Introduction
VacationVIP LLC, its affiliates and subsidiaries ("Company," "We," “Us,” and “Our”) respects your privacy and are committed to protecting it through our
compliance with this policy. This policy describes the types of information we
may collect from you or that you may provide when you visit the website (our
"Website") or social media sites we control and our practices
for collecting, using, maintaining, protecting, and disclosing that
information.
This policy applies to information we collect:
- On or through this Website.
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Over the phone, email, text, and other electronic messages between you and
Us.
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Through mobile and desktop applications you download from this Website,
which provide dedicated non-browser-based interaction between you and this
Website.
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When you interact with our advertising and applications on third-party
websites and services, if those applications or advertising include links to
this Website.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Please read this policy carefully to understand our policies and practices
regarding your information and how we will treat it. If you do not agree with
our policies and practices, your choice is to not use our Website. By
accessing or using this Website, you agree to this privacy policy. This policy
may change from time to time (see Changes to Our Privacy Policy). Your
continued use of this Website after we make changes is deemed to be acceptance
of those changes, so please check the policy periodically for updates.
We collect several types of information from and about users of our
Website, including the following categories of information:
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Purchasing Information. This is information that we may
collect about your transactions in our stores, on our websites or via our
mobile applications including what products you purchase, how frequently you
purchase them, any rewards or promotions associated with a purchase.
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Personal Information. This is information by which you may
be personally identified, through your account with us or otherwise, such as
name, postal address, e-mail address, telephone number, address, or any
other identifier by which you may be contacted online or offline (“Personal
Data”). The collection of such personal information is necessary for Us to
provide you with our services.
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Device and Usage Information. This is information about
your internet connection (ISP), IP address, device and mobile ad
identifiers, the website that referred you to our website, the subject of
the ads you click or scroll over, Cookies, Analytics, the equipment you use
to access our Website and usage details. To collect this information, we use
automatic data collection cookies, web beacons and similar technologies.
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Location information. This is information about the
location of your device, including GPS location, for purposes of enhancing
or facilitating our services, such as enabling the functionality of our
websites or mobile applications that provide you with information about
offers near you, enabling you to remotely order and pay for our products and
services, or have certain products delivered by a third-party vendor. If you
want to opt out of the collection of this location information, please see
the section below titled Choices on How We Use and Disclose Your Information
or by contacting us as detailed under Contact Information.
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Public information. Some information we gather is publicly
available. We may also gather information about you from third-parties and
other companies.
We collect this information:
- Directly from you when you provide it to us.
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Some information such as your internet connection and equipment you use to
access our Website and usage details is automatically collected as you
navigate through the site. Information collected automatically may include
usage details, IP addresses, location and information collected through
cookies and other tracking technologies.
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We use third party analytics providers and products, such as Google
Analytics, to obtain, compile and analyze information about how users are
using and interacting with the Website. In order to collect this
information, such providers may set cookies on your browser or mobile device
or read cookies that are already there. Google Analytics may also receive
information about you from apps you have downloaded, that partner with
Google. We do not combine the information collected through the use of
Google Analytics with personally identifiable information. You can control
the information provided to Google and opt out of certain ads provided by
Google by using one of the of the methods set forth in
https://www.google.com/policies/privacy/partners/
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From third parties, for example, our business partners, affiliates and
agents.
Information You Provide to Us. The information we collect on
or through our Website may include:
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Certain general data and Personal Data (“Personal Data”) that identifies our
customers, that you provide or give us in another way. This may include your
first and last name, postal address, telephone number, email address, date
of birth, citizenship, and passport details, and if you make a purchase,
your credit/debit card details in order to make a payment and confirm the
purchase.
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Information that you provide by filling in forms on our Website. This
includes information provided at the time of registering to use our Website,
subscribing to our service, posting material, or requesting further
services. We may also ask you for information when you enter a contest or
promotion sponsored by us, and when you report a problem with our Website.
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Records and copies of your correspondence including email addresses, if you
contact us.
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Your responses to surveys that we might ask you to complete for research
purposes.
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Details of transactions you carry out through our Website and of the
fulfillment of your travel and purchases. You may be required to provide
financial information including credit or debit card information before
placing an order through our Website.
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Your search queries or preferences through use of the Website, including the
election to share location information with us and our website applications.
You also may provide information, or comments, or photographs to be published
or displayed (hereinafter, "posted") on public areas of the
Website or transmitted to other users of the Website or third parties
(collectively, "User Contributions"). Your User Contributions
are posted on and transmitted to others at your own risk. Although we limit
access to certain pages/you may set certain privacy settings for such
information by logging into your account profile, please be aware that no
security measures are perfect or impenetrable. Additionally, we cannot control
the actions of other users of the Website with whom you may choose to share
your User Contributions. Therefore, we cannot and do not guarantee that your
User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection
Technologies.
