Effective: May 22nd, 2020
Protecting the Privacy and Security of Your Personal Information is Very Important to Us
• What types of information CE gathers from consumers who inquire about CE’s products or services, apply to purchase such products or services, apply to us for the financing of their membership purchase, and who use our websites.
• How CE uses the personal information that you share with us and the information we learn about you as a result of our relationship.
• How CE uses log files, “cookies” and other Internet-related tools.
• What personal information, if any, CE may share about you with others and the conditions that protect your information if it must be shared.
• What kind of security measures CE takes to protect your information from loss or disclosure and how CE will inform you in the event of a security breach.
• The circumstances under which you can access the personal information you have shared with CE in order to have that information corrected, restrict CE’s use of that information, and/or have it removed from our records.
• Other things you should know about privacy and your relationship with CE.
The Types of Information CE Collects About You
CE 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 CE’s products or services, or your application for the purchase of CE’s products or services. For example, you may provide information to CE when you register with, sign into, or search any of our websites. You may also provide information to CE whenever you participate in a survey, request our marketing brochures, or communicate with CE’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 Club Esprit membership 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 CE Uses Information About You
CE collects and uses personal information from you in several key ways:
• Website usage. CE or CE’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 CE’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 Club Esprit membership 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 CE 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 CE affiliates for the purpose of those affiliates offering their own products and services to you. Your personal information is shared with CE affiliates only so that our affiliates may market CE’s products or services or otherwise provide services on CE’s behalf.
Disclosures to Affiliated or Third Party Service Providers.
We may share your personal information with third parties or affiliates of CE, 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 Club Esprit membership or so they can process and fulfill your request for information about special guest at a Club Esprit affiliate.
We may share your personal information to third parties or affiliates of CE 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 CE products and services. These companies are not authorized to retain, share, store or use personal information for any secondary purposes.
CE acknowledges the individual’s right to access their personal data. 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 CE at 1101 Miranda Ln, Kissimmee, FL 34741.
You Have Choices When It Comes to How CE 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 CE’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.
CE is subject to the jurisdiction and enforcement authority of the United States Federal Trade Commission.
CLUB ESPRIT LLC., DO NOT CALL POLICY
The Telephone Consumer Protection Act (“TCPA”) was passed in 1991. The Federal Communications Commission’s rules and regulations implementing the act went into effect on December 20, 1992. The Federal Trade Commission concurrently implements the Act through the Telemarketing Sales Rule, issued January 29, 2003. Various states have also enacted statutes that govern telemarketing activities. It is CLUB ESPRIT LLC’s policy to comply with these rules, and in particular, to respect and honor the requests of consumers to be placed on CLUB ESPRIT LLC’s internal Do Not Call list, so that such consumers will not receive sales calls from CLUB ESPRIT LLC unless and until they provide consent to receive sales calls. Please note that placement on CLUB ESPRIT LLC’s internal Do Not Call list does not restrict CLUB ESPRIT LLC’s ability to place informational and / or collections calls to its customers.
CLUB ESPRIT LLC retains third-party vendors to telemarket its goods and services to customers as well as non-customers who do not have an existing business relationship with CLUB ESPRIT LLC. CLUB ESPRIT LLC will not call any CLUB ESPRIT LLC customer who has communicated his or her desire to not receive sales calls. Requests to not receive sales calls are reflected in the customer’s account records. Additionally, the phone number will be added to CLUB ESPRIT LLC’s internal Do Not Call list. In compiling a list of customers to call for a particular telemarketing campaign, CLUB ESPRIT LLC will not include any customer whose account record is marked “do not call.”
Third-party vendors who telemarket to non-customers (persons who do not have an existing business relationship with CLUB ESPRIT LLC) subscribe to and scrub against all applicable state and federal “Do Not Call” registries, as well as CLUB ESPRIT LLC’s internal Do Not Call list. CLUB ESPRIT LLC requires that all third-party vendors telemarketing at its request and under its direction ensure they are in compliance with federal and state laws regarding telemarketing and that they fully understand and agree to follow the procedures for maintaining “do not call” data. CLUB ESPRIT LLC requires its vendors to report to CLUB ESPRIT LLC all consumer requests to be removed from telemarketing lists so that each request can be added to CLUB ESPRIT LLC’s internal Do Not Call list. CLUB ESPRIT LLC does not condone telemarketing activities conducted in violation of the TCPA, federal rules and regulations, and state laws regarding telemarketing.
CLUB ESPRIT LLC requires all third-party service agencies that make telephone solicitations at CLUB ESPRIT LLC’s request and under its direction to:
Institute procedures for maintaining a list of people who do not wish to receive telephone solicitations (a “do-not-call list”);
Scrub all leads against this do-not-call list before initiating any telephone solicitations;
When applicable, scrub against required state and federal “Do Not Call” registries;
Institute and maintain a procedure to capture all do-not-call requests and transmit them in the daily results file to CLUB ESPRIT LLC
Develop a written policy implementing this requirement to keep a do-not-call list and make this written procedure available to anyone on demand;
Maintain the do-not-call list for a period of 10 years and refrain from selling or sharing the do-not-call list (except with a subsidiary or affiliated company) without the customer’s consent;
Train and inform personnel engaged in any aspect of telephone solicitation in the existence and use of the do-not-call list;
Provide the called party with the name of the individual caller, the person or entity on whose behalf the call is made and a telephone number (which may not be a 900 number or any other number for which charges exceed local or long distance transmission charges) or address at which that person or entity may be contacted;
Make a record of the name and telephone number of the CLUB ESPRIT LLC customer or consumer who requests not to be called again and forward such record to (a) CLUB ESPRIT LLC, via the daily results file, (b) the party maintaining the vendor’s do-not-call list and (c) affiliated entitles (where appropriate); and
Place the consumer or CLUB ESPRIT LLC customer’s name and number on the do-not-call list of any affiliate of the telemarketer where the customer would reasonably expect to be included on such list given the identity of the telemarketer and the product or service being advertised.
CLUB ESPRIT LLC maintains a record of the name and telephone number(s) for consumers who do not wish to be called. Upon request, consumers’ telephone number(s) will be added to CLUB ESPRIT LLC’s internal Do Not Call List within five (5) business days of receipt of such request. This record will be retained for at least ten (10) years. You may get on the internal do not call list by calling 800.637.4787 and speaking with our associate who answers the phone or by emailing your full name and phone number to Info@myclubesprit.com.
Consumers have additional avenues available to them that will help reduce or eliminate unwanted telephone solicitations. Consumers may place their telephone number(s) on the National Do Not Call Registry online at www.donotcall.gov. In addition, the Direct Marketing Association also offers a free service titled “Telephone Preference Service.” Consumers may register for this service online at www.dmachoice.org