Effective: July 17th, 2017
Protecting the Privacy and Security of Your Personal Information is Very Important to Us
• What types of information GD gathers from consumers who inquire about GD’s products or services, apply to purchase such products or services, apply to us for the financing of their vacation resort ownership purchase, and who use our websites.
• How GD uses the personal information that you share with us and the information we learn about you as a result of our relationship.
• How GD uses log files, “cookies” and other Internet-related tools.
• What personal information, if any, GD may share about you with others and the conditions that protect your information if it must be shared.
• What kind of security measures GD takes to protect your information from loss or disclosure and how GD will inform you in the event of a security breach.
• The circumstances under which you can access the personal information you have shared with GD in order to have that information corrected, restrict GD’s use of that information, and/or have it removed from our records.
• Other things you should know about privacy and your relationship with GD.
The Types of Information GD Collects About You
GD collects information you provide to us or that we learn about you through a variety of ways, including through your use of our websites, your inquiries regarding GD’s products or services, or your application for the purchase of GD’s products or services. For example, you may provide information to GD when you register with, sign into, or search any of our websites. You may also provide information to GD whenever you participate in a survey, request our marketing brochures, or communicate with GD’s customer service personnel. As a result of those actions, you might provide us with information such as your name, address, phone number, email address, and product or service preferences. We also automatically gather and store certain types of information whenever you visit one of our websites. We might also receive information about you from other sources, and we may add that information to our database in order to, for example, provide you with special offers that we think will be of interest to you.
If you apply through us for the financing of your GDV vacation resort ownership purchase, we may also collect personal information about you from the following sources: applications or other forms (including collecting of information such as name, address, social security number, assets, and income); your financial transactions with us and other financial organizations; consumer reporting agencies (to obtain information regarding credit worthiness and credit history); information from outside sources regarding your employment, credit and other relationships; data from public records; and as may be required by the USA PATRIOT Act to verify your identity.
How GD Uses Information About You
GD collects and uses personal information from you in several key ways:
• Website usage. GD or GD’s authorized service providers may observe activities, preferences and transactional data (such as your IP address, browser type and operating system) relating to your use of our websites. We may use this collected or logged information in order to provide better service, to facilitate improved use of our websites, to track usage of the website, to address security hazards, and to track aggregate traffic patterns throughout our websites. We may use aggregated, statistical information to describe our customer audience, products and services, and to develop partnerships with third parties to offer products and services in which we believe our customers will be interested. For example, if 25% of our customers are interested in car rentals, we may share that statistic with travel service companies with the possibility of offering our customers access to car rental opportunities directly through our website, our call center or our affiliates.
• Online Transactions. We collect information about you whenever you use our websites and we may use the information for GD’s marketing purposes. Our customers are given the option to access their account online. In order to access such online services and protect your account information, you will be asked to choose a password, and you may be required to provide your name, account number, email address and other basic personal information. If you choose not to provide the information, your ability to access certain online features may be denied. For example, if you should forget your password and you have not provided us with your email address, we will be unable to email your password to you.
• Account Information. We collect information from you, about you from credit reporting agencies, and from other sources when you apply through us to obtain financing of your vacation resort ownership purchase. We use this information to provide you with financing. We also use this information to service and collect on your account.
Disclosures to Unaffiliated Third Parties for Marketing Purposes.
We do not sell your personal information to third parties for any reason. We do not disclose your personal information to unaffiliated third parties who may want to offer you their own products and services unless you have requested or expressly authorized us to do so. We may, however, send information directly to you about these unaffiliated third parties’ products and services if we believe they may be of interest to you.
We may disclose personal information regarding our customers to third parties for certain non-marketing purposes, such as disclosures that are required or permitted by law. We may make disclosures if required by law, such as in connection with a subpoena or similar legal process. We may also disclose personal information as permitted by law, such as when we believe that action is necessary to investigate or protect against harmful activities to GD guests, visitors, employees, or property (including our websites), or to others.
We may also disclose personal information in connection with a merger, acquisition or bankruptcy. We may also disclose personal information about our customers to credit bureaus and similar organizations in connection with our financing or collection activities.
We do not disclose personal information about former customers, except as permitted or required by law.
No Disclosures to Affiliates for Marketing Purposes
We do not share your personal information with GD affiliates for the purpose of those affiliates offering their own products and services to you. Your personal information is shared with GD affiliates only so that our affiliates may market GD’s products or services or otherwise provide services on GD’s behalf.
Disclosures to Affiliated or Third Party Service Providers.
We may share your personal information with third parties or affiliates of GD, which may include both financial service entities and non-financial companies, where it is necessary for us to complete a transaction or do something you have asked us to do. For example, we might need to provide your personal information to a third party or an affiliate to assist you with obtaining financing for your GDV ownership or so they can process and fulfill your request for information about special guest services at a GD resort.
We may share your personal information to third parties or affiliates of GD with whom we have contracted to perform services on our behalf. For example, we may also use a credit card processing company to bill customers for their purchase of certain GD products and services. These companies are not authorized to retain, share, store or use personal information for any secondary purposes.
GD acknowledges the individual’s right to access their personal data under the Privacy Shield. EU or Swiss individuals who wish to view their data to update, correct, or delete it may do so by logging into their customer account or by emailing us at firstname.lastname@example.org or in writing to GD at 25510 Commercentre Dr. Suite 100, Lake Forest, CA 92630.
You Have Choices When It Comes to How GD Uses Your Personal Information for Direct Marketing
All customers who register to access their account information online may receive a welcome email immediately after completing the online registration form. Registered customers will occasionally receive information regarding products, services, or special promotions. We do not want to send promotional materials you do not want to receive, nor do we want to contact you via email or telephone regarding GD’s products, services, or special promotions if you do not wish to receive such emails or telephone calls. As such, you may choose not to receive marketing offers from us by direct mail, telephone and/or email. Please note that, even if you elect to not receive marketing information from us by direct mail, telephone or email, you will continue to:
• Be contacted as necessary to service your account.
EU-US Privacy Shield
GD is subject to the jurisdiction and enforcement authority of the United States Federal Trade Commission.
GD may be liable for the onward transfer of EU personal data to third parties.
Note that we may be required to release EU personal data in response to lawful requests from public authorities including to meet national security and law enforcement requirements.
In compliance with Privacy Shield GD commits to resolve complaints about our collection or use of your personal information. European individuals with inquiries or complaints regarding our Privacy Shield policy should first contact GD at:
Andrew Gennuso – email@example.com
GD has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. The services of BBB EU Privacy Shield are provided at no cost to you.
Finally, as a last resort and under limited circumstances EU individuals with residual complaints can invoke a binding arbitration option before the Privacy Shield Panel.