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Grand Pacific Resorts Privacy Policy

Effective Date: January 1, 2020

Last updated: September 9, 2021

Grand Pacific Group (refer to Addendum 1: Grand Pacific Group) and the Grand Pacific Contract Resort Properties (refer to Addendum 2: Grand Pacific Contract Resort Properties) (collectively “GPR”, “we”, “us” or “our”) respect your privacy and we want you to be familiar with how we collect and use the data we collect through websites operated by us (our “Websites”), social media pages that we control (our “Social Media”), email messages we send you (our “E-communications”), when you communicate with our account representatives by telephone (your “Tele-communications”), or when you purchase or own a timeshare interval at one/more of the properties we manage, or when you visit or stay as a guest at one of the properties we manage or our corporate offices (your “Property Visits”). Collectively, Websites, Social Media and E-communications are referenced in this Privacy Policy as Online Services (see section titled “Collection Of Personal Data”; sub section “Online Services”) and, together with Tele-communications and Property Visits are referenced as “Services”. By engaging the Services, you agree to the terms and conditions of this Privacy Policy.

This Privacy Policy does not apply to third party websites that may be accessible through a GPR website, or to third party websites linked to GPR. Please refer to each third party privacy notice to understand how the third party handles your personal information.

We respect your privacy rights. If you would like to update your preferences, please let us know by updating your Cookie Settings (see section titled “Preferences, Access and Retention”; subsection “Cookie Settings”) or your Communication Preferences (see section titled “Preferences, Access and Retention”; subsection “Communication Preferences”). If you would like to request access, change, delete or restrict the processing of your Personal Data, please let us know by updating your Preferences, Access and Retention (see section titled “Preferences, Access and Retention”). Your privacy rights are important to us and we will respond to all verified requests as soon as reasonably practicable and within the time periods consistent with applicable law. For your protection, we only fulfill requests for personal data associated with the email addresses identified in your request, and we may need to verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs associated with responding to your request.

Personal Privacy Data

We collect the pertinent information you voluntarily provide in order for us to provide Services you request. We may also use the personally identifiable information we collect for other business purposes such as to better understand your needs, enhance relationships, make appropriate offers, or facilitate third party offers we select which may be of interest to you. Detail about the types of Personal Data we collect is described in the section below entitled Categories of Personal Data. Detail about the method of collection of Personal Data is described in the section below entitled Collection of Personal Data. Detail about the third parties with whom we may share Personal Data and Other Data is described below in the section entitled Use of Personal Data and Other Data.

Categories Of Personal Data

“Personal Data” as referenced in this Privacy Policy include all forms of data that identify you as an individual or relate to an identifiable individual. At touchpoints throughout your interaction with us, we collect Personal Data, including without limitation:

Name (actual or name identifier)
Address (physical or electronic)
Telephone number
Email address
Any other identifier that permits online or physical contacting of specific individual
Credit card, debit card or other payment information
Reservation booking information, including dates of booking, arrival/departure times, selected choices for guest reservation preferences, activities, services and amenities which we may learn about during your on-property visit
Social Security number, if submitted to us
Driver’s license, Government ID, or U.S. Passport number, if submitted to us
Vehicle information (license plate, make, model) provided in connection with your stay at one of our managed properties
Communication preference information
Your professional or employment related information
Your timeshare marketing and sales transaction information
Your purchase information for transactions at our managed properties
Your financial information for financed timeshare sales transactions or for payments collected
Your ownership information such as assessment balances, real estate taxes due
Your geographic location and navigation information
Your biometric data, such as digital images
Your demographic information
Your identified gender
Your comment or request communicated to us via our call center, email, chat or blog
Your Social Media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts
Your voluntary testimonial or story submitted to us
Your voluntary photos or videos submitted to us
Your voluntary referral information to refer a friend’s contact information
Your voluntary participation/comments/ratings/posts in a survey, sweepstakes, or contest

In special circumstances, we may also collect additional information such as:

Data about family members and companions, which may include the names and ages of children.
Images and video and audio data via (a) security cameras located in public areas, such as common area lobbies, pool, and hallways at our corporate office or managed resorts; (b) promotional photography/videos during posted events at our managed resorts.
Your voluntary biometric data provided in connection with your account information or your visit to our corporate offices or one of our managed properties, such as body temperatures, health related symptoms or diagnosis information which may include sensitive medical information you opt to voluntary provide.

