Privacy Policy

UPDATED ON JANUARY 9, 2018


Spinnaker Resorts is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Notice describes our practices in connection with information that we collect through websites operated by us (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), and through our social media pages that we control (collectively, our “Social Media Pages”), all of which from which you are accessing this Privacy Notice (collectively, including the Websites, the Apps and our Social Media Pages, the “Services”). This Privacy Notice also applies to our offline collection of information. The information you provide helps us to operate effectively and continually provide you with the best hospitality products, services and experiences. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Please read the following to learn more about our privacy practices. NOTICE TO TIMESHARE OWNERS/FINANCING CUSTOMERS: You may receive a separate notice regarding “Your Financial Privacy” by mail. If this Website provides you the ability to access your account online, and you agree to receive annual notices online, we will provide you with annual notices through this Website. Further, if we provide you with updated notices online, we will require you to acknowledge receipt of the updated notice through this Website or another identified Website. Acceptance of Our Privacy Notice: By using the Services, you accept the terms of this Privacy Notice and the ways we may use your information. If you do not accept the terms of this Notice, please do not continue to use the Services.

 

What Information Is Collected and How Is It Collected?

We may collect personal information (which is 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)
  • Telephone number
  • Email address
  • Driver’s License or Government-issued ID
  • Credit and debit card number
  • Financial information
  • Profile picture
  • Social media account ID
  • Stay information
  • Communication preferences
  • Subscribing membership ID

 

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

  • Register for a product or service
  • Contact us with a question or request, or request, including by use of any Website chat features
  • Use our Services
  • Make a payment for a product or service
  • Stay at one of our affiliated resorts
  • Provide a testimonial or story, or submit a review or comment
  • Participate in a competition or sweepstakes
  • Participate in any loyalty or other programs
  • “Like”, “Follow” or otherwise connect with or post to one of our Social Media Pages

From Other Sources: We may receive your personal information from other sources such as public databases; joint marketing partners; data firms; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your Website account, certain personal information from your social media account will be shared with us, which may include personal information that is part of your profile or your friends’ profiles.

 

Other Information We Collect about you

 

  • Cookies: This Website uses “cookies”. Cookies are small text files that the Website sends to your computer for record-keeping purposes and 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 that we can use these to improve your next visit to the Website.

     

    • One of the purposes of cookies is to simplify the use of the Website. A cookie may save a user’s login details, for example, so that the user does not need to login every time. Cookies, by themselves, do not provide us with your personal information.
    • 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 purposes, to determine how the Website is used, as well as to serve ads to you while you are on the Website. These cookies are provided by us as well as by third parties (e.g., advertising partners). While we do not control or have access to the advertiser cookies we do permit those cookies to be used on the Website to facilitate tailored advertising and to monitor patterns of buying specific goods or interest in, for example, holidays or hobbies. These cookies run advertisements tailored to the user based on his online buying habits.
  • “Do Not Track” Browser Settings: At this time, we do not respond to browser ‘do not track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit our Website. Please see the Interest Based Advertising section below to learn about how to exercise choice regarding their collection of such information for the delivery of interest-based advertising.
  • Google Analytics: We use Google Analytics to help us get a better understanding of how visitors use the Website. The information generated by the Google Analytics cookie about your use of the Website is transmitted to and stored by Google. If you do not want your activity on the Website to be tracked by Google Analytics, you may opt out by using this link http://tools.google.com/dlpage/gaoptout?hl=en.
  • Pixels, Beacons: We and/or our third party service providers may use invisible pixels or beacons on this Website to count how many users visit certain pages. This information is collected and reported in the aggregate. We may use this information to improve our marketing programs and content and to target advertisements at this Website and/or on other sites.
  • Interest Based Advertising: We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Services and other websites, apps or online services, based on information relating to your access and use of our Services and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may 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 how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit http://networkadvertising.org/managing/optout.asp and http://www.aboutads.info/choices/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. You may opt out in Twitter by going to your account privacy settings and unchecking the box next to “Tailor ads based on information shared by ads partners.”
  • Mobile Devices: When you use or access our Services from a mobile device, we may collect information such as your unique device ID and your location information. When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number, as well as any other information specified by the App in its terms or notices.
  • Information Provided by you: We collect other information from you when you voluntarily provide it, such as stay, trip, product, service or related information; communication, product, service or other customer preferences; special needs or conditions that may impact your stay; and demographic information.
  • IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

How Do We Use Your Information?

 

The information we collect from you helps us to identify ways that we can continue to serve you in the best way possible and provide you with personalized products and services that suit your lifestyle. We use personal information for the following purposes:

  • To respond to your inquiries and fulfill your requests, such as to send you newsletters.
  • To send administrative information to you, for example, information regarding the Services or an event in which you are attending and changes to our terms, conditions, and policies.
  • To complete and fulfill any purchases or requests for services, for example, to process your payments or a hotel stay or vacation rental, communicate with you regarding your purchase and provide you with related customer service.
  • To send you marketing communications that we believe may be of interest to you via postal mail, email, telephone or SMS.
  • To personalize your experience on the Services by presenting products and offers tailored to you.
  • To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these rules carefully.
  • To facilitate social sharing functionality.
  • To allow you to send messages to a friend through the Services. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address.
  • For our business purposes, such as 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.
  • As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • We may also aggregate and/or anonymize personal information for research, to improve our products and services, and for other business purposes. We may use and disclose information that does not personally identify you for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat such other information as personal information under applicable law, then we may use it for the purposes for which we use and disclose personal information, as set forth in this Privacy Notice.

