Travel Raintree privacy policy

1. Introduction.

This Privacy Policy (“Policy”) applies to RVC Members, LLC (“RVC”), the operator of Travel Raintree, and unless stated otherwise, its parent, sister and subsidiary companies and other affiliates, and all of the resorts within Travel Raintree (hereinafter collectively "Travel Raintree", "we", "us", or "our"), located at 10000 Memorial Drive, Suite 480, Houston, Texas 77024. We recognize that privacy is important to our guests and have developed this Policy to explain our practices regarding the personal information we collect from or about you when you buy any product or service from us, when you visit one of our resorts, when you use this website or any of our other mobile or social media applications, when you communicate with us verbally or in writing or through any other sources. The term “you” or “yours” when used in this Policy and whenever applicable shall also include any individuals in your immediate family (e.g. spouse or children) or travel party, e.g. other relatives or friends. While this Policy broadly describes the practices we have adopted throughout Travel Raintree, local laws may vary and some jurisdictions may place additional restrictions on our information gathering or processing activities. Therefore, our practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements. By purchasing or using any of our products or services, visiting any of our resorts, accessing this website or any of our other mobile or social media applications or by communicating with us in writing or verbally, you agree to the collection, use and sharing of personal information by us as described in this Policy.

2. Personal Information Collected by Us.

As we interact with you, we may collect personal information, i.e. information that identifies you or relates to you as an identifiable person (“Personal Information”). This Personal Information may include the following:

• Contact information such as your name, home address, telephone number (home, office and mobile phone), and email addresses.
• Individual information such as your age, nationality, occupation, marital status, annual income, driver’s license, and passport information; social security or similar national identification number, travel history, family composition and other personal characteristics.
• Payment information such as your credit or debit card numbers, bank account numbers and other billing or account information.
• Information related to your reservation, check-in stay, or visit to one of our resorts including your resort or room preferences, special needs or conditions that may impact your stay, frequency of travel, use of on-resort services such as concierge services, fitness center, spa, child care services, or equipment rental, and other vacation history information.
• Information related to your purchase and receipt of products or services from us or your membership in Raintree Vacation Club.
• Information provided on any account application or document related thereto.
• Information obtained from your participation in a survey, contest, sweepstakes, or marketing program (even if you do not stay at one of our resorts).
• Information obtained from your reviews of our resorts.
• Information regarding your internet click activity on our websites, mobile and social media applications, as well as your IP address or device id and other information related thereto.
• Information obtained from any airline, rental car or activities packages booked through us or other third parties.
• Other types of information that you choose to provide to us.

We may also collect information about you from third parties, including information from our airline, car rental, credit card, and other partners and from other third-party sources. We may append this information to the information we have on file for you and share it with others consistent with this Policy.

3. Where and How Do We Collect Your Personal Information.

We collect the Personal Information listed above as follows when you:

• Purchase a product or service from us.
• Make a reservation with us.
• Check-in and stay at one of our affiliated resorts.
• Use any of our services or products.
• Pay for a product or service purchased from us.
• Contact us with a question or request.
• Interact with us through your account if you are a member of the Raintree Vacation Club.
• Participate in a sweepstake, promotional activity or other marketing program.
• Participate in any loyalty or similar programs.
• Participate in an online survey conducted directly or indirectly by us.
• Connect with or post to one of our social media pages.
• Use any of our websites.
• Tour any of our resorts.

4. Use of Your Personal Information.

In general, we may use your Personal Information in the following ways:

• To perform our obligations under any oral or written contractual relationship we may have entered into with you.
• To provide you with any products or services you may have purchased or requested from us or that we are contractually bound to provide to you.
• To respond to any inquiries from you and fulfill any request you may make of us.
• To process your registration or reservation and to otherwise manage your account.
• To provide you with information regarding your reservation and stay at any of our resorts.
• To fulfill other purposes disclosed to you at the time you provide us with Personal Information or otherwise where we are legally permitted to do so.
• To allow you to electronically interact with us to administer your account yourself, e.g. make reservations or payments online.
• To personalize content and provide you with offers or promotions that we believe may be of specific interest to you for our own products or services or on behalf of affiliated third parties.
• To provide you with newsletters or other communications that may of interest to you.
• To administer our websites, mobile or social applications.
• To improve and/or enhance our services or products for you.
• To allow you to participate in sweepstakes, contests or similar promotions and to administer these activities properly.
• To comply with any laws, rules or regulations and our specific obligations thereunder.
• To respond to any request from any governmental authorities.
• To monitor, investigate and respond to security concerns.
• To perform audits of our business operations, perform security reviews, and meet other legal obligations.
• To conduct commercial transactions such as mergers, acquisitions, asset sales or transfers, bankruptcy or reorganizations or other similar transactions.
• To protect or defend our rights and interests and those of third parties including, without limitations, to respond to or otherwise defend against legal claims or disputes.
• To facilitate collections of any amounts due from you while staying at one of our resorts or thereafter.

