MVW's Global Privacy Policy

Introduction

Marriott Vacations Worldwide Corporation ("MVWC") is a global vacation company that offers vacation ownership, exchange, rental, and resort and property management, along with related businesses, products, and services. MVWC has more than 100 resorts and over 660,000 Owners and members in a diverse portfolio that includes seven vacation ownership brands. It also includes exchange networks and membership programs comprised of more than 3,000 resorts in over 80 nations and approximately two million members, as well as management of more than 180 other resorts and lodging properties. As a leader and innovator in the vacation industry, MVWC upholds the highest standards of excellence in serving its customers, investors, and associates while maintaining exclusive, long-term relationships with Marriott International and Hyatt Hotels Corporation for the development, sales, and marketing of vacation ownership products and services.

MVWC has a strong commitment to providing excellent service to our customers, Owners, and guests, which includes respecting their concerns about privacy. This Global Privacy Statement ("Statement") applies to MVWC and its affiliated operating companies ("Affiliates"), except for Aqua-Aston Hospitality, Hyatt Vacation Ownership, ILG, Interval 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 and mobile apps.

MVWC and its Affiliates (collectively referred to in this Statement as "we," "our," or "us") have prepared this Statement to inform you of the privacy principles that govern our use of information we obtain from our customers, Owners and guests, including information we obtain through websites and mobile apps we own or control (collectively, the "Platforms"), your communications with us, our communications with you, your stay with us at one of our properties, or our license agreements with Marriott International, Inc. or The Ritz-Carlton Hotel Company, L.L.C.

This Statement, along with our Cookies & Related Technologies Table (the "Table") that outlines our use of cookies and related technologies and is available here, contains information about the steps we take to respect your privacy, the types of cookies and similar technologies we use, the information we collect, how we use that information, and for how long collected information is retained. We have organized the Statement by major topic areas, including region-specific details, so that you can quickly access and review the information of most interest to you. Please note that we are not affiliated with Marriott International, Inc. and The Ritz-Carlton Hotel Company, L.L.C., and a separate privacy statement and separate terms and conditions apply to the Marriott BonvoyTM program.

Information We Collect and Its Uses

When we need to collect personal information to execute a transaction or provide a particular service you requested, we will ask you to voluntarily supply us with any information we need. In connection with a purchase and sale transaction, we may ask you for personal information such as name, address, telephone and facsimile numbers, email address, occupation, government issued ID number, and nationality and passport number. We may use such information to verify your identity, complete the transaction, administer your memberships associated with MVWC and/or its Affiliates, send you commercial messages, advise you of other offers and information, carry out general recordkeeping, maintain a list of current and former Owners or members, create informational or analytical reports, supplement your disclosed information, carry out verifications, planning or other legitimate business needs of MVWC and/or its Affiliates, allow for revenue collection or debt recovery, respond to your inquiries or others who you have identified as an authorized agent or proxy, and such other purposes as permitted by applicable law.

Other circumstances in which we may need to collect and use your personal information include reservations, online payments, and other related business activities. For example, if you would like to make a reservation at one of our resorts, we will ask you for information such as name, address, telephone number, and email address to process your reservation. If you elect to make an online payment, you will be asked to supply information that is necessary to process your payment. We typically use your email address to send a confirmation and, if necessary, might use the other information to contact you for help in processing. When you provide contact details for transaction requests, such as scheduling an appointment or requesting a proposal, we will use the contact information to keep you updated about our future offers or promotions.

We may record telephone calls, through which we may capture your personal information, for quality assurance, training, compliance, and security purposes. You will be notified whether the call is being recorded at the start of the call, and we will obtain your consent where required by law to record the call.

We may also collect and use your personal information to satisfy any applicable law, regulation, legal process, or enforceable governmental request, or when we have a good faith belief that use and disclosure is necessary to investigate, prevent, or protect against harmful activities to MVWC or Affiliates, Owners, guests, visitors, associates, or property (including our Platforms), or to others.

We may use third parties to provide, confirm, or supplement for us other information based on the information you provided to us directly. We would then use this information for market analysis and our direct marketing purposes.

We or our service providers may aggregate Personal Data we collect. This aggregated data will not personally identify you or any other user; it is de-identified. Aggregate data may be used by us or our service providers to divide customers into segments, or groups, in order to provide more relevant advertising or to improve services. Additionally, we may share aggregated and non-personal data/information with service providers to develop and deliver targeted advertising, including on our Sites, our App, and third-party sites. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Sites and the most popular features or services accessed. This information does not contain any personal information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.

