports about how visitors interact with our website so we can improve it. Google Analytics collects information anonymously. Google uses first party cookies and IP addresses, and it reports website trends without identifying individual visitors. We do NOT authorize Google Analytics to use the data it collects from this site. For more information related to Google Analytics, click here. For information about and to install Google Analytics Opt-out Browser Add-on, click here.
Usage Information. We and our suppliers may automatically collect your usage activity, preferences, and browser details (such as your IP address and browser type), as well the ID and type of the device you use to connect or interact with our Services, and other details about your use or interaction with our Services. This may also include the collection of information about your online activities over time and across third-party websites or online services and across devices that you use.
Location Data. Some of our Services may collect geo-location data to provide or improve our Services and location-related functionality, such as the location of your nearest business and (ii) your precise location while at a business. We may link location data to other information we have collected about you.
How We Collect Information
Information You Provide. We may collect the information you voluntarily provide to us in connection with using our Services, including through inquiries, technical services or questions, support, events and promotions, job applications, other inquiries and transactions. Our suppliers also may collect information from you, including, for example, when you participate in our contests, sweepstakes, surveys, and other promotions. Some portions of the Services may allow you to submit comments, reviews, ratings and other content.
Information We Obtain from Affiliates, Business Customers, Suppliers and Others. We may obtain information about you from outside sources. For example, our affiliates, Business’s and Partners that work with GEVC may share with us certain information you provided to them. They may also inform us whether you have been approved for credit and related information. We also may obtain demographic and other information about you from third parties. If you engage via social media with us, our affiliates, our business customers, or our suppliers, the social media platforms also may share certain information with GEVC. You may be able to adjust your social media privacy settings to limit the sharing of your social media data.
Data Collection and Use by Third Parties
Our Services may include third-party advertising, promotions, co-branded features, links to other websites, and other programs offered by or in collaboration with third-party businesses, such as Facebook, Microsoft and Google. In addition to collecting information directly from you, these third-party businesses may use tracking technology to measure the effectiveness of their ads, personalize or optimize advertising content, and track users who click on the links made available through the Services. We may also use Bing Universal Event Tracking (UET) from Microsoft Bing Ads that places a tag on your computer when you visit one of our websites through Bing Ads advertisements. The UET tag is used for user tracking and data sharing with third parties for advertising and marketing purposes, and to measure ad effectiveness. For more information about Microsoft’s privacy practices, please see Microsoft’s Privacy Statement: https://privacy.microsoft.com/en-us/privacystatement.
When you use or interact with our Services, these third-party businesses may collect information about you, including your online activities over time and across third-party websites or online services. We are not responsible for the privacy practices of these third parties and their suppliers, and we encourage you to read their privacy policies, which may apply to these third-party programs. Some of the ads you receive on websites are customized based on predictions about your interests generated from your visits to different websites. This type of ad customization is sometimes called “online behavioral” or “interest-based” advertising. The Digital Advertising Alliance (“DAA”) provides a “Consumer Opt-out” for certain companies that have agreed to provide that functionality.
How We Use Your Information
A primary use of your information is to better serve you, which requires certain sharing with our affiliates and business customers. The following are examples of the types of general purposes for which we may use your information.
Provide Products and Services. We may, for example, use your information to complete a transaction you have asked us to do, including “information requests”, or to send you communications regarding products or service or even general information inquiries. We may also, for example, use your information to provide you with an improved experience when interacting with us, our affiliates and business owners.
Operate our Business and Develop and Improve Our Products and Services. Examples include using information collected through cookies and similar technology to better understand how our Services are used, develop new offerings, or personalize your experience when using the Services.
Customer Service. If you request support or other information, we may use your information to respond to your request. We may follow up with you to notify you periodically about important topics, like Services updates or changes to our Privacy Statement.
Marketing. We may use your information to let you know about current offers, invite you to participate in those offers and manage your participation in them. We also may use information about you, your use or your interaction with our Services to tailor our offers to your preferences or to offer you products and services that we believe may be of interest to you. Business owners, Associations and our affiliates may use your information for their own marketing purposes. Among other privacy choices described in this Privacy Statement, you may direct us to not send you email marketing communications by clicking on the unsubscribe link included in the emails you receive from us.
Recruitment and Job Applications. We may use the information submitted on resumes and similar documents through our websites and our suppliers for the purpose of employment consideration. We may keep your information on file for future consideration.
Compliance with Legal Requirements, Rules and Internal Policies. We may be required by law or internal data retention policies to maintain information about you for a certain period of time, or to notify you of a security breach. We also may be required by social media platform rules (such as Facebook) to handle the social media information you or the platform share with us in a certain manner.
A primary use of your information is to better serve you, which requires certain sharing with our affiliates and business customers. This section describes the types of organizations with whom we may share your information.
Within GEVC. GEVC may authorize access to your information within our enterprise, by our employees and other personnel, to fulfill our obligations to you and to operate our business.
