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Privacy Policy

Central Florida Investments, Inc., as parent company of Westgate Resorts, Inc. and together with its related and affiliated entities (“Affiliates”) (collectively “Westgate”, “we”, “us” or “our”) has a strong commitment to providing excellent service to our customers, owners and guests. At Westgate, meeting your needs and expectations for the foundation of everything we do—including protecting your privacy. Westgate wants you to be familiar with how we collect, disclose, and use information about you, and have thus prepared this Privacy Policy Statement (“Statement”).

Westgate has prepared this Statement to inform you of the privacy principles that govern our use of information we obtain from our customers, owners and guests, including information we obtain through this website (“Site”) or other websites we own or control or that link to this statement (collectively, the “Websites”), your communications with us, our communications with you, mobile applications, and through offline activities, such as when you provide your data by phone via our call centers or in person, or your stay with us at one of our properties.

This Statement applies to Westgate and its Affiliates who link to this statement. In the course of providing you with services and products, we collect certain personal information from you personally, or about you. By using this site and other Westgate Websites, you consent to this Statement, you agree to the terms of this Policy. If you do not agree to the terms of this Policy, please do not use the website. We reserve the right to change this Policy without prior notice. You agree to obtain annual notices of, and changes to, this Policy electronically by visiting this website. You can determine when this Policy was last revised by referring to the "Last Revised" legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the website. Use of the website following such changes constitutes your acceptance of the revised Policy then in effect. Therefore, we encourage you to review this website from time to time for changes to our Policy.

Browsing this Site

Please note that this Site does not collect personally identifiable information when you browse this Site or request pages from our servers, unless you provide such information to us. This means that we will not know your name, your email address, or any other personally identifiable information just because you browse the Site unless you:

• access the Web site from a link in an email that we sent;

• input your personally identifiable information via your owner account management login;

• are a Westgate Rewards member or have created a profile and you either log-in to your account or choose to be remembered via your cookie, including on your web-enabled mobile device; or

• input your personally identifiable information via a section of our Site in which you are requesting to be contacted by Westgate.

Information We Collect and Its Uses

When we need to collect personally identifiable information from you to provide you with a particular service, we will ask you to voluntarily supply us with the information we need. We often collect and maintain both Personal Information (information that identifies you, relates to you, describes you or is reasonably capable of being association with, or could reasonably be linked, directly or indirectly with you as a particular individual) and other information which cannot be used to identify you. We collect this information from a variety of sources and use and disclose it for multiple purposes.

For example, if you would like to make a reservation at one of our properties, we may ask you for information such as your name, address, telephone number, email address, credit card number, and room preference to process your reservation. We will use your email address to send a confirmation and, if necessary, might use the other information to contact you for help in processing the reservation. We may also use your contact information to send you a non-marketing informational pre-arrival message summarizing your confirmation details and providing other information about the area and the hotel; notify you about special offers and promotions as described in this privacy statement; as well as send you periodic satisfaction or market research surveys.

How and When We Collect Information

We collect and use information we believe is necessary to provide you with the products and services you request while also promoting our business. We collect and gather information from a variety of sources and in a variety of ways, such as, but not limited to, the following:

• You may provide information to us when you sign up for rewards programs; book a room reservation through our Websites, reservations call center or online travel agency; sign up to receive marketing, promotions or offer emails or text messages from us; install or use one of our mobile apps (i.e. WGLV Casino and WGLV SuperBook apps); enter a promotion or contest; request information from us; provide personal identification information to us at hotel check-in; submit an application for employment; and/or apply for credit or provide feedback to use in an online satisfaction survey.

• When you visit our property, Websites, or purchase and use our products or services, you may provide us with your payment card information, financial account information, driver’s license number, license plate number, photo identification card number, social security number, passport number, or we may obtain videos, recordings, and images of you.

• If you install or use one of the mobile apps, we may collect and use information regarding your mobile device, including but not limited to technical information about your mobile device, system and application software, peripherals, and location information, including GPS.

• We may obtain information about you from other sources, including third parties or publicly available sources, which we consider personal information when aggregated with information you have provided us as described above. We may use third parties to provide, confirm or supplement for us other information based on the information you provided to us directly. We are not responsible for the accuracy of any information provided by third parties or third-party policies or practices.

• Personal information will be retained only until it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by its retention and the retention is no longer necessary for legal or business purposes.

• We will maintain your personal information in whole, usable and up-to-date form. Please contact us as described below in the event you would like to correct or update any of your information.

