Privacy Policy

Throughout your interactions with Westgate we collect Personal Data in accordance with the law, and to provide you with exemplary services. Personal Data is information that may identify you as an individual or relate to you as an identifiable individual. We collect and process the following types of Personal Data about you:

General Identifying Information

Including full name, postal address, e-mail address, telephone number, social media account ID, profile photo and other data made publicly available, or data made available by linking your social media and loyalty accounts, or other similar identifiers.

Demographic Information and Important Dates

Including gender, language preferences, nationality, or birthdays.

Government-Issued Identification

Including passport, visa, or other government-issued identification (and the Personal Data contained therein).

Financial Information

Including credit, debit, or other payment data. We may also collect information regarding your credit score and accounts if you become a member of one of our loyalty programs or purchase a property or time share.

Loyalty Program Information

Including membership or loyalty program data, co-branded payment cards information, and travel partner program affiliations.

Travel Information

Including prior guest stays or interactions (including interactions via our chat functionalities), goods and services purchased, special service and amenity requests, travel itinerary, tour group information, activity data, or employer details (for business-related bookings).

In more limited circumstances, we may also collect:

• Data about family members and companions (including names, and ages of children);

• Biometric data; and

• Images, videos, and audio data via: (a) recordings of your voice (such as when we record customer service calls for quality assurance); (b) security cameras located in public areas, such as hallways and lobbies, in our properties or camera’s worn by our security personnel.

If you submit any Personal Data about other people to us or our Service Providers (e.g., if you make a reservation for another individual), you represent that you have the authority to do so and you permit us to use the data in accordance with this Privacy Statement.

We may also collect “Other Data” that does not directly identify you. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data.

Other Data includes:

System Data: When you use both desktop and mobile devices to access the Online Services, we collect certain data through your browser or automatically through your device, such as your computer type, screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services you are using.

IP Address: We also collect your IP address, a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.

Precise Location-Based Services: With your consent, we may collect the precise geolocation of your device by using satellite, cell phone tower, Wi-Fi signals, or other technologies. We will collect this data if you opt-in through the App or other program (either during your initial login or later) to improve special offers and to enable location-driven capabilities on your device. If you have opted-in to share your location, the App or other program will continue to collect location data based on how you choose to share the data.

• Precise Location Choices: You can specify via your device operating system (such as through the “Settings” icon) to always share location data, only when the App is in use, or never. If you choose only when the App is in use, we will have access to the data until you log off or close the application or until you use your phone or other devices settings to disable location capabilities for the App or another program.

Cookies and Similar Technologies on our Websites:

When you visit our Websites from either a desktop or mobile device, we may collect and use cookies or other identifiers to serve you with personal advertisements for Westgate and third-party products, via email, on our Websites, or on other websites on the Internet; to measure how you interact with our Websites; and to maintain your preferences. We do this primarily through cookies, which are pieces of data stored directly on the computer or mobile device that you are using. We do not currently respond to browser do-not-track signals.

You can learn more about cookies at: http://www.allaboutcookies.org/manage-cookies/index.html↗.

In general, we use four different types of cookies:

• Strictly Necessary Cookies: These cookies are necessary to enable the basic features of our Websites and Apps, such as providing a secure log-in or booking a stay.

• Functional Cookies: These cookies allow our Websites and Apps to remember your site preferences and choices you make on the site. We also use functional cookies to facilitate navigation, to display content more effectively, and/ or to personalize your experience.

• Advertising Cookies: Advertising cookies allow us to select which advertisements or offers are most likely to appeal to you. We also use them to track responses to online advertisements and marketing, and we may use them to better understand your interests so we can present you with relevant messages and offers. These cookies may us used to gather more information about you such as your email address so we can market Westgate products and services to you.

• Analytics Cookies: Analytics cookies help us improve our Websites and Apps by collecting and reporting information on how you use it.

Cookie Choices

There are several ways to opt-out of cookies, if however, you do not accept any cookies, you may experience some inconvenience in your use of the Online Services. For example, we will not be able to recognize your computer, and you will need to log in every time you visit. You may not receive advertising or other offers from us that are relevant to your interests.