Personal information will be retained only until it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by its retention and the retention is no longer necessary for legal or business purposes.

We will maintain your personal information in whole, usable, and up-to-date form. Please contact us as described above in the event you would like to correct or update any of your information.

Creating an Account Profile

Owners of our products and programs may, at their choice, create a personal account profile online within our password-protected Platforms. Creating an account profile makes use of our Platforms more convenient by eliminating the need to repeatedly enter personal contact or preference information. In addition, if you choose, you can perform certain functions within your account, such as making online Club Dues or maintenance fee payments. The security of this information is addressed in the security section below. You can access and review, update, or deactivate the information in your account profile online.

Please note that we will never send you an email requesting your username, password, credit card, social security, or national insurance numbers. If you receive an email that looks like it is from us, but asks you for your credit card number, social security, or national insurance number, it is a fraudulent email or "phish."

If you believe "phishers" have obtained access to your personal or financial information, we recommend that you change your password and contact credit reporting services and have a fraud alert attached to your credit report file. Please be aware that the perpetrator may attempt to use your information to establish accounts or obtain credit at other businesses in their name or yours. We will not be able to secure your information and we will not be liable for any resulting breach of any law if you reveal your password to anyone.

Our Mobile Application

This section of the Statement describes our distinct practices related to the use, storage, and disclosure of information we collect from or about you while providing services through our mobile app ("App"). The privacy policy link within the App will point your device to our most current version of this Statement. Please review regularly for the most recent version of this Statement.

We collect and use information about you and your device, including device ID, through the App to maintain and provide you with services, to respond to your questions and instructions, to maintain the integrity of our network and address security issues, to investigate or to take action regarding violations or suspected violations of law or the App's Terms and Conditions, and to improve our services.

You may opt out of information collection by uninstalling the App. You may use the standard uninstall application and data management process available as part of your mobile device or via the removal features provided in your chosen mobile app store or network. Once the App is uninstalled, information provided which is related to your online account (including shared photos, videos, and stories; as well as updates to your password will be stored in our server so that we may provide you with your requested services.

Other than as stated in this section, this Statement is applicable to the App.

You may sign up to receive push notification messages from the App ("Push Notification Service"). To ensure messages reach the correct devices, the Push Notification Service generates a unique token for your device and shares it with us for administrative purposes. While we will be able to access a list of the tokens, the tokens will not reveal your actual identity or contact information to us. We may collect the following: The time of an event and information about the device an App user is utilizing such as the identity of the user's operating system. If, at any time, you wish to stop receiving push notifications, you can opt out of receiving push notifications by changing your relevant device settings.

Security of Information

We treat the personal information you provide to us as confidential; it is, accordingly, subject to our organizational, physical, and technical security measures, procedures, and policies regarding protection and use of confidential information. After information reaches us, it is stored on a secure server that resides behind firewalls designed to block unauthorized access. Because laws applicable to personal information vary by country, additional measures that satisfy applicable legal requirements may be put in place.

When we ask you for credit card information, it is transferred using secure transmission protocols. We also use secure transmission protocols on other select pages where you would enter personal information. This ensures that your information is encrypted as it travels over the Internet. This secure mode is enabled before any such information is transmitted from your computer. You will know you are in secure mode when the padlock or key icon in the lower right-hand or left-hand corner of the computer screen appears in the locked position. In addition, when accessing a secure server, the first characters of the site address will change from "http" to "https." There is no guarantee, however, that the transmission, Internet, or storage system is fully secure. Please immediately notify us using the contact methods contained in the Introduction section of this Statement if you have reason to believe that your interaction with us has been compromised.

Confidentiality of Identification Numbers

When collected, social security, national insurance, and other government-issued identification numbers are treated with great care, including our satisfaction of applicable laws and regulations. Social Security, National Insurance and other government-issued identification numbers are collected and retained in order to comply with various United States Federal and State laws and International regulations. For general information systems, we use customer numbers and employee identification numbers that are not derived from government-issued identification numbers. We use policies, procedures, training, technology, and auditing to protect the confidentiality and privacy of social security, national insurance, and other government-issued identification numbers and ensure that proper controls are in place concerning the collection, use, disclosure, processing, recording, holding, storing, and/or sharing of this information.