Affiliates, Business Customers and Suppliers. Our Affiliates, Business Customers and Suppliers may access and use your information for the purposes we describe in this Privacy Statement, including as necessary to provide functionality, products, and services to us and you in connection with the Services. For example, when you register for a sweepstakes, a supplier may process the sweepstakes entry. We may also allow our Affiliates, Business Customers and Suppliers to have access and use aggregate statistics – statistics not linked by us to any specific consumer – about consumer behavior, sales, online activity patterns, and related Services information.
Marketing Partners. We may share your information with our marketing partners when, for example, we participate in a co-branded promotion with another company. Other than as described in this Privacy Statement, we will not share your information with third parties for their own marketing purposes.
Your Public Comments. Some portions of our Services may allow you to submit comments, reviews, ratings and other content. This content may be displayed on the Services and may be viewable by other users of the Services or the public generally.
Mergers, Acquisitions or Insolvency. If GEVC should ever file for bankruptcy or merge with another company, or if GEVC should decide to buy, sell, or reorganize some part or all of its business, GEVC reserves the right to disclose your information, including to prospective or actual purchasers in connection with one of these transactions.
As Required by Law and Other Disclosures. GEVC may be required to disclose your information if it:
- believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority;
- would potentially lessen our liability in an actual or potential lawsuit or investigation; or
- is necessary to protect our or others’ rights or property.
We take reasonable measures to secure our systems and protect your personal information. These measures include computer safeguards and physical controls. However, data transmissions over the Internet and otherwise can never be guaranteed to be 100% secure, and we cannot ensure the security of any information you transmit to us and you do so at your own risk.
By providing your email address to us or using the Services, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues. If we learn of a security breach, we may attempt to notify you electronically. You may have a legal right to receive this notice in writing. To receive a free written notice in the event of a security breach (or to withdraw your consent from receiving electronic notice), or if you want to update the contact information you have previously provided to us, you should contact us at email@example.com.
Access and Control of Information You Have Provided to US
You may request to access, correct, update or delete the personal information you have provided to us, or otherwise adjust your privacy preferences by writing to us at firstname.lastname@example.org.
We may limit or deny access to information where providing such access is unreasonably burdensome or expensive under the circumstances, or as we otherwise deem appropriate. In addition, please note that we may not be able to edit or delete your information stored with our third-party service providers, or we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).
We may use or share non-personal information, aggregated information, de-identified or pseudonymized information, and statistical information for any lawful purpose. Any obligations or restrictions contained in this Privacy Statement do not apply to such information.
Our Services are not directed at children or intended to be used by children. Do not send any information about yourself to us if you are under the age of sixteen (16). In addition, if we learn a person under the age of thirteen (13) has submitted information to us, we will attempt to delete this information. If you have reason to believe that we may have accidentally received information from a child under the age of thirteen (13), please contact us immediately at email@example.com.
Your California Privacy Rights
California Civil Code Section 1798.83 permits visitors to the Services who are California residents to request certain information, once a year, regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email using the contact information provided below and put “Shine the Light Request” in the subject line of your email.
If you are a California resident, as of January 1, 2020, you have the following additional rights:
- You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.;
- You have the right to request information about our sale or disclosure for business purposes of your personal information to third parties.;
- You have the right to opt-out of the sale of your personal information to third parties. We do not sell your personal information to third parties.;
- You have the right to request the deletion of your personal information. Please note that notwithstanding your request, California law permits us to retain certain categories of personal information for numerous purposes, including to complete a transaction, to perform a contract between you and us, and to comply with a legal obligation, such as a record retention requirement.;
- You have the right to not be discriminated against for exercising any of these rights.
- If you would like to exercise one or more of the above rights, you can request the information that you provide directly to us and that we obtain from others as need to serve you be removed us by e-mailing firstname.lastname@example.org. We will send you an e-mail to confirm your request. After we receive confirmation, we will remove your information from our active database, but some information may remain in our database and/or archives for our own corporate recordkeeping and as required to comply with law.
To submit your request, please email email@example.com.
Your Nevada Privacy Rights
If you are a Nevada resident, you have the right to opt-out of the sale of personal information to third parties that may be collected by GEVC. To submit your request, please send an email referencing your Nevada rights to: firstname.lastname@example.org.
This is a U.S. website, and this site and our Services are subject to U.S. laws, including those governing the privacy and security of your information. By using the Services or providing your information to us through the Services you consent to the transfer of your personal information to the United States, and our handling of your information in accordance with applicable U.S. requirements.
Changes to This Privacy Statement
If this Privacy Statement changes, we will post it on our website and include the effective date of the update.
Retention of Your Information
We retain your information for as long as it is necessary and relevant for the purposes described in this Privacy Statement. The information we retain about you will be handled in accordance with this Privacy Statement.
Contacting Global Exchange Vacation Club
If you have any questions, comments, or concerns about our information practices or this Privacy Statement, please email us at email@example.com or write to us at:
Global Exchange Vacation Club Legal and Compliance Department
Attn: Data Privacy
27405 Puerta Real Suite 100
Mission Viejo, CA 92691