There are several ways to manage cookies:

1. Browser settings: You can opt out of cookies on your browser. Every browser is different, please check the instructions provided by your browser.

2. Through the Tracking Preferences page.

3. Google Analytics: We collect data through Google Analytics, which use cookies and technologies to collect and analyze data about use of the Online Services. These services also collect data regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/↗ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout↗.

4. Submitting a Data Request: Depending on where you reside, you might have certain rights regarding the use of your personal data, which may include the right to limit the use of cookies for certain advertising purposes. To submit one of these requests, please visit our Data Requests page.

Advertising Choices

We may use third-party advertising companies to serve advertisements on our Websites, Apps, and other websites regarding both Westgate and third-party goods and services that may interest you when you access and use the Online Services or other websites or online services. You may receive advertisements based on information relating to your access to and use of the Online Services and other websites or online services on any of your devices, as well as on information received from third parties. We may also recive your email address from these third parties, and send you markeing emails for products or services that you might be interested in.

To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn about your choices in connection with it, please visit http://www.networkadvertising.org/managing/opt_out.asp↗ and http://www.aboutads.info/↗, http://www.youronlinechoices.eu↗ or https://business.safety.google/privacy/↗.

For the advertisements you see on the Online Services, you can also opt-out:

• directly in the ad by clicking on the AdChoices icon;

• by opting out of Advertising Cookies in our “Tracking Preferences” page; or

• by visiting https://business.safety.google/privacy/↗.

To learn more about how we Sell and Share Other Information for Purposes of Cross-Context Behavioral Advertising, please review our Collection Sale and Disclosure of Personal Data section of this policy.

Apps and Mobile Devices

We collect certain data when you download and/or use an App, such as App usage data, the date and time the App on your device accesses our servers, and what data and files have been downloaded to the App based on your device id. We use this data to ensure that the Online Services function properly.

With your consent if required by the operating system and/or applicable law, we may also collect mobile device advertising identifiers to enhance and personalize your experience and deliver relevant products, content, or ads to show you on our Websites, Apps, or through external advertising.

Chat Technologies

If you use our automated chat functionalities or AI-powered chat technologies, we collect the Personal Data that you submit to provide, improve, or develop the chat functionality, so we can better respond to your and other customers’ future interactions. If you choose to use our automated chat functionalities, you understand that Westgate and our third-party service providers will be using the information in the chat for quality and training purposes. We may employ third-party service providers to assist with providing the chat functionalities. By using these chat services, you understand and agree that these third parties may have access to your personal information and may share that information with Westgate and other service providers.

We collect and use information we believe is necessary to provide you with the products and services you request while also promoting our business. We collect and gather information from a variety of sources and in a variety of ways, such as, but not limited to, the following:

1. You may provide information to us when you sign up for rewards programs; book a room reservation through our Websites, reservations call center or online travel agency; sign up to receive marketing, promotions or offer emails or text messages from us; install or use one of our mobile apps (i.e. WGLV Casino and WGLV SuperBook apps); enter a promotion or contest; request information from us; provide personal identification information to us at hotel check-in; submit an application for employment; and/or apply for credit or provide feedback to use in an online satisfaction survey.

2. When you visit our property, Websites, or purchase and use our products or services, you may provide us with your payment card information, financial account information, driver’s license number, license plate number, photo identification card number, social security number, passport number, or we may obtain videos, recordings, and images of you.

3. If you install or use one of the mobile apps, we may collect and use information regarding your mobile device, including but not limited to technical information about your mobile device, system and application software, peripherals, and location information, including GPS.

4. When you visit our Website, we may use a pixel or other third-party tracking technology that may allow us to obtain more of your personal information, such as your email address, even if you have not provided it to us directly. To limit the use of these technologies please visit the Tracking Preferences page.

5. We may obtain information about you from other sources, including third parties or publicly available sources, which we consider personal information when aggregated with information you have provided us as described above. We may use third parties to provide, confirm or supplement for us other information based on the information you provided to us directly. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices.

6. 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.

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

Careers and Text/SMS Communications for Job Applicants

We use third parties 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 Westgate and may be shared among Westgate, its Affiliates, and recruiters working on behalf of Westgate 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. Westgate 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.