Disclosure of Information to Third Parties

We do not sell your personal information to other companies. We do not transfer your personal information to other companies for their own use unless we have your approval and provide you the opportunity to opt out. MVWC and its Affiliates, located in the United States and around the world, may share your personal information among themselves. We may maintain personal information in databases controlled by MVWC and/or any service providers and third parties (including auditors) engaged by MVWC and/or its Affiliates in the United States or other jurisdictions and may process, use, transfer, and disclose such information to non-affiliated companies when we need to share your information to provide the product or service you have requested or need to send the information to companies who work on our behalf, to provide a product or service to you, for general recordkeeping, informational and/or analysis reports, to supplement your information, or have your consent when consent is necessary to share the information. These non-affiliated companies do not have any right to use the information we provide to them for any purpose beyond what is necessary to assist us. We will protect your personal information in accordance with applicable data protection laws and will take steps to ensure any transferees do the same.

We share personal information with other companies, organizations, or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

Satisfy any applicable law, regulation, legal process, or enforceable government request;
Investigate, prevent, or otherwise address fraud, security, or technical issues; or
Investigate, prevent, or protect against harmful activities to MVWC or Affiliates Owners, guests, visitors, associates, or property (including our Platforms), or to others, as required or permitted by law.
We may disclose your personal information in relation to the reorganization, sale, or disposal of all or a part of our business or assets, joint ventures, and related business transactions, including in relation to audit or reporting and other regulatory requirements. Any successor or assign may use your personal information for the same reasons as set out in this Statement.

Children’s Privacy

Our platforms are not intended for children, and we do not knowingly solicit or collect personal information from children. If we are notified or discover that a child under the age of 13 has submitted personal information to us, we will take reasonable steps to delete the information.

Cookies, Pixels, And Related Technologies

We may collect certain information from pixel tags, web beacons, or similar technologies for web analytics and direct marketing. These technologies are pieces of data stored on the computer or mobile device you are using. We use these technologies to allow us to recognize the device you are using, save your selections and preferences, and provide you with a more customized and beneficial experience on our websites, including providing the functionality that allows you to interact with a representative while you are on some of our websites.

If you want to know more about cookies, what they are, the different categories, and how we use them, please scroll down to the next section: Cookie Details.

Third-Party Technologies

We may use Facebook Products (as defined by Facebook, which includes Messenger, Instagram, and Audience Network) that enable us to follow the actions of visitors to our websites who are redirected to our websites after clicking on a Facebook advertisement; record the efficacy of Facebook advertisements for marketing, statistical, and market research purposes; and serve targeted advertisements on Facebook that match interests determined by your activity on our websites and deliver ads on other websites within the Facebook Audience Network. For further information on Facebook's data collection and use and about your rights and options to protect your privacy, please refer to Facebook's data protection policies. You also can deactivate the Facebook Conversion Tracking Pixels.

We may use Google Marketing Platform, Google Ad Manager, and Google Display Network for marketing and remarketing purposes and may allow third parties, including our service providers, advertising companies, and ad networks, to display advertisements on our websites. This technology enables (a) users who have already visited our websites and have shown interest in our products or services to see targeted advertising on websites within the Google partner network and (b) us to provide targeted advertising based on user interest. These companies may use tracking technologies to collect information about users who view or interact with their advertisements. This information allows them to deliver targeted advertisements and gauge their effectiveness. More about Google Marketing Platform and Google Ad Manager may be found here. If you would like to opt out of such ad targeting from Google, please visit the Google Ads settings page here.

You may set your browser to block, refuse, reject, or delete cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use particular functionality, and access certain content on our websites. We only use cookies or related technologies as your browser permits. For more information about cookies or if you do not want data collected with cookies, visit allaboutcookies.org, aboutads.info, and networkadvertising.org.

By continuing to use our websites you agree to our placing cookies, pixels, beacons, and other related technologies on your computer or mobile device. Based upon your jurisdiction, we will provide you with the appropriate consent or notice related to the use of these technologies.

Cookie Details

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Functional Cookies
These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.

Targeting Cookies
These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Click to Chat

We use third-party software to proactively initiate or offer online chat if we believe you would benefit from assistance. All information you enter via online chat may be associated to your email address and will be stored in our systems with any other information you provide and any transaction details.

Sweepstakes

On occasion, we conduct sweepstakes that entitle the winners to prizes. Each sweepstakes has its own terms and conditions. As part of entering a sweepstakes, certain personal information such as name and email address will generally be required. We may use this information to send future communications about specials and offers.

