Last Updated: November 30, 2016

This privacy policy ("Privacy Policy") covers the treatment of personally identifiable information (“PII”) collected by or submitted to Exclusive Resorts, LLC and its affiliates, including Exclusive Resorts Club Management, LLC (collectively, the “ER Group”), including information submitted via the Internet, by telephone, mail, applications, or otherwise. PII is further detailed and defined herein, below. We understand and respect your desire for privacy and will make reasonable efforts to use PII in accordance with this Privacy Policy. Because this Privacy Policy addresses our use of PII, we suggest that you review this Privacy Policy carefully and periodically, as it is subject to change.

Please note that to the extent any portions of the following Privacy Policy are inconsistent with applicable law or regulations, or to the extent you provide your express consent for uses not specifically described below, then such laws or regulations, or your express consent, will govern our use of your PII.

This Privacy Policy governs our use of information obtained from our customers and prospective customers, including information obtained through our Websites, including exclusiveresorts.com, telephone, mail, applications, and other websites owned or controlled by the ER Group that may be accessed via any electronic device (these communication mediums are collectively referred to herein as the “Websites”). As used in this Privacy Policy, the term “Licensees” means certain companies, partners, and/or service providers who have entered into a license or similar agreement with an ER Group company to sell, market, or promote goods or services under an ER Group brand or co-brand. Licensees are independent from the ER Group. 

CONTACT INFORMATION
You may contact us at any address or number that we have provided to you, or, as a general matter, at the following:
Exclusive Resorts Club Management, LLC
1515 Arapahoe Street Tower 3, Suite 500
Denver, CO 80202
800-447-8988
privacy@exclusiveresorts.com

INFORMATION COLLECTION

Information Collection - Generally, it is our policy not to request or collect sensitive personal information, such as religious preferences, racial or ethnic background or other similar forms of data.

We collect PII that you provide to us over the Internet (especially via our Websites), by email, regular mail, or by phone, from third parties that give your information to us and through other legal means.

The types of PII that we collect includes:

  • Your name, gender, home and work contact details, date of birth, and nationality;
  • Personal interests relating to travel, dining, and activity preferences, information regarding your interest and use of our services, and Websites;
  • Your occupation, background information relevant to your Membership application (if you submit any) and other information relevant to responding to your inquiries and providing services to our members, prospective members, guests, customers, and business partners;
  • Any personal information necessary to fulfill special requests, including preferences in accommodations, services, meals, etc.;
  • Financial information, such as credit card numbers, including the three or four digit CCV code on the back or upper right hand corner of the credit card, billing addresses, expiration dates, etc., in order to facilitate the billing and payment of your accounts, if you have elected to store your financial information with us;
  • Online user accounts details, profile or password detail and any frequent flyer or travel partner program affiliations;
  • Information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers;
  • Information including contact information that we may obtain through third parties that we do business with.
  • Content and/or payload data of chat messages between a member and an ER Group representative or chat messages between members
  • any other information submitted by you that includes information specific to you

Information Collected through Third Parties

We may collect this information through a variety of ways, including from you directly, through Licensees, through third parties, and through other means as identified in this Privacy Policy. This information may include information from our airline, credit card, and other partners, information from social media sites, and other third party providers.

We use third party software to proactively initiate or offer online chat in order to provide you with exceptional service. Online chat services include messaging services between members and ER Group representatives as well as member to member messaging. All information provided via online chat may be associated with your email or IP address and may be stored in our systems along with the other types of PII we collect.

For information you submit to us, we attempt to notify you which categories of information are required and which are optional. If you do not wish to provide us optional information that we request, then you should not provide such information. However, please be aware that if you do not provide us with certain information that we require, then we may not be able to respond to your requests, process your applications, bill or pay you in accordance with your proposed contracts with us, or provide you complete services. If you have any concerns about the nature of the information we collect, you may contact us at the above address, or as set forth below.

Occasionally, you may be requested to provide PII about others to us (for example, individuals for whom you are travelling with). In such cases, your provision of the information of other asserts that you have obtained the express consent of the other party to supply such information. We will use this information of others in accordance with the terms of this Privacy Policy.

