Internet Privacy Statement

Introduction
Grand Residences by Marriott has a strong commitment to providing excellent service to all of our customers and owners, including respecting their concerns about privacy. We understand that visitors to this website may have questions about whether and how this website collects and uses information. We have prepared this statement (“Statement”) to inform you of the privacy principles that govern this website.

This Statement contains numerous general and technical details about the steps we take to respect your privacy concerns. We have organized the Statement by major processes and areas so that you can quickly link to the information of most interest to you. Please note that a separate privacy statement and separate terms and conditions apply to the Rewards program, although the same governing Marriott philosophy applies.

At Grand Residences by Marriott, meeting your needs and expectations form the foundation of everything we do – including protecting your privacy.

If after reviewing this Statement, should you have any questions or privacy concerns please send an email to privacy@vacationclub.com or send a letter to:

Grand Residences by Marriott
Attn: Information Protection & Privacy
9002 San Marco Court
Orlando, Florida 32819

Browsing
Information We Collect and Its Uses
Create an Account Profile
Securing the Transmission and Storage of Information
Confidentiality of Social Security Numbers
Disclosure of Information to Third Parties
Children’s Privacy
Cookies
Sweepstakes
Other Sites
Legal Issues
grandresidenceclub.com Internet Privacy Statement Changes

Browsing
This website does not collect personally identifiable information from your computer when you browse this website and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your email address or any other personally identifiable information. When you request a page from our website, our servers log the information provided in the HTTP request header including the Internet Protocol (IP) address, the time of the request, the URL of your request, and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our website function correctly and provide the functionality that you see on this website. We also use this information to better understand how visitors use our website and how we can better tune it, its contents and functionality to meet your needs.

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Information We Collect and Its Uses
When we need to collect personally identifiable information from you to execute the requested transaction or provide you with a particular service, we will ask you to voluntarily supply us with the information we need. For example, if you would like to make a reservation at one of our resorts, we will ask you for information such as name, address, telephone number and email address 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. On occasion, we use third parties to provide or confirm for us contact information given the information you provided to us directly. We would then use this information for market analysis and marketing purposes.

In addition, when you provide contact details for transaction requests, such as scheduling an appointment or requesting a proposal, we will use the contact information to keep you updated about future offers or promotions unless you opt-out online or otherwise notify us.

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Creating an Account Profile
Owners of Grand Residences by Marriott properties may, at their choice, create a personal account profile online within our password protected area. Creating an account profile makes it more convenient for you by eliminating the need to repeatