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PRIVACY POLICY



This Privacy Policy (“Policy”) applies to Holiday Inn Club Vacations
Incorporated and/or its Affiliates. Holiday Inn Club Vacations Incorporated and
its Affiliates (collectively referred to as “we”, “us” or “our”) have prepared
this Policy to inform you of the privacy principles that govern our use of
Personal Information we obtain from our customers, owners and guests, including
information we obtain through our Websites, social media pages that we control
and through any of our offline activities, such as when you provide information
on the telephone or in person.

In our efforts to protect your Personal Information, we use generally accepted
standards for safeguards including administrative, technical and physical
measures. These safeguards are continually updated and maintained by qualified
information security professionals.


PERSONAL INFORMATION WE MAY COLLECT AND ITS USES

We collect and use information we believe is necessary to administer our
business and to provide you with customer service. We may collect and maintain
several types of personal information needed for these purposes. Personal
Information means data that could be used to identify you, which includes
without limitation, the following:

Name

Postal Address

Phone Number

Email Address

Credit or debit card number

Financial Information

Stay, trip, service information and preferences, such as your preferred
location, dates and number of people traveling, communication preferences, and
location information, etc.

Special needs or conditions that are relevant to your stay

Driver’s license, government issued ID, or passport

Geolocation information

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

Demographic information

Internet Activity on our websites

IP address or Device ID

Account or Membership ID

We may also collect certain information automatically from your device. In some
countries, including countries in the European Economic Area (EEA), this
information may be considered Personal Information under applicable data
protection laws, including the General Data Protection Regulation (GDPR).
Specifically, the information we collect may include information such as your IP
address, device type, unique service identification numbers, browser-type, broad
geographic location and other technical information. We may also collect
information about how your device has interacted with our Website, including the
pages accessed and the links clicked. Some of this information may be collected
using cookies and similar tracking technology, as explained further below.

If you are located outside the United States and choose to provide information
to us, please note that we transfer information, including Personal Information,
to the United States and process it in the United States. Your consent to this
Privacy Policy followed by your submission of such Personal Information
represents your agreement to such transfer. We may also collect information such
as your history of presence at our resorts, account data, preferences you
provide to us or generated through your presence at our resorts, including
inferences we may make based on our experience with you.

We may also collect and maintain audio recordings of telephone calls between you
and us, where permitted by law and photos and videos of you, including the use
closed circuit television and other technologies at our properties that may
capture or record images of you in public areas, as well as information related
to your location while on our properties.

If you choose to participate in our social media activities or offerings, we may
collect certain information from your social media account consistent with your
settings within the social media service, such as location, check-ins,
activities, and interests. We may send you newsletters or marketing
communications we believe may be of interest to you or allow you to provide a
testimonial or story or submit a review or comment. We may also allow you to
enter contests and other social media driven activities to provide photos which
you may share with your connections on social media for votes, shared offers or
other promotions.

You can also access our Websites to request that we contact you. to process your
request, we may collect your Holiday Inn Club membership number (for members of
the Holiday Inn Club), your first and last name, your mailing address, your
e-mail address(es) and your telephone number(s), as well as any other content
included in the email, in order to send you a reply. If you do not agree to the
collection and use of your Personal Information as described in this Privacy
Policy, please do not provide us with any information and cease using this
Website and other company-related Websites.


COOKIES

Our Websites make limited use of “cookie” technology. When you visit our
Websites, you will be assigned a “cookie” (a small text file) to be stored on
your computer’s hard drive. The purpose of the cookie is to identify you when
you visit our Website so we can enhance and customize your online experience.
Persistent cookies remain on your computer hard drive until you delete them or
are otherwise removed upon expiration of the file. The cookies we use do not
contain any Personal Information and we do not use cookies to gather any
personal information about you. Cookie technology may be used by our affiliates,
analytics providers or other service providers. These technologies may be used
in analyzing trends, administering the sites, tracking your movements around the
Websites and to gather demographic information about our user base as a whole.
We may receive reports based upon the use of these technologies by such
companies on an individual as well as an aggregated basis. You can choose to
visit our Websites without cookies, but without these identifying files you will
not be able to take advantage of certain desirable features of our Websites.
These features include remembering your login (so you don’t have to remember
your login information) and providing a more personalized online experience. to
visit without cookies, you can configure your browser to reject all cookies or
notify you when a cookie is set. Each browser is different, so check the “Help”
menu of your browser or visit www.allaboutcookies.org to learn how to change
your cookie preferences.

Third-party vendors, such as Google, show our ads on sites across the internet,
and in some cases, through remarketing, use cookies to serve ads based on
someone’s past visits to our website. You can opt-out of Google’s use of cookies
by visiting Google’s Ads Settings:
https://support.google.com/ads/answer/2662922?hl=en. You can also opt-out of all
third-party vendors’ use of cookies by visiting the Network Advertising
Initiative opt out page at: https://networkadvertising.org/.