As you navigate through and interact with our Website, we may use automatic
data collection technologies to collect certain information about your
equipment, browsing actions, and patterns, including:
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Details of your visits to our Website, including traffic data, logs, and
other communication data and the resources that you access and use on the
Website.
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Information about your computer and internet connection, including your IP
address, operating system, and browser type.
The information we collect automatically is statistical data and does not
include personal information, but we may maintain it or associate it with
personal information we collect in other ways or receive from third parties.
It helps us to improve our Website and to deliver a better and more
personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
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Store information about your preferences, allowing us to customize our
Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
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Cookies (or browser cookies). A cookie is a small file
placed on the hard drive of your computer. You may refuse to accept browser
cookies by activating the appropriate setting on your browser. However, if
you select this setting you may be unable to access certain parts of our
Website. Unless you have adjusted your browser setting so that it will
refuse cookies, our system will issue cookies when you direct your browser
to our Website.
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Flash Cookies. Certain features of our Website may use
local stored objects (or Flash cookies) to collect and store information
about your preferences and navigation to, from, and on our Website. Flash
cookies are not managed by the same browser settings as are used for browser
cookies. Information on how to disable or remove flash cookies can be found
below under the section titled Choices on How We Use and Disclose Your
Information.
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Web Beacons. Pages of the Website and our e-mails may
contain small electronic files known as web beacons (also referred to as
clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for
example, to count users who have visited those pages or opened an email and
for other related website statistics (for example, recording the popularity
of certain website content and verifying system and server integrity).
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Java Scripts. Java scripts are code snippets embedded in
various parts of websites and applications that facilitate a variety of
operations including accelerating the refresh speed of certain functionality
or monitoring usage of various online components.
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Entity Tags. Entity Tags are HTTP code mechanisms that
allow portions of websites to be stored or “cached" within your browser and
validates these caches when the website is opened, accelerating website
performance since the web server does not need to send a full response if
the content has not changed.
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HTML5 Local Storage. HTML5 local storage allows data from
websites to be stored or “cached" within your browser to store and retrieve
data in HTML5 pages when the website is revisited.
We do not collect personal information automatically through the above
technologies, but we may tie this information gathered to personal information
about you that we collect from other sources or you provide to us.
THIRD PARTY COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications, including advertisements, on the Website are
served by third-parties, including advertisers, ad networks and servers,
content providers, and application providers. These third parties may use
cookies alone or in conjunction with web beacons or other tracking
technologies to collect information about you when you use our website. The
information they collect may be associated with your personal information or
they may collect information, including personal information, about your
online activities over time and across different websites and other online
services. They may use this information to provide you with interest-based
(behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may
be used. If you have any questions about an advertisement or other targeted
content, you should contact the responsible provider directly.
HOW WE USE YOUR INFORMATION AND LEGAL BASES FOR PROCESSING
We only process your information where it is necessary for:
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our legitimate interests to establish and manage our relationship with you,
for administrative purposes, and other legitimate business interests such as
credit assessment, marketing, presenting and improving our website;
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fulfilling our contractual obligations towards you (e.g., sending
confirmations, invoices, and travel documentation to you), our affiliated or
related entities, associates, partners, and the customers of such affiliated
or related entities, associates and partners; and
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compliance with applicable laws and regulations and our legal obligations,
such as accounting and tax requirements.
There may be occasions where we request your consent to process your personal
data. Where applicable, you may withdraw consent subsequently at any time by
contacting us as detailed under Contact Information, below,
without affecting the lawfulness of processing based on consent before its
withdrawal. For example, we may use your information to contact you about our
own and third-parties' goods and services that may be of interest to you. We
may use the information we have collected from you to enable us to display
advertisements to our advertisers' target audiences. Even though we do not
disclose your personal information for these purposes without your consent, if
you click on or otherwise interact with an advertisement, the advertiser may
assume that you meet its target criteria. Information on how to opt-out of
interest-based advertising can be found under the section titled Choices on
How We Use and Disclose Your Information or by contacting us as detailed under
Contact Information.
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that
does not identify any individual, without restriction. We may disclose
personal information that we collect or you provide as described above (How We
Use Your Information and Legal bases for Processing) to the following:
- To our subsidiaries and affiliates.
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To contractors, service providers, and other third parties we use to support
our business and who are bound by contractual obligations to keep personal
information confidential and use it only for the purposes for which we
disclose it to them.