For employees and applicants for employment, we also collect additional information in person and on our career site related to the employment/potential employment relationship such as:

Name
Contact information
Employment application information
Pre-employment screening information applicable to the applied for job position
Personnel related information
Employee benefits related information
Employee leave related information

Employment and applicant information is regarded as strictly confidential (released only as compliant and or as required by law) and retained only as applicable to the employment/pre-employment relationship. Please note when requesting deletion of personal information, we will remove your entire candidate profile from the career site for any active job applications. Personnel and employment records will be retained in accordance with applicable law.

Collection Of Personal Data

We collect Personal Data directly from information you expressly provide to us or through the following Services:

Online Services. We collect Personal Data when you transact or communicate with us such as booking a reservation on our Websites, purchasing a vacation package, communicating via online chat service, posting to our Social Media pages, subscribing to our newsletters or E-communications, participating in a survey, contest or promotional offer.
Owner and Vacation Services. We also collect Personal Data when you communicate with our assessment billing services or vacation services call centers via telephone, email, fax, or U.S. Mail. These communications may be monitored or recorded for purposes of quality assurance and training.
Property Visits. We collect Personal Data when you visit our managed properties or use on-property services such as retail outlets, restaurants, concierge services, etc.
Internet-Connected Devices. We collect Personal Data from internet-connected devices available within our managed properties. For example, a front desk concierge or smart home assistant may be available for your use and to customize your accommodations and experience. Personal Data may also be collected if you provide the precise physical location of your personal device via satellite, cell phone tower, WIFI signals or other technologies when you opt-in through third party apps.
Strategic Business Partners. We collect Personal Data from third party companies to provide you with goods, services or offers based on your experiences at our managed properties, including without limitation concierge services, timeshare marketing and sales services, vacation travel services and booking platforms.
Other Sources. From time to time, we may collect Personal Data from other sources, such as public databases, joint marketing partners, social media platforms, and other third parties, which may include other persons you are friends with on social media platforms. For example, if you elect to connect your social media account to your GPR account, certain Personal Data that is part of your public profile or your friends’ public profiles. We may receive your Personal Data from an agent or other person that makes a reservation on your behalf.

Categories Of Other Data

“Other Data” as referenced in this Privacy Policy include data which generally does not reveal your specific identity or does not directly relate to an identifiable individual. To the extent that Other Data may reveal your specific identity or relate to an identifiable individual, we will treat Other Data as Personal Data. We collect Other Data, including without limitation:

Brower and device data
App usage data
Data collected through Cookies (see section titled “Collection of Other Data”; subsection “Cookies”), pixel tags and other technologies to capture your transaction or search patterns
Demographic data and other data provided by you
Statistical data
Aggregated data

Collection Of Other Data

We collect Other Data via various interactive use touchpoints such as:

Your IP Address. We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically by our server log files when a user accesses the Online Services, along with the capturing the date and time of your visit, duration of your visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer Online Services. We may also derive your approximate location from your IP address.
Your browser or device. We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, and the version of Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.
Cookies. We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality. You are free to decline cookies when visiting our websites. You can configure your browser to accept all cookies, reject all cookies, erase cookies or notify you when a cookie is set. Electing to reject or disable cookies may substantially limit your ability to use our Online Services.
Pixel Tags and other similar technologies. We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.
Analytics. We use several third party platforms (such as Google, Triptease, and others) with analytics features in order to collect data to better serve our customers. Google Analytics and other third parties use cookies or other tracking technologies. At this time we use Triptease and Google Analytics demographics and interest reporting features. This allows us to collect information about the web usage statistics and demographics of people who access our websites. We do not use these features to collect or use any personally identifiable information. If you wish to disable or opt-out, please follow the instructions provided directly by Google Analytics at https://tools.google.com/dlpage/gaoptout/. You may also learn more about Triptease by going to the https://www.triptease.com/en/cookie-policy/. The use of cookies by Google Analytics or other third party service providers is not covered by this Privacy Policy. We do not have access or control over these cookies.
Aggregate Data. We may aggregate data that we collected and this aggregated data will not personally identify you or any other user.

Use Of Personal Data And Other Data

We, or one of our affiliates, will use Personal Data and Other Data to provide you with Services, to personalize Services, and to develop new offerings. In some instances we will request that you provide Personal Data or Other Data to us directly (with your express consent or response) so that we may comply with a legal obligation. We will not discriminate against any persons who exercise their right under applicable law, and we will strive to provide you with your full requested Services in all cases. However due to the nature of hospitality, your perception of preferable vacation experiences may be impacted.