Central Florida Investments, Inc., as parent company of Westgate Resorts, Inc. and together with its related and affiliated entities (“Affiliates”) (collectively “Westgate”, “we”, “us” or “our”) offers you the option to engage in SMS text conversations about your job application. By participating, you also understand that message frequency may vary depending on the status of your job application, and that message and data rates may apply. Please consult your carrier for further information on applicable rates and fees. Carriers are not liable for delayed or undelivered messages. Reply STOP to cancel and HELP for help.

By opting-in to receiving SMS text messages about your job application, you acknowledge and agree that your consent data, mobile number, and personal information will be collected and stored solely for the purpose of providing you with updates and information related to your job application. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

The following chart details categories of Personal Data we collect, as well as categories of Personal Data we have collected and disclosed for operational business purposes in the preceding 12 months. The chart also details the categories of Personal Data that we “sell” or “share” for purposes of cross-context behavioral or targeted advertising, including within the preceding 12 months.

For purposes of this Statement, “sold” or “sale” means the disclosure of Personal Data for monetary or other valuable consideration but does not include, for example, the transfer of Personal Data as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business. For the categories below, Westgate “sells” or “shares” the data solely for the purposes of Marketing and Promotion.

Categories of Personal Data

Identifiers, such as name, nationality, passport, visa or other government-issued ID, and online identifiers

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

-Service Providers

-Franchisees

-Owners

-Homes and Property Management Companies

-Strategic Business Partners

-Third Parties (for purposes of approved Linked Accounts and Promotional activities)

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

-Advertising Partners

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

-Advertising Partners

Processing Purposes

-Booking & Guest Registration

-On-Site Reception & Stay Services

-Conferences & Events

-Operations & General Business

-Emergency & Incident Response

-Legal & Compliance

-Spa, Beauty, Golf & Fitness Services

-Food & Beverage Services

-Child-Related Services (for Parents & Legal Guardians)

-Loyalty Programs, Accounts & Relationship Management

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Personal information, as defined in the California safeguards law, such as name, contact information, government-issued ID, and financial information

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

Service Providers

-Franchisees

-Owners

-Homes and Villas Property Management Companies

-Marketing Partners

-On-Property or Travel Partners

-Strategic Business Partners

-Third Parties (for purposes of approved Linked Accounts and Promotional activities)

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

-Advertising Partners

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

-Advertising Partners

Processing Purposes

-Booking & Guest Registration

-On-Site Reception & Stay Services

-Conferences & Events

-Emergency & Incident Response

-Legal & Compliance

-Spa, Beauty, Golf & Fitness Services

-Food & Beverage Services

-Child-Related Services (for Parents & Legal Guardians)

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Characteristics of protected classifications under California or federal law, such as gender, age, medical conditions, primary language, national origin, citizenship, and marital status

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

-Service Providers

-Franchisees

-Owners

-Homes and Property Management Companies

-Authorized Licensees

-On-Property or Travel Partners

-Strategic Business Partners

-Third Parties

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

-Advertising Partners

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

-Advertising Partners

Processing Purposes

-Booking & Guest Registration

-On-Site Reception & Stay Services

-Conferences & Events

-Operations & General Business

-Emergency & Incident Response

-Legal & Compliance

-Spa, Beauty, Golf & Fitness Services

-Food & Beverage Services

-Child-Related Services (for Parents & Legal Guardians)

-Loyalty Programs, Accounts & Relationship Management

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Commercial information, such as transaction information, purchase history, financial details, payment methods, and membership or loyalty program data

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

Service Providers

-Franchisees

-Owners

-Homes and Villas Property Management Companies

-Authorized Licensees

-On-Property or Travel Partners

-Strategic Business Partners

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

-Advertising Partners

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

-Advertising Partners

Processing Purposes

Booking & Guest Registration

-On-Site Reception & Stay Services

-Conferences & Events

-Operations & General Business

-Spa, Beauty, Golf & Fitness Services

-Food & Beverage Services

-Child-Related Services

-Loyalty Programs, Accounts & Relationship Management

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Internet or network activity information, such as browsing history and interactions with our and other websites and computer systems

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

-Service Providers

-Governmental Agencies (if required)