Certain Other Forms of Information Collected on the Internet

Use Data
If you use our Websites, we may collect non-personally identifiable information about your use of the Websites (such as IP addresses, domains, browser type and version, and operating system) ("Use Data").

Cookies and IP Addresses

ER Group may use cookies to collect information. A cookie is a small text file stored on a user's computer that contains information about the user. The ER Group, along with third party marketing partners, may use session ID and/or persistent cookies, invisible pixels and web beacons. For the session ID cookie, once a user closes the browser, the cookie simply terminates. A persistent cookie is a small text file stored on a user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. By showing how and when you use our Websites, cookies help us see which areas are popular and which are not and help in targeting information based on your interests. Cookies also allow us to store the personal preferences that you set during each visit to our Websites, which in turn allows us to speed up your future activities at our Websites.

To learn more about cookies , the following websites provide useful information:

www.allaboutcookies.org

www.youronlinechoices.eu

http://helpx.adobe.com/flash-player/kb/disable-loca-shared-objects-flash.html


Log Files

Like most standard website servers, we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.

Clear GIFs (Web Beacons/Web Bugs)

We employ a software technology called clear GIFs (a.k.a. Web Beacons/Web Bugs), which help us better manage content on our Site by informing us what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. The main difference between the two is that clear GIFs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. In addition, we may use clear GIFs in our HTML-based emails to let us know which emails have been opened by the recipients.

Do Not Track Signals

"Do Not Track" ("DNT") signal is a HTTP header field indicating your preference of web browser tracking. We currently do not recognize DNT signals. Further, we work with third parties that use tracking technologies on our Websites in order to provide tailored advertisements on our behalf and on behalf of our business partners. These companies may collect information about your activity on our Websites and your interaction with advertising and other communications. This information may then be used to determine which ads you see on our Websites, third party websites and applications.

Most browsers are initially set to accept cookies and DNT signals. You can set your browser to notify you when you have received a cookie or DNT signal, giving you the opportunity to decide whether to accept it (except Flash cookies). You have the option to reject our cookies and/or DNT signals and still use our Websites, but you may not be able to access or use some of the features we offer on our Websites (including certain members-only functions and functions with respect to our referral and/or loyalty programs).Check your browser’s Help menu or your built-in mobile device settings to find out how to manage your cookie and/or DNT signal preferences. Some mobile devices store cookies and/or DNT signals not only in areas connected to the browser, but also in areas that are app-specific. Check your app settings options to manage those preferences. USE OF INFORMATION How We


USE OF INFORMATION

How We Use PII

We may use PII in a variety of ways, including through personal contact, via our Websites, through emails and correspondence, and through third parties, such as travel and other business partners. We use PII for the purposes we have disclosed to you, or as permitted by law. Generally, PII is used to provide you with the services you requested, maintain and manage membership accounts, provide you with suggested activities, accommodations and events, conduct periodic customer satisfaction and marketing research, understand your needs as a customer, comply with legal obligations, personalize your ER account, customize website and application settings, and protect ER Group properties. We also use the information to provide or offer you newsletters, promotions and featured specials, other marketing communications, product or service awareness marketing, and to conduct surveys, sweepstakes, prize draws, and other contests. We may provide these communications online, via email, telephone, mobile/text messaging (including SMS and MMS) and postal mail. We may also aggregate your PII with data from third-party sources.

If ER Group intends to disclose PII to a type of third party not previously discussed, ER Group will notify you and provide you with the opportunity to opt out of this disclosure. For sensitive personal information, ER Group will provide you with the opportunity to opt in to third party disclosure if this sensitive personal information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected and authorized.

Use to Fulfill Our Obligations and Your Requests

We will use your PII to provide you with certain requested information, including sales and marketing materials, and to address communications that you may have initiated or authorized. We will also use your information to fulfill our obligations to you pursuant to any contracts or agreements that you may enter into with us, in connection with any of our programs, events or promotions in which you register or participate or to fulfill our obligations to our business partners. As examples, please consider: If you are a prospective member, we use PII you submit in connection with your application to process your application (which may include a background check), establish your account and activate your membership. If you are a member, we use your PII to provide you services and administer your account, including as necessary to make travel arrangements and reservations and to bill you. If you are a participant in one of our sales or marketing programs, we will send you information relevant to your participation, such as marketing materials or announcements about upcoming events related to the program. We may also use your PII to provide assistance or support with respect to your use of our services or Websites, to troubleshoot problems and to resolve disputes that may arise. Further, we may use your PII to improve our content, advertising or services, or to analyze trends or to customize the display or format of our marketing content or Websites. From time to time, we may send you information about our services and offerings, and about certain products and services of selected third parties, in which we think you may be interested. We will not use your PII or send you information if you have notified us of your preference not to have your PII so used, or not to receive such information, or when we are prohibited by law from doing so.