Provide the Services you request. We, or one of our affiliates, will use Personal Data and Other Data to provide Services you request and manage our contractual relationship with you, including:
Process reservations, payment, send administration booking confirmation and information or pre-arrival messages, to assist you with meetings and events and to provide you with information about the area and the property which you are scheduled to visit.
Complete the reservation transaction during your stay, for example, to process your payment, ensure that your room is available and provide you with related customer service during your stay.
Provide electronic receipt information, for example, when you provide an email address in making a reservation, we use that email address to send you a copy of your folio bill. If you make a reservation for another person using your email address, that person’s folio bill will be emailed to you, as well. You can opt out of receiving your folio bill via email and instead receive a paper copy by contacting the front desk of the property.

We, or one of our affiliates, will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

Personalize the Services according to your Preferences. We, or one of our affiliates, will use Personal Data and Other Data to personalize the Services and improve your experiences, including when you contact our call center, visit one of our properties or use Online Services to:
Customize your experience according to your Preferences.
Present special offers based on your Preferences.

Communicate with you about goods and services according to your Preferences. We, or one of our affiliates, will use Personal Data and Other Data to:
Send you marketing communications and promotional offers, as well as periodic customer satisfaction, market research or quality assurance surveys.

Owners Services. We, or one of our affiliates, will use Personal Data and Other Data to:
Offer and manage your participation with your owners association and our benefit promotions, as well as others that are specific to certain properties or tailored to your ownership interests.
Communicate with you about your association account status and activities at your home resort.
Provide loan servicing and communicate with you about your loan account (if applicable to your timeshare purchase).
Communicate with you about owner benefits, including bonus weeks, rental options, and exchange options.
Communicate with you about resale options and purchases.
Administer owner benefit programs and promotions.
Conduct annual owners meeting event and annual elections.
Conduct owners ballot campaigns.

Sweepstakes, activities, events and promotions. We, or one of our affiliates, will use Personal Data and Other Data to allow you to opt-in to participate in sweepstakes, contests and other promotions and to administer these activities. Some of these activities had additional rules and may contain additional information about how we use and disclose your Personal Data. We suggest that you read any such rules carefully before voluntary participation.

Maintaining our facilities, systems, and infrastructure. We, or one of our GPR affiliates, will use Personal Data and Other Data to maintain our facilities, systems and infrastructure pursuant to applicable legal and business purposes.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for such activity.
Debugging to identify and repair errors that impair existing intended functionality.
Protecting against security risks.
Protecting and maintaining a safe and healthy facility for the public, our guests and our employees, which may include sharing your biometric and geolocation information with public health authorities (including data aggregators for purposes of public safety).
Conducting audits and measurements for data analysis.

We, or one of our GPR affiliates, will use Personal Data and Other Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.

Business Purposes. We use Personal Data and Other Data for data analysis, audits, security and fraud monitoring and prevention (including with the use of security monitors, card keys, and other security systems), developing new goods and services, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

Disclosure Of Personal Data And Other Data

Our goal is to provide you with the highest level of hospitality and Services, and to do so, we share Personal Data (refer to section titled “Categories of Personal Data”) and Other Data (refer to section titled “Categories of Other Data”) with the following:

Grand Pacific Group. We disclose Personal Data and Other Data to other companies within the Grand Pacific Group (refer to Addendum 1: Grand Pacific Group) for purposes described in this Privacy Policy, such as providing and personalizing the Services, communicating with you, facilitating the owner programs, and to accomplish our business purposes. Grand Pacific Resorts, Inc. is the party responsible for the management of the jointly-used Personal Data. We share your Personal Data and Other Data used for making a reservation with the applicable property to fulfill and complete your reservation.
Resort Properties. We disclose Personal Data and Other Data to Grand Pacific Contract Resort Properties (refer to Addendum 2: Grand Pacific Contract Resort Properties) and their service providers for the purpose stated in this Privacy Statement, such as providing, facilitating and personalizing Services.
Service Providers and Strategic Business Partners. We disclose Personal Data and Other Data to select service providers, timeshare exchange companies, hotel brand franchisors and strategic business partners under contract with the Grand Pacific Group (refer to Addendum 1: Grand Pacific Group) or Grand Pacific Contract Resort Properties (refer to Addendum 2: Grand Pacific Contract Resort Properties) for the purpose stated in this Privacy Statement, such as providing, facilitating and personalizing Services. For example, this sharing enables you to purchase goods and services, including timeshare properties. By sharing Personal Data and Other Data with these service providers and strategic business partners we are able to make personalized services and unique travel experiences available to you. Examples of service providers include companies that provide website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer services, email delivery, marketing, auditing and other services. This sharing also enables us to provide you with a single source for purchasing packages that include travel-related services.
Exchange Companies. We disclose Personal Data and Other Data to timeshare exchange companies for the purposes described in this Privacy Statement, such as providing, facilitating and personalizing the Services and facilitating exchange company service programs.
Franchisors. We disclose Personal Data and Other Data to Franchisors/Licensors including branded properties for the purposes described in this Privacy Statement, such as providing, facilitating and personalizing the Services and facilitating franchisors loyalty programs.
Authorized Licensees. We disclose Personal Data and Other Data to our Authorized Licensees for the purposes described in this Privacy Statement, such as providing and personalizing Services and fulfilling your requests.
Promotional Activity. We partner with certain third parties that allow you to enroll in their services or participate in their promotions. For example, certain companies allow you to use to Online Services login to receive or register for their services. When you enroll in those services, we disclose your Personal Data and Other Data to those third parties. If you do not want us to share your Personal Data or Other Data in this way, do not use your Online Services login to register for third-party promotions and do not connect your Online Services account with accounts on third-party services. Data shared in this way will be governed by the third party’s privacy policy and not our/this Privacy Policy.
Mandate/Legal Disclosures.
We will use and disclose Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your jurisdiction of your permanent residence; (b) to comply with legal process; (c) to respond to requests from government authorities, including outside of your jurisdiction of permanent residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of the Grand Pacific Group, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
We will not discriminate against you for exercising your rights provided under applicable law.
We may use and disclose Other Data for any purpose, except where we are not allowed to under applicable law. In some instances, we may combine Other Data with Personal Data (such as combining your name with your location). If we do, we will treat the combined data as Personal Data as long as it is combined.
Corporate Reorganization. We may disclose or transfer your Personal Data and Other Data to a third party in the event of any corporate reorganization such as a merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Grand Pacific Group entities, businesses of such entities, assets or stock.
Disclaimer for non-related third party entities. We are not responsible for the privacy, data or other practices of any entities outside of the Grand Pacific Group, including Resort Properties, Service Providers and Strategic Business Partners, Exchange Companies, Franchisors, Authorized Licensees, or any third party operating any site or service to which the Services link, payment service, programs, or website that is a landing page of the high-speed Internet providers at our properties. The inclusion of a link on the Online Services does not imply endorsement of the linked site or service by us. We have no control over, and are not responsible for, any third party’s collection, use and disclosure of your Personal Data. In addition, we are not responsible for the data collection, use, disclosure or security policies or practices of other organizations such as Facebook, Apply, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Data you disclose to such organizations.

Security

We strive to use reasonable organizational, technical and administrative measures to protect Personal Data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example if you believe the security of your account has been compromised), please immediately Contact Us (refer to section titled “Contact Us”).

Sensitive Data

Unless Personal Data is specifically requested, we ask that you not provide us, and you do not disclose, on or through the Services, any sensitive personal data, including without limitation, any information on race, religion, ethnicity, sex, gender, sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records or information on other judicial of administrative proceedings.

Use Of Services By Minors

The Services are not directed to persons under the age of 18 years and we request minor person not provide Personal Data through the Services. We do not knowingly collect, maintain or use personal information from persons under 18 years of age. If you are under the age of 18, please do not browse our websites or use our Services and do not provide any Personal Data. A parent or guardian of persons under the age of 18 may Contact Us (refer to section titled “Contact Us”) on behalf of a minor person.

Privacy Policy Changes Or Updates

We reserve the right to make changes to this Privacy Policy. Any changes will become effective upon the date the revision to the Privacy Policy is posted for Online Services. Please review the posted Privacy Policy prior to your use of Online Services to ensure that you have reviewed the current Privacy Policy. Your use of Services following the effective date of the Privacy Policy means that you accept the revised Privacy Policy. If you would like to review any earlier version of the Privacy Policy, please contact us at gpvspecialist@gpresorts.com.

Applicable Law

Your use of Services is your agreement that the applicable law to be applied in all cases will be California law. This Privacy Policy is adopted to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined under CCPA have the same meaning when used in this Privacy Policy. We also follow California’s “Shine the Light” law under California Civil Code Section 1798.83. Your use of Services is your agreement that the sole and proper jurisdiction and venue is Carlsbad, California. In the event that litigation is filed in federal court, the proper court will be San Diego, California.