-Geolocation data, such as device location and IP location

Categories of Third Parties to Whom Personal Data Has Been Sold

-Advertising Partners

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

-Advertising Partners

Processing Purposes

-Booking & Guest Registration

-On-Site Reception & Stay Services

-Conferences & Events

-Operations & General Business

-Legal & Compliance

-Spa, Beauty, Golf & Fitness Services

-Food & Beverage Services

-Child-Related Services (for Parents & Legal Guardians)

-Loyalty Programs, Accounts & Relationship Management

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Geolocation data, such as device location and approximate location derived from IP address

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

-Service Providers

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

-Advertising Partners

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

-Advertising Partners

Processing Purposes

-Booking & Guest Registration

-Operations & General Business

-Emergency & Incident Response

-Legal & Compliance

-Loyalty Programs, Accounts & Relationship Management

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

-Service Providers

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

Westgate does not sell or share this data

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

Westgate does not sell or share this data

Processing Purposes

Booking & Guest Registration

-Conferences & Events

-Operations & General Business

-Emergency & Incident Response

-Legal & Compliance

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Inferences drawn from any of the Personal Data listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

-Property Management Companies

-On-Property or Travel Partners

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

-Advertising Partners

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

-Advertising Partners

Processing Purposes

-Booking & Guest Registration

-On-Site Reception & Stay Services

-Conferences & Events

-Operations & General Business

-Spa, Beauty, Golf & Fitness Services

-Food & Beverage Services

-Marketing, Promotions, Contests & Third-Party Products

Categories of Personal Data

Sensitive Personal Data

-Personal Data that reveals an individual’s Social Security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, citizenship, immigration status, or union membership; the contents of mail, email, and text messages unless Westgate is the intended recipient of the communication; genetic data;

-The processing of biometric information for the purpose of uniquely identifying an individual;

-Personal Data collected and analyzed concerning an individual’s health;

-Personal Data collected and analyzed concerning an individual’s sex life or sexual orientation;

-Personal Data collected from a known child.

Categories of Third Parties to Whom Personal Data Has Been Disclosed for Operational Business Purposes

-Service Providers

-Governmental Agencies (if required)

Categories of Third Parties to Whom Personal Data Has Been Sold

Westgate does not sell or share this data

Categories of Third Parties to Whom Personal Data Has Been Shared for Cross-Context Behavioral or Targeted Advertising

Westgate does not sell or share this data

Processing Purposes

Booking & Guest Registration

-On-Site Reception & Stay Services

-Conferences & Events

-Operations & General Business

-Emergency & Incident Response

-Legal & Compliance

-Spa, Beauty, Golf & Fitness Services

-Food & Beverage Services

-Child-Related Services

-Marketing, Promotions, Contests & Third-Party Products

As a company that conducts activities that are financial in nature, Westgate is a “financial institution” as that term is defined in the Gramm-Leach-Bliley Act (“GLBA”). While the CCPA does not exempt financial institutions, Section 1798.145(e) of the CCPA does exempt personal information collected by a financial institution pursuant to the GLBA.

Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information otherwise excluded from the CCPA’s scope, such as information collected pursuant to the GLBA.

We have obtained the categories of personal information listed above from the following categories of sources:

1. Directly from you. For example, from forms you complete or products and services you purchase.

2. Indirectly from you. For example, from information we obtain in the course of providing our services to you, or from observing your actions on our website.

3. From third-party business partners including, but not limited to, social media sites, ad networks, and analytics providers.

We do not knowingly “sell” or “share” the Personal Data, including the Sensitive Personal Data, of individuals under the age of 16.

We may also use and disclose Personal Data to a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Legitimate Business Interests/Purposes for Collecting Information

We may use the Personal Information you provide to Westgate to verify your identity, complete your transaction, administer your memberships associated with Westgate, 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 Westgate, 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.

We may use information provided to Westgate for Marketing Purposes including ‘Targeted Marketing’ which generally include, but are not limited to, the operation of our rewards programs and notifying you about promotions and special offers regarding products and services provided by Westgate, contacting you via email or text message, and contacting you in response to your inquiries, comments and suggestions. These notifications are provided via our Websites, mobile apps, direct mail or email, text messages, or by telephone. Depending on your location, you may have certain rights regarding the Personal Data we collect. To review these rights or submit a request, please visit our Data Requests page.

