RCI Privacy Notice to Business Relations
Wyndham Destination Network, LLC is a subsidiary of Travel + Leisure Co., and does business as "Panorama." Panorama’s business operations include many subsidiary entities and consists of brands including RCI, Panorama Travel Solutions, 7Across (formerly DAE), The Registry Collection, Love Home Swap, TripBeat, @Work International, and Alliance Reservations Network (collectively "Panorama," the “Panorama Group of Companies” “we”, “us”, or “our”).
The Panorama Group of Companies provide a wide range of products and services to individual consumers and to businesses or other organizations through our websites, mobile and software applications, social media pages we control, and other online and offline activities such as when you provide your information on the phone via our call centers or in person (collectively, the “Services”). When Services are provided to business, enterprise or other organizations but not an individual consumer contracting directly with us, it is referred to as “B2B Services.”
The Panorama Group of Companies care about privacy issues and wants you to be familiar with how we collect, disclose, and otherwise use (“Process”) information about you, including information that identifies or relates to you as an identifiable person (“Personal Information”).
Scope and Application
This Privacy Notice to Business Relations (this “B2B Privacy Notice”) describes how Panorama Processes Personal Information about our and our prospective business clients, suppliers, service providers, agents, consultants, advisors, business partners, and investors (“Business Relations”).
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.
Our privacy practices also may vary among entities within the Panorama Group of Companies as well as amongst and between Panorama and Travel + Leisure Co. and any of its other affiliated operating entities (excluding the Panorama Group of Companies, the “T + L Affiliates”) depending upon their function and their offered products and services. Please review the privacy notices linked to or referenced in their respective Services and note that the data controller of your Personal Information will be the T + L Affiliate or Panorama entity which provides the Services to you. The T+ L Affiliate brands can be found here.
California Residents: Click here to read about "Your California Privacy Rights"
If you or your company or organization have separate contractual agreements with us concerning our collection, use, or disclosure of your Personal Information, those agreements control and supersede anything stated in this B2B Privacy Notice.
This B2B Privacy Notice does not apply to our processing of Personal Information (as defined in the respective privacy notices) about individual consumers, our employees or our contractors (whether directly or indirectly contracted). Please refer to the privacy notice linked to the specific Service for more information.
Please note that your access to and use of our B2B Services may be administered by your company or other organization to which you are a member. In such cases, authorized personnel at your organization may have access to your Personal Information collected by these B2B Services, and your organization may have policies applicable to your use of them. Panorama is not responsible for our Business Relations' policies and practices related to data privacy and security, which may be different from this B2B Privacy Notice and any applicable specific privacy notices. If your organization is administering your use of our B2B Services, please contact your company with any privacy questions or requests related to your use of the specific B2B Service.
Information We Collect and How It Is Collected
Most of the Personal Information that we handle in connection with the B2B Services is not collected on this website, but rather through separate contractual relationships governing our collection, use, or disclosure of your Personal Information.
When you access this website or engage with us by email or other transaction or interaction, we may collect the following Information:
1. We may collect Personal Information about you such as your:
o Title, rank or other designation held within your organization
o Business or organization name
o Postal address (including billing and shipping addresses)
o Phone number
o Email address
o Billing and financial details, including payment, insurance, fiscal and banking data
o Social media account information
o Stay, trip, product or service information, such as your preferred location/facilities, dates and number of people/children travelling with you
o Special needs or conditions that may impact your visit to our facilities
o Driver's license, government-issued ID, or passports
o Geolocation information
o Communication, product, service or other preferences
o Your opinions, comments, suggestions, inquiries and other communications you provide to us
o Demographic information
o Audio/Visual recordings such as when you call our customer service phone number or participate in having a photo taken for an activity, resort, etc.
o Internet Click Activity on our websites
o IP address or Device ID
o Account registration ID and password
o Screening. Information required to screen individuals such as directors, officers, sole proprietors, and equity holders of our current and potential counterparties. This screening takes place against publicly available or government issued-sanctions lists and media sources.