Careers

We use third-party service providers that provide applications, tools, databases, or websites that assist us in collecting the personal information of individuals who wish to be considered for potential employment. The information you provide as part of your application for employment is accessible to MVWC and may be shared among MVWC, its Affiliates, and recruiters working on behalf of MVWC or its Affiliates for the purpose of managing your application for employment, including administering the application, arranging interviews, applicant selection, scoring, assessment, issuing offers to successful candidates, and to comply with legal and regulatory requirements. MVWC uses the information provided for its (a) legitimate interest in fully assessing applications to ensure that only appropriate candidates are assessed and selected and (b) legal obligations to comply with employment laws and other legal and regulatory requirements.

Other Companies and Sites

Our Platforms may contain links to third-party sites that might be of interest to you (such as airlines or car rental companies). We are only responsible for the privacy statement and content of our Platforms. We are not responsible for, and have no control over, the privacy practices or data collection, use, disclosure, or security practices of any other company, such as airlines, car rental companies, Facebook, Google, or any other provider or website.

Platform Survey

We value your input. If you accept, we welcome your participation in surveys regarding the usefulness of our Platforms. We will only use the information you provide for research and analysis, and possibly to contact you to address customer service matters.

Region-Specific Privacy Provisions

Our Platforms are generally operated from the United States in accordance with laws of the United States, and visitors to our Platforms should be aware that the laws of the United States may differ from those of your country of residence.

Australia
Where personal information has been collected about you by an Affiliate that is incorporated in Australia, you are entitled to access the information we hold about you. You can do this by making a request for access to our Privacy Officer using the contact details set out on the first page of this Statement.

If information we hold about you is incorrect, we would like to know so that we can promptly correct this. You have a right to seek the correction of incorrect information we hold about you. In certain situations, we may not agree to a request to correct information we hold about you. If this occurs, we will advise you of this and our reason for not agreeing to the correction request.

If you want to make a complaint about our handling of personal information about you, we ask that you contact us as a first step. We will then follow our internal Compliant Handling Process to seek to address and resolve your complaint. You can contact us to lodge a complaint using the contact details for our Privacy Officer set out on the first page of this Statement.

If, for any reason, your complaint remains unresolved, you may refer the matter to the Office of the Australian Information Commissioner (OAIC). The contact details for the OAIC are:

The Office of the Australian Information Commissioner
GPO Box 2999
Canberra, ACT 2601
Australia
Phone: 1300-363-992
Fax: 02-9284-9666
Website: oaic.gov.au

European Economic Area (EEA) and Switzerland
For residents of the European Economic Area (EEA), the following additional privacy elements apply to you:

We are committed to protecting your privacy and will only use your personal information in accordance with applicable data protection legislation, including the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016) and implementing legislation.

Lawful Basis for Processing Personal Information
The lawful basis for our collection and use of your personal information described in this Statement is that the processing is (i) necessary for our legitimate interests in carrying out our business, provided those interests are not outweighed by your rights and interests; (ii) necessary to perform a contract with you; (iii) necessary to comply with a legal obligation; or (iv) based, when necessary, on your consent.

Cookies & Related Technologies
When you visit our websites, you will be asked to consent to cookies, which are described in this Statement and the Table.

Disclosure and Cross-Border Transfer
Personal information that is shared with third parties as described in this Statement is done pursuant to contracts that include the requisite protections under the GDPR.

We are a global company, and your personal information will be shared among us and transferred outside of your country of residence. In accordance with GDPR, personal information that is transferred outside of the European Economic Area is conducted in accordance with compliant arrangements such as data transfer agreements that contain standard data protection clauses adopted by the European Commission that provide safeguards for such transfers or legally recognized certifications.

Special Categories of Data
We request that you do not send to us (unless we specifically request) any Special Categories of Data, which is defined under the GDPR as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric characteristics, health, or sexual orientation.

How to Contact Us Concerning Your Personal Information
If you wish to "opt out" of our direct marketing communications you receive, you may make the request via our Privacy Portal and select "Opt Out" under the select request section or send us a letter at the address stated in our "How to Contact Us" section of this policy. Once we receive and process your request we will cease using the information for such purposes at no charge to you.