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To a buyer or other successor in the event of a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of
some or all of VVIP's stock or assets, whether as a going concern or as part
of bankruptcy, liquidation, or similar proceeding, in which personal
information held by VVIP about our Website users is among the assets
transferred.
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To third parties, including but not limited to suppliers, third-party
vendors, business partners, and corporate affiliates for the same legitimate
purposes as detailed above.
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To fulfill the purpose for which you provide it. For example, if you give us
an email address to use the "email a friend" feature of our Website, we will
transmit the contents of that email and your email address to the
recipients.
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For any other purpose disclosed by us when you provide the information, with
your consent, as applicable.
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To comply with any court order, law, or legal process, including to respond
to any government or regulatory request. When the disclosure of such
personal information is required to be made to a governmental or regulatory
agency, we will ensure that such personal information will only be shared
with the relevant governmental or regulatory agency and not released to the
general public. However, you will hold Us harmless if the personal
information is disclosed by the governmental or regulatory agency to any
third party or the public.
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To enforce or apply our terms of use of or terms and conditions posted on
the Website and other agreements, including for billing and collection
purposes.
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If we believe disclosure is necessary or appropriate to protect the rights,
property, or safety of VVIP, our customers, or others. This includes
exchanging information with other companies and organizations for the
purposes of fraud protection and credit risk reduction.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you
provide to us. Below are some of the mechanisms available to change control
over your information automatically provided when visiting the Website:
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Tracking Technologies and Advertising. You can set your
browser to refuse all or some browser cookies, or to alert you when cookies
are being sent. To learn how you can manage your Flash cookie settings,
visit the Flash player settings page on Adobe's
website. If you disable or refuse cookies, please note that some parts of this
site may then be inaccessible or not function properly.
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Google Analytics. You can control the information provided
to Google and opt out of certain ads provided by Google by using one the of
the methods set forth in
https://www.google.com/policies/privacy/partners/
or use the Google Analytics opt out browser add-on at
https://tools.google.com/dlpage/gaoptout?hl=en.
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Cookies; Web Beacons; Entity Tags; and HTML5 Local Storage; and other
similar technologies.
Persistent cookies can be removed by following your web browser’s
directions. A session cookie is temporary and disappears after you close
your browser. You can reset your web browser to refuse all cookies or to
indicate when a cookie is being sent. However, some features of the Site may
not function properly if the ability to accept cookies is disabled. Turning
off the browser's cookies will prevent web beacons from tracking your
specific activity. The web beacon may still record an anonymous visit from
your IP address, but unique information will not be recorded. If you do not
want to receive tracking pixels, you will need to disable HTML images in
your email client, and that may affect your ability to view images in other
emails that you receive. Each browser is different, but many common browsers
(Internet Explorer, Chrome, Firefox, and Safari) have preferences or options
that may be adjusted to allow you to either accept or reject cookies and
certain other technologies before they are set or installed or allow you to
remove or reject the use or installation of certain technologies altogether.
To find out how to see what cookies have been set and how to reject and
delete the cookies, please visit: https://www.aboutcookies.org.
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Opting out of sharing location information. You may be able
to adjust the settings of your device so that information about your
physical location is not sent to us or third parties by (a) disabling
location services within the device settings; or (b) denying certain
websites or mobile applications permission to access location information by
changing the relevant preferences and permissions in your mobile device or
browser settings. Please note that your location may be derived from your
WiFi, Bluetooth, and other device settings. See your device settings for
more information
We do not control third parties' collection or use of your information to
serve interest-based advertising. However, these third parties may provide you
with ways to choose not to have your information collected or used in this
way. You can opt out of receiving targeted ads from members of the Digital
Advertising Alliance or the Network Advertising Initiative ("NAI") on the
NAI's website or by visiting
www.AboutAds.info.
INFORMATION SENT ABROAD
VVIP is a global organization and provides global services. In certain
circumstances, sharing data cross-border is essential to the services you
receive from Us.
I. Special Requirements under EU Data Protection Laws (GDPR):
In order to complete your booking, complete analysis, or for other legitimate
purposes we transfer, process and store information about you outside of the
EEA on servers located in the United States by VacationVIP LLC and its
affiliates located at 6675 Westwood Blvd, Suite 200, Orlando FL 32821.
