Supplemental Privacy Notice for California Residents
Marriott Vacations Worldwide Corporation (“MVWC”) provides this supplemental privacy notice (“CCPA Notice”) for consumers that reside in California (“you,” or “your”) as required under California privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”). This CCPA Notice applies to MVWC and its affiliated operating companies (“Affiliates”), except for Aqua-Aston Hospitality, Hyatt Vacation Ownership, ILG, Interval International, Trading Places International, Vacation Resorts International, Vistana Signature Experiences, and Worldwide Vacation & Travel whose individual privacy practices are governed by each operating company’s privacy policy that can be found at their respective websites.
MVWC and its Affiliates (collectively referred to in this CCPA Notice as “we,” “our,” or “us”) provide this CCPA Notice to inform you about how we collect, use or disclose your personal information. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA. This CCPA Notice supplements our Privacy Policy. In the event of a conflict between our Privacy Policy and this CCPA Notice, this CCPA Notice will prevail for California residents and their rights under California law.
Personal information we collect, use, or disclose that is governed by the federal Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, or the federal Fair Credit Reporting Act, such as consumer credit reports or information relating to your financing of a vacation ownership product, is not subject to the CCPA and this CCPA Notice.
Categories of Personal Information that We Collect, Use, and Disclose
The type of personal information we collect, use, and disclose will depend on your interaction or relationship with us. The chart below generally identifies the personal information we collect based on the categories of personal information set forth in the CCPA.
Name, Contact Information and other Identifiers:
Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP)
address, email address, account name, social security number, driver’s license number, passport number, or other similar
identifiers.
We may collect information such as your name, address, email address, telephone numbers, date of birth, owner number, and IP address. In more limited circumstances, such as when you purchase or finance a vacation ownership product, we may collect information such as social security number, driver’s license number, or passport number.
Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information.
Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information. We may collect information such as your name, address, email address, telephone numbers, owner number, and credit or debit card information. In more limited circumstances, such as when you purchase or finance a vacation ownership product, we may collect information such as current employment, employment history, social security number, passport number, driver’s license or state identification, and other financial or payment information.
Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.
We may collect information such as your gender or age. In more limited circumstances, we may collect disability information to provide you with appropriate accommodations or services at our resorts.
Purchase History and Tendencies Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
We may collect information such as the products or services you purchased or utilized.
Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
We may collect voice recordings when we monitor and record telephone calls.
Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.
We may collect this information as part of your interaction with our Websites (as defined in our Privacy Policy) or mobile application, and through advertisements.
Geolocation Data: Precise geographic location information about a particular individual or device.
We may collect information such as your postal address, zip code, or the location associated with an IP address or particular device.
Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars).
Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars). We may collect voice recordings when we monitor and record telephone calls, photos or videos that are tagged or shared with us through social media posts, or audio, video, or images captured in security footage of our resorts.
Professional or employment-related information: Employment history, qualifications, licensing, disciplinary record.
In limited circumstances, such as when you purchase or finance a vacation ownership product, we may collect information such as employment history.
Education Information: Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
We do not collect this information.
Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
We may collect or derive information such as your preferences, characteristics, predispositions, and behavior based on other information we have about you.
We collect these categories of personal information from the sources described in our Privacy Policy and for the purposes described in the “Information We Collect and Its Uses” section of our Privacy Policy. We disclose your personal information to third parties, such as our service providers, as described in the “Disclosure of Information to Third Parties” section of our Privacy Policy. We do not collect personal information directly from children under the age of sixteen (16), but may receive such information from parents and guardians when, for example, making resort, cruise, or other travel reservations.
Third-Party Cookies & Similar Technologies
We may also use standard internet technology, such as cookies, web beacons, pixels, and other similar technologies (collectively “cookies”) to track your use of our Websites as defined in our Privacy Policy. We may include web beacons in promotional email messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. See the “Cookies & Related Technologies” section of our Privacy Policy for more information. Data that is collected through network advertising or social media cookies may be disclosed by such network advertisers or social media to other network advertisers that allows those advertisers to also display ads to you. While there is currently no industry consensus, we do not consider these additional disclosures to be our sale of personal information under the CCPA. If you do not want information collected by cookies, however, please visit www.aboutads.info and www.networkadvertising.org to opt-out.
California Resident Rights
If you are a California resident, you have certain rights with respect to your personal information as set forth below.
Request to Delete: You may request that we delete personal information we have collected about you, subject to certain exemptions provided by law.
Request to Know: You may request, subject to certain exemptions, that we disclose to you the categories of personal information collected; the categories of sources of personal information; the business or commercial purposes for collecting and selling your personal information; the categories of third parties with whom we have shared your personal information; the categories of personal information that we have disclosed or shared with a third party for a business purpose; the categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; and the specific pieces of personal information that we have collected about you in the prior 12 months.
Request to Opt-out of Our Sale of Your Personal Information: We do not sell your personal information.
Submitting Requests: To make a Request to Delete or a Request to Know, please contact us at 844-711-2582 or privacy@mvwc.com. Please include your full name, postal address, email address, and your owner number (if applicable). If you designate an authorized agent to make a request on your behalf, we require you to provide a written and signed authorization of your agent’s permission to exercise your rights on your behalf as provided for in this section. Please include your full name, postal address, email address, and your owner number (if applicable) along with your agent’s full name, postal address, email address, and relationship to you.
If we are unable to verify your identity based on this information, we will take additional steps to verify your identity before responding to your request. We will respond to verifiable requests received from California residents or their authorized agents in accordance with the law, which provides certain exemptions for disclosure or deletion. For example, if you are an owner of a vacation ownership product, we may retain your personal information as permitted by law to maintain and service your ownership and account.
These rights do not apply to personal information we collect about job applicants, independent contractors, or our current or former full-time, part-time and temporary employees and other staff, or information we collect when we act as a service provider.
Non-Discrimination: We are not permitted to nor do we discriminate against California residents who exercise their rights under the law.
Other California Privacy Rights
We do not permit personal information as defined by California’s Shine the Light law that we share with third parties to be utilized for their marketing activities. If you are a customer who resides in the State of California, however, you have the right to request from us a list of third parties with whom we shared personal information about you for their own direct marketing purposes during the previous calendar year by contacting us at privacy@mvwc.com or by sending a letter to Marriott Vacations Worldwide Corporation (Attn: Privacy Officer), 6649 Westwood Blvd, Suite 500, Orlando, FL 32821. Privacy rights under Shine the Light and the CCPA are provided under different legal rules and must be exercised separately.
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 Websites.
Last Update
This CCPA Notice was last updated on February 4, 2020.