We may use information provided to Westgate for Non-Marketing Purposes, which generally include, but are not limited to, validating your identity, recording gaming-related activity, issuing credit and collecting debt, facilitating reservations and processing purchase transactions from payment cards or other financial transactions, conducting market research and to improve customer service, complying with legal and regulatory requirements, satisfying contractual obligations and application for employment verifications.

We may 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 Westgate, owners, guests, visitors, associates, or property (including our Websites), or to others, prevent fraud, or cooperate with law enforcement or other government agencies.

Data from your information may also be used generally for our legitimate business interests/ purposes concerning data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing our services, helping us comply with legal requirements or process, enforcing compliance with our Terms and Conditions or any product, service or program terms and conditions, helping protect our Services, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We also may share certain information with Affiliates and other non-affiliated third parties as permitted by law and as described below under “Disclosure of Information to Third Parties.”

Reservation Information

The Personal Information you provide to us for making a reservation is made available to the applicable property for the purpose of meeting your reservation request. After making a reservation or completing your stay at a Westgate property, unless you tell us otherwise, the information you provide may be used by us and our Authorized Licensees for marketing of Westgate properties and certain other Westgate branded products. Westgate may use the services of third-party mail houses for the sole purpose of mailing materials.

After your stay, we retain your personally identifiable information including details of your stay, room type and accommodation type.

User Generated Content

We may offer platforms for users to submit content such as reviews, message boards or other content. Any information disclosed in these areas becomes public information and you should always be careful when deciding to disclose your Personal Information. We are not responsible for privacy practices of other users including website operators to whom you provide information.

Internet Based Advertising

Westgate and third parties may use the information collected through our Websites using cookies, web beacons, and other technologies to help manage online advertising programs and deliver electronic advertisements that may be more relevant to individual consumers. Please see Cookies and Related Technologies below for more information.

Westgate may ‘sell’ your Personal Data as defined by the applicable data privacy laws as defined in this Statement for the purposes of online advertising. Depending on where you live, you may have certain rights regarding the use or disclosure of your personal data for these purposes. To review your personal data rights or submit a request, please visit our Data Requests page.

Westgate may use the services of third party processors, such as market researchers, fulfillment houses, email service providers and mail houses that process mail for Westgate, Westgate's Authorized Licensees, persons authorized by you, as well as such entities and marketing companies that provide these services for Westgate, and Westgate's Authorized Licensees. We may disclose your information to other third parties who provide services for Westgate, including but not limited to, travel services, financial and/or tax services data hosting or processing, credit card processing, credit or background checks, vacation insurance, website hosting, order fulfillment, information technology and related infrastructure provision, customer service, legal advisers, accountants, auditing, or processing and fulfilling reservations or purchases. These third parties are contractually prohibited from using personally identifiable information for any purpose other than for the purpose Westgate specifies.

Westgate may process, use, transfer and disclose your Personal Information to non-affiliated third party 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 require these providers to exercise reasonable care to protect your personal information and restrict its use to the purposes for which it was provided to them. 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 also 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:

1. Satisfy any applicable law, regulation, legal process or enforceable governmental request;

2. Investigate, prevent or otherwise address fraud, security or technical issues; or

3. Investigate, prevent or protect against harmful activities to Westgate or Affiliates, owners, guests, visitors, associates, or property (including our Websites), or to others, as required or permitted by law.

We may provide non-personally identifiable information to certain third parties who provide services for Westgate for their use on an aggregated basis for the purpose of performing their contractual obligations to us. Westgate and these third parties may collect usage information when you visit and use our Websites and mobile apps. This may include browser type and/or settings, operating system, page(s) served, the time, request source, preceding page view, and similar data. We may analyze this information and use it to help us determine how our Websites and mobile apps are used, such as how visitors arrive at the Websites and mobile apps, what content is popular or most relevant and what type of visitors are interested in certain content or ads. We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and improve our services. We may use such data by itself in anonymized form or aggregate it with information obtained from others. We may share such data with our affiliated companies and third parties to achieve these objectives and others, but the aggregate or anonymized data does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may use it in turn to serve ads tailored to your interests), but this will not personally identify you.