If you would like to request access to your personal information; to rectify such information when it is inaccurate or incomplete; to cancel or delete your personal information; to oppose the use your information for a specific purpose; or to revoke consent previously granted to the extent permitted by law, please send us your request via our Privacy Portal or by mail:

Marriott Vacations Worldwide Corporation
Attn: Privacy Office
9002 San Marco Court
Orlando, Florida 32819
United States of America

We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any matters related to the use and disclosure of your personal information.

Hong Kong
For residents of Hong Kong, the following additional privacy elements apply to you:
Our Platforms do not collect personal information from your computer or mobile device when you browse and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personal information, we will not know your name, your email address, or any other personal information. When you request a page from our Platforms, our servers log the information provided in the HTTP request header including the Internet Protocol (IP) address, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our Platforms function correctly and provide the functionality that you see on our Platforms. We also use this information to understand how visitors use our Platforms and to permit us to adjust its contents and functionality to meet their needs.

When you visit our Platforms, our server software records the domain name of your computer and its IP address. We may also track the pages you visit within our sites. We do these things so that we may measure website traffic, gauge the popularity of various parts of our Platforms, gain some general knowledge about your preferences, and compile aggregated statistics to improve the visitor's experience.

Data that we collect is used only for the purposes indicated within this Statement or as stated within materials you receive requesting your consent. We utilize your personal information for purposes, which include, but are not limited to:

• To better service your account and preferences by keeping you informed of your account status and activities through printed or electronic statements.
• To process payments that you elect to make online.
• To assess your entitlements to benefits.
• To collect and process charges you incur in our facilities.
• To offer you additional products and services.
• To send periodic satisfaction or market research surveys.

Personal information will not be disclosed to any third party except as noted below:

• On a confidential basis to trusted affiliates in the ordinary course of our business, such as for data management and distribution of our promotional materials.
• As we may be required to disclose by law.
• To process payments that you elect to make online.
• As you indicate your choice to receive promotional materials from third parties within forms you receive.

If you wish to "opt out" of our direct marketing communications you receive, you may make the request via our Privacy Portal and select "Opt Out" under the select request section or send us a letter at the address stated in our in our "How to Contact Us" section of this policy. Once we receive and process your request we will cease using the information for such purposes at no charge to you.

Please note that sweepstakes or similar promotions offered to residents of Hong Kong will only occur in accordance with Hong Kong laws.

If you have any questions or privacy concerns, please contact us via the Privacy Portal or send us a letter at the address stated in our our "How to Contact Us" section of this policy.

Malaysia
For residents of Malaysia, the following additional privacy elements apply to you:
MVWC, its Affiliates, and its successors collect and maintain data, including your personal details (provided by you voluntarily on an MVWC or Affiliate website or otherwise, in connection with a marketing event or purchase transaction, as a member of the Marriott Bonvoy program or otherwise), such as name, address, telephone and facsimile numbers, email addresses, occupation, government-issued ID number, nationality, and passport number, in databases controlled by MVWC, its Affiliates, or any service providers and third parties (including auditors) engaged by MVWC, its Affiliates, or any successors, in Singapore, Hong Kong, the United States, or elsewhere and your providing personal information shall be deemed to be your consent to the processing, use, transfer, and disclosure of such data by MVWC to and/or by its Affiliates worldwide.

Mexico
For residents of Mexico, the following additional privacy elements apply to you:

Data Controller
Promociónes Marriott, S.A. de C.V.
Andres Bello No. 29
Polanco, Mexico City 11560
Mexico

Promocines Marriott, S.A. de C.V. is an affiliate of MVWC (MVWC and Promocines Marriott, S.A. de C.V. are collectively referred to as "MVWC" in this Statement).

Use of Your Information

Personal data that we collect is used only for the purposes contained in the Information We Collect and Its Uses section of this Statement or as stated within materials you receive, including, but not limited to:

• To better service your account and preferences by keeping you informed of your account status and activities through printed or electronic statements;
• To process payments that you elect to make online.
• To assess your entitlements to benefits.
• To collect and process charges you incur in our facilities.
• To offer you additional products and services.
• To send periodic satisfaction or market research surveys.

In accordance with the Federal Law on Protection of Personal Data Held by Private Parties and its accompanying regulations, you consent to the processing of your personal data in accordance with the provisions of this Statement unless you express your objection in the manner provided for under the Your Rights section of this Statement. We may process financial or asset information to provide you with our products and services for the purpose of fulfilling obligations under a legal relationship between you and us.