The foregoing may include private contact information (versus business contact information), if necessary. It is possible that you may submit other Personal Information to Panorama, for example in a question you ask through a contact page or submit in the comment box with your order.
2. We may collect information from you when you interact with us such as when you:
· 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.
· 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.
· 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.”
o 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 http://www.aboutads.info/ and http://www.networkadvertising.org/.
· Data Collected Automatically: In addition to any Personal Information or other information you choose to provide to us or that we otherwise collect about you as described in this Privacy Notice 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. 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 website usage information with the Personal Information you provide, but we will treat the combined information as Personal Information.
We use 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.
As aggregated, de-identified or anonymized information does not constitute Personal Information, we may use it for any purpose.
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:
o Entering into or performing a contract with you.
o Responding to your inquiries and fulfilling your requests.
o Sending administrative information to you, for example, information regarding the B2B Services or an event you are attending.
o Completing and fulfilling any purchases or requests for B2B Services.
2. For our legitimate business interests, including, but not limited to:
o Personalizing your experience on the Services by presenting products and offers tailored to you.
o 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).
o Facilitating social sharing functionalities of your social media account(s).
o 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 in accordance with applicable law.
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:
o Under applicable law.
o Complying with legal process.
o Responding to requests from public and government authorities, including those outside your country of residence.
o Enforcing our terms and conditions in connection with the Services or any B2B Services.
o Protecting our operations or those of any of our Affiliates, or other third parties.
o Protecting our rights, privacy, safety or property, or that of our Affiliates, , you or other third parties.
o Allowing us to pursue available remedies or limit damages we, our Affiliates, or other third parties, may sustain.
When We Disclose Your Information
We may disclose your information as follows:
o Affiliates: We may disclose your Personal Information to any other entity that is directly or indirectly controlled by, or under common control with us, including but not limited to any member of the Panorama Group of Companies (“Affiliates”) for the purposes described in this B2B 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?”.
o Vendors and Service Providers: We may disclose your 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.
o Business Partners, Sponsors, and Other Third Parties: We may disclose your Information to other Business Relations, co-sponsors of promotions, and other third parties in order to provide you with B2B Services that may interest you. For example, we may co-sponsor promotions, sweepstakes, or other events with a third party and may share your Information in connection with these events. If you provide additional information to any of these third parties, such information provided to these third parties will be subject to each third parties’ own privacy practices and policies.
o Message Boards: We may make reviews, message boards, blogs, and other such user-generated content facilities available to users. Any Personal 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 Information is disclosed.
o Change in Control: We may disclose your Information to a third party (e.g., prospective buyers and insolvency practitioners) in connection with any change in control of any part of our business or the business of any of our Affiliates, including, without limitation, merger, consolidation, divestiture, spin-off, purchase of all or a substantial portion of our assets, dissolution, liquidation, administration, receivership or other form of insolvency.
o Disclosure Permitted by Law: We may disclose your 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.
Safeguarding 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
o 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 B2B Privacy Notice.
o 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 Personal Information through them.
o 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 our applications or social media pages.
o Changes to Our Privacy Notice: From time to time we may revise this B2B Privacy Notice. Updated versions will be posted on the respective Services.
o Minors: We do not knowingly collect, maintain or use Information provided by individuals under 18 years of age in connection with, and no part of our websites, social media pages, and mobile and software applications is directed to, individuals under the age of 18. If we do discover we have collected Personal Information from minors in violation of applicable law, we will delete it.
o International Transfers: We are an international company and we may, subject to applicable law, transfer your Personal 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 Personal Information may be stored on servers located in other jurisdictions). We will utilize appropriate safeguards governing the transfer and usage of your Personal Information.
o Retention Period: We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this B2B Privacy Notice unless a longer retention period is required or permitted by law.
Your Choices and Rights
· Changes to Your Marketing Preferences: You can change your marketing preferences by:
· 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.
· 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.
