Owners & Members Privacy Notice

Last Updated: December 5th, 2025

Hilton Grand Vacations Inc. and our HGV Family (collectively, “HGV”, “we”, “us”, or “our”) care about your privacy. This HGV Global Privacy Notice (“Notice”) describes how we collect, use, disclose, and otherwise process Personal Information about individuals associated with our marketing activities, vacation package holders, guests who stay at our resorts properties, and those that interact with the HGV Site.

For more information about our privacy practices, you can find our Owner & Members Privacy Notice here.

1. INTRODUCTION & WHO WE ARE

This Notice applies to all interactions made by HGV and its subsidiaries under any of our brands including Hilton Grand Vacations Club, Hilton Vacation Club, Hilton Club, The Club, Embarc, Extraordinary Escapes, and Bluegreen Vacations Club (the “HGV Family”).

Who are the Data Controllers. We have many subsidiaries, affiliates and managed resorts around the world that may act as the data controller of, or process, your Personal Information, including entities that operate outside of the jurisdiction in which it was collected or where you reside. In most cases, the HGV data controller principally responsible for the processing of your Personal Information will be as follows:

  • If you purchase a timeshare from us, and unless otherwise indicated, the data controller will be the HGV entity which appears on your purchase agreement.
  • If you purchase a promotional vacation package, agree to participate in a promotional sales presentation, book a meeting or stay at one of our properties, the data controller will be the entity named on your confirmation.
  • If you have booked a vacation through a third-party booking website for a stay at an HGV property that third-party share with us your Personal Information but will also be the data controller of certain Personal Information;
  • If you elect seller financing in connection with the purchase of a timeshare from us, the data controller with respect to your loan will be the entity that appears on your financing documents (e.g., your promissory note, instalment agreement, deed of trust etc.).
  • If you participate in one of our membership exchange programs, the data controller will depend on which program:
    • For Hilton Grand Vacations Club or the Hilton Club, the controller will be Hilton Grand Vacations Club LLC;
    • For The Club, the controller is HVC International Club, Inc.;
    • For Extraordinary Escapes, the controller is Extraordinary Escapes Corporation; and
    • For Destinations Xchange, the controller is DestinationXchange, LLC.
  • With respect to annual maintenance fees owed in connection with HGV timeshare ownership, the data controller responsible for collecting your annual fees, will be the entities named on your billing statement.

If you require further information on the data controller(s) for your jurisdiction, please get in touch using the details in the “Contact Us” section below.

Defined Terms. In this Notice we refer to a few defined terms as follows:

Owner – When you acquire a timeshare with the HGV Family, you become an Owner. When you become an Owner. For certain ownership arrangements, you will be automatically enrolled in a relevant membership program, whilst for other ownership arrangements membership must be requested by you. When you are a member of one of our membership programs, you may be referred to as “Member”. References to “Owner” and “Owner Information” in this notice also apply to any of our membership programs for which you are a member.

Vacation Package Holder – This means anyone that purchases a vacation package on our Site, over the phone or face-to-face.

Guest – This means anyone that visits or stays at our properties.

Personal Information – This means any information that identifies or relates to you as an individual, either on its own or in combination with other information. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using means reasonably available to us.

Site – This means the websites operated by the HGV Family and related apps and associated services we provide.

2. TYPES OF PERSONAL INFORMATION WE COLLECT

The Personal Information we collect will depend upon many factors including our relationship with you, whether you purchase our vacation packages, purchase a timeshare from the HGV family, the programs or promotions you participate in, how you engage with our Site, the resort(s) at which you vacation and, in some cases, the jurisdiction in which you reside.

Below are various types of Personal Information we may collect depending on your relationship with us and whether collected via a Site, over the phone, or face-to-face.

Vacation Package Holder Information – We collect your name, contact information, as well as information related to your eligibility to participate in promotions such as your age, state or country of residence, annual household income, occupation, credit history, marital status and travel preferences. We use this information to contact you, invite you to participate in promotions as well as to provide you information about products, benefits and services that may be suitable for you.

Meeting or Event Profile Information – We collect meeting and event specifications such as the date of the event, number of Guests, details of the Guest rooms, along with information about Guests that are a part of an event. If you visit us as part of a group, we may have Personal Information about you provided to us by the group and may market to you as a result of your stay with a group or attendance at an event. If you are an event planner, we may share information about your event with third-party service providers who may market event services to you.

Payment and Points Information – When you purchase a product or service from us (such as acquiring a timeshare, booking a vacation package, meeting or event), we collect your credit or debit card details, bank account information, or other payment information as required. If you use points to make your purchase, we collect information about the account for which the points are attributable.

Booking Information – If you book a stay at one of our properties, we collect or receive (from an applicable third-party) your name, contact information, dates of stay and number of Guests. We may also collect details about any special requests you have made.

Guest Information – When you arrive at our front desk, we collect information related to your reservation, stay or visit to a property, the purchase and receipt of products or services during a stay, vehicle information (make, model, plate), passport number and date and place of issue if you are a Guest at one of our properties outside the United States, payment card number and other card information, and frequent flyer or travel partner program affiliation and related account number. We may also collect Personal Information about you associated with your stay: for example, if you have an accident on site, we will typically complete a formal report and we will ask you to provide personal details as well as details of the accident.