Options to Limit the Use of Your Information
If you wish to "opt out" of our direct marketing communications you receive, you may make the request via our Privacy Portal and select "Opt Out" under the select request section or send us a letter at the address stated in our in our "How to Contact Us" section of this policy. Once we receive and process your request we will cease using the information for such purposes at no charge to you.

Your Rights
You have 5 (five) days after this Statement has been brought to your attention to refuse to allow the processing of your personal information for purposes that are different than those that are necessary and create a legal relationship between you and us; otherwise, you are deemed to have consented to such processing. You also have the right to access your personal information; to rectify such information when it is inaccurate or incomplete; to cancel or delete your personal information; to oppose the use your information for a specific purpose; or to revoke consent previously granted to the extent permitted by law. If you cancel or revoke our ability to use certain personal information, we may not be able to provide certain goods and services to you.

To exercise any of the rights described above, please contact our Privacy Officer via the Privacy Portal. You must include (a) your full name, (b) your contact information, including your mailing address, email address, and telephone number; (c) the right you wish to exercise; (d) proof of your identity or your legal representative; and (e) any other information, item, or document that will assist us in locating your personal data.

We will respond to your request within 20 (twenty) days after receipt of your request and verification of your identity or any longer period permitted by law. We may contact you (i) to request additional information from you if we are not able to verify your identity from the information you provide in your email request; (ii) to inform you of the timeframe within which you will receive a response to your request; (iii) to provide you with directions on how you must submit your request, including the forms you can use to submit your application, if any, and; (iv) to inform you about how we will deliver to you the information you requested (which usually would be copies of documents or information).

Data Transfers
We may transfer your personal data as provided for in the Disclosure of Information to Third Parties section of this Statement. Such transfer is among affiliates of MVWC, including Promociónes Marriott, S.A. de C.V., to third parties who are necessary for providing our goods and services to you, to affiliates of MVWC or third parties that are necessary pursuant to our legal relationship with you. We will seek your consent when required if such transfer is not for the stated purposes identified in this Statement.

Changes or Updates
We reserve the right at any time to modify or update this Statement. You can verify whether this Statement has been changed or updated by referencing the updated revision date, which is contained in the Privacy Statement Changes section of this Statement. Changes or updates to this Statement are effective as of last updated date. Your continued use of our Platforms or our products or services after last updated date of this Statement represents your consent to any changes or updates to this Statement.

Singapore
For residents of Singapore, the following additional privacy elements apply to you:
Our Platforms do not collect personal information from your computer or mobile device when you browse and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personal information, we will not know your name, your email address, or any other personal information. When you request a page from our Platforms, our servers log the information provided in the HTTP request header including the Internet Protocol (IP) address, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our Platforms function correctly and provide the functionality that you see on our Platforms. We also use this information to better understand how visitors use our Platforms and to permit us to adjust its contents and functionality to meet your needs.

Your providing personal information shall be deemed to be your consent to MVWC, its Affiliates, and its successors to the collection, use, processing, disclosure, and transfer of such information as described in this Statement or as stated within materials you receive requesting your consent. Data that we collect is used only for the purposes indicated within this Statement or as stated within materials you receive requesting your consent. We will protect your personal data in accordance with the Personal Data Protection Act 2012 (No 26 of 2012). The use and transfer of your personal data may result in your data being transferred outside of the location in which it is collected to the United States or other jurisdictions. If your data is transferred outside of the location in which it is collected, we will protect your personal data in accordance with a standard comparable to the protection under the PDPA.

By continuing to use our websites, you agree to our placing cookies on your computer in order to analyze the way you use our websites, provide you with enhancements and customized content, and improve your browsing experience while on our websites.

Please view our Cookies and Related Technologies Table for more details about the information we collect when you use any of our websites.

If you do not wish to accept cookies in connection with your use of our websites, you must disable the acceptance of cookies within your browser or stop using our websites. Note, if you disable the use and acceptance cookies within your browser, many features and benefits within our websites, and other websites across the Internet, will no longer be available to you.