For Australia Residents: Your Australia Privacy Rights
1. This section of our B2B Privacy Notice applies specifically to individuals located in Australia. If you are located in Australia, to the extent of any inconsistency between this section of our B2B Privacy Notice and the remaining sections of our B2B Privacy Notice, this section will prevail.
2. This B2B Privacy Notice applies to the Panorama group of companies. Each entity in the Panorama group of companies may share your Personal Information with other entities within the group.
3. Definition of “Personal Information”
3.1. For individuals located in Australia, “Personal Information” includes an opinion about you.
4. By providing Personal Information to us, you consent to our collection, use and disclosure of your Personal Information in accordance with this B2B Privacy Notice and any other arrangements that apply between us. We may change our B2B Privacy Notice from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current B2B Privacy Notice.
5. In the course of providing you with products or services, we collect Personal Information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your Personal Information from you directly. In some cases however, we will collect information about you from a third party. For example, we may collect Personal Information about you from third party service providers or agents assisting us to provide products or services to you.
6. Overseas disclosure of Personal Information
6.1. As part of a global business, we may disclose your Personal Information to recipients that are located outside of Australia, including to our Affiliates located in the United States, United Kingdom, and Singapore.
6.2. When you provide your Personal Information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that Personal Information in compliance with the Privacy Act 1988 (Cth) and the associated Australian Privacy Principles (APPs). We will, however, take reasonable steps to ensure that any overseas recipient will deal with such Personal Information in a way that is consistent with the APPs
6.3. The privacy and collection practices of entities to which we disclose Personal Information are governed by their own privacy policies and collection notices.
7. Correcting Personal Information
7.1. If you believe that the Personal Information we hold about you is inaccurate or incomplete, please contact us and we will use all reasonable efforts to correct the information.
7.2. If we do not believe the information to be incorrect, we will take reasonable steps to add a statement to the Personal Information stating that you believe the information is inaccurate, incomplete or out of date.
8.1. If you have a complaint about our collection, use or disclosure of your Personal Information, or you wish to make a complaint about a breach of the APPs, please contact us at the details set out below. You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.
How Can You Contact Us?
FOR RESIDENTS OF CANADA, USA, AND ENGLISH SPEAKING CARRIBEAN ISLANDS
If after reviewing this B2B Privacy Notice, you have any questions, complaints or privacy concerns, or would like to make any requests in relation to your Information, or obtain further information on safeguards used for international transfers please send an email to our Privacy Officer at email@example.com or send a letter to (please also indicate the Panorama entity or brand you typically do business with):
Panorama Attn: Legal Services– Privacy 6277 Sea Harbor Drive Orlando, FL 32821
FOR RESIDENTS OF EUROPE, MIDDLE EAST, AND AFRICA
RCI Europe, Kettering Parkway,
Kettering, Northamptonshire, United Kingdom NN15 6EY
If you have a complaint or concern about how we Process your Information, we will work to address such concern(s). You may also direct your complaint/concern to the applicable data protection authority.
FOR RESIDENTS OF BRASIL, MEXICO, LATIN AMERICA, AND SPANISH SPEAKING CARRIBEAN ISLANDS
If after reviewing this B2B Privacy Notice, you have any questions, complaints or privacy concerns, or would like to make any requests in relation to your Information, or obtain further information on safeguards used for international transfers please send an email to our Privacy Officer at ProtecciondeDatosPersonales@latam.rci.com or send a letter to (please also indicate the Panorama entity or brand you typically do business with):
Resort Condominiums Internacional de México, de RL de CV Horacio 1855, PH, Polanco, Polanco I Secc, Miguel Hidalgo, 11510 Ciudad de México, CDMX
FOR RESIDENTS OF ASIA, INDIA, AND THE PACIFIC
RCI Asia-Pacific Singapore, LLC 223 Mountbatten Road #03-14 Singapore 398008
FOR RESIDENTS OF AUSTRALIA
7ACROSS, Level 4, Bermuda Point, 1 Lake Orr Drive, Varsity Lakes, Queensland, QLD 4227, Australia