Use of Resort Services – We may collect information in connection with your use of on-property services and activities, such as concierge services, health clubs, spas, activities, childcare services, and equipment rental and your preferences whilst staying at our resorts.

Concierge Services – We may collect information (such as your name, confirmation number, check-in and checkout dates, and room number) in providing concierge services. These services may be available face-to-face, real-time or via virtual “concierge” features, which may be pre-loaded onto a device owned by us, or downloadable to your web-enabled mobile device. For example, you may be able to communicate directly with the resort; order services from the resort, such as room service or valet parking; access our websites; access third-party websites, including local attractions and social media; and book a reservation. If you request or agree to receive SMS (i.e., text message) communications, you will be asked to provide your phone number and carrier.

Family and Visitor Information – We may collect Personal Information about your family or visitors including names, addresses and frequent flyer numbers. If we collect this information from you, on behalf of your family and visitors, you should make sure that the person whose Personal Information you are providing knows that you have done so and that they have read this Notice.

Vehicle and Driver Information – – We collect information about vehicles you may bring onto our properties including license plate information, vehicle make and model, and the age of the driver(s) of any rental car. We may use this information if you use our valet parking services.

Complaints and feedback – If you provide feedback or raise a complaint at one of our resorts, we may associate that feedback or complaint with your Personal Information in case we need to contact you further.

Account Information – When you access your account, we may collect your name, contact information, and account credentials for the creation or access of your account and in order to process your transactions.

Owner Information – When you purchase a timeshare from use, we collect your name, contact information, confirmation number, or social security or national identification number. These details can be used to create an online account. We also collect information about your nationality and language preferences, and in some instances real estate title preferences. If you enroll in membership programs then, we also collect user IDs and passwords for your membership online and app accounts. We will also collect transaction and correspondence details.

Borrower Information – If you apply for financing from us, we may from you and any co-applicant your age, state or country of residence, annual household income, homeownership status, occupation, credit history, previous addresses, dates of birth, bank account information, as well as credit information and payment history.

Online Contact Information – If you submit an online "pre-application" for a timeshare, an online reservation or information request/inquiry, or participate in an online "click-to-chat" feature, we may ask you to provide your contact information, contact preferences, country and/or state of residence, annual income range, reservation information, marital status, Lead Number, Member Number, Hilton Honors Number, and whether you own a home. We may also request information regarding your vacation preferences including destinations, seasons of interest, accommodations, and length of stay. If we deliver our presentation to you virtually or over the phone, we may also collect audio recordings (for more information, see the “CCTV and Audio Recordings” section below). If you are looking to participate in a transfer of ownership program, we may ask for information to determine your eligibility such as existing participation with exit firms or listing companies, original acquisition information, and future plans of use for your timeshare).

Device and Usage Information – We may collect information about your computer or device and Internet or other electronic network activity information. This includes:

  • Device identifiers, such as IP address, WIFI MAC address, and Bluetooth address;
  • Geolocation information such as your mobile device’s Global Positioning System (GPS) technology, other technology (such as wireless transmitters known as beacons) and information about your contacts, depending on your device settings (for more information, see the “Geolocation Data” section below);
  • Information about your online activity, including through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies, as further set forth in our Cookie Statement, and your offline activity, including information about your visit to our resorts or properties; and
  • Information about the use of our Sites such as how often you visit our Sites, what pages you visit, and what other sites you used prior to visiting our Sites. For more information, see the “Web Analytics” section below.

Sweepstakes and Contest Information – If you enter our contests or sweepstakes we may collect your name, contact information, age, and account information (if you are an Owner). We may also collect information about your vacation interests as well as information relative to your eligibility to purchase a timeshare such as income. If you are a winner of a contest or sweepstakes, we will also collect your social security number or national identification number.

Chatbot – If you use our chatbot feature, you will provide your contact information and any information you choose to provide in your message. Our chat features are provided by third parties, such as ChatGPT. Our third-party chat feature providers may collect, record, and store the information you provide in the chat.

AI Technologies – The AI-powered technologies we use to provide certain features on our Sites will collect your personal information to respond to your interaction and to provide certain features or services to you.

Forward-to-a-Friend Information and Referral Programs – We may offer a referral program that allows you to share an electronic postcard or message with a friend, whether via the Internet, a stand-alone kiosk or mobile device. If you choose to use these features or participate in our referral programs, we will collect the recipient's name and contact information, along with the text of any message you choose to include, if applicable. You should make sure that the person whose Personal Information you are providing knows that you have done so and that they have read this Notice.

