RCI, LLC 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 information we collect through our
websites (“Websites”), social media
pages we control (“Social Media Pages”),
and software applications we make available for use on or through computers and
mobile devices (“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 phone via our call
centers or in person (“Offline
Activities”) (collectively, including the Websites, Apps, Social Media
Pages, and Offline Activities, the “Services”).
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?
1. We may collect “Personal Information” (information that identifies you or relates to you as an identifiable person) about you such as your:
- Postal address (including billing and shipping addresses)
- Phone number
- Email address
- Credit or debit card number
- Financial information
- Social media account information
- Stay, trip, product, service or related information, such as your preferred location/facilities, dates and number of people/children travelling with you
- Special needs or conditions that may impact your stay
- Driver’s license, government-issued ID, or passports
- Geolocation information
- Communication, product, service or other preferences
- Demographic information
- IP address or Device ID
- Subscribing Membership ID
2. We may collect information from you when you interact with us such as when you:
- Register for, use, or make a payment for a product or service
- Contact us with a question or request
- Use our Services
- Make a reservation
- Stay at one of our affiliated resorts
- Provide a testimonial or story, or post or submit a photo, review or comment
- Participate in a competition, promotional activity or sweepstakes
- Participate in any loyalty or other programs
- “Like”, “Follow” or otherwise connect with or post to one of our Social Media Pages
3. 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.
- One purpose of cookies is to simplify the use of the Website. For example, cookies may save a user’s login details, so that they do not need to login every time.
- Cookies may be either “persistent” or “temporary” (or “session”) cookies. A persistent cookie retains user preferences for a particular Website allowing those preferences to be used in future browsing sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies are also used for statistical or marketing purposes, to determine how the Website is used. These cookies are provided by us or by third parties (e.g., advertising partners). While we do not control or have access to the advertiser cookies we do permit them to be used on this Website to facilitate tailored advertising and monitor patterns of buying specific goods or interest in - for example, holidays or hobbies. These cookies run advertisements tailored to the user based on his online buying habits.
- Pixels, Beacons: We or third party ad servers,
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
- 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 as described above). 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 visitwww.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
addition to any Personal Information or other information 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 website 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 website
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 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:
1. Our business transactions with you, including, but not limited to:
- Entering into or performing a contract with you.
- Responding to your inquiries and fulfilling your requests.
- Sending administrative information to you, for example, information regarding the Services or an event you are attending.
- Completing and fulfilling any purchases or requests for services.
2. For our legitimate business interests, including, but not limited to:
- Personalizing your experience on the Services by presenting products and offers tailored to you.
- Allowing you to participate in sweepstakes, contests, and similar promotions, and administering such activities (each of which may have additional rules and could contain additional information about how we Process your Personal Information).
- Facilitating social sharing functionalities of your social media account(s).
- Subject to your marketing preferences (which may include consent to marketing under applicable law), to send you newsletters or marketing communications we believe may interest you, for our own products and services, and on behalf of our Affiliates or selected third parties, via postal mail, email, phone or text messaging.
3. In accordance with any consent you may have provided.You have the right to decline to provide your consent and, if consent is provided, to withdraw it at any time.
4. As necessary or appropriate for legal reasons, including, but not limited to:
- Under applicable law.
- Complying with legal process.
- Responding to requests from public and government authorities, including those outside your country of residence.
- Enforcing our terms and conditions.
- Protecting our operations or those of any of our Affiliates, RCI affiliated resorts or other third parties.
- Protecting our rights, privacy, safety or property, or that of our Affiliates, RCI affiliated resorts, you, or other third parties.
- Allowing us to pursue available remedies or limit damages we, our Affiliates, RCI affiliated resorts or other third parties, may sustain.
- When We Disclose Your Information
We may disclose your information as follows:
- Affiliates: We may disclose your personal
information to any other entity that is,at the time you disclose your Personal Information, directly or indirectly
controlled by, or under common control with us (“Affiliates”) for the purposes described in this Privacy Notice,
including under “Why and How We Use Your
Information”, unless otherwise prohibited by applicable law. You can find
more information about our primary operating Affiliates in our Annual Report as
of the date the Annual Report was published or by contacting us at the contact
information set forth below in the section titled “How Can You Contact Us?”.
- Vendors and Service Providers: We may disclose your personal information to
vendors and service providers we retain in connection with our business such
as: travel services companies, financial services companies, property owners’
associations, vacation insurance companies, website hosting, data analysis,
payment processing, order fulfillment, information technology and related
infrastructure provision, customer service, email delivery, credit card
processing, tax and financial advisers, legal advisers, accountants, auditing services or others.
- Business Partners, Sponsors, and Other Third Parties: We may disclose your Personal
Information to business partners, co-sponsors of promotions, and other third
parties in order to provide you with services that may interest you. For
example, we may share your Personal Information with the owners and operators
of affiliated and unaffiliated hotels and resorts, airlines,
car rental services, retail stores, credit agencies and other third parties to
facilitate reservations, to offer you products or services, or in connection
with any loyalty program we may provide or a loyalty program of one of our
partners. We may also co-sponsor promotions, sweepstakes, or other events with
a third party and may share your Personal Information in connection with these
events. Further, we may share your Personal Information with third party
providers located on-site at hotels or resorts, such as time-share, spa, golf,
concierge, and dining providers. If you provide additional information to any
of these third parties, such information will be subject to such third parties’
or Business Partners: We may share Personal
Information with RCI affiliated resort owners and operators in order to provide
you with services, facilitate a booking you requested, generate leads in
connection with their offers to sell timeshares to you, to facilitate their
understanding of their owners’ exchange history and utilization, or to respond
to your inquiry for further information about mini-vacations at resorts where a
resort tour is either required or requested of you by the resort owner or
- Message Boards: We may make reviews, message
boards, blogs, and other such user-generated content facilities available to
users. Any information disclosed in these areas becomes public information and
you should always be careful when deciding to disclose your Personal
Information. We are not responsible for privacy practices of other users
including website operators to whom you provide information.
