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Privacy Notice


Last Updated: May 31, 2021

Click to read the Special Notice for Collection of Personal Information Related to the COVID-19 Pandemic.

Introduction to this Privacy Notice

RCI India Private Limited is a subsidiary of Travel + Leisure Co., and does business as "Panorama." Panorama’s business operations include many subsidiary entities and consists of brands including RCI, Panorama Travel Solutions, 7Across (formerly DAE), The Registry Collection, Extra Holidays, Love Home Swap, TripBeat, @Work International, and Alliance Reservations Network (collectively "Panorama," the “Panorama Group of Companies”we”, “us”, or “our”). We care about privacy issues and want you to be familiar with how we collect, disclose, and otherwise use (“Process”) information about you. This privacy notice (“Privacy Notice”) describes our practices in connection with information we collect through our websites (“Websites”), social media pages we control (“Social Media Pages”), and software applications we make available for use on or through computers and mobile devices (“Apps”), that include a link to this Privacy Notice, and through any of our offline activities, such as when you provide your information on the phone via our call centers or in person (“Offline Activities”) (collectively, including the Websites, Apps, Social Media Pages, and Offline Activities, the “Services”).

Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements, such that our practices may be more limited in such jurisdictions.

Our privacy practices also may vary among entities within the Panorama Group of Companies as well as amongst and between Panorama and Travel + Leisure Co. and any of its other affiliated operating entities (excluding the Panorama Group of Companies, the “T + L Affiliates”) depending upon their function and their offered products and services. Please review the privacy notices linked to or referenced in their respective Services and note that the data controller of your Personal Information will be the T + L Affiliate or Panorama entity which provides the Services to you. The T+ L Affiliate brands can be found here. The Panorama brands can be found here.



California Residents: Click here to read about “Your California Privacy Rights”.

What Information Is Collected and How Is It Collected?

  1. We may collect “Personal Information” (information that identifies you or relates to you as an identifiable person) about you such as your:

    • Name

    • Postal address (including billing and shipping addresses)

    • Phone number

    • Email address

    • Credit or debit card number

    • Financial information in certain circumstances

    • Social media account information

    • Stay, trip, product or service information, such as your preferred location/facilities, dates and number of people/children travelling with you

    • Special needs or conditions that may impact your stay

    • Driver's license, government-issued ID, or passports

    • Geolocation information

    • Communication, product, service or other preferences

    • Your opinions, comments, suggestions, inquiries and other communications you provide to us

    • Demographic information

    • Audio/Visual recordings such as when you call our customer service phone number or participate in having a photo taken for an activity, resort, etc.

    • Internet Click Activity on our websites

    • IP address or Device ID

    • Subscribing Account or Membership ID


  1. We may collect information from you when you interact with us such as when you:

    • Register for, subscribe to, use, or make a payment for a product or service

    • Contact us with a question or request

    • Use our Services

    • Make a reservation

    • Stay at one of our affiliated resorts

    • Provide a testimonial or story, or post or submit a photo, review or comment

    • Participate in a competition, promotional activity or sweepstakes

    • Provide feedback or participate in a survey

    • Participate in any loyalty or other programs

    • “Like”, “Follow” or otherwise connect with or post to one of our Social Media Pages

    • Provide goods or services to us (for example, as a vendor or contractor)



  1. Other information we collect about you:

    • Cookies: Our Services may use “cookies” and similar technologies (collectively, “cookies”). Cookies are small text files this Website sends to your computer for recordkeeping purposes; this information is stored in a file on your computer's hard drive. Cookies make web surfing and browsing easier for you by saving your preferences so we can use these to improve your next visit to our Website.

      • One purpose of cookies is to simplify the use of the Website. For example, cookies may save a user's login details, so that they do not need to login every time.