Sensitive Information. – Through your interactions with us, we may collect certain Personal Information of a more sensitive nature. This includes Personal Information that may be subject to special processing conditions in your country of residence (e.g., financial information, health information or ID information). The sensitive information which we may collect or process about you includes:

  • Health information (including medical history, disabilities, and details of any on-site accidents) – for example, as a Guest you may volunteer information relating to any disabilities, medical conditions, allergies and intolerances, or any accessibility requirements you may have. In addition, if an accident occurs then health data will be collected through an incident form; this may include information of a hospital visit (but not doctors reports) and the form typically asks if an accident is related to a Guest’s pre-existing medical history. Photos of injuries may also be collected and, in such circumstances, those photographs would constitute sensitive information. This information is transferred to the US as it may need to be reported to insurers.
  • Social Security Numbers – Only in the circumstances where you purchase a timeshare or seek financing from us, as noted above, we collect your social security or national identification number.
  • ID information – in addition to the information outlined in Guest Information, in many locations, the passport or other government issued photo identification of Guests are scanned at check-in and the scans are kept for the verification of the Guest’s identity and to comply with local laws.
  • Credit Information – as part of you expressing an interest in our timeshare products, submitting a "pre-application" for a timeshare, or electing financing from use, we will collect financial information about you and any co-applicant (e.g., your income, your home ownership status, your work history, your previous addresses, date of birth and bank account information, as well as credit information and credit history) and will request a copy of your credit report. The exact nature of the information we may collect may differ depending on your place of residence and the type of financing you have applied for and you may be presented with additional information about our use of Credit Report Information depending on your location. Your credit information is used to allow us to determine your eligibility for particular timeshare products and any requested level of finance and we treat this derived information as sensitive Personal Information.
  • Credit Report Information – When you apply for a loan with us to purchase your timeshare we will collect financial information about you, including your Credit History (see the Sensitive Information section above) and will request a copy of your credit report. We may collect further background information about you and any co-borrower from your credit file. The exact nature of this information may differ depending on your place of residence and the type of financing you receive or apply for, and you may be presented with additional information about our use of Credit Report Information depending on your location (e.g., if you are a US resident, we will provide you with a mandatory disclosure notice under the Gramm–Leach–Bliley Act).
  • Children’s data – Personal Information of children of Guests may be processed either incidentally (e.g., through the use of CCTV at our resorts or participation in on-site activities) or intentionally as part of local laws. For further information please see the “Personal Information about children” section below.

Investor Relations – If you subscribe to our investor relations email alert service, we will collect your email address.

Other – In addition, we may collect Personal Information through a variety of other interactions and activities, including but not limited to:

  • When you communicate with us via phone, email, text message, live chat, social media, or other means;
  • When you complete online forms, surveys, or questionnaires related to our services or promotional offers;
  • When you submit a job application or inquiry regarding employment or contracting opportunities with us;
  • When you voluntarily provide personal information for any other purpose not specifically described in this policy.

Anonymous or Aggregated Data – We may also collect certain information about you that is not Personal Information. This may include intellectual property or other company information you share with us, in accordance with any applicable agreements between you or, if applicable, your company, including for example, trademarks, logos, and other intellectual property you own. We also might collect and/or generate anonymized and aggregated information from your use of our Sites. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of our Site. Anonymized or aggregated information is not Personal Information.

3. PERSONAL INFORMATION OBTAINED FROM OTHER SOURCES

We may also obtain Personal Information about you from other sources. The information you provide to third parties is subject to their privacy statements. Such third parties may include the following affiliates and vendors:

Loyalty and Membership Program Providers – When you enroll in a loyalty or membership program, then your Personal Information will be collected by the providers of those programs. In some instances, that information may be shared with us. In particular, as part of our long-standing partnership with Hilton Worldwide, we receive data about you from your Hilton stays and your Hilton Honors membership and may link or associate this information with your HGV Account.

Booking Agents – If you use a travel agent or third party booking site (including online travel agencies such as Expedia) to make a reservation for you at our properties then your Personal Information is shared with us by such third party.

External Exchange Companies – We may run soft credit checks and receive certain Personal Information from credit reporting agencies..

Data Verification Providers – We receive updates from data verification providers, such as the U.S. Postal Service, that help us to maintain the accuracy of the Personal Information we maintain, such as your correspondence address.

Event Planners – If you are a participant in a group reservation, we collect Personal Information from the event planners responsible for your event.

Social Media – If you choose to participate in social media activities or offerings sponsored by us, 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, interests, photos, status updates and friend list.

Marketing Partners – We may receive your contact information from Hilton Worldwide, from our other partners or from other sources, which, where permissible, we may use for telemarketing purposes, electronic mail, text message (including SMS and MMS), push notifications, in-app messaging, and other means.

If someone makes a reservation for you – In the event that someone else makes a reservation for you at our properties, or if you are a Guest of an Owner, we will collect Personal Information about you from that person.

4. HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your Personal Information depend on your relationship with us. In general, we use Personal Information to:

Manage certain aspect of our business and your account including to:

  • Fulfill our agreement with you and manage your reservations and associated bookings, including communicating with you about your reservations and any associated bookings when you contact us or log on to your account, we will verify your identity or user credentials so that we can protect your information;
  • Administer contests and sweepstakes;
  • Fulfill other purposes disclosed to you at the time you provide us with your information or otherwise where we are legally permitted to do so;
  • Understand your location, including based on your IP address and information you provide to third parties (see the “Mobile app and location-based data” section below for more information);
  • Keep our Sites safe and secure and to prevent and detect fraud and abuse; and
  • Administer and manage our Sites including content and layout, Sites usage, troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • Comply with our legal obligations, policies, and procedures;

To provide services you have requested including to:

  • Allow you to complete reservations, make payments, service your requests and administer our relationship with you;
  • Make, amend and administer your booking or intended booking, send your itinerary or other details relating to your booking, send you service messages relating to your booking (for example, to confirm your booking or notify you or any issues), and update you on changes to your travel itinerary (for example, if there is a change to your booking pre-travel).
  • Process your ownership account information or assist with transfers related to your account including your payment information for transactions

To communicate with you such as to:

  • Provide you customer service and to process your requested transactions or respond to your queries;
  • Send you information about our products and services including sending you information about promotions, that may be of interest to you by electronic mail, text message (including SMS and MMS) and (depending on location) by phone
  • Provide you with updates and other information regarding your accounts;
  • Serve you targeted and personalized advertising about our products and services depending on your location and your privacy choices;
  • Display pricing personalized to you and to remember your information for future visits to our Site through the use of cookies and related technology.