If you have any questions relating to our collection, use, or disclosure of personal data, privacy concerns, or would like to make corrections to personal data you have shared with us, please contact Simona Chan at 65-6877-6118, during regular Singapore business hours at This email address is being protected from spambots. You need JavaScript enabled to view it. or send a letter to:

MVCI Asia Pacific Pte. Ltd.
8 Temasek Blvd.
#09-01/02 Suntec Tower 3
Singapore 038988
Attn.: Data Protection Officer

People's Republic of China (PRC)
We do not collect personal sensitive information directly from people with limited capacity for civil conduct and those with incapacity for civil conduct, such as minors under the age of 16. If indeed necessary, personal sensitive information of such subjects shall be collected after acquiring expressed consent from the legal custodian of the said people.
You consent and allow MVWC and its Affiliates and successors to collect and maintain data, including your personal details (provided by you voluntarily on our Platforms, in connection with a marketing event or purchase transaction, as a member of the Marriott Bonvoy program or otherwise), such as name, address, telephone and facsimile numbers, email address(es), occupation, government issued ID number, nationality and passport number, in databases controlled by us and/or any service providers and third parties (including auditors) engaged by MVWC, its Affiliates, or any successors, in Singapore, Hong Kong, the United States or elsewhere, and consent to the processing, use, transfer, and disclosure of such data by us to and/or by its Affiliates worldwide and to their agents and partner companies, to: verify your identification; complete any purchase transaction; administer your Club Membership; send commercial messages (to your address, email, telephone number or otherwise); advise you of other offers and information; carry out general record keeping and maintain a list of current and former Club Members; create informational or analysis reports; supplement your disclosed information; carry out verifications, mailhouse, planning, or other legitimate business needs in connection with the improvement of the Club membership experience, the provision of related services and the management thereof; allow for revenue collection or debt recovery; respond to queries by you or others who have been identified by you as your authorized representative or proxy; and such other purposes as permitted by applicable law. MVWC, its Affiliates, and its successors shall permit third parties to have, process, use, and disclose your data only for purposes as necessary to assist MVWC, its Affiliates, and its successors to achieve the foregoing. We will protect your details in accordance with applicable data protection laws. The use and transfer of this information may result in personal data being transferred outside of the location in which it is collected to the United States, Singapore, and other jurisdictions. We will protect your details in accordance with applicable data protection laws and shall take steps to ensure any transferees do the same.

United States
For residents of the United States, the following additional privacy elements apply to you:

If you receive an email that looks like it is from us but asks you for your credit card or social security number, it is a fraudulent email or "phish." We recommend that you do the following:

• Forward the email to the U.S. Federal Trade Commission at This email address is being protected from spambots. You need JavaScript enabled to view it. or call 1-877-FTC-HELP (1-877-382-4357) to report it. The FTC uses the spam stored in this database to pursue law enforcement actions against people who send deceptive email.
• Delete the email.

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. You can learn more about what information we collect by visiting our Cookies and Related Technologies Table.

California residents: If you are a resident of the State of California, please see our Supplemental Privacy Notice for California Residents section.
If you have any questions or privacy concerns, please contact us via the Privacy Portal or send us a letter at the address stated in our our "How to Contact Us" section of this policy.

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, 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.

Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.

Categories of personal information as set forth in the CCPA Personal information we collect: 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. 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: 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 recordings (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, attitudes, 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 aboutads.info and 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 via the Privacy Portal or at 888-914-9661 Pin: 401282. Please complete the form as completely as possible, some of the information we need is: a) full name, b) email address, c) Owner number (if applicable), d) Marriott Bonvoy number (if applicable), and e) cell phone associated with your account. 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 the same information as previously stated 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 via the Privacy Portal or by sending a letter to:

Marriott Vacations Worldwide Corporation
(Attn: Privacy Officer)
9002 San Marco Court
Orlando, FL 32819

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.

How to Contact Us

If you have any questions about this Privacy Policy, concerns about our information-handling practices, or you would like to submit a data subject access request please notify us via our Privacy Portal or our postal address listed below. Our Privacy Officer also serves as our Grievance Officer and on behalf of our Privacy Department, as may be required under applicable countries' and other jurisdictions' regulations.

Marriott Vacations Worldwide Corporation
Attn: Privacy Officer
9002 San Marco Court
Orlando, Florida 32819
United States of America
Colombia: 1-800-011-0204

Also, if you do not want us to use your personal information for our direct marketing purposes, you may contact us at the Privacy Portal and select "Opt Out" under the select request section. We will cease using the information for such purposes at no charge to you. Meeting your needs and expectations form the foundation of everything we do. - including protecting your privacy.

Privacy Statement Changes

We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the effective data at the bottom of this policy. If we make any material changes in the way we collect, use, or share your personal information, we will make all changes here so that you will always know where to go to understand what information we gather, how we might use that information, and whether we will disclose it to anyone. We recommend that you check our website from time to time to keep yourself informed.