Legitimate Business Interests/Purposes for Collecting Information

We may use the Personal Information you provide to Westgate to verify your identity, complete your transaction, administer your memberships associated with Westgate, send you commercial messages, advise you of other offers and information, carry out general recordkeeping, maintain a list of current and former owners or members, create informational or analytical reports, supplement your disclosed information, carry out verifications, planning or other legitimate business needs of Westgate, allow for revenue collection or debt recovery, respond to your inquiries or others who you have identified as an authorized agent or proxy, and such other purposes as permitted by applicable law.

With your consent, we may use information provided to Westgate for Marketing Purposes, which generally include, but are not limited to, the operation of our rewards programs and notifying you about promotions and special offers regarding products and services provided by Westgate, and contacting you in response to your inquiries, comments and suggestions. These notifications are provided via our Websites, mobile apps, direct mail or email, text messages, or by telephone.

We may use information provided to Westgate for Non-Marketing Purposes, which generally include, but are not limited to, validating your identity, recording gaming-related activity, issuing credit and collecting debt, facilitating reservations and processing purchase transactions from payment cards or other financial transactions, conducting market research and to improve customer service, complying with legal and regulatory requirements, satisfying contractual obligations and application for employment verifications.

We may collect and use your Personal Information to satisfy any applicable law, regulation, legal process, or enforceable governmental request, or when we have a good faith belief that use and disclosure is necessary to investigate, prevent or protect against harmful activities Westgate, owners, guests, visitors, associates, or property (including our Websites), or to others, prevent fraud, or cooperate with law enforcement or other government agencies.

Data from your information may also be used generally for our legitimate business interests/ purposes concerning data analysis, audits, fraud monitoring and prevention, internal quality assurance, developing new products, enhancing our services, helping us comply with legal requirements or process, enforcing compliance with our Terms and Conditions or any product, service or program terms and conditions, helping protect our Services, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

We also may share certain information with Affiliates and other non-affiliated third parties as permitted by law and as described below under “Disclosure of Information to Third Parties.”

Reservation Information

The Personal Information you provide to us for making a reservation is made available to the applicable property for the purpose of meeting your reservation request. After making a reservation or completing your stay at a Westgate property, unless you tell us otherwise, the information you provide may be used by us and our Authorized Licensees for marketing of Westgate properties and certain other Westgate branded products. Westgate may use the services of third-party mail houses for the sole purpose of mailing materials.

After your stay, we retain your personally identifiable information including details of your stay, room type and accommodation type.

User Generated Content

We may offer platforms for users to submit content such as reviews, message boards or other content. Any information 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.

Internet Based Advertising

Westgate and third parties may use the information collected through our Websites using cookies, web beacons, and other technologies to help manage online advertising programs and deliver electronic advertisements that may be more relevant to individual consumers. Please see Cookies and Related Technologies below for more information.

Disclosure of Information to Third Parties

Westgate does not permit the sale or transfer of Personal Information to entities outside of the Westgate family of companies, and properties and our third-party service providers for any non-Westgate use without your approval. Westgate and its Affiliates and Service Providers may share your Personal Information among themselves.

Westgate may use the services of third party processors, such as market researchers, fulfillment houses, email service providers and mail houses that process mail for Westgate, Westgate's Authorized Licensees, persons authorized by you, as well as such entities and marketing companies that provide these services for Westgate, and Westgate's Authorized Licensees. We may disclose your information to other third parties who provide services for Westgate, including but not limited to, travel services, financial and/or tax services data hosting or processing, credit card processing, credit or background checks, vacation insurance, website hosting, order fulfillment, information technology and related infrastructure provision, customer service, legal advisers, accountants, auditing, or processing and fulfilling reservations or purchases. These third parties are contractually prohibited from using personally identifiable information for any purpose other than for the purpose Westgate specifies.

Westgate may process, use, transfer and disclose your Personal Information to non-affiliated third party companies when we need to share your information to provide the product or service you have requested or need to send the information to companies, who work on our behalf, to provide a product or service to you, for general recordkeeping, informational and/or analysis reports, to supplement your information, or have your consent when consent is necessary to share the information.

These non-affiliated companies do not have any right to use the information we provide to them for any purpose beyond what is necessary to assist us. We require these providers to exercise reasonable care to protect your personal information and restrict its use to the purposes for which it was provided to them. We will protect your personal information in accordance with applicable data protection laws and will take steps to ensure any transferees do the same.