5. SHARING OF PERSONAL INFORMATION

We may disclose your Personal Information to the following entities within our group and to our business partners:

HGV Family – We may share Personal Information within the HGV Family, as well as with owners and operators of resorts that we manage or are affiliated with but do not own, resorts that may individually or jointly provide you with services, personalization and for the purposes described above. In addition, when we cease managing a resort that we do not own or end an affiliation relationship, we may provide the resort's owner or manager with certain information about past or future Guests of that resort.

Loyalty and Membership Program Providers – If you enroll in other loyalty or membership programs with which we have a relationship, then we may share your Personal Information with the providers of those programs.

Business Partners – We may partner with other companies to provide you with products, services, or offers based upon your experiences at our properties or otherwise with the HGV Family. For example, we may help to arrange flights, rental cars or other services from our business partners to allow our business partners to provide those services to you. We may also share your Personal Information, such as your email address, with our corporate travel partners to help them assess compliance with travel policies or participation in special rate plans or to engage in co-branded marketing with our corporate travel partners. We may also work with third parties, such as our airline, cruise, hotel providers, car rental partners and retail partners, to allow us and our partners to deliver advertisements to our shared customers. Additionally, we may allow third-party partners to recognize you when you visit that partner’s website or app, or to recognize you as one of their customers when you visit our Sites or apps so that they may provide more relevant offers to you. We may share your email address with third parties using available security measures that may match it with their own email addresses so that they can send online and email advertisements to you on our behalf. We may also share geolocation information with business partners and service providers to provide information, offers, and services that may be of interest to you.

External Exchange Companies – You may have a membership with a third-party organization or otherwise have rights to access the benefits and services of a third-party organization, such as RCI or Interval International, that allows you to "exchange" your timeshare interests or points for other weeks, products and services. We may send your Account Information to that exchange company to allow it to service your account and facilitate your exchange requests.

Resort Services – We may share Personal Information with third-party providers of on-property services such as concierge services, childcare services, spa treatments, golf, or dining experiences.

Co-Sponsors of Promotions – We co-sponsor promotions, sweepstakes, prize draws, competitions or contests with other companies, and we provide prizes for sweepstakes and contests sponsored by other companies. If you enter one of these sweepstakes or contests, we may share your information with the co-sponsor or third-party sponsor.

Event Planners – If you visit one of our properties or resorts as part of a group event or meeting, information collected for meeting and event planning may be shared with the organizers of those meetings and events, and, where appropriate, Guests who organize or participate in the meeting or event.

Homeowners’ Associations and Related Parties – We may share Personal Information with third parties, such as Homeowners Associations, property management providers, and trust companies, to enable them to perform their supervisory and regulatory functions with respect to the management and maintenance of your property and/or ownership interest. In respect of Homeowners’ Associations, HGV typically collects maintenance fees relating to your timeshare on behalf of the Homeowners’ Association and, consequentially, we will need to share certain information about you regarding your maintenance payments.

Finance Providers and Financial Institutions – Where you have elected to finance the purchase of your timeshare with a third-party financial institution, we will share Personal Information relating to your timeshare and membership with that financial provider. In addition, for Owners located in Japan and other non-US regions, we may introduce you to certain third-party financial providers who allow you to make payments in local currency and, where you elect to use such a facility, we will share information relating to those payments with those providers. Those financial institutions will also process your Personal Information for their own purposes and provide a privacy notice relating to such activities.

Escrow and Title Companies and Related Parties – As part of registering your ownership interest, we share information with Escrow, trust companies and local county recorders offices.

Credit Reference Agencies – We share information with credit reference and credit reporting agencies as part of our processing of your Credit Reporting Information. Those agencies may adjust your credit file depending on the information you provide us as part of their wide credit monitoring activities. The type and extent to which we share such information with credit reference agencies will depend on your location and, in some cases, may be further set out in a supplemental privacy notice.

Debt Management and Claims – As part of our collections and/or foreclosure activities we may engage the services of third-party claims and debt management company and may share your information with those companies associated with such activities.

Web Analytics and Other Third-Party Analytics – We use tools to collect information about the use of our Sites (e.g., web analytics tools, such as Google Analytics, collect information such as how often users visit our Sites, what pages they visit when they do so, and what other sites they used prior to visiting the Sites). The providers of these tools only collect the IP address assigned to you on the date that you visit the Sites, rather than your name or other identifying information. The information collected through the use of such tools is not combined with your Personal Information.

Other – We may share Personal Information with any third-party who is restructuring, selling, franchising, licensing or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organization or similar event and in order to comply with any legal or regulatory obligation or request, including by the police, tribunals, regulators, the government or related agencies.