Therefore, your information may be transferred to, stored, or processed in the
United States. We will ensure that in terms of Data Security Standards of our
systems in the US will have the same level of data protection that is adhered
to by Us. If we transfer your Personal Data to agencies or third parties
outside the EEA, we require similar, binding EU Standard Contractual Clauses,
and we monitor compliance with such. Our affiliated or related entities,
associates and partners have also agreed to adopt equivalent measures. Copies
of these measures can be obtained by contacting Us as detailed under Contact
Information below. You may lodge a complaint with the UK Information
Commissioner’s Office if you consider that our processing of your Personal
Data infringes applicable law.
II. Special Requirements under Mexican Data Protection Laws
In accordance with the requirements of the Mexican Federal Law on the
Protection of Personal Data Held by Private Parties ( Ley Federal de
Protección de Datos Personales en Posesión de los Particulares ) (the “Mexican
DP Law”), We inform our users and subscribers located in Mexico of Our
compliance with this Law. Under Mexican DP Law, we do not need to obtain your
consent for the processing of your personal data for the purposes that give
rise and are necessary for the fulfillment of our relationship (e.g. personal
information required in order for you to subscribe to our vacation programs).
In case you do not agree with the processing of your personal information for
such purposes and as described in this policy, please abstain from acquiring
or using our services.
Our Website users and subscribers located in Mexico should note that:
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The personal data provided by you to Us through email, fax, websites, online
services, enrollment or subscription forms and agreements, telephone calls
or any other means, is processed by Us for the purposes set forth in section
How We Use Your Information; in the understanding that, in order to comply
with the Mexican DP Law, below we have set forth those purposes that are not
required to fulfill the relationship between us, commonly known as
“additional or secondary purposes”:
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To provide you with updates about discounted availability, special offers,
new services and products which may be of interest to you and other
noteworthy news items.
- Send advertisements, promotions and brochures.
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To contact you about our and third parties’ goods and services that may be
of interest to you.
- To ask for ratings and reviews of services or products.
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Should you not wish that your personal information be used for the purposes
listed immediately above, please send an email to [email protected]
with subject line “Request for Restriction on the use of My Personal
Information for Secondary Purposes / Mexico”.
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That this privacy policy applies to all your personal information that We
may have access to, including: name, nationality, birthdate and birthplace,
age, address, telephone number, cell phone number, email, tax identification
number, handwritten signature, as well as personal information that may be
considered sensitive and related to recorded video or photographs, health
condition, economic and financial data, including your bank account
information and information of your credit or debit cards, as well as other
personal data listed in the section Information We Collect About You and How
We Collect It.
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As described above (see Information We Collect Through Automatic Data
Collection Technologies), We also collect information using various
technologies, such as cookies and web beacons.
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That your personal information will be solely treated in accordance with the
terms and conditions of this privacy policy.
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In order for you to: (i) exercise your rights to Access, Rectify, Cancel,
and Object to the use of your personal information (known as “ARCO Rights”),
and (ii) to limit the use and disclosure or to revoke your consent to the
use of your personal information for the secondary purposes described above,
please send an email to [email protected] with subject line “Exercise
of ARCO Rights / Mexico”. The request should include, as minimum:
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Copy of your official ID and/or of your legal representative. Such documents
should be scanned and attached to the corresponding email communication. For
legal representative, please also attach a copy of his/her
power-of-attorney.
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Clear and precise description of the personal information about which the
ARCO Rights are to be exercised, as well as the right or rights you wish to
exercise. This description could be included in the email cover letter or in
a document attached thereto, scanned and initialized in each of its pages.
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Expressly state your agreement to receive our response through an email
communication, specifying the corresponding email address.
- Any other data that allows US to locate your personal data.
We will issue a response within the following 20 business days after we
receive your request. Once you receive our response, you will have a 15
business day period to respond to our communication. In case you do not reply
to our response within the mentioned period, we will understand in good faith
that you agree with our response. We may refuse the exercise of your ARCO
Rights in the cases permitted by applicable law, and shall inform you about
such decision. The refusal may be partial, in which case We will carry out the
access, rectification, cancellation or objection in the corresponding part.
As mentioned below, you can also review and change your personal information
by logging into the Website and visiting your account profile page.
See the section Disclosure of Your Information for information regarding the
manner in which we share your personal information with third parties and
data-processors. Please note that we require your consent to transfer your
personal data to third parties to market their own products or services to
you.
Should you not wish that your personal data be transferred to third parties
for their own marketing purposes please send an email to
[email protected] with subject line “Request for Restriction on the
Transfer of Personal Data to Third Parties for their Own Marketing Purposes /
Mexico”.
This privacy policy may be modified as described in the section “Changes to
the Privacy Policy” set forth below.
YOUR RIGHTS TO ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your personal information by logging into the
Website and visiting your account profile page. You have the right to ask VVIP
not to process your Personal Data for marketing purposes. You also have the
right to access Personal Data about you by VVIP and to correct inaccurate
Personal Data. Please ensure that we have an up-to-date active and deliverable
email address for you. In accordance with applicable law, you may also have
the right to object to or request restriction of the processing of your
Personal Data and to request erasure and to port Personal Data about you.
Should you wish to exercise your rights, or to unsubscribe please contact
[email protected] or Attn: Privacy Policy Manager, VacationVIP, LLC at
6675 Westwood Blvd, Suite 200 Orlando, FL 32821 or via our toll-free number:
800-266-0602.
Access to your Personal Data will be granted in accordance with the
requirements of applicable national legislation. The information will be
forwarded to you within an appropriate period of time in accordance with
applicable law, and where any discrepancies are discovered following your
enquiry, we will take immediate steps to validate and, where appropriate,
correct our records.
RETENTION OF DATA
We will retain your personal information during the term of the provision of
the services availed by You only for so long as reasonably necessary for the
purposes set out herein, in accordance with applicable laws.
MARKETING CONSENT
Upon contacting VacationVIP, LLC. (VVIP) and providing PII such as your full
name, e-mail address, and/or contact number, You expressly authorize and
consent to receive autodialed and/or pre-recorded telemarketing calls, as well
text messages and emails, from or on behalf of Vacation VIP, LLC at the
telephone number(s) provided. You hereby understand that your permission
overrides your listing on any state, federal or company do not call list. You
also understand that your consent is not a condition of purchasing any good or
service. You agree to waive your rights under TCPA. You agree to receive
communication via SMS, email and telephone on an ongoing basis and understand
that you can opt-out of these communications at any time. You understand that
this means both marketing and informational communication. You understand that
message and data rates may apply to any communication via SMS.
CHILDREN UNDER THE AGE OF 16
Our Website is not intended for children under 16 years of age. No one under
age 16 may provide any personal information to Company or on the Website. We
do not knowingly collect personal information from children under 16. If you
are under 16, do not use or provide any information on this Website or on or
through any of its features/register on the Website, make any purchases
through the Website, use any of the interactive or public comment features of
this Website or provide any information about yourself to us, including your
name, address, telephone number, email address, or any screen name or user
name you may use. If we learn we have collected or received personal
information from a child under 16 without verification of parental consent, we
will delete that information. If you believe we might have any information
from or about a child under 16, please contact us as detailed under Contact
Information, below.
DATA SECURITY AND RETENTION
We have implemented measures designed to secure your personal information from
accidental loss and from unauthorized access, use, alteration, and disclosure.
All information you provide to us is stored on our secure servers behind
firewalls. Any payment transactions provided therewith will be encrypted.
The safety and security of your information also depends on you. Where we have
given you (or where you have chosen) a password for access to certain parts of
our Website, you are responsible for keeping this password confidential. We
ask you not to share your password with anyone. We urge you to be careful
about giving out information in public areas of the Website like message
boards. The information you share in public areas may be viewed by any user of
the Website.
Unfortunately, the transmission of information via the internet is not
completely secure. Although we do our best to protect your personal
information, we cannot guarantee the security of your personal information
transmitted to our Website. Any transmission of personal information is at
your own risk. We are not responsible for circumvention of any privacy
settings or security measures contained on the Website.
Your Personal Data will be retained only for so long as reasonably necessary
for the purposes set out above, in accordance with applicable laws.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits users of our Website that are
California residents to request certain information regarding our disclosure
of personal information to third parties for their direct marketing purposes.
To make such a request, please contact us as detailed under Contact
Information.
Click here to see your rights
as a resident of California under the California Consumer Privacy act (CCPA).
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 Privacy Policy Manger at
[email protected] or send a letter to:
Vacation VIP, LLC
6675 Westwood Blvd.
Orlando, FL 32821
Attn: Privacy Policy Manager
CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this
page with a pop-up notice that indicates the privacy policy has been updated
on the Website home page. The date the privacy policy was last revised is
identified at the top of the page. Please visit our Website and this privacy
policy periodically to check for any changes.
CONTACT INFORMATION
To ask questions or comment about this privacy policy and our privacy
practices, or request that we remove or opt-out any information gathered about
you, that we actually control, please email or write to us at:
[email protected] or Attn: Privacy Policy Manager, VacationVIP, LLC 6675
Westwood Blvd, Suite 200 Orlando, FL 32821 or via our toll-free number:
800-266-0602. The Privacy Policy Manager would also act as a designated
grievance officer and shall address any discrepancies and grievances that you
may have with respect to this Privacy Policy.
Effective as of: 4/20/2020