We also share Personal Information with other companies, organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Satisfy any applicable law, regulation, legal process or enforceable governmental request;

• Investigate, prevent or otherwise address fraud, security or technical issues; or

• Investigate, prevent or protect against harmful activities to Westgate or Affiliates, owners, guests, visitors, associates, or property (including our Websites), or to others, as required or permitted by law.

Non-Personal Information

We may provide non-personally identifiable information to certain third parties who provide services for Westgate for their use on an aggregated basis for the purpose of performing their contractual obligations to us. Westgate and these third parties may collect usage information when you visit and use our Websites and mobile apps. This may include browser type and/or settings, operating system, page(s) served, the time, request source, preceding page view, and similar data. We may analyze this information and use it to help us determine how our Websites and mobile apps are used, such as how visitors arrive at the Websites and mobile apps, what content is popular or most relevant and what type of visitors are interested in certain content or ads. We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities and improve our services. We may use such data by itself in anonymized form or aggregate it with information obtained from others. We may share such data with our affiliated companies and third parties to achieve these objectives and others, but the aggregate or anonymized data does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may use it in turn 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.

Merger or Acquisition

We may disclose your Personal Information in relation to the reorganization, sale or disposal of all or a part of our business or assets or the business of any of our Affiliates (whether such acquisition is by way of merger, consolidation, divestiture, spin-off, or purchase of all or a substantial portion of our assets), joint ventures and related business transactions, including in relation to audit or reporting and other regulatory requirements. Any successor or assign may use your personal information for the same reasons as set out in this Statement.

Security of Information

We treat the information you provide to us as confidential information; it is, accordingly, subject to our company's security procedures and policies regarding protection and use of confidential information. When we ask you for credit card data, it is transferred over a Secured Sockets Layer (SSL) line, provided you are using a SSL enabled browser such as Microsoft Internet Explorer or Mozilla Firefox. We also use SSL on other pages where you would enter personally identifiable information. This ensures that your information is encrypted as it travels over the Internet. This secure mode is enabled before any such information is transmitted from your computer or web-enabled device. You will know you are in secure mode when the padlock or key icon in the lower right-hand or left-hand corner of the computer screen appears in the locked position. In addition, when accessing a secure server, the first characters of the site address will change from "http" to "https." There is no guarantee, however, that the transmission, Internet, or storage system is fully secure. Please immediately notify us using the contact methods contained in the Introduction section of this Statement if you have reason to believe that your interaction with us has been compromised.

After information reaches us, it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside of Westgate. Because laws applicable to personal information vary by country, our properties or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on the Web sites covered by this privacy statement is generally processed and stored in the United States. We typically maintain records for a minimum of five (5) years.

Confidentiality of Identification Numbers

When collected, Social Security, National Insurance and other government-issued identification numbers are treated with great care, including our satisfaction of applicable laws and regulations. Social Security, National Insurance and other government-issued identification numbers are collected and retained in order to comply with various United States Federal and State laws and International regulations. For general information systems, we use customer numbers and employee identification numbers that are not derived from government-issued identification numbers. We use policies, procedures, training, technology and auditing to protect the confidentiality and privacy of Social Security, National Insurance other government-issued identification numbers and ensure that proper controls are in place concerning the collection, use, disclosure, processing, recording, holding, storing, and/or sharing of this information.

Cookies & Related Technologies

We may use third-party advertising companies to serve ads for goods and services that may interest you when you access and use our Websites and mobile apps, or others’ services, based on information about online activities across sites. These companies may use a unique cookie on your browser (including using pixel tags) to collect data about your online use and to recognize you across devices. If you would like more information about this practice, and learn how to opt out of it on your device browsers, visit www.aboutads.info and www.networkadvertising.org. You may also opt out in certain social media platforms by reviewing your account settings and restricting sharing your information with ad partners or tailoring ads based on information shared by ads partners.

We automatically track and collect general log information when you visit the Web sites, including your Internet Protocol (IP) address, domain server, operating system, and type of internet browser as well as the website pages you visit. We may collect certain information from cookies, pixel tags, web beacons or similar technologies for web analytics and direct marketing. Cookies are pieces of data stored on the computer or mobile device you are using. Our Site requires the use of a Cookie throughout the online reservation process. Without Cookies we will not be able to keep information you enter on multiple pages together. We use cookies to allow us to recognize the device you are using, save your selections and preferences, and provide you with a more customized and beneficial experience on our Websites, including providing the functionality that allows you to interact with a representative while you are on some of our Websites.