We may also share your information when you specifically request it or give us permission to do so.

We may also share your information when we suspect criminal or fraudulent activity, and when we are required by law such as when we receive a subpoena or a court order.

When sending your Personal Information to third parties, we only disclose Personal Information that is necessary for them to provide their services and we have a contract in place that requires them to keep your information secure and, where they are act as our processor, not to use it other than in accordance with our specific instructions.

Third parties that are controllers of your Personal Information may disclose or transfer it to other organizations in accordance with their data protection policies. This does not affect any of your data subject rights.

6. NOTICE OF FINANCIAL INCENTIVE/LOYALTY PROGRAM

We may provide rewards, benefits, con or special offers when you participate in our loyalty programs, sign up for our mailing list, or provide us with referrals. Categories of Personal Information that we may collect through such programs include your name and contact information and/or the name contact information of the person you are referring.

Disclosures to Third Parties and Loyalty Program Partners

We may disclose your personal information that we collect through our loyalty programs to our loyalty program partners Hilton Honors and Choice Hotels, and financial incentives to third parties.

How to Opt-In and Right to Withdraw

Signing up for discounts and price differences through a loyalty program, newsletter, or referral program is optional. By providing your email address or name and email address and/or the name and email address of the person you are referring, you affirmatively opt in to receiving the financial incentive and to joining our loyalty program and/or mailing list. You have the right to withdraw from the financial incentive at any time. If you opt out of receiving a financial incentive, we will not reduce the value of any financial incentives you previously received from us. If you wish to withdraw from receiving the financial incentive, you may submit such a request at any time by emailing us at privacyhgv@hgvc.com.

Please note that if you request deletion of any loyalty program account and/or personal information, then we will no longer be able to provide you with the same benefits, rewards, and promotions. We must maintain the personal information that you provide for us to provide the benefits to you.

How the Financial Incentive is Reasonably Related to the Value of Your Personal Information

The financial incentive or price difference is reasonably related to the value provided by your personal information. We take into consideration, without limitation, the anticipated revenue generated from such information, the anticipated expenses which we might incur in the collection, storage, and use of such information, and the anticipated expenses which we might incur related to the offer, provision, and imposition of any financial incentive or price difference. Based on this analysis, the value of your personal information that allows us to make these offers and financial incentives is the value of the offer itself.

7. INTERNATIONAL TRANSFERS

HGV is a global company headquartered in the US. Your information will likely be collected by an HGV controller in your country and subsequently transferred to or stored by an HGV controller, our service providers and other third parties including in other countries that may have privacy protections less stringent than in your country. In accordance with applicable law, we implement measures, such as standard contractual clauses or declarations by regulators or governments (e.g. adequacy decisions) to ensure that any transferred Personal Information remains protected and secure.

Please contact us using the details in the “Contact Us” section of this Notice for more information about the protections that we put in place and to obtain a copy of the relevant documents.

8. RETENTION

We retain the Personal Information we receive for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

When determining how long this retention period will last once the purpose of processing the Personal Information has been satisfied, we consider the length of time Personal Information is required to:

  • continue to develop, tailor, upgrade, and improve our Sites;
  • maintain business records for analysis and/or audit purposes;
  • comply with record retention requirements under the law;
  • defend or bring any existing or potential legal claims; or
  • address any complaints regarding our Site.

9. SECURITY AND LINKS TO OTHER SITES

The security of your Personal Information is important. We take reasonable steps to use appropriate technical or organizational measures to protect your Personal Information, including against unauthorized or unlawful processing and accidental loss, destruction, or damage. We have implemented technical, administrative, and physical security measures designed to protect your Personal Information from unauthorized access, disclosure, use, and modification. Although we strive to keep your Personal Information secure, no security measures are absolute. Use caution when transmitting Personal Information over the Internet.

By using our Sites, or providing Personal Information to us, you agree that we may communicate with you regarding any security, privacy, and administrative issues relating to your use of our Sites. If we learn of a security system’s breach, we may attempt to notify you by placing a notice on our Sites, by post or by sending you an email.

Third Party Sites – Our Sites may contain links to third parties' websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on and use third-party sites, the privacy notices and terms of service on those sites are applicable.

On Property Internet Service – We may also partner with a limited number of Internet providers to offer Internet access to our Guests. Your use of on-property Internet service is subject to the third-party Internet provider’s terms of use and privacy notice. You can access those terms and policies using the links on the service sign-in page, or by visiting the Internet provider’s website.

Social Plug-ins & Targeted Advertising – Our Sites may support certain third-party social sharing sites or buttons for Facebook, X (formerly known as Twitter), Pinterest, Instagram, YouTube. These features use third-party cookies that are directly set on your device by these services.

In addition, we may use third-party platforms, some of which are operated by social networks (in particular Facebook) to show you interest-based ads. We may convert your email address, telephone number or other information into a unique value which can be matched by those third parties with a user on their platform or with other data they may have collected from you. This matching allows interest-based ads to be delivered on those platforms. These platforms may have their own privacy notices or policies, which we strongly suggest you review.

We may also communicate with you by means of third-party digital messaging apps. If we do so, the privacy policies of those services apply.