      • Cookies may be either “persistent” or “temporary” (or “session”) cookies. A persistent cookie retains user preferences for a particular Website allowing those preferences to be used in future browsing sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

      • Cookies are also used for statistical or marketing purposes, to determine how the Website is used. These cookies are provided by us or by third parties (e.g., advertising partners). While we do not control or have access to the advertiser cookies we do permit them to be used on this Website to facilitate tailored advertising and monitor patterns of buying specific goods or interest in - for example, holidays or hobbies. These cookies run advertisements tailored to the user based on your online buying habits.



We use information in a variety of ways, including to analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and to improve our services.

As aggregated, de-identified or anonymized information does not constitute Personal Information, we may use it for any purpose.

Why and How We Use Your Information

We may Process Personal Information in connection with any of the following:

  1. Our business transactions with you, including, but not limited to:

    • Entering into or performing a contract with you

    • Responding to your inquiries and fulfilling your requests

    • Sending administrative information to you, for example, information regarding the Services or an event you are attending

    • Completing and fulfilling any purchases or requests for services

  2. For our legitimate business interests, including, but not limited to:

    • Personalizing your experience on the Services by presenting products and offers tailored to you

    • Allowing you to participate in sweepstakes, contests, and similar promotions, and administering such activities (each of which may have additional rules and could contain additional information about how we Process your Personal Information)

    • Facilitating social sharing functionalities of your social media account(s)

    • Carrying out data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing, improving or modifying our Services, identifying usage trends, auditing use and functionality of our Services, helping enforce compliance with our Terms of Use, helping protect our Services, determining the effectiveness of our promotional campaigns and operating and expanding our business activities

    • Subject to your marketing preferences (which may include consent to marketing under applicable law), sending you newsletters or marketing communications we believe may interest you, for our own products and services, and on behalf of our Panorama Group of Companies, T + L Affiliates or selected third parties, in accordance with applicable law.

  3. In accordance with any consent you may have provided. You have the right to decline to provide your consent and, if consent is provided, to withdraw it at any time.

  4. As necessary or appropriate for legal reasons, including, but not limited to:

    • Under applicable law

    • Complying with legal process

    • Responding to requests from public and government authorities, including those outside your country of residence

    • Enforcing our terms and conditions in connection with the Services

    • Protecting our operations or those of any of the Panorama Group of Companies or T + L Affiliates or other third parties

    • Protecting our rights, privacy, safety or property, or that of the Panorama Group of Companies, T + L Affiliates, RCI affiliated resorts, you, or other third parties

    • Allowing us to pursue available remedies or limit damages we, the Panorama Group of Companies, the T + L Affiliates, RCI affiliated resorts or other third parties, may sustain

When We Disclose Your Information

We may disclose your information as follows:

How Do We Safeguard Your Information?

Other Important Information





Your Choices and Rights

Your Nevada Privacy Rights

Notice to Nevada Residents: If you are a resident of Nevada, under certain circumstances, Nevada Civil Code Section NRS 603A.340 allows you to request operators of websites not to sell your Personal Information. To make such a request, please send an email to our Privacy Group at privacy@rci.com or send a letter to (please indicate the Panorama entity or brand you typically do business with):

RCI India Private Limited

Pine Valley, First Level

Embassy Golf Links Business Park

off Intermediate Ring Road

Bangalore 560 071

India


Your California Privacy Rights

  1. Shine the Light Law: If you are a resident of California, California Civil Code Section 1798.83 allows you to request information regarding the Personal Information we collected and third parties to whom we disclosed your Personal Information for the third parties' direct marketing purposes during the preceding calendar year. To send this request, you may contact us using one of the methods in the “How Can You Contact Us?” section of this Privacy Notice.

  2. California Consumer Privacy Act (“CCPA”): This section 2 is intended to satisfy the requirements of the California Consumer Privacy Act (“CCPA”). This section supplements our Privacy Notice. The rights herein are in addition to any other rights applicable to you in this Privacy Notice. Where there is a conflict between this section and other provisions of this Privacy Notice, this section will prevail for California residents and their rights under the CCPA and applicable California law.