Facebook Pixel is a tracking code which allows us to track and monitor the
success of advertisements we use on Facebook and to improve the effectiveness of
those advertisements by recording information such as the device you used to
access our website and the actions you took on our website using cookies. We may
also use Facebook Pixel to create retargeting advertisements and custom
audiences for our advertisements on Facebook and on our website. For more
information about how to control the ads you see on Facebook and how to manage
your ad settings and preferences, visit:
https://www.facebook.com/help/562973647153813/.


SECURING THE TRANSMISSION AND STORAGE OF INFORMATION

One of the security techniques we use for online transactions is a technology
called Secure Sockets Layer (SSL). If your browser is capable of SSL (and most
are), your personal information will be automatically encrypted, or encoded,
before it is sent over the Internet. More about SSL Technology.

When you enter a secure portion of our Websites (which is any page containing
any of your personal information), an image of a closed lock or a solid key
should appear in your browser window. In addition, when accessing a secure
server, the first characters of the website address will change from “http” to
“https.”


HOW WE USE AND SHARE YOUR PERSONAL INFORMATION

We take your personal privacy seriously. As such, we do not sell your personal
data or provide it to persons or organizations who are conducting business on
our behalf for their own marketing purposes. We will not sell your mobile
information to third parties for marketing purposes. Please note that some state
statutes may define a “sale” to include sharing of personal information with
third parties for valuable consideration. Many companies have common
arrangements with online advertising networks, marketers and analytics companies
that may potentially be considered sales under these definitions. From
time-to-time we may share your personal information in connection with any of
the following:

Business Transactions with you: We may process your Personal Information to: 1)
enter into or perform a contract with you; 2) respond to your inquiries and
fulfill your requests; 3) send administrative information to you, for example,
information regarding the Services or an event in which you are attending; or 3)
to complete and fulfill loyalty program activities or any purchases or requests
for services.

Legitimate Business Interests:

Service Providers: We share limited information with trusted third-party service
providers and contractors for certain purposes, such as conducting Holiday Inn
Club member and guest satisfaction surveys; contacting you regarding your
membership; registering you as an account holder; communicating personalized or
special offers and featured items to you (except when prohibited) on our
websites or on third party websites that may be of interest to you; facilitating
your account transactions; and contacting you in response to your request. These
third-party providers include internet service providers, data analytics
providers, operating system, platform and social network providers and they have
agreed to maintain the confidentiality of your information. They were engaged to
provide specific services and the use of any Personal Information they have
access to will be dictated by us. If you do not want us to share your personal
information with these companies, please contact us at
complianceofficer@holidayinnclub.com.

Promotional Partners: We may share limited personal information with third
parties with whom we partner to provide promotions, activities, contests and
sweepstakes, or other promotional activities. The partner will usually be
identified by name in our promotion, contest, or sweepstakes communication.

Select Marketing and Strategic Business Partners: We may share limited data with
our marketing and strategic business partners, who may use this information for
their own business and commercial purposes in accordance with their own privacy
policies.

Health and Safety Reasons: We may share personal information with third parties
if we reasonably believe that such action is necessary to protect the health and
safety of our guests, family members or other individuals or where we believe in
good faith that such disclosure is necessary to support the health and wellbeing
of our guests, their families or others.

Corporate Transactions: We may also disclose your Personal Information to a
potential buyer (and its agents and advisors) in connection with any proposed
purchase, merger, or acquisition of any part of our business, provided that we
inform the buyer it must use your Personal Information only for the purposes
disclosed in this Privacy Policy.

At Your Request: With your consent or direction, we may share your information
with your friends and family or with third parties to whom you direct us to
share information. Law Enforcement, Government Authorities, Regulators and for
Safety or Legal Reasons: We will also share your Personal Information when
required to do so by law, such as to comply with a court-issued subpoena or
judicial order or for tax or financial processing, when we believe doing so will
protect the rights, property or personal safety or health of us, our guests,
online visitors, or any other third party, for fraud prevention or compliance
verification or other purposes.

We may also share information with third parties or service providers in an
aggregated or otherwise anonymized form that does not reasonably identify you
who may use it 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.

All the above categories exclude text messaging originator opt-in data and
consent; this information will not be shared with any third parties.


LINKS TO OTHER SITES

Please note that our Website links to other websites and that the privacy
policies of those websites may differ from ours. We advise you to check the
privacy policies of other websites before disclosing any personal information.
In any event, please note that these websites do not share your personal
information with us.

Occasionally when linking to another website, you may still see our Website’s
logo or frame. This is to provide you with a seamless experience when visiting
our Website. In these cases, you are no longer on our Website and are now on a
different Website whose information collection practices may differ from ours.
The privacy policy of the website you are on will govern how information
collected from you is used. You can always verify which website you are on by
checking the location bar within your browser.


