What Information Is Collected and How Is It Collected?

Transcription

1 RCI PRIVACY NOTICE RCI Asia Pacific Singapre LLC, Singapre Branch is cncerned abut privacy issues and wants yu t be familiar with hw we cllect, use and disclse infrmatin. This Privacy Ntice describes ur practices in cnnectin with infrmatin we cllect thrugh: websites we perate frm which yu are accessing this Privacy Ntice (the Websites ), any sftware applicatins we make available fr use n r thrugh cmputers and mbile devices (the Apps ), and scial media pages we cntrl frm which yu are accessing this Privacy Ntice (ur Scial Media Pages ), (cllectively, including the Websites, Apps and Scial Media Pages, the Services ). This Privacy Ntice als applies t ur ffline cllectin f infrmatin. The infrmatin yu prvide helps us perate effectively and prvide yu with premium hspitality prducts, services and experiences. Our privacy practices may vary amng the cuntries in which we perate t reflect lcal practices and legal requirements. Please read the fllwing t learn mre abut ur privacy practices. Yur Acceptance f Our Privacy Ntice: By using the Services, yu accept the terms f this Privacy Ntice and the ways we may use yur infrmatin. If yu d nt accept this Ntice s terms, please d nt cntinue t use the Services. What Infrmatin Is Cllected and Hw Is It Cllected? 1. We may cllect persnal infrmatin (infrmatin that identifies yu r relates t yu as an identifiable persn) abut yu such as yur: Name Pstal address (including billing and shipping addresses) Telephne number address Credit r debit card number Financial infrmatin Stay, trip, prduct, service r related infrmatin Cmmunicatin, prduct, service r ther custmer preferences Subscribing membership ID Scial media accunt ID r prfile picture Special needs r cnditins that may impact yur stay Demgraphic infrmatin IP address We may cllect infrmatin frm yu when yu interact with us such as when yu: Register fr a prduct r service Cntact us with a questin r request, including by use f any Website chat features Use ur Services Make a payment fr a prduct r service Stay at ne f ur affiliated resrts Prvide a testimnial r stry, r submit a review r cmment Participate in a cmpetitin, prmtinal activity r sweepstakes Participate in any lyalty r ther prgrams Like, Fllw r therwise cnnect with r pst t ne f ur Scial Media Pages Prvide services t us (fr example, as a vendr r cntractr) 2. Other Infrmatin We Cllect abut yu: Ckies: This Website uses ckies. By using this Website and agreeing t this Ntice, yu cnsent t ur use f ckies in accrdance with this Ntice s terms. Ckies are small text files this Website sends t yur cmputer fr recrd-keeping purpses and this infrmatin is stred in a file n yur cmputer s hard drive. Ckies make web surfing and brwsing easier fr yu by saving yur preferences s we can use them t imprve yur next visit t this Website. One purpse f ckies is t simplify the use f the Website. A ckie may save a user s lgin details fr example, s the user des nt need t lgin every time. Ckies, by themselves, d nt prvide us with yur persnal infrmatin. 1