      1. Personal Information Definition:
        For 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 individual or household.

      2. Exclusions:
        Some Personal Information is not subject to the CCPA such as consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, Personal Information governed by the Gramm-Leach Bliley Act, the Fair Credit Reporting Act, the California Financial Information Privacy Act, and any other Personal Information exempt from the CCPA. This CCPA section does not apply to our employees. A separate privacy notice applies to our employees.

      3. The Categories of Personal Information We Collect and Why We Collect Them.
        Generally, where applicable, in our role as a “Business” under CCPA, we may collect the following categories of Personal Information (as set forth in the CCPA) about you for the following purposes:

Personal Information Category

Identifiers: Identifiers such as your real name, alias, title, military or other service rank, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, account number, rewards program number, and other similar identifiers.

Purposes of Collection

We may collect this information to establish a business record of you, setup rewards and other accounts, create login credentials for you, and for similar reasons.

We may collect this information to communicate to you about your purchases, transactions, contracts, our business relationship with you, and for similar reasons.

We may collect this information to provide you with surveys for quality assurance, product development and more.

We may collect this information to facilitate communications to you regarding products/services that may be of interest to you.

We may collect this information to provide a list to resorts, homeowner's associations ("HOAs"), and third party partners related to your transactions, election activities, ownership and more.

We may collect this information to verify your identity such as when you request access to your Personal Information or apply for financing.

We may collect this information such as government id related information in order to process your financing application or provide information to a travel provider such as an airline pertaining to your reservation.

We may collect this information to provide a list of your emergency contacts.

We may collect this information to meet a legal requirement such as recording a title or similar functions.

We may collect your signature on documents like contracts, financing terms, waivers, etc.



Personal Information Category

Customer Records: Paper and electronic 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 number, insurance policy number, bank account number, credit or debit card number or any other financial or payment information, medical information or health insurance information. Some information in this category may overlap with other categories.

Purposes of Collection

We may collect this information to set up ownership, membership, online and other accounts you request.

We may collect this information to process and/or administer your financing applications and financing, your contracts, your reservations, your loyalty and/or rewards accounts, and more.

We may collect this information to determine your eligibility for certain products or services.

We may collect this information to process payments and purchases of any of our products or services.

We may collect this information to verify your identity such as when you request access to your Personal Information or apply for financing.

We may collect this information if you engage in certain physical, sports or similar activities at our resorts and other properties.

We may collect this information to detect and prevent fraud.

We may collect this information to comply with applicable laws and to meet other legal obligations.



Personal Information Category

Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Purposes of Collection

We may collect this information to process and/or administer your financing applications and financing, your contracts, your reservations, your loyalty and/or rewards accounts, and more.

We may collect this information to personalize your services/products, provide helpful suggestions, respond to your commercial inquiries, and facilitate communications to you of products/services and related features that may be of interest to you.

We may collect this information to create efficiencies in managing reservations and recurring commercial interactions with you or otherwise managing our ongoing business relationship.

We may collect this information to maintain a record of your consuming history preferences and tendencies to better serve you, to personalize an experience for you, and to meet other needs of offering, providing and maintaining an ongoing service relationship with you.

We may collect your survey answers about events, products/services and more for quality assurance, product improvement, and to facilitate marketing that may be of interest to you.



Personal Information Category

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.

Purposes of Collection

We may collect this information where needed for a legal or financial document such as when we collect your marital status for a financing application.

We may collect this information where needed for a reservation, such as where we may need your gender to report to the airlines. We may also collect this information like gender to address you with the proper salutation.

We may collect this information to provide you with the proper accommodations or assistance such as when you notify us of health related accommodations you require related to a reservation.

We may collect additional information in this category as appropriate.



Personal Information Category

Biometric Information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including fingerprint, faceprint, hand, palm, and voice recordings, and health or exercise data that contain identifying information.