Preferences, Access And Retention

You have choices when it comes to how we use your Personal Data and Other Data and we want to ensure you have the information to select the preferences that are right for you.

Tracking Preferences

We want to learn what is relevant to you and ensure you have a personalized experience. We use digital tools such as Cookies (see section titled “Cookies”) and tags on our Website pages. Cookies help us provide, protect, and improve our Services. To adjust your cookie preferences, please visit our Tracking Preferences form.

You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on Tracking Preferences form. If however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit.

Do Not Track (DNT) Browser Settings

At this time, we do not respond to browser DNT signals, as we await the development of new 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.

Communication Preferences

We want to engage with you in a way that is valuable to you. You may update your Communication Preferences by clicking the unsubscribe link at the bottom of any of our E-communications to you. Please note, even if you chose to opt out of E-communications, we will continue to send you transactional messages about your timeshare interval ownership (if applicable), and transactional messages about your guest reservations or stays, including pre-arrival, confirmation and guest satisfaction surveys.

Right to Your Personal Data

Please submit this Personal Data Request form if you would like to request to access, change, delete, or restrict the use or object to the processing of your Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent those rights are provided to you by law applicable to your jurisdiction of permanent residence).

Contact Us

If you have questions about the form or our process, please contact us at:

Email: gpvspecialist@gpresorts.com

Fax: 1-760-828-4239

Physical Address: Attn: Legal Department, 5900 Pasteur Court, Suite 200, Carlsbad, CA 92008

Telephone Number (within U.S.): 1-888-477-6967

If outside US: 1-760-431-8500

For your protection, we will only fulfill requests for the personal data associated with email addresses or owner account information that you identify in your request, and we may need to verify your identity before fulfilling certain requests. When permitted by law, we may charge an appropriate fee to cover the costs of responding to your request.

Grand Pacific Group acknowledges and respects our guests’ privacy and we will work to comply with your request as soon as reasonably practicable and consistent with applicable law.

Addendum 1 : Grand Pacific Group

Advanced Commercial Corporation
Advanced Financial Company
Carlsbad Ranch Restaurant Company, LLC
Grand Pacific Carlsbad, L.P.
Grand Pacific Carlsbad Hotel, Inc.
Grand Pacific Carlsbad Hotel, L.P.
Grand Pacific Development, Inc.
Grand Pacific Hotel Holdings, Inc.
Grand Pacific Hotel Holdings, L.P.
Grand Pacific Hotel Services, Inc.
Grand Pacific Hotel Services, L.P.
Grand Pacific Land Holdings, Inc.
Grand Pacific Palisades Hotel, Inc.
Grand Pacific Palisades Hotel, L.P.
Grand Pacific Palisades, L.P.
Grand Pacific Plaza, L.P.
Grand Pacific Resort Services, L.P.
Grand Pacific Resorts, Inc.

Addendum 2 : Grand Pacific Contract Resort Properties

California Vacation Club
Capistrano Surfside Inn Vacation Plan Owners Association
Carlsbad Inn Vacation Condominium Owners Association
Carlsbad Inn, LLC
Carlsbad Inn, Ltd.
Carlsbad Seapointe Resort Owners Association, Inc.
Channel Island Shores Vacation Plan Association
Circle J Club
Coronado Beach Resort Owners Association, Inc.
Grand Pacific Contract Resort Properties
Grand Pacific MarBrisa Owners Association, Inc.
Grand Pacific Palisades Owners Association, Inc.
Grand Pacific Vacation Club
Hanalei Bay Vacation Owners Association
Association of Unit Owners of Hanalei Bay Resort
Indian Palms Timeshare Estate Owners Association
Makai Club at Princeville
The Makai Club
Makai Club Cottages at Princeville
Mandalay Shores Resort
The Cottages Interval Owners Association
The Cassara Carlsbad
The Westin Carlsbad Resort and Spa
Red Wolf Lakeside Lodge Owners Association, Inc.
San Clemente Cove Vacation Owners Association
Sheraton Carlsbad Resort and Spa
Southern California Beach Club Vacation Owners Association
Squaw-Tahoe Resort Time Interest Owners’ Association
Tamarack Beach Vacation Owners Association
Tahoe Sands Resort
Villa L’Auberge Del Mar Owners Association, Inc.
Village Inn Owners’ Association
Vista Mirage Resort
Wave Crest Owners Association

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