10. OTHER IMPORTANT INFORMATION

CCTV and Audio Recordings – We may utilize CCTV at our properties as part of our legitimate business interests in protecting the safety of our Guests, Members, and our properties. Our CCTV practices are based on an assessment of the data protection interests of affected data subjects against our legitimate interests. This may entail consideration, for example, of the likelihood and impact of unlawful or impermissible conduct on our communities and expectations of privacy in particular facilities or spaces that may be subject to CCTV. Visible signage is displayed at all premises where CCTV is in use and no CCTV is deployed in an area where it would not otherwise be permissible under the relevant law. We may also use closed circuit television and other security measures at our properties that may capture or record images of Guests and visitors in public areas.

We may also collect information related to conversations, including audio recording or monitoring customer service calls and other communications such as in-app messages and SMS (i.e., text messages) and in-person, virtual or telephonic presentations.

Mobile App and Location-Based Data – We provide mobile apps that can be downloaded to your smartphone or mobile device. These apps have a variety of functionalities that enhance the customer experience. In addition to providing services, our apps may collect Personal Information and other information that will be used in accordance with this Notice. We provide a link to this Notice to customers prior to their downloading of any of our apps.

Geolocation Data – If you set your devices to allow access to location information on your device, we may use your mobile device’s Global Positioning System (GPS) technology and other technology (such as wireless transmitters known as beacons) to provide you with information and offers based on the location of your device. Beacons allow us to collect information about your location within participating resorts by communicating with mobile devices that are in range. We may use this location information to enhance your on-property experience by delivering push notifications and other content to your mobile device, providing navigation assistance as you move around our locations, and sending you information and offers about products, services, or activities we believe may be of interest to you. To the extent any location data is combined with Personal Information, that information will be treated as Personal Information in accordance with this Notice. You may prevent or limit collection of location information by changing the settings in your device’s settings.

Card Payments – To protect your privacy, please do not send payment card numbers or any other confidential Personal Information to us via email or any other unencrypted method. We will not contact you by SMS/text messaging or email to ask for your payment card details. We will only ask for payment card details by telephone when you are booking a reservation or otherwise making a payment toward a product or service you have agreed to purchase. We will not contact you to ask for your account log-in information. If you receive this type of request, you should not respond to it. We also ask that you please notify us of any such a request at Guestexperience@hgv.com

Personal Information about Children – We may process Personal Information, including sensitive information, about children under the age of 18 who stay at our properties as your family members or Guests, both incidentally (such as through the CCTV present in many of our resorts or through their participation in activities) but also intentionally in accordance with local laws and requirements. In particular, in our Austrian resorts it a requirement for the name and date of birth of all Guests, including minors, to be recorded, whilst in many of our other European resorts the names and ages of minors will be listed on the main Guest’s booking.

Lastly, our resorts may take photographs or video of Guests for various purposes; where this includes photographs or video of children, consent of the parent/guardian will be obtained first.

As individuals must be over the age of 18 to be eligible for a timeshare purchase, financing or to be nominated as an assignee of a timeshare, we do not knowingly process Personal Information about children in this context of our timeshare offerings.

Information we send using social media and marketing technologies – We partner with companies such as Meta (who operates the Facebook and Instagram platforms) who will serve cookies to you when you visit our Site.

In particular Meta may use this information to provide services to us and also for further processing for its own business purposes. We and Meta are joint controllers of the processing involved in collecting and sending your Personal Information to platforms such as Facebook and Instagram, including through the use of Facebook’s “Website Custom Audiences” services (which includes ‘lookalike audience’ targeting). The data from these tools allows us to target advertising to you within Meta’s social media platforms by creating audiences based on your actions on our Site. They also allow Facebook to improve and optimize the targeting and delivery of our advertising campaigns for us.

Meta may also process your Personal Information as our processors, for the purposes of matching, online targeting, measurement, reporting and analytics purposes. These services include the processing Meta’s platforms carry out when they display our advertisements to you in your news feed at our request after matching contact details for you that we have uploaded to them.

The Facebook company that is a joint controller of your Personal Information is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland and further information regarding Meta’s use of your Personal Information, can found as follows:

Cookies – We may collect Personal Information about your devices and their location, and your use of our Site, including through cookies, pixels, web beacons, logs, and other Internet technologies.

For detailed information regarding cookies and related data processing activities please refer to our Cookie Statement.

11. UNIVERSAL OPT-OUT MECHANISMS

The Sites recognize the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs If you choose to use the GPC signal, you will need to turn it on for each supported brow.ser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.