How Do We Disclose Your Information?

 

Your personal information may be disclosed as follows:

  • Affiliates: We may disclose your personal information to other businesses (our “Affiliates”), who may jointly use the personal information for the purposes described in this Privacy Notice.
  • Business Partners & Sponsors: We may disclose your Personal Information to third party business partners or sponsors, as described below and elsewhere in this Privacy Notice. In the event and to the extent that there are additional uses of your Personal Information by Spinnaker Resorts business partners or sponsors (which additional uses are not otherwise described in or contemplated by this Notice), any such additional uses will be specifically described to you prior to or at the time such Personal Information is collected or prior to any transfer of such Personal Information to the business partners or sponsors. We may share your personal information with third parties, subject to any choices you have made. Many promotions offer opportunities for you to request additional information from such business partners and sponsors. By requesting additional information, you signify your consent to Spinnaker Resorts’s transfer of your Personal Information to the applicable business partners or sponsors so that they can respond to or fulfill your request. Although, in many instances, only your email address will be shared with these business sponsors and partners, Spinnaker Resorts is not limited to the type of Personal Information that it may disclose, provided that you requested the additional information and that Spinnaker Resorts has otherwise complied with this Privacy Notice. Vacation rentals: We may share your information with the owners and Business Partners of resorts we do not own, property owners associations and those with whom we have a sales and marketing relationship, in order to provide you with services.
  • Vendors and Service Providers: We may disclose your information to vendors and service providers retained by us in connection with our business such as: travel services companies and providers; financial services companies; credit bureaus; property owners’ associations; vacation insurance companies; companies providing website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery services; tax and financial advisers; legal advisers; accountants; and auditors.
  • Message Boards: We may make message boards, blogs, and other such user- generated content facilities available to users. Any information that is 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.
  • Merger or Acquisition: We may disclose your personal information to a third party who acquires any part of Spinnaker Resorts itself or any of its Affiliates, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets (including in connection with a bankruptcy or similar proceedings).
  • Disclosure Permitted by Law: We may disclose your personal information to law enforcement authorities, government or public agencies, regulators, insurers and/or to any other person or entity having appropriate legal authority or justification for receipt of your information, if we believe that we are required or permitted to do so by law or legal process, to respond to claims, or to protect our rights, interest, privacy, property or safety and/or that of our Affiliates, you or others.
  • Anonymized/Aggregated Information: Because aggregated or anonymized information does not personally identify you, we may use and disclose it for any purpose.

 

How Do We Safeguard Your Information?

 

Security of Your Information: We take reasonable steps to help protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of information that you provide to us via the Services.

 

Other Important Information

 

  • Information Provided on Someone Else’s Behalf: If you provide us with information about someone else, you represent that you have the person’s permission to do so for the purposes detailed in this Privacy Notice.
  • Links to Websites: The Services may have links to other websites that are not operated by us. We have no control over how these websites may collect your information and no responsibility or liability for the practices, policies and security measures implemented on these websites. You should read the privacy notices on those other websites before you submit your information through them.
  • Social Media Sites: Please note that we are not responsible for the information collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal information you disclose to such other organizations through or in connection with the Apps or our Social Media Pages.
  • Changes to Our Privacy Notice: From time to time we may revise this Notice to reflect new uses of personal information, to meet changes in the regulatory or business environment, or to satisfy the needs of our customers and service providers. Updated and date stamped versions will be posted on the Services, and, by using the Services following any such revision, you agree to the revised Notice.
  • Minors: We do not knowingly collect, maintain or use personal information from children under 18 years of age, and no part of Services is directed to individuals under the age of 18.
  • International Transfers: The Services are controlled and operated by us from the U.S. and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the U.S. For example, your information may be stored on servers located in other jurisdictions. By using the Services, you consent to the transfer of information to countries outside your country of residence and back, including to the U.S.
  • Retention Period: We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

 

Choices and Contact Us with Your Questions

  • Marketing: We may contact you by email, telephone, SMS or postal mail with information about products or services offered by Spinnaker Resorts or a third party that may be of interest to you. You can opt-out of receiving such marketing communications at any time.
  • Access to Information We Hold about You: If you would like to access, update, correct or request that we suppress or delete any of the personal information we have collected from you or if you require further information from us about how we use your information please contact us at webmarketing@spinnakerresorts.com. In some jurisdictions, you may be charged a reasonable fee for access to your information.

 

Contact Information

If after reviewing this Notice, you have any questions or privacy concerns please send an email to webmarketing@spinnakerresorts.com or send a letter to: Spinnaker Resorts Corporate Compliance Officer 35 DeAllyon Ave Hilton Head Island, SC USA

 

California Privacy Rights

Notice to California Residents: If you are a resident of California, California Civil Code Section 1798.83 allows you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes.

Effective Date: Jan. 1, 2018 Last Updated Date: Jan. 19, 2018