Purposes of Collection

We may collect biometric information in order for you to access portions of a resort or property or to assist in a law enforcement investigation.



Personal Information Category

Internet Activity: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident's interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any company device, network or other information resource.

Purposes of Collection

We may collect this information to improve our website functionality, improve transaction throughput, and personalize your experience. We may collect this information to determine what interests you to facilitate targeted communications of products and services to you. We may collect this information to judge the effectiveness of any online marketing campaigns.



Personal Information Category

Geolocation Data: General or precise geographic location information about a particular individual or device.

Purposes of Collection

We may collect your postal address and/or the location associated with your device to create demographic analysis of visits to our site, prevent fraud and promote interest in our products to better market to and understand our customers.

Your location may be used to send you messages or notifications depending on your jurisdiction and settings.

We may collect this information because of differences in jurisdictional laws to be sure we are compliant in our presentation of content.



Personal Information Category

Audio/Visual Data: audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV images and photographs, and audio recordings (e.g., recorded meetings).

Purposes of Collection

We may collect this information for quality assurance of product/service presentations or communications, when you pose for videos/photos or provide audio recordings at our resorts or to us in any manner in order to improve our products and services, when you participate in activities or excursions or attend other events as part of service delivery.

We may collect this information in public areas of our facilities and online to provide safe and secure facilities and to ensure quality assurance.



Personal Information Category

Employment History: professional or employment-related information.

Purposes of Collection

We may collect details of your employment history such as job title and length of time at your employment to process a financing application. We may collect employment history as part of a larger analysis of you and what products/services would be well suited for you. We may collect details of your employment history as part of your credentials if you run for an elected position within the HOA of your vacation ownership property.



Personal Information Category

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).

Purposes of Collection

For example, we may collect this information in order to process financing, in order to match your potential interest and likelihood of purchasing certain products/services, and as part of any office election you may run for as a candidate related to an HOA.


Personal Information Category

Profiles and Inferences: inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Purposes of Collection

For example, we may infer what products or services may interest you, your predicted attachment to your purchased products, your likelihood of purchasing other products, your likelihood of exacting contract and financing terms, and more. We may collect demographic information about you, such as your age, income, etc.



OTHER PURPOSES FOR COLLECTING AND USING YOUR PERSONAL INFORMATION: Generally, we may use all of the above categories of Personal Information for the following purposes where applicable:

  1. WHERE DO WE GET YOUR PERSONAL INFORMATION: We may collect all of the Personal Information categories above primarily from you such as when you fill out a form, contact us, submit documents to us, use our Websites or Mobile Apps, apply for financing, and interact with us in other ways. We may collect it from within the Panorama Group of Companies, T + L Affiliates, third party partners or data management companies. We may collect it from social media accounts such as when you connect to our Websites through such an account. We may collect it from travel agents who provide it to us on your behalf or other persons who provide your information.

  2. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?: We disclose Personal Information to T + L Affiliates, any entity within the Panorama Group of Companies, vendors and service providers, legal and regulatory agencies under certain circumstances, third party product and service providers, third party partners, and others under certain circumstances. Please see the “When We Disclose Your Information” section for more.

  3. SELLING YOUR PERSONAL INFORMATION: Based on the CCPA's broad definition of "sale," certain data collection on our sites and applications by third parties for purposes of internet-based advertising and social media tools, as well as some other activities involving the disclosure of personal information to another business or a third party, may be a "sale" under the CCPA even if we do not share your information for money. Under some circumstances as described below, we may "sell" or license your Personal Information under this broad definition.

  4. Partners: We may sell your Personal Information to sweepstakes, contest, promotion partners or other third parties so that they can market to you. This will only occur if you agree to participate in such a promotion and will be subject to your marketing preferences.

  5. T + L Affiliates and Entities within the Panorama Group of Companies: We may sell your Personal Information to T + L Affiliates or entities within the Panorama Group of Companies so that they can market to you their products and services provided that such sharing is subject to your marketing preferences.