5. Disclosure of Personal Information.

In order to perform our obligations to you and to provide you with the best level of service, we may share your Personal Information with any entities or individuals as set forth below:

• Our Affiliates: Any entity that is, at the time you disclose your Personal Information to Travel Raintree, directly or indirectly controlled by or under common control with us.
• Our Resorts: Any resorts affiliated with Travel Raintree, including those affiliated resorts that are not managed by RVC, to provide you with services and for the other described above.
• Our Business Partners: Any entity with which we have entered into a contractual relationship or otherwise partnered with to provide you with products, services, or offers based upon your experiences at our resorts. For example, we may share your Personal Information with third parties located on-site at any of our resorts or off-site, such as spa, concierge, and leisure activities providers.
• Vendors and Service Providers: Any vendors and service providers we retain in connection with our business such as exchange network companies, travel services companies, financial services companies, timeshare sales companies, property owners" associations, vacation insurance companies, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, tax and financial advisers, legal advisers, accountants or auditing services.
• Potential Acquirors: We may disclose your information to a third party who may wish to acquire any part of RVC or any of its affiliates, whether such acquisition is by way of merger, consolidation, or purchase of all or a substantial portion of the assets, stock, or interests of RVC or any of its affiliates.
• Other: We may disclose your Personal Information (i) to law enforcement authorities, government or public agencies or officials, regulators, and/or to any other person or entity having appropriate legal authority or justification for receipt of your Personal Information, if required or permitted to do so by law or legal process, (ii) to respond to claims, or (iii) to protect our rights, interests, privacy, property or safety, and/or that of our affiliates, you or other third parties, (iv) to protect the rights, privacy, safety, or property of RVC, resort visitors, guests, employees, or the public, (v) to permit us to pursue available remedies or limit the damages that we may sustain, (vi) to enforce our websites" terms and conditions, and (vii) to respond to an emergency.

6. Protecting Your Personal Information

Travel Raintree will take reasonable measures to: (i) protect Personal Information from unauthorized access, disclosure, alteration, or loss or destruction, and (ii) keep Personal Information accurate and up-to-date as appropriate. We have implemented appropriate physical, electronic, and managerial procedures to help safeguard and secure your Personal Information from such before-mentioned events. Unfortunately, no security system is 100% secure; thus, we cannot ensure the security of all Personal Information you provide to us. We also seek to require our affiliates, business partners, vendors, and service providers with whom we share Personal Information to exercise reasonable efforts to maintain the confidentiality of your Personal Information. For online transactions, we use reasonable technology to protect the personal information that you transmit to us via our site. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure.

7. Your Personal Information Choices and Rights

Following are certain choices and rights you may have regarding your Personal Information:

• Accessing Personal Information: In accordance with applicable law, you may access your Personal Information. Any request to access or obtain copies of your Personal Information must be made in writing by contacting us as set forth in Section 10 - How to Contact Us below. If permitted by applicable law, we may charge a nominal fee to cover some of our administrative costs in connection with your request. Please note that we will ask you to verify your identity and to provide further details relating to your request.
• Correcting your Personal Information: We will take reasonable steps to ensure the accuracy of the Personal Information we retain about you. It is your responsibility to ensure you submit true, accurate, and complete information to us, and timely update us in the event this information changes. You may request that any inaccurate or incomplete Personal Information held by us or on our behalf is corrected by contacting us as set forth in Section 10 - How to Contact Us below.
• Deletion of Personal Information: Under certain circumstances, you may request we delete Personal Information we hold about you by contacting us as set forth in Section 10 - How to Contact Us below. We will review your request and determine, under applicable law, whether we are required to delete this information. Please note that if we comply with your request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.
• Withdrawing Consent: As permitted by applicable law, you may withdraw any consent you have provided to us to process your Personal Information at any time. Please note that if we comply with your request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.
• Objecting to Processing: If you would like us to stop processing your Personal Information, you can make such a request by contacting us as set forth in Section 10 - How to Contact Us below. We will review your request and determine, under applicable law, whether we have any justification to continue the processing of your Personal Information. Please note that if we comply with your request, we may not be able to provide you with the same quality and variety of services to which you are accustomed.
• Marketing Preferences: You can opt-out from receiving future marketing communications from us at any time by using the unsubscribe function in the email you receive from us or by contacting us as set forth in Section 10 - How to Contact Us below.

Any request by you concerning the above should contain your (i) name and address/e-mail address or other means by which we can respond to you, (ii) documentation or other proof that you are indeed the individual making such request, (iii) a clear and precise description of the Personal Information you wish to access, correct, delete, or withdraw or object your consent to use and (iv) any other information or document that may assist us in locating the Personal Information referenced in your written request. We will endeavor to respond to any request made by you in a timely fashion but in no event later than as required under any applicable law.

8. Nevada Privacy Rights

Notice to Nevada Residents: If you are a resident of Nevada, under certain circumstances, Nevada Civil Code Section NRS 603A.340 allows you to request operators of websites not to sell your Personal Information. To make such a request, please send an email to privacy@raintreeresorts.com or send a letter to:

• Raintree Vacation Club
• Member Services – Privacy Administrator
• 10000 Memorial Drive
• Suite 480
• Houston, Texas 77024

9. California Consumer Privacy Act Notice

Special Notification for California Residents only.

The California Consumer Privacy Act (“CCPA”) provides California residents certain rights regarding their Personal Information. For purposes of the CCPA and this Section 9, the term “Personal Information” is defined as 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 individual or household. This section 8 is intended to satisfy the requirements of the CCPA. The rights of the CCPA are in addition to any other rights applicable to you in this Privacy Notice. Please note that some Personal Information is not subject to the CCPA such as consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, and any other Personal Information exempt from the CCPA. Additionally, this Section 9 does not apply to our employees.

Personal Information Collected

Generally, we may collect the following categories of Personal Information for the following purposes:

• Identifiers: Identifiers such as your name, address, email address, account name, social security number, driver’s license number, passport number, account number and other similar identifiers. Purpose: To establish a business record of you, to verify your identity, set up your membership or accounts, to communicate to you about your purchases, transactions, contracts, our business relationship with you, to facilitate communications to you regarding products/services that may be of interest to you, to comply with legal requirements and for other similar reasons.
• Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Purpose: To process and/or administer your contracts, your reservations, your loans, to personalize your services/products, respond to your inquiries and facilitate communications to you, to manage our ongoing business relationship with you, to maintain a record of your preferences to better serve you and for other similar reasons.
• 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 Purpose: To collect information where needed for legal or financial documents, for a reservation, to address you with the proper salutation and for other similar reasons.
• Biometric Information - physiological, biological, or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including, without limitation, fingerprint, or facial recognition and for other similar reasons. Purpose: To collect biometric information in order for you to access portions of a resort or room therein or to assist in a law enforcement investigation.
• Internet Activity - internet or other network information, including without limitation, browsing history, search history, and information regarding a California resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any network or other information resource. Purpose: To improve our website functionality, to personalize your experience, to determine what your interests are to facilitate targeted communications of products and services to you, to judge the effectiveness of our online communications with you and for other similar reasons.
• Geolocation Data - precise geographic location information about a particular individual or device. Purpose: To collect your physical address or the location associated with the device used for your internet activity in order to create demographic analysis of visits to our site and promote interests in our products, to better market to and understand our customers and for other similar reasons.
• Audio/Visual Data - audio, electronic, visual, or similar information such as, CCTV images, photographs, and audio recordings (e.g., recorded meetings). Purpose: To collect information for quality assurance of product/service presentations or communications, when you pose for videos/photos or provide audios at our resorts or to us in any manner in order to improve our products and services, when you participate in activities or excursions or attend other events as part of service delivery and for other similar reasons.
• Employment History- professional or employment-related information. Purpose: To collect details of your employment history such as job title and length of time at your employment for contractual or financial reasons, or as part of a larger analysis of you and what products/services would be well suited for you and or other similar reasons.
• Education Information - information about education history or background that is not publicly available. Purpose: To collect information to match your potential interest and likelihood of purchasing certain products/services and for other similar reasons.
• Profiles and Inferences- inferences drawn from any of the information identified above to create a profile about a California resident reflecting such resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes and for other similar reasons. Purpose: To collect information to infer what products or services may interest you, your predicted attachment to your purchased products or services, your likelihood of purchasing other products or services, your likelihood of complying with contract and loan terms and for other similar reasons.

• The categories of Personal Information we have collected about you.
• The categories of sources from which we collected the Personal Information.
• Our business or commercial purpose for collecting the Personal Information.
• The categories of third parties with whom we share the Personal Information.
• The specific pieces of Personal Information we have collected about you.

10. How to Contact Us

If you have any questions, complaints, or privacy concerns after reviewing this Privacy Notice, or would like to make any requests in relation to your Personal Information, please email our Privacy Administrator at privacy@raintreeresorts.com or a letter to:

• Raintree Vacation Club
• Member Services – Privacy Administrator
• 10000 Memorial Drive
• Suite 480
• Houston, Texas 77024

11. Amendments to Privacy Policy

Travel Raintree may amend or revise this Policy from time to time. Any amendments or revisions to this Privacy Notice will be set forth at Travel Raintree’s website at https://www.travelraintree.com/enor we may also inform you through other communication channels. Any changes to our Policy will become effective upon posting of the revised Policy on the before-referenced website. Continued use of such website or any of our other mobile or social media applications or any of our products, services or resorts, continuing to communicate with us in writing or verbally or otherwise providing consent to the updated Policy following such changes, constitutes your acceptance of the revised Policy. You should therefore visit Travel Raintree's website frequently to check for any future updates. This Policy was updated last on March 31, 2022.