Sharing of Information

For the purposes described above and to the extent permitted by law and regulations, we may share your PII with the following categories of entities:

  • Third parties that perform information processing on our behalf, such as companies that manage our emails, that conduct surveys, which perform background checks, that help us send information regarding companies, products or services in which we believe you may be interested, or that provide analyses of use of our services or Websites.
  • On-property Services: We may share PII with providers of on-property services that provide services such as concierge services, spa treatments, golf, or dining experiences
  • Service Providers: We rely on service providers to provide certain products and services, such as to facilitate administrative functions and information technology operations, credit card billing, providing services in connection with our websites, including airline and rental car packages; processing credit card transactions; professional services such as accounting, auditing and legal advice; investigating accident reports; processing insurance claims; and administering sweepstakes, prize draws, competitions and customer surveys. ER Group will disclose PII to service providers as appropriate.
  • Third parties, including Licensees, that perform on our behalf, which help us perform, or that offer you services through their relationship with ER Group to meet our contractual obligations or to enhance your service experience with us.
  • Our corporate affiliates and other entities that operate the Website or other Websites for the ER Group.
  • In response to a request by law enforcement or other governmental personnel or court order or subpoena; if we are under a legal obligation to do so; to protect the integrity of our company if we believe that a user has committed unlawful or otherwise harmful acts; to protect our interests in connection with a legal proceeding; in emergency situations to protect health or safety; if we believe such disclosure is in your, any ER Group member, guests, visitors, associates, or property (including our Websites), or to others vital interest; or if we obtained your information from public sources.
  • Third parties with whom we have advertising or promotional relationships (provided that we are not otherwise restricted from making such disclosures).
  • In connection with any reorganization, merger or consolidation, or sale or disposal of substantially all or a part of our assets, joint venture or partnership and related business transactions, including in relation to audit or reporting and other regulatory requirements. Any successor or assign may use your PII provided that such party agrees to comply with our Privacy Policy or you are given a choice if such party would like to use such information in a manner materially different from that disclosed in our Privacy Policy.


Use of Use Data and other Internet-Based Information

We use aggregated (i.e., non-personally identifiable) Use Data for purposes of site administration and to compile information about usage of our Websites and services. We may share aggregated information (which does not contain your PII) with third parties, such as advertisers and marketing partners.

We may combine PII with Use Data to help us serve you better in connection with your use of our services or Websites, and to respond to your requests for technical assistance (e.g., we may record which web browser or app you use in order to help respond to your questions with difficulties using our Websites). We may share this combined information with third parties as described more specifically in this Privacy Policy.

International Transfer of Information - Residents of Countries outside the United States

If you are a resident of a country outside the U.S., then by your submission of information through this website, you confirm that you know the Websites are websites operated by the ER Group in the U.S., and you consent to the transfer of your PII to the U.S., where your PII will be subject to U.S. law and where the level of data protection may be different compared to your country. You also agree to the Terms of Service and this Privacy Policy which describe how your PII will be used.

For PII of members, potential members, and employees, that ER Group receives from entities in the European Union and Switzerland, ER Group handles such personal information in accordance with the Privacy Shield Framework (the “Framework”). ER Group certifies that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Litigation; Access; and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Framework, visit https://www.privacyshield.gov/. To view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.

ER Group is responsible for the processing of PII it receives, under the Framework. For PII transferred from the EU, if ER Group transfers your PII to a third party, ER Group will ensure that the third party is contractually obligated to process your data only for limited, specific purposes consistent with this Policy. ER Group will also ensure that the third party will apply the same level of protection to that data as the EU-U.S. Privacy Shield Principles and will notify us if it makes a determination that it can no longer meet this obligation. ER Group also complies with the Privacy Shield Principles for the onward transfer liability provisions.