    • Internet-Based Advertising/Social Media Tools: To the extent certain information collection on our sites and through third-party applications is considered a "sale" under the CCPA, you may either opt-out through the "Do Not Sell My Information" link or as provided in the section "Other information we collect about you" in our general Privacy Notice.

    • Opt-Out: You have the right to opt-out of having your Personal Information sold. Please see the section of this Privacy Notice: "California Rights". Once we share your Personal Information with another business or a third party for such purposes, the information shared becomes subject to such other business or third party's privacy practices.

  6. California Rights: If you are a California resident, you have certain rights with respect to your Personal Information as set forth below:

    • Right to Know: You have a right to know what Personal Information Categories we have collected, used, disclosed or sold about you in the previous 12 months and the purposes of such actions. You have a right to know the sources of collection of such information and to whom we have disclosed it to for business purposes or a sale. You also have a right to receive a list of the Personal Information we have collected about you in the last 12 months from the date of your request. You may request any or all of this information up to two times in a 12-month period. You may exercise this right by filling out and submitting a Privacy Rights Request Form where one is available (See ‘California Privacy Rights Request Form Link' below) or by contacting us using one of the methods listed in the “How Can You Contact Us?” section of this Privacy Notice.

    • Right to Delete: You have a right to instruct us to delete certain Personal Information we hold about you. We will assess your request and determine, under the CCPA, what Personal Information we are required to delete. If we retain any Personal Information, we will notify you of what we have retained and why. For information we delete, we will notify you of the method of deletion. You may exercise this right by filling out and submitting a Privacy Rights Request Form where one is available (See ‘California Privacy Rights Request Form Link' below) or by contacting us using one of the methods listed in the “How Can You Contact Us?” section of this Privacy Notice.

    • Right to Opt-Out of Sale of Your Personal Information: You have the right to instruct Us not to sell your Personal Information. You may exercise this right by filling out and submitting this Opt-Out Request Form or by contacting Us using one of the methods listed in the “How Can You Contact Us?” section of this Privacy Notice.

    • Nondiscrimination: You shall not incur or be subject to any price or quality of service difference from us for exercising any of your rights under the CCPA. If you feel you have been treated unfairly for exercising any of your rights under the CCPA, please contact us immediately using one of the methods listed in the “How Can You Contact Us?” section of this Privacy Notice.

    • Verification: We will require certain information from you to verify your identity as the requestor. Generally, we will ask you information that we have already collected about you to provide this verification. For instance, if you submit a “Right to Know” request, we may ask your name, address, email address, account number if applicable, and phone number. We reserve the right to ask additional questions and/or to contact you directly if in our discretion we determine we need additional verification.

    • Agents: You may have an agent exercise your rights on your behalf. If an agent provides a Power of Attorney in compliance with California Probate Code Sections 4000-4464, we will process such request. If however, your agent does not provide such Power of Attorney, we will need you to provide written permission to us of the agent's right to exercise your rights in this section on your behalf. Please include your full name, the address and email associated with your account with us, your member number if applicable, the agent's full name and address, and the agent's email. Please send this permission to privacy@rci.com. Furthermore, in addition to your written permission, we may contact you and/or your agent for further verification of your request.

    • California Privacy Rights Request Form Link: Access/Delete Form


How Can You Contact Us?

If after reviewing this Privacy Notice, you have any questions, complaints or privacy concerns, or would like to make any requests in relation to your Personal Information, or obtain further information on safeguards used for international transfers, please send an email to our Privacy Group at privacy@rci.com or send a letter to (please indicate the entity within the Panorama Group of Companies or brand you typically do business with):


RCI India Private Limited

Pine Valley, First Level

Embassy Golf Links Business Park

off Intermediate Ring Road

Bangalore 560 071

India

If you have a complaint or concern about how we Process your Personal Information, we will work to address such concern(s). You may also direct your complaint/concern to the applicable data protection authority.