If we subsequently associate your usage data or re-identify anonymized data with Personal Information you provide in a way that allows us to identify you as an individual or for California residents, as part of a household, we will treat the combined data as Personal Information.

We may disclose your Personal Information in relation to the reorganization, sale or disposal of all or a part of our business or assets or the business of any of our Affiliates (whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our 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.

We treat the information you provide to us as confidential information; it is, accordingly, subject to our company's security procedures and policies regarding protection and use of confidential information. When we ask you for credit card data, it is transferred over a Secured Sockets Layer (SSL) line, provided you are using a SSL enabled browser such as Microsoft Internet Explorer or Mozilla Firefox. We also use SSL on other pages where you would enter personally identifiable 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 or web-enabled device. 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.

After information reaches us, it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside of Westgate. Because laws applicable to personal information vary by country, our properties or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the Web sites covered by this privacy statement is generally processed and stored in the United States. We typically maintain records for a minimum of five (5) years.

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 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.

Individual Rights

If you are afforded Individual Rights under applicable law you can exercise these rights by completing the form in our Data Requests page, or by emailing us at privacyprogram@wgresorts.com.

Depending on where you reside, you may have the ability to make the following requests regarding your personal data, subject to applicable law:

Request to Know. You may request to know whether we process your Personal Data and to access such Personal Data. You may request to receive the specific pieces or a copy of your Personal Data, including, where applicable, a copy of the Personal Data you provided to us in a portable format.

Depending on where you reside, you may request that we disclose to you the following information:

• The categories of Personal Data we collected about you and the categories of sources from which we collected such Personal Data;

• The business or commercial purpose for collecting, selling, or sharing (if applicable) Personal Data about you;

• The categories of Personal Data about you that we sold or “shared” and the categories of third parties to whom we sold or “shared” such Personal Data (if applicable); and

• The categories of Personal Data about you that we otherwise disclosed, and the categories of third parties with whom we disclosed such Personal Data (if applicable).

Request to Delete. You may request that we delete your Personal Data.

Request to Correct. You may request that we correct inaccuracies in your Personal Data.

Request to Opt-Out of Sale, Targeted Advertising, and/or Sharing. You may request to opt-out of the “sale” of your Personal Data and/or targeted advertising, including the “sharing” of your Personal Data for cross-context behavioral advertising purposes.

How You Can Request to Know, Delete, Correct, Appeal, or Opt-Out of Sale, Targeted Advertising, and/or Sharing of Your Personal Data

To make a Request to Opt-Out of Sale, Targeted Advertising, and/or Sharing, Know, Delete, or Correct, please contact us via our Data Requests page, or by emailing us at privacyprogram@wgresorts.com. We may request information from you in order to verify your request, such as your name, email address, postal address, phone number, or loyalty number, and then use that information to match it with information we already have. We may also ask you for additional identifiers such as your date of birth or the last four digits of your credit card if we need additional information to verify your identity. We will respond to your request consistent with applicable law.

To Request an Appeal to a prior Individual Rights Request, contact us at privacyprogram@wgresorts.com or through an active open request via our Individual Rights Request portal.

You have the right to be free from unlawful discrimination for exercising your rights under applicable law.

Authorized Agents: If you’re reside in a state that recognizes data privacy requests, and would like an authorized agent to submit a request on your behalf, the agent may do so by using the submission methods noted above. Upon receipt of a Request to Know, Delete, or Correct by an agent, we may ask the resident for written, signed permission that the agent has been authorized by the resident to act on their behalf. Once written authorization is provided, we will open a request for the resident in the portal. We will respond directly to the individual email address provided by the authorized agent regarding the fulfillment of the request, and not in a platform or portal.

Changes To This Privacy Statement

We may change or update this Privacy Statement from time to time. When we do, we will post the revised Privacy Statement on this page with a new “Last Updated” date.

Additional Information

For your protection, we only fulfill requests for the Personal Data associated with the email address and/or loyalty account number that you identify in your request, and we may need to verify your identity before fulfilling certain requests.

We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that all individual rights may not be available under applicable law to all our guests or other users of our Services.

By providing information to us, you are consenting to the collection, use and disclosure of such Personal Information in the manner described in this Statement.