INFORMATION SAFEGUARDS

We have implemented reasonable and appropriate physical, technical and
administrative steps to help protect your personal information from loss,
misuse, unauthorized access or disclosure, alteration or destruction.
Unfortunately, no security system is 100% secure, thus we cannot ensure or
guarantee the security of all.


YOUR RIGHTS AND CHOICES

By accessing this Website, you consent to the processing of your personal
information as provided in this Notice. Holiday Inn Club Vacations Incorporated
adheres to applicable data protection laws in the EEA, which if applicable to
you, include the right to:

 1. Withdraw consent to the processing of your Personal Information at any time
    where processing of Personal Information is based on legitimate grounds
    relating to your situation, and we will apply your preferences going
    forward.
 2. Request access to, updating, or erasure of your Personal Information, or to
    transfer or receive a copy of your Personal Information in a usable format.
 3. Object to the processing of your Personal Information under certain
    circumstances.
 4. Lodge a complaint with an applicable data protection authority.

To help protect your privacy and maintain security, we may take steps to verify
your identity before granting you access to your information.


INFORMATION APPLICABLE TO CALIFORNIA RESIDENTS

If you are a California Resident, California law permits you to request
Information regarding the:

 * Categories of Personal Information (as defined by California law) collected,
   sold or disclosed by us;
 * Purposes for which categories of Personal Information collected by us are
   used;
 * Sources of information from which we collect Personal Information; and
 * Specific pieces of Personal Information we have collected about you;

In addition, if you are a California Resident you may:

 * Opt-out of the sale or disclosure of your Personal Information, in some
   circumstances;
 * Opt-out of receiving marketing communications from us, however, you may still
   receive administrative communications regarding our services; or
 * Request deletion of your Personal Information by us and our service
   providers, in some circumstances.

As a California Resident, you have the right not to be discriminated against (as
provided for in applicable law) for exercising your rights, including by:

 * Denying you goods or services
 * Charging different prices or rates for goods or services, including through
   the use of discounts or other benefits or imposing penalties;
 * Providing you a different level or quality of goods or services; or
 * Suggesting that you will receive a different price or rate for goods or
   services or a different level or quality of goods or services.

To exercise the rights described above, a verifiable consume request can be made
to us by either contacting us at 888-884-8532 or emailing us at
PII_Privacy@holidayinnclub.com and providing information necessary for
verification and fulfillment of your request.

Please note that certain information may be exempt from such requests under
California law. For example, we may need certain information in order to provide
services to you. We also will take reasonable steps to verify your identity
before responding to a request, which may include, at a minimum, depending on
the sensitivity of the information you are requesting and the type or request
you are making, verifying your name, email address, and other account
information. You are also permitted to designate an authorized agent to submit
certain requests on your behalf. In order for an authorized agent to be
verified, you must provide the authorized agent with signed, written permission
to make such requests. We may also follow up with you to verify your identity
before processing the authorized agent’s request.

We endeavor to respond to a verifiable consumer request within forty-five (45)
days of its receipt. If we require more time (up to an additional 45 days), we
will inform you of the reason and extension period in writing. We will deliver
our written response by mail. If we are unable to verify you based on the
information you provided and the information in our system(s) we will advise you
that we cannot complete your request based on an inability to verify you.

Disclosures we provide may only cover the 12-month period preceding the
verifiable consumer request’s receipt. The response will also explain the
reasons we cannot comply with a request, if applicable.


CHILD PRIVACY

Our Websites are not intended for use by children and we do not knowingly
solicit or collect any Personal Information from children. If we learn that we
have collected personal information from a child under the age of 18, we will
promptly delete that information from our records. If you believe we have
personal information from someone under 18, please contact us at
complianceofficer@holidayinnclub.com.


HOW TO CONTACT US

If you have any questions or concerns about our Privacy Policy or our use of
your personal information, please contact us at
complianceofficer@holidayinnclub.com.

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Holiday Inn Club Vacations Incorporated, the Holiday Inn Club® program, and the
Holiday Inn Club Vacations® resorts are independently owned, operated and
marketed and are not owned, operated or marketed by any InterContinental Hotels
Group (“IHG”) companies, or by IHG One Rewards, or by the owner or licensor of
the Holiday Inn® brand. The owner of the IHG One Rewards program is not
affiliated with the owner of the Holiday Inn Club program and reserves the right
to change, limit, modify or cancel the IHG One Rewards program terms and
conditions.

Copyright © 2024 Holiday Inn Club Vacations Incorporated. All rights reserved.

THIS MATERIAL IS BEING USED FOR THE PURPOSE OF SOLICITING SALES OF TIMESHARE
INTERESTS

Holiday Inn Club Vacations Incorporated, 9271 S John Young Parkway, Orlando, FL
32819

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