2 Ckies may be either persistent r temprary (r sessin ) ckies. A persistent ckie retains user preferences fr a particular Website allwing them t be used in future brwsing sessins and remains valid until its set expiry date (unless previusly deleted by the user). A temprary ckie expires at the end f the user sessin, when the web brwser is clsed. Ckies are als used fr statistical r marketing purpses, t determine hw the Website is used. These ckies may be prvided by us as well as third parties (e.g., advertising partners). While we d nt cntrl r have access t any advertiser ckies, we may permit their ckies t be used n this Website t facilitate tailred advertising and t mnitr patterns f buying specific gds r interest in - fr example, hlidays r hbbies. These ckies run advertisements tailred t the user based n their nline buying habits. Pixels, Beacns: We r third party ad servers may use invisible pixels r beacns n this Website t cunt hw many users visit certain pages. This infrmatin is cllected and reprted in the aggregate. We may use this infrmatin t imprve ur marketing prgrams and cntent, and t target advertisements at this Website and/r n ther sites. Frm Other Surces: We may receive yur persnal infrmatin frm ther surces, such as public databases; jint marketing partners; data firms; scial media platfrms; frm peple with whm yu are friends r therwise cnnected n scial media platfrms, as well as frm ther third parties. Mbile Devices: When yu use r access ur Services frm a mbile device, we may cllect infrmatin such as yur unique device ID and yur lcatin infrmatin. If yu dwnlad and use an App, we and ur service prviders may track and cllect App usage data, such as the date and time the App n yur device accesses ur servers and what infrmatin and files have been dwnladed t the App based n yur device number, as well as any ther persnal infrmatin specified by the App in its terms r ntices. Hw D We Use Yur Infrmatin? The infrmatin we cllect frm yu helps us identify ways we can cntinue t serve yu in the best way pssible and prvide yu with persnalized prducts and services that suit yur lifestyle. We use persnal infrmatin fr the fllwing purpses: T respnd t yur inquiries and fulfill yur requests, such as t send yu newsletters. T send administrative infrmatin t yu, fr example, infrmatin regarding the Services r an event yu are attending and material changes t ur terms, cnditins, and plicies. T cmplete and fulfill any transactins r requests fr services, fr example, t prcess yur payments r cmmunicate with yu regarding yur transactins and prvide yu with related custmer service. T send yu marketing cmmunicatins we believe may interest yu via pstal mail, r phne. T persnalize yur experience n the Services by presenting prducts and ffers tailred t yu. T allw yu t participate in sweepstakes, cntests and similar prmtins and t administer these activities. Sme f these activities have additinal rules, which culd cntain additinal infrmatin abut hw we use and disclse yur Persnal Infrmatin, s we suggest that yu read these rules carefully. T facilitate scial sharing functinality. Fr ur business purpses, such as data analysis, audits, fraud mnitring and preventin, internal quality assurance, develping new prducts, enhancing, imprving r mdifying ur Services, identifying usage trends, auditing use and functinality f ur Services, helping enfrce cmpliance with ur Terms f Use, helping prtect ur Services, determining the effectiveness f ur prmtinal campaigns and perating and expanding ur business activities. As we believe t be necessary r apprpriate: (a) under applicable law, including laws utside yur cuntry f residence; (b) t cmply with legal prcess; (c) t respnd t requests frm public and gvernment authrities including public and gvernment authrities utside yur cuntry f residence; (d) t enfrce ur terms and cnditins; (e) t prtect ur peratins r thse f any f ur Wyndham Affiliates r RCI affiliated resrts; (f) t prtect ur rights, interests, privacy, safety r prperty, and/r that f ur Wyndham Affiliates r RCI affiliated resrts, yu r thers; and (g) t allw us t pursue available remedies r limit the damages that we may sustain. We may als aggregate and/r annymize persnal infrmatin fr research, t imprve ur prducts and services; and fr ther business purpses. Other than as described herein, RCI des nt: (1) sell r rent yur persnal infrmatin, (2) use yur persnal infrmatin t make decisins abut granting r extending cnsumer credit unless yu submit a separate credit applicatin and authrize us t use r disclse yur infrmatin; r (3) use yur persnal infrmatin t act as a cnsumer 2

3 reprting agency r furnish infrmatin abut yur credit wrthiness, credit standing, credit capacity, character, general reputatin, persnal characteristics r mde f living t any cnsumer reprting agency. Hw D We Disclse Yur Infrmatin? Yur infrmatin may be disclsed as fllws: Affiliates: T ther Wyndham businesses (ur Affiliates ) which may jintly use the persnal infrmatin fr the purpses described in this Privacy Ntice. A list f ur primary Affiliates can be fund in Wyndham s current Frm 10-K. Resrts r Business Partners: We may share persnal infrmatin with the wners and peratrs f RCI affiliated resrts in rder t prvide yu with services, facilitate a bking yu requested, generate leads in cnnectin with their ffers t sell timeshares t yu, t facilitate their understanding f their wners exchange histry and utilizatin, r t respnd t yur inquiry fr further infrmatin abut mini-vacatins at resrts where a resrt tur is either required r requested f yu by the wner r peratr f the resrt. We may disclse yur infrmatin t business partners, spnsrs r ther third parties in cnnectin with administering prmtins, sweepstakes r similar activities. Yu may be ffered an pprtunity t request additinal infrmatin, materials r ffers frm the spnsr r ther third party; shuld yu make such a request, we will prvide yur persnal infrmatin t the third party s that they can fulfill yur request. Vendrs and Service Prviders: We may disclse yur infrmatin t vendrs and service prviders we retain in cnnectin with ur business such as: travel services cmpanies, financial services cmpanies, prperty wners assciatins, vacatin insurance cmpanies, website hsting, data analysis, payment prcessing, rder fulfillment, infrmatin technlgy and related infrastructure prvisin, custmer service, delivery, credit card prcessing, tax and financial advisers, legal advisers, accuntants r auditing services. Message Bards: We may make reviews, message bards, blgs, and ther such user-generated cntent facilities available t users. Any infrmatin disclsed in these areas becmes public infrmatin and yu shuld always be careful when deciding t disclse yur persnal infrmatin. We are nt respnsible fr privacy practices f ther users including website peratrs t whm yu prvide infrmatin. Merger r Acquisitin: A third party wh acquires any part f Wyndham Wrldwide Crpratin itself r any f its Affiliates, whether such acquisitin is by way f merger, cnslidatin r purchase f all r a substantial prtin f ur assets. Disclsure Permitted by Law: We may disclse yur persnal infrmatin t law enfrcement authrities, gvernment r public agencies r fficials, regulatrs, and/r t any ther persn r entity having apprpriate legal authrity r justificatin fr receipt f yur infrmatin, if we believe that we are required r permitted t d s by law r legal prcess, t respnd t claims, r t prtect ur rights, interests, privacy, prperty r safety, and/r that f ur Wyndham r RCI affiliated resrts, yu r thers. Annymized/Aggregated Infrmatin: Because aggregated r annymized infrmatin des nt persnally identify yu, we may use it fr any purpse. If we cmbine annymized r aggregated data with persnal infrmatin, we will treat the cmbined infrmatin as persnal infrmatin accrding t this Privacy Ntice. Hw D We Safeguard Yur Infrmatin? Security f Yur Infrmatin: We will take reasnable steps t prtect the infrmatin yu prvide us frm lss, misuse and unauthrized access, disclsure, alteratin and destructin. We have implemented apprpriate physical, electrnic and managerial prcedures t help safeguard and secure yur infrmatin frm lss, misuse, unauthrized access r disclsure, alteratin r destructin. Unfrtunately, n security system is 100% secure, thus we cannt ensure the security f infrmatin yu prvide t us via the Services. 3