12. YOUR STATE PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES

Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. For example, California, Colorado, Connecticut, Delaware, and other states have passed privacy laws. If you are a California resident, please see our “NOTICE TO CALIFORNIA RESIDENTS” section below. For other state residents, your privacy rights may include (if applicable):

  • The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
  • The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
  • The right to obtain a list of specific third parties to which we have disclosed your personal data (unless we do not maintain this information in a format specific to you, in which case, we will provide a list of specific third parties to which we have disclosed any consumers’ personal data);
  • The right to obtain a list of categories of third parties to which we have disclosed your personal data;
  • The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
  • The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
  • The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • If your personal data is profiled in furtherance of decisions that produce legal or similarly significant effects concerning you, you have the right to question the result of the profiling, to be informed of the reason that the profiling resulted in the decision, and, if feasible, to be informed of what actions you might have taken to secure a different decision (and the actions that you might take to secure a different decision in the future). If applicable, you also have the right to review the personal data used in the profiling and, if the decision is determined to have been based upon inaccurate personal data, the right to have the data corrected and the profiling decision reevaluated based upon the corrected data;
  • If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
  • The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

Depending on how the applicable privacy law defines a “sale,” we may sell personal data to third parties. For instance, if you are a resident of Colorado or Connecticut, our use of cookies and tracking technologies constitutes a sale of personal data to third-party advertisers. We also use cookies and other tracking technologies to display advertisements about our products to you on non-affiliated websites, applications, and online services. This is “targeted advertising” under applicable privacy laws. We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request here or by calling us at 1-888-905-4482. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision through our interactive webform available here or by calling us at 1-888-905-4482.

To opt out of marketing emails, send a message to Guestexperience@hgv.com.

To opt out of marketing text messages, reply “STOP” to the message you received or send a message to Guestexperience@hgv.com.

To opt out of HGV’s telephonic promotional offers, send a message to Guestexperience@hgv.com.

13. NOTICE TO CALIFORNIA RESIDENTS

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy notice that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Notice is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “NOTICE TO CALIFORNIA RESIDENTS” section we will refer to this information as “Personal Information.”

This notice does not apply to our employees. A separate privacy notice applies to our employees.

Notice at Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Notice, have collected the following categories of Personal Information:

  • Identifiers (name, online identifier, Internet Protocol address, email address, account name/number)
  • Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
  • Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature, telephone number, employment, bank account number, credit card number, debit card number, or any other financial information, including income information and credit history, medical information, as well as the categories listed in “Identifiers” category above)
  • Characteristics of protected classifications under California or federal law (age (40 and older), national origin, disability, marital status)
  • Commercial information (records of products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies; or other commercial information, including vehicle information and home ownership status)
  • Biometric information (imagery of face)
  • Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application or advertisement)
  • Geolocation data
  • Audio and visual information
  • Professional or employment-related information (including employment history)

We collect Personal Information directly from California residents and from loyalty and membership program providers, travel agents, credit reporting agencies, data verification providers, event planners, social media networks, and third-party booking websites. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “HOW WE USE YOUR PERSONAL INFORMATION” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

  • Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
  • Debugging to identify and repair errors that impair existing intended functionality
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information or providing similar services
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service
  • Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

Sale, Sharing, and Disclosure of Personal Information

The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of Personal Information under California law. This may include displaying advertisements on other websites.

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Notice and, for each category, the categories of third parties to whom we sold or shared Personal Information:

Category of Personal InformationCategories of Third Parties
Identifiers (Internet Protocol address)Data analytics providers
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)Advertising networks; data analytics providers

We sold or shared Personal Information to third parties to advance our commercial and economic interests.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Notice and, for each category, the categories of recipients to whom we disclosed Personal Information.

Category of Personal InformationCategories of Recipients
Identifiers (name, email address, account name/number)Resorts; loyalty and membership program providers; business partners; promotion providers; event planners; resort service providerss
Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (telephone number)Resorts; loyalty and membership program providers; business partners; promotion providers; event planners; resort service providers
Characteristics of protected classifications under California or federal law (age (40 and older), national origin, disability, marital status)Resorts; loyalty and membership program providers; resort service providers
Commercial information (records of products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies; or other commercial information)Resorts; loyalty and membership program providers; business partners; promotion providers; event planners
Geolocation informationBusiness partners

We disclosed Personal Information for the following business or commercial purposes:

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information or providing similar services
  • Undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance the service
  • Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction

We do not knowingly collect, sell, or share Personal Information of consumers under 16 years of age. We do not use Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

Retention

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us

Your Rights

California residents have the following rights:

  • The right to know what Personal Information we collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you.
  • The right to request that we delete certain Personal Information we hold about you.
  • If we sell or share Personal Information, the right to opt out of the sale or sharing of Personal Information.
  • The right to correct inaccurate Personal Information.
  • If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure of sensitive Personal Information.
  • The right not to receive discriminatory treatment by us for exercising any of your privacy rights.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct here or by calling us toll free at 1-888-905- 4482.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing by clicking here. Please see the “Universal Opt-Out Mechanisms” section above for more information.

Notice of Financial Incentive

Please review our “Notice of Financial Incentive/Loyalty Program” section above. /p>

Shine the Light Law

If you are a California resident and have an established business relationship with us, you may request that we do not disclose your personal information to third parties for the third parties’ own direct marketing purposes (as those terms are defined in California Civil Code § 1798.83). You may submit such a request by clicking here.

To opt out of marketing emails, send a message to Guestexperience@hgv.com.

To opt out of marketing text messages, reply “STOP” to the message you received or send a message to Guestexperience@hgv.com.

To opt out of HGV’s telephonic promotional offers, send a message to Guestexperience@hgv.com.

14. EUROPE AND THE UNITED KINGDOM

Legal bases for processing Personal Information if you reside in the UK or EU

We use Personal Information, as described above, where it is necessary to meet our contractual obligations to you, to meet our legal obligations, or to meet our legitimate interests in providing our services. Our legitimate interests may include providing you and others with a secure environment, analyzing, improving, and better tailoring our products and services, being more efficient, fulfilling any contracts you have with us and helping to prevent fraud.