We may use cookies and IP addresses to identify who you are and may use them when you visit the Websites, click on our ads, or open our emails. By continuing to use our Websites, you agree to our placing cookies on your computer or mobile device. We, however, will seek your explicit consent if you are in a jurisdiction that requires it.

The types of Cookies that we use are referred to as "Session" Cookies and "persistent" Cookies. Session Cookies are temporary and are automatically deleted once you close your internet browser. Persistent Cookies remain on your computer hard drive until you delete them or are otherwise removed upon expiration. We do not use Cookies to ascertain any personally identifiable information about you apart from what you voluntarily provide us in your dealings with us. Cookies do not corrupt or damage your computer, programs, or computer files.

We may use social media sites’ tools to enable us to follow the actions of visitors to our Websites who are redirected to our Websites after clicking on an advertisement; record the efficiency of social media advertising for marketing, statistical, and market research purposes; and serve targeted advertisements determined by your activity on our Websites. For further information on any social media site’s data collection and use about your rights and options to protect your privacy, please refer to that specific social media site’s data protection policies.

We may use Google AdWords cookies provided by Google Inc. for remarketing purposes. This technology enables (a) users who have already visited our Websites and have shown interest in our products or services to see targeted advertising on websites within the Google partner network and (b) us to provide targeted advertising based on user interest. You can opt- out of Google AdWords cookies by visiting the Google Ads Settings page at http://www.google.com/settings/ads.

You may set your browser to block, refuse, reject, or delete cookies (consult the instructions for your particular browser on how to do this), although doing so may adversely affect your ability to perform certain transactions, use particular functionality and access certain content on our Websites. We only use cookies or related technologies as your browser permits. For more information about cookies or if you do not want data collected with cookies, visit www.allaboutcookies.org, www.aboutads.info, and www.networkadvertising.org.

Your Choices/Opt-Out

We offer you choices when we ask for personal information, whenever reasonably possible. We provide you the opportunity to 'opt-out' of having your Personal Information used for certain purposes not essential to Westgate's providing services to you, when we ask for this information. You may decline to provide Personal Information to us and/or refuse cookies in your browser, although some of our features or services may not function properly as a result. If you no longer wish to receive promotional communications, you may opt-out of receiving them by following the instructions included in each communication or by emailing or calling us per the information contained on our contact page.

By providing information to us, you are consenting to the collection, use and disclosure of such Personal Information in the manner described in this Statement. We provide you the opportunity to withdraw your consent at any time by following the procedure described in this Choice/Opt-Out provision and as described for specific states below. Also note that laws related to personally identifiable information vary by country.

Such consent may be withdrawn in writing and sent to our customer service department as set forth at the end of this section.

Notice to European Residents

We provide our European consumers with certain rights. To the extent required by applicable law, you have the right to: Request access to your personal data (commonly known as a "data subject access request"); Request correction of the personal data we hold about you; Request erasure of your personal data; Object to processing of your personal data in certain circumstances; Request restriction of processing of your personal data; Request the transfer of your personal data to you or to a third party (data portability); Withdraw consent at any time where we are relying on consent to process your personal data.

We will make a reasonable effort to comply with these requests as required by law. Please address requests and questions about this to our contact information below. Please use “GDPR Privacy” in the subject of your email and inform us what country you are a resident of.

Contact Us

If you have any privacy-related questions or concerns, or would like to make any requests in relation to your Personal Information, your choices, rights, or would like to withdraw consent, please send a letter to our customer service department at the following physical address:

Westgate Resorts

Privacy Program

2801 Old Winter Garden Road

Ocoee, FL 34761-2965

Or e-mail us at privacyprogram@wgresorts.com

State-Specific Choices/Opt-Out

Notice to Vermont Residents

In response to Vermont regulations, we automatically treat accounts with Vermont billing addresses as if you requested that we not share your information with nonaffiliated third parties, and that we limit the information we share with our affiliates. If we disclose information about you to nonaffiliated third parties with whom we have joint marketing agreements, we will only disclose your name, address, other contact information, and information about our transaction and experiences with you.

Notice to Nevada Residents

We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing at Westgate Resorts, Privacy Program, 2801 Old Winter Garden Road, Ocoee, FL 34761. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us.

In accordance with SB 220, Nevada residents may opt out of the monetary sale of their personal information collected on-line. The designated email address for these requests is wglvprivacycompliance@wgresorts.com.