- Merger or Acquisition: We may disclose your Personal
Information to a third party who acquires any part of our business or the
business of any of our Affiliates, whether such acquisition is by way of
merger, consolidation, divestiture, spin-off, or purchase of all or a substantial
portion of our assets.
- Disclosure Permitted by Law: We may disclose your Personal Information to law
enforcement authorities, government or public agencies or officials,
regulators, and/or to any other person or entity having appropriate legal
authority or justification for receipt of your information, if required or
permitted to do so by law or legal process, to respond to claims, or to protect
our rights, interests, privacy, property or safety, and/or that of our
Affiliates, you or other third parties.
How Do We Safeguard 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.
Other Important Information
- Information Provided on Someone
Else’s Behalf: If
you provide us with information about someone else, please ensure you have the
person’s permission to do so for the purposes detailed in this Privacy Notice.
- Links to Websites: The Services may have links to other
websites that are not operated by us; we have no control over how these
websites may collect your information and no liability for the practices,
policies and security measures implemented on these websites. You should read
the privacy notices on those other websites before you submit your information
- Social Media Sites: Please note that we are not
responsible for the collection, usage and disclosure policies and practices
(including data security) of other organizations, such as Facebook, Apple,
Google, Microsoft, RIM or any other app developer, app provider, social media
platform provider, operating system provider, wireless service provider or
device manufacturer, including any Personal Information you disclose to other
organizations through or in connection with the Apps or our Social Media Pages.
- Changes to Our Privacy Notice: From time to time we may revise this
Privacy Notice and/or use Personal Information for new, unanticipated uses not
previously disclosed to meet changes in the regulatory or business environment,
or to satisfy the needs of our customers and service providers. Updated and
date stamped versions will be posted on the Services. Unless otherwise required
under applicable law (e.g. obtaining consent from you for the relevant material
changes) the revised Privacy Notice will take effect immediately upon such
- Minors: We do not knowingly collect,
maintain or use Personal Information from individuals under 18 years of age in
connection with, and no part of our Websites, Social Media Pages, and Apps is
directed to, individuals under the age of 18.
If we do incidentally collect or maintain Personal Information from
individuals under 18 years of age, you may request deletion of such information
by contacting us as set forth under “How
Can You Contact Us?” below.
- International Transfers: We are an international company and
we may, subject to applicable law, transfer your information, to our Affiliates
or selected third parties outside the country where you are located and where
information protection standards may differ (e.g., your information may be
stored on servers located in other jurisdictions). We will utilize appropriate
safeguards governing the transfer and usage of your Personal Information, such
as an adequacy decision by the European Commission, Model Clauses or other
applicable adequacy mechanisms. If you would like further detail on the
safeguards we have in place you can contact us directly as set forth in “How Can You Contact Us” below.
- 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
Your Choices and Rights
- Changes to Your Marketing
Preferences: You can
opt-out from receiving future marketing communications from us at any time by:
- Using the unsubscribe function in the email you receive from us; or
- Contacting us as set forth under “How Can You Contact Us?” below.
- Withdrawing Your Consent: You may withdraw any consent you
have provided to us to Process your information at any time.
- Accessing your Information: In accordance with applicable law,
you may access the Personal Information we Process about you.
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.
- Correcting your Information: We will take reasonable steps to ensure the accuracy of the
Personal Information we retain about you. It is your responsibility to ensure
you submit true, accurate, and complete information to us, and timely update us
in the event this information changes. You may request that any inaccurate or
incomplete Personal Information held by us or on our behalf is corrected, by
contacting us as set forth under “How
Can You Contact Us?” below.
- Deleting your Information: Under certain circumstances, you
may request we delete Personal Information we hold about you by contacting us
as set forth under “How Can You Contact
Us?” below. We will assess your request and determine, under applicable
law, whether we are required to delete this information.
- Objecting to Processing: If you would like us to stop
Processing your Personal Information, you can request this by contacting us as
set forth under “How Can You Contact Us?”
below. We will assess your request and determine, under applicable law, whether
we have any justification for the continued Processing.
- Transferring your Information: Under certain circumstances, you
may receive your Personal Information in a format that allows you to send it to
another company or to direct us to transfer it directly to another company.
Notice to California Residents: Your California Privacy Rights
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.
Notice to Nevada Residents: Your Nevada Privacy Rights
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 firstname.lastname@example.org or send a letter to:
The Registry Collection
P.O. Box 2099
Carmel, IN 46032-2099
Attn: Legal - Privacy
How Can You Contact Us?
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 email@example.com or send a letter to:
The Registry Collection
P.O. Box 2099
Carmel, IN 46032-2099
Attn: Legal - Privacy
If you have a complaint or concern about how we Process your Personal Information, we will work to address such concern(s). You may also direct your complaint/concern to the applicable data protection authority.