With respect to PII received or transferred pursuant to the Framework, ER Group is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ER Group may be required to disclose PII in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.
In compliance with the EU-U.S. Privacy Shield, ER Group strives to resolve all complaints about privacy and the collection or use of customer information. If you have questions about our participation in the Privacy Shield program or have a complaint, please send an email to jneal@exclusiveresorts.com . If you have any unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider JAMS- Privacy Shield at https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.

Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How –to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

SECURITY

We have taken appropriate technical and organizational measures to help prevent unauthorized access, maintain data security, and to make proper use of the information that we collect; however, no transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee the security of any information you provide to us. For example, third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, we do not promise or guarantee, and you should not expect, that your PII or communications with us will always remain private.

DATA INTEGRITY

ER Group takes reasonable measures to ensure that your PII is accurate and used for its intended purposes. This includes taking reasonable efforts to ensure that your PII is protected from unauthorized access, disclosure, destruction, or modification. This also includes taking reasonable efforts to ensure that your PII is up to date and accurate.

CAREERS

ER Group uses tools and databases hosted and/or operated by ER Group or third parties to collect PII from individuals that wish to be considered for potential employment. By submitting your application and providing this PII, you understand and agree that your PII will be used for consideration of employment.

CALIFORNIA RESIDENTS

Residents of the State of California have the right to request a list of third parties with whom we share PII about you for their own direct marketing purposes during the previous calendar year. It is standard practice for the ER Group to not share PII with unrelated third parties for their own direct marketing purposes, however, many of ER Group’s business partners may obtain PII through their relationship and agreements with the ER Group. If you would like to request information about third parties that may have obtained PII about you during the immediately preceding calendar year, please send an email to privacy@exclusiveresorts.com or letter to the address provided in this Privacy Policy.

MODIFYING OR DELETING PII

We intend to keep your PII accurate and up to date. You have the opportunity to review and correct any of your information that we may have, or to restrict the uses we make of your PII. In order to review or correct your PII that we have on file, please take the following steps:

Contact us via email at privacy@exclusiveresorts.com

Give us your name and email address, together with any information that might help us more effectively serve or communicate with you.

Let us know how we can help you - if you would like to review your information, etc.

Let us know the most convenient way for us to communicate with you (email, phone, etc.)


If you request that certain information be amended, we will use reasonable efforts to accommodate your request in a timely manner. If you are a member or otherwise have established a contractual relationship with us, there is certain information that we must maintain in order to properly service your account. We retain certain information in our sole discretion that we need to process your information in order to fulfill your requests and our contracts with you, to maintain our records in accordance with industry practices, to resolve disputes, to troubleshoot problems, to enforce this Privacy Policy, or for other valid business reasons; it is not our policy to retain more information for longer than is necessary. Please note that we will not remove your non-personally identifiable Use Data from our aggregated files. Furthermore, please be aware that even if you request that your information be removed from our systems, such information may never be completely removed due to technical and legal constraints, including backup and disaster recovery systems, as well as the need to keep some information to track
and record your requests. 

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

We may, at our sole discretion, revise this Privacy Policy at any time in a manner consistent with applicable law and regulations. When we revise this Privacy Policy, we will incorporate the revisions into this Privacy Policy and will revise the "last updated" date at the top of this web page. Please check this Privacy Policy periodically for the most current version of our Privacy Policy to confirm your continued agreement with its terms, which will be inferred by your continued association with us following any such modifications.

MINORS

Our Websites and services are not directed toward individuals under twenty three years  old ("Minors") nor do we knowingly collect information from Minors.

LINKS

Our Websites may contain links to other Websites. Please be aware that we are not responsible for the privacy practices of such other Websites. We encourage our users to be aware when they leave our Websites and to read the privacy statements of each and every website that collects personally identifiable information.


ADDITIONAL CONTACT INFORMATION

If you have any questions or comments regarding our Privacy Policy, please contact us at the addresses or phone numbers listed above. If you have any technical questions or comments regarding the website itself, you make direct your inquiries to webmaster@exclusiveresorts.com

Original effective date of this policy: May 28, 2015

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