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UPDATED PRIVACY NOTICE
LAST UPDATED: 1 January 2020
Introduction to this Privacy Notice
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 Wyndham Asia MEMBERS/ FINANCING CUSTOMERS: 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.
What Information Is Collected and How Is It Collected?
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.
Why and How We Use Your Information
We may Process Personal Information in connection with any of the following:
When We Disclose Your Information
We may disclose your information as follows:
How Do We Safeguard Your Information?
Other Important Information
Your Choices and Rights
Any request to access or obtain copies of your Personal Information must be made in writing by contacting us as set forth under “How Can You Contact Us?” below. We may, depending on the applicable law in your country, be entitled to charge a nominal fee to cover some of our administration costs in connection with the provision of such information. We may also ask you to verify your identity and to provide further details relating to your request.
Access to information
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 request takes time for us to provide to you.
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 Club Wyndham Asia Member, you may do so by making a written request to Wyndham, except that Wyndham also has an obligation that all information collected is accurate, complete, up to date and relevant.
Complaints
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.
How Can You Contact Us?
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 contact Member Services to be directed to our legal department. Contact details for Member Services is on our website membersupport@ihc-wyn.com or you can send a letter to:
The Privacy Officer
Club Wyndham Asia
3 Phillip Street #08-03/04 Royal Group Building
Singapore 048693
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 in your country of residence.
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 a letter to:
The Privacy Officer
Club Wyndham Asia
3 Phillip Street #08-03/04 Royal Group Building
Singapore 048693
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, please send a letter to:
The Privacy Officer
Club Wyndham Asia
3 Phillip Street #08-03/04 Royal Group Building
Singapore 048693
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:
| Personal Information Category | Identifiers: Identifiers such as your 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, account number, rewards program number, and other similar identifiers. |
| Purposes of Collection | We may collect this information to establish a business record of you, setup rewards and other accounts, create login credentials for you, and for similar reasons.
We may collect this information to communicate to you about your purchases, transactions, contracts, our business relationship we you, and for similar reasons. We may collect this information to provide you with surveys for quality assurance, product development and more. We may collect this information to facilitate communications to you regarding products/services that may be of interest to you. We may collect this information to provide a list to resorts, Home Owner’s Associations (HOAs), and third party partners related to your transactions, election activities, ownership and more. We may collect this information to verify your identity such as when you request access to your Personal Information or apply for a loan. We may collect this information such as government id related information in order to process your loan application or provide information to a travel provider such as an airline pertaining to your reservation. We may collect this information to provide a list of your emergency contacts. We may collect this information to meet a legal requirement such as recording a title or similar functions. We may collect your signature on documents like contracts, loan terms, waivers, etc. |
| Personal Information Category | Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
| Purposes of Collection | We may collect this information to process and/or administer your loan applications and loans, your contracts, your reservations, your loyalty and/or rewards accounts, and more.
We may collect this information to personalize your services/products, provide helpful suggestions, respond to your commercial inquiries, and facilitate communications to you of products/services and related features that may be of interest to you. We may collect this information to create efficiencies in managing reservations and recurring commercial interactions with you or otherwise managing our ongoing business relationship. We may collect this information to maintain a record of your consuming history preferences and tendencies to better serve you, to personalize an experience for you, and to meet other needs of offering, providing and maintaining an ongoing service relationship with you. We may collect your survey answers about events, products/services and more for quality assurance, product improvement, and to facilitate marketing that may be of interest to you. |
| Personal Information Category | Protected Classifications: characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information. |
| Purposes of Collection | We may collect this information where needed for a legal or financial document such as when we collect your marital status for a loan application.
We may collect this information where needed for a reservation, such as where we may need your gender to report to the airlines. We may also collect this information like gender to address you with the proper salutation. We may collect this information to provide you with the proper accommodations or assistance such as when you notify of us health related accommodations you require related to a reservation. We may collect additional information in this category as appropriate. |
| Personal Information Category | Biometric Information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
| Purposes of Collection | We may collect biometric information in order for you to access portions of a resort or property or to assist in a law enforcement investigation. |
| Personal Information Category | Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any company device, network or other information resource. |
| Purposes of Collection | We may collect this information to improve our website functionality, improve transaction throughput, and personalize your experience. We may collect this information to determine what interests you to facilitate targeted communications of products and services to you. We may collect this information to judge the effectiveness of any online marketing campaigns. |
| Personal Information Category | Geolocation Data: Precise geographic location information about a particular individual or device. |
| Purposes of Collection | We may collect your postal address, the location associated with the device used of your internet activity in order to create demographic analysis of visits to our site and promote interests in our products to better market to and understand our customers.
We may collect this information because of differences in jurisdictional laws to be sure we are compliant in our presentation of content. |
| Personal Information Category | Audio/Visual Data: audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV images and photographs, and audio recordings (e.g., recorded meetings). |
| Purposes of Collection | We may collect this information for quality assurance of product/service presentations or communications, when you pose for videos/photos or provide audios at our resorts or to us in any manner in order to improve our products and services, when you participate in activities or excursions or attend other events as part of service delivery.
We may collect this information in public areas of our facilities and online to provide safe and secure facilities and to ensure quality assurance. |
| Personal Information Category | Employment History: professional or employment-related information. |
| Purposes of Collection | We may collect details of your employment history such as job title and length of time at your employment to process a loan application. We may collect employment history as part of a larger analysis of you and what products/services would be well suited for you. We may collect details of your employment history as part of your credentials if you run for an elected position within the association of your vacation ownership property. |
| Personal Information Category | Education Information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). |
| Purposes of Collection | For example, we may collect this information in order to process a loan, in order to match your potential interest and likelihood of purchasing certain products/services, and as part of any office election you may run for as a candidate related to an HOA. |
| Personal Information Category | Profiles and Inferences: inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
| Purposes of Collection | For example, we may infer what products or services may interest you, your predicted attachment to your purchased products, your likelihood of purchasing other products, your likelihood of exacting contract and loan terms, and more. We may demographic information about you such as your age, income, etc.
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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:
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 International Limited, Wyndham Destinations International Limited Singapore Branch, Wyndham Destinations (Singapore) Pte. Ltd., Wyndham Vacation Resorts (Thailand) Ltd, Wyndham Services Asia Pacific (Philippines) Inc, PT Wyndham Hotel Management, Wyndham Destinations Consulting (Shanghai) Limited, Wyndham Destinations Japan Ltd. and any entities within the Wyndham Destinations, Inc. group of companies.
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