4 Other Imprtant Infrmatin Infrmatin Prvided n Smene Else s Behalf: If yu prvide us with infrmatin abut smene else, please ensure yu have the persn s permissin t d s fr the purpses detailed in this Privacy Ntice. Links t Websites: The Services may have links t ther websites nt perated by us; we have n cntrl ver hw these websites may cllect yur infrmatin and n respnsibility r liability fr the practices, plicies and security measures implemented n these websites. Yu shuld read the privacy ntices n thse ther websites befre yu submit yur infrmatin thrugh them. Scial Media Sites: Please nte that we are nt respnsible fr the cllectin, usage and disclsure plicies and practices (including data security) f ther rganizatins, such as Facebk, Apple, Ggle, Micrsft, RIM r any ther app develper, app prvider, scial media platfrm prvider, perating system prvider, wireless service prvider r device manufacturer, including any persnal infrmatin yu disclse t ther rganizatins thrugh r in cnnectin with the Apps r ur Scial Media Pages. Changes t Our Privacy Ntice: Frm time t time we may revise this Ntice and/r use persnal infrmatin fr new, unanticipated uses nt previusly disclsed herein t meet changes in the regulatry r business envirnment, r t satisfy the needs f ur custmers and service prviders. Updated and date stamped versins will be psted n the Services. Minrs: We d nt knwingly cllect, maintain r use persnal infrmatin frm children under 18 years f age, and n part f Services is directed t individuals under the age f 18. Internatinal Transfers: We are an internatinal cmpany and we may, subject t applicable law, transfer yur infrmatin t ur Affiliates r selected third parties where infrmatin prtectin standards may differ. Fr example, yur infrmatin may be stred n servers lcated in ther jurisdictins. We will take steps t help prtect yur infrmatin when it is transferred. Our U.S. entities cmply with the EU-US and Swiss-US Safe Harbr privacy framewrks regarding persnal infrmatin transferred frm Affiliates and ther rganizatins in the Eurpean Ecnmic Area r Switzerland t the U.S. Please click here t view ur RCI U.S. Safe Harbr Custmer and Supplier Privacy Ntice. Retentin Perid. We will retain yur persnal infrmatin fr the perid necessary t fulfill the purpses utlined in this Privacy Ntice unless a lnger retentin perid is required r permitted by law. Chices and Cntact Us With Yur Questins Marketing: We may cntact yu by , phne r pstal mail with infrmatin abut prducts r services ffered by RCI r a third party that may be f interest t yu. Yu can pt-ut at any time by: Using the unsubscribe functin in the yu receive frm us; r Cntacting us at asiamembers@rci.cm if yu d nt wish t receive further direct marketing frm us abut Wyndham prducts r services. D Nt Track Brwser Settings: At this time, we d nt respnd t brwser d nt track signals, as we await the wrk f interested stakehlders and thers t develp standards fr hw such signals shuld be interpreted. Third parties, including ur service prviders, may cllect infrmatin abut yur nline activities ver time and acrss different websites, including when yu visit ur Website. Yu can learn abut hw t exercise chice regarding the cllectin f infrmatin abut yur nline activities ver time and acrss third-party websites r nline services by visiting and Access t Infrmatin We Hld abut Yu: If yu wuld like t access, btain cpies, update, crrect r request that we suppress r delete any f the infrmatin we hld abut yu r if yu require further infrmatin frm us abut hw we use yur infrmatin please cntact us at asiamembers@rci.cm. In sme jurisdictins, yu may be charged a reasnable fee fr access t yur infrmatin. 4

5 Cntact Infrmatin If after reviewing this Ntice, yu have any questins r privacy cncerns please send an t asiamembers@rci.cm r send a letter t: RCI Asia Pacific Singapre LLC, Singapre Branch 223 Muntbatten Rad #03 11 Singapre Attn: Legal Privacy Ntice t Califrnia Residents If yu are a resident f Califrnia, Califrnia Civil Cde Sectin allws yu t request infrmatin regarding the disclsure f yur persnal infrmatin by us t third parties fr the third parties direct marketing purpses. With respect t these entities, this Ntice applies nly t their activities within the State f Califrnia. T make such a request, please cntact us at asiamembers@rci.cm. Effective Date: April 24, 2015 Last Updated Date: April 24,