Trading Places International Inc.
Effective Date: May 13, 2022
Trading Places International, Inc. ("TPI") respects the privacy of the users of its website and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy is intended to describe for you the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.
We encourage you to read this Privacy Policy carefully when using our websites or services or transacting business with us. By using our websites, you are accepting the practices described in this Privacy Policy. TPI (“we,” “our,” or “us”) is an indirect subsidiary of Capital Vacations, LLC (“CV”) which is a travel platform and vacation product company that offers vacation ownership, exchange, rental, and resort and property management, along with related businesses, products and services
If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.
1. California Consumer Privacy Act of 2018
The California Consumer Privacy Act of 2018 (“CCPA”) requires that we provide consumers that reside in California certain information 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.
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.
| 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, and IP address. In more limited circumstances, we may collect information such as social security number or tax identification 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, we may collect information such as social security number 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. |
| Purchase History and Tendencies: Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. | We may collect information such as the products or services you purchased or utilized. |
| Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | We may collect voice recordings when we monitor and record telephone calls. |
| Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement. | We may collect this information as part of your interaction with our websites or through advertisements. |
| Geolocation Data: Precise geographic location information about a particular individual or device. | We may collect information such as your postal address, zip code, or the location associated with an IP address or particular device. |
| Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars). | 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. | We do not collect this information unless you are a job applicant. |
| Education Information: Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). | We do not collect this information. |
| Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. | We may collect or derive information such as your preferences, characteristics, predispositions, and behavior based on other information we have about you. |
We collect these categories of personal information from the sources described in the “Information we collect about you” section of this Privacy Policy and for the purposes described in the “How we use the information we collect” section of this Privacy Policy. We disclose your personal information to third parties, such as our authorized service providers and business partners, as described in the “With whom we share your information” section of this 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 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. 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 “Use of cookies and other technologies to collect information” section of this Privacy Policy for more information. Data that is collected through network advertising or social media cookies may be disclosed by such network advertisers or social media to other network advertisers that allows those advertisers to also display ads to you. While there is currently no industry consensus, we do not consider these additional disclosures to be our sale of personal information under the CCPA. If you do not want information collected by cookies, however, please visit www.aboutads.info and www.networkadvertising.org to opt-out.
California Resident Rights:
If you are a California resident, you have certain rights with respect to your personal information as set forth below.
Request to Delete:You may request that we delete personal information we have collected about you, subject to certain exemptions provided by law.
Request to Know: You may request, subject to certain exemptions, that we disclose to you the categories of personal information collected; the categories of sources of personal information; the business or commercial purposes for collecting and selling your personal information; the categories of third parties with whom we have shared your personal information; the categories of personal information that we have disclosed or shared with a third party for a business purpose; the categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; and the specific pieces of personal information that we have collected about you in the prior 12 months.
Request to Opt-out of Our Sale of Your Personal Information: We do not sell your personal information.
Submitting Requests: To make a Request to Delete or a Request to Know, please contact us at 877-973-6725 or privacy@capitalvacations.com. Please include your full name, postal address, and email address. If you designate an authorized agent to make a request on your behalf, we require you to provide a written and signed authorization of your agent’s permission to exercise your rights on your behalf as provided for in this section. Please include your full name, postal address, and email address along with your agent’s full name, postal address, email address, and relationship to you.
If we are not able 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 make a reservation, we may retain your personal information as permitted by law to provide the service you requested.
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.
2. Other California Privacy Rights
California’s Shine the Light law provides certain privacy rights to individual customers who are California residents. If you are a resident of California, in addition to the rights set forth in this Privacy and Cookie Policy, you have the right to request information from us regarding the manner in which we share certain categories of personal information with third parties for their direct marketing purposes. You may request to receive information about (a) the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; (b) the names and addresses of the third parties that received that information; and (c) examples of the products or services marketed if the nature of the third party's business cannot be determined from their name. We may provide this information in a standardized format that is not specific to you. The designated email address for these requests is privacy@capitalvacations.com.
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 authorized service providers, may collect information about your online activities over time and across different websites, including when you visit our websites.
In general. We may collect personal information that can identify you such as your name and email address and other information that does not identify you. When you provide personal information through our website, the information may be sent to servers located in the United States and other countries around the world.
Use of cookies and other technologies to collect information. We use various technologies to collect information from your computer and about your activities on our site.
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 effectiveness of Facebook advertisements for marketing, statistical, and market research purposes; 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 at https://www.facebook.com/about/privacy/. You also can deactivate the Facebook Conversion Tracking Pixel at https://www.facebook.com/settings/?tab=ads#_=_.
We may also 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. Our websites do not provide any personal information to these third parties. These companies may use tracking technologies, such as cookies, 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 at http://support.google.com/dfp_premium/answer/2839090. If you would like to opt out of such ad targeting from Google, please visit the Google Ads settings page at http://www.google.com/settings/ads.
In general. We may use information that we collect about you to:
Financial information. We may use financial information or payment method to process payment for any purchases made on our website, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
Job applicants. If your personal information is submitted through our website when applying for a position with our company, the information will be used solely in connection with considering and acting upon your application. We may retain your personal information for a period of time, but only for the purpose of considering your application for current or future available positions. This information may be shared with other CV subsidiaries for the purpose of evaluating your qualifications for the particular position or other available positions, as well as with third-party service providers retained by us to collect, maintain and analyze candidate submissions for job postings.
We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on our web site or while using our services.
Personal information. We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:
Any third parties to whom we may disclose personal information may have their own privacy policies which describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.
Aggregated and non-personal information. We may share aggregated and non-personal information we collect under any of the above circumstances. We may also share it with our affiliated companies and third parties to develop and deliver targeted advertising on our websites and on websites of third parties. 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 resort clients the number of visitors to our website and the most popular resorts, features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
There may be places on our website where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement on our website, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the ”privacy“ link typically located at the bottom of the webpage you are visiting.
You can review and update your personal information by contacting us. More information about how to contact us is provided below.
If you request that your personal information be removed from our records, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.
TPI employs security firewalls and network-based intrusion detection monitors to protect your personal data. When you place an order online, your personal data and credit card information are tokenized before being sent over the Internet. This protects your personal data from being stolen or intercepted while being transferred through cyberspace. Your credit card information is never stored on our web servers.
We want you to feel confident using our websites to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.
Our website is a general audience site, and we do not knowingly collect personal information from children under the age of 13.
This Privacy Policy is intended to cover collection of information on our websites from residents of the United States. If you are visiting our websites from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.
This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the website.
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" date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by sending an e-mail to the e-mail address you most recently provided us when making a reservation (unless we do not have such an email address), and/or by prominently posting notice of the changes on our website. We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.
If you have any questions about this Privacy Policy or our information-handling practices, please contact us by e-mail or postal mail as follows:
Customer Relations
25510 Commercentre Drive, #100
Lake Forest, CA 92630
E-mail address: privacy@capitalvacations.com
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