We provide our European consumers with certain rights. To the extent required by applicable law, you have the right to: Request access to your personal data (commonly known as a "data subject access request"); Request correction of the personal data we hold about you; Request erasure of your personal data; Object to processing of your personal data in certain circumstances; Request restriction of processing of your personal data; Request the transfer of your personal data to you or to a third party (data portability); Withdraw consent at any time where we are relying on consent to process your personal data.

We will make a reasonable effort to comply with these requests as required by law. To submit a request, please visit our Data Requests page.

Contact Us

If you have any privacy-related questions or concerns, or would like to make any requests in relation to your Personal Information, your choices, rights, or would like to withdraw consent, you may also write to our customer service department at the following physical address or email address:

Westgate Resorts

Privacy Program

2801 Old Winter Garden Road

Ocoee, FL 34761-2965

Or e-mail us at privacyprogram@wgresorts.com

State-Specific Choices/Opt-Out

Notice to Nevada Residents

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing at Westgate Resorts, Privacy Program, 2801 Old Winter Garden Road, Ocoee, FL 34761. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.

In accordance with SB 220, Nevada residents may opt out of the monetary sale of their personal information collected on-line. The designated email address for these requests is wglvprivacycompliance@wgresorts.com.

This Site is not intended for children or anyone under the age of 16 and we do not knowingly solicit or collect personally identifiable information from children. We may present information regarding Westgate programs that are for kids on this site for the reference of adults that are interested in activities at our locations for children. We do not knowingly collect information from children. If you believe that we have received information from a child or other person who is not of a majority age in their relevant jurisdiction, please contact us at our email or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).

You can access our Site from a web-enabled mobile device to find a property (including clicking to call the hotel) or view a reservation. If you desire to view a reservation you will be required to enter your Westgate account username and password, or Westgate confirmation number and zip/postal code or country. No other personally identifiable information will be requested. In addition, you can make a reservation from a web-enabled device. When you make a reservation, you will need to provide certain personally identifiable information such as name, email address and credit card information. Additionally, you can make payments to Westgate, via credit card, by accessing our website from a web-enabled mobile device. To review the security measures Westgate has in place regarding your credit card data, please review the section below titled Securing the Transmission and Storage of Information ASAS.

It is our intention that you should only receive email communications that will be useful to you and that you want to receive. We may be provided your email address from third party marketing companies and service providers, based on your activity across multiple websites, even if you have not provided it to us directly. We may also give you the opportunity to receive Offers and Promotions from Westgate and, its Affiliates concerning other Westgate-branded offers and promotions that we believe would be of interest to you.

We typically use third party email service providers to send emails. These service providers are contractually prohibited from using your email address for any purpose other than to send Westgate related email.

Each time you receive an email, you will be provided the choice to opt-out of future emails by following the instructions provided in the email. Please allow 10 business days for us to process your opt-out.

We use third parties 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 Westgate and may be shared among Westgate, its Affiliates, and recruiters working on behalf of Westgate 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. Westgate 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.

Our Websites and mobile apps may contain links to third party sites that might be of interest to you (such as airlines or car rental companies). We do not have access to or control over these third-party websites or services, and you should review their individual privacy policies and settings. Westgate is only responsible for the privacy statement and content of this Site and information we collect. We are not responsible for the data collection and use practices and privacy policy or the use of Cookies on websites that you have accessed this Site from and to the non-Westgate websites that you may access from this Site, including but not limited to any other company such as airlines, car rental companies, Facebook, Google, or any other provider or website.

We are not responsible for the privacy policies and/or practices of third parties such social media platform or site providers, RIM or any other app developer or provider, operating system provider, wireless service provider or device manufacturer, and/or any data you disclose to them. We attempt to monitor comments and ratings on social media services or customer review sites and may contact you regarding these postings to address customer service issues. We recommend that you do not post any personal information through our Websites that would allow strangers to identify or locate you or that you otherwise do not want to share with the public.

If you have any questions or comments regarding this policy, please contact us using the information below:

Westgate Resorts

Privacy Program

2801 Old Winter Garden Road

Ocoee, FL 34761-2965

Or e-mail us at privacyprogram@wgresorts.com