We also generally rely on our legitimate interests in marketing to you, and providing promotions or administering contests and sweepstakes, where permitted by applicable law. We provide you with choices about how we use your Personal Information, in accordance with applicable law, by allowing you to opt-out of receiving all such communications (unless they are transactional solely related to the provision of our services to you and have no marketing element) and, where required, by not sending you any such messages without your prior consent. Where applicable, we also may process Personal Information with your consent. Remember that in certain circumstances, and where permitted by applicable law, you may have the right to object to our uses of your Personal Information as further described in the “Your Rights” section of this Notice.

Your rights

If you are resident in the UK or EU, you may have the right to:

  • request confirmation of whether we store, use, or share any of your Personal Information and be informed about third parties with whom your Personal Information has been shared;
  • obtain access to or a copy of your Personal Information;
  • receive an electronic copy of the Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”);
  • restrict our uses of your Personal Information or, as described above, object to those uses or restrict our sharing of your Personal Information;
  • seek correction of inaccurate, partial, untrue, or incomplete Personal Information. In some cases, we may provide self-service tools that enable you to update your Personal Information;
  • request erasure, anonymization, or blocking of Personal Information we hold about you, subject to certain exceptions prescribed by law, when processing is based on your consent or when processing is unnecessary, excessive or non-compliant;
  • object to automated decision-making. We do not envisage that any decisions that have a legal or significant effect on you will be made about you using purely automated means, however, we will update this Notice and inform you if this position changes; or
  • withdraw your consent to our processing of your Personal Information, including sensitive information.

To exercise any other rights set out above please contact us at privacyhgv@hgvc.com.

Marketing and Opt-out

We may inform you about our products and services or invite you to events via email, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, postal mail, our customer service call center, and other means (including on-property messaging, such as your in-room television).

You may opt-out of receiving marketing messages from us. If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the unsubscribe function in the email you receive from us. Opt-out requests can take up to ten business days to be effective.

To opt out of marketing text messages, reply “STOP” to the message you received.

To opt out of HGV’s telephonic promotional offers, send a message to Guestexperience@hgv.com.

For more information about cookies and interest-based advertising and to learn about how to manage these technologies, please see our Cookie Statement.

Right to complain

If you would like to make a complaint or if you have any questions about how we use or keep your Personal Information, you may contact us using the details in the “Contact Us” section below. In addition, if you believe our processing of your Personal Information violates applicable law, you also may have the right to lodge a complaint with the relevant supervisory authority for your jurisdiction. However, we would ask that you contact us so that we may try to address any privacy concerns you may have.

15. NOTICE TO RESIDENTS OF CANADA

Depending on the jurisdiction in which you are located, you may have certain rights with respect to your Personal Data. For example, you may have the right to:

  • access your Personal Information;
  • confirm whether we are processing your Personal Information;
  • receive a copy of your Personal Information, including in a machine-readable format;
  • rectify your Personal Information;
  • withdraw your consent;
  • information about the possibility of denying consent and the consequences of such denial;
  • data portability;
  • delete your Personal Information;
  • not be subject to automated decision-making;
  • file a complaint; and
  • submit an inquiry about our policies and procedures relating to processing Personal Information.

If you would like to exercise your legal rights, please contact our Legal Department. We will process your request in accordance with any applicable legal requirements.

C/O Chief Compliance Officer
Hilton Grand Vacations
5323 Millenia Lakes Boulevard
Orlando, FL 32839

Phone: 407-613-3100
E-mail: privacyhgv@hgvc.com

For categories of Personal Information collected, their corresponding purposes, and the categories of entities that receive or have access to your Personal Information, please see the section “Notice to California Residents – Sale, Sharing, and Disclosure of Personal Information” above.

If you are a resident of the province of Quebec, we may communicate your Personal Information to entities located outside of the province of Quebec for the purposes mentioned in this Privacy Policy. Before communicating your Personal Information outside of the province of Quebec, we will conduct a privacy impact assessment in accordance with any applicable legal requirements. Your Personal Information will only be communicated outside of the province of Quebec if the privacy impact statement establishes that it would receive adequate protection.

16. CHANGES TO THIS NOTICE

Any Personal Information that we collect is covered by the Notice in effect at the time such information is collected. We reserve the right to change, modify, add, or remove portions of this Notice at any time and at our sole discretion. If we make any material changes to this Notice, we will notify you of those changes by posting them on our Sites or by sending you an email or other notification, as required by applicable law, and we will update the “Last Updated” date (at the top of the Notice) to indicate when those changes became effective. Your continued relationship with us after the posting or notice of any amended Notice shall constitute your agreement to be bound by any such changes. Any changes to this Notice take effect immediately after being posted or otherwise provided by HGV.

17. CONTACT US

If you have any questions or comments regarding this Notice, please contact us at privacyhgv@hgvc.com.

To opt out of marketing emails, send a message to Guestexperience@hgv.com.

To opt out of marketing text messages, reply “STOP” to the message you received or send a message to Guestexperience@hgv.com.

To opt out of HGV’s telephonic promotional offers, send a message to Guestexperience@hgv.com.