Notice to California Residents

If you are a California resident, California law may provide you with additional rights concerning Trifecta’s collection and use of your personal information. After reading this Online Privacy Policy, please click here to visit Westgate’s California Privacy Notice

( https://www.westgateresorts.com/ccpa/) to learn more about your California Privacy Rights.

Children’s Privacy

This Site is not intended for children or anyone under the age of 16 and we do not knowingly solicit or collect personally identifiable information from children. We may present information regarding Westgate programs that are for kids on this site for the reference of adults that are interested in activities at our locations for children. We do not knowingly collect information from children. If you believe that we have received information from a child or other person who is not of a majority age in their relevant jurisdiction, please contact us at our email or physical mailing address listed in the “Contact Us” section below and we will take all reasonable efforts to remove the information. Visit the Federal Trade Commission website for more information about the Children’s Online Privacy Protection Act (COPPA).

Accessing this Site from a Mobile Device

You can access our Site from a web-enabled mobile device to find a property (including clicking to call the hotel) or view a reservation. If you desire to view a reservation you will be required to enter your Westgate account username and password, or Westgate confirmation number and zip/postal code or country. No other personally identifiable information will be requested. In addition, you can make a reservation from a web-enabled device. When you make a reservation, you will need to provide certain personally identifiable information such as name, email address and credit card information. Additionally, you can make payments to Westgate, via credit card, by accessing our website from a web-enabled mobile device. To review the security measures Westgate has in place regarding your credit card data, please review the section below titled Securing the Transmission and Storage of Information ASAS.

Click to Chat

We use third party software to proactively initiate or offer online chat if we believe you would benefit from assistance. All information you enter via online chat may be associated to your email address and will be stored in our systems with any other information you provide and any transaction detail.

Emails About Special Offers and Promotions and Opt-Out

It is our intention that you should only receive email communications that will be useful to you and that you want to receive. When you communicate with Westgate via email and provide your email address, Westgate may periodically contact you via email and provide information about Westgate special offers and promotions that may be of interest to you (unless you opt out). We may also give you the opportunity to receive Offers and Promotions from Westgate and, its Affiliates concerning other Westgate-branded offers and promotions that we believe would be of interest to you.

We typically use third party email service providers to send emails. These service providers are contractually prohibited from using your email address for any purpose other than to send Westgate related email.

Each time you receive an email, you will be provided the choice to opt-out of future emails by following the instructions provided in the email. Please allow 10 business days for us to process your opt-out.

Careers

We use third parties that provide applications, tools, databases, or websites that assist us in collecting the personal information of individuals who wish to be considered for potential employment. The information you provide as part of your application for employment is accessible to Westgate and may be shared among Westgate, its Affiliates, and recruiters working on behalf of Westgate or its Affiliates for the purpose of managing your application for employment, including administering the application, arranging interviews, applicant selection, scoring, assessment, issuing offers to successful candidates, and to comply with legal and regulatory requirements. Westgate uses the information provided for its (a) legitimate interest in fully assessing applications to ensure that only appropriate candidates are assessed and selected and (b) legal obligations to comply with employment laws and other legal and regulatory requirements.

Other Companies and Sites

Website Links

Our Websites and mobile apps may contain links to third party sites that might be of interest to you (such as airlines or car rental companies). We do not have access to or control over these third-party websites or services, and you should review their individual privacy policies and settings. Westgate is only responsible for the privacy statement and content of this Site and information we collect. We are not responsible for the data collection and use practices and privacy policy or the use of Cookies on websites that you have accessed this Site from and to the non-Westgate websites that you may access from this Site, including but not limited to any other company such as airlines, car rental companies, Facebook, Google, or any other provider or website.

Social Media Platforms or Websites

We are not responsible for the privacy policies and/or practices of third parties such social media platform or site providers, RIM or any other app developer or provider, operating system provider, wireless service provider or device manufacturer, and/or any data you disclose to them. We attempt to monitor comments and ratings on social media services or customer review sites and may contact you regarding these postings to address customer service issues. We recommend that you do not post any personal information through our Websites that would allow strangers to identify or locate you or that you otherwise do not want to share with the public.

Contact Us

If you have any questions or comments regarding this policy, please contact us using the information below:

Westgate Resorts

Privacy Program

2801 Old Winter Garden Road

Ocoee, FL 34761-2965

Or e-mail us at privacyprogram@wgresorts.com

Please print and retain a copy of this California Privacy Notice for your records.

Last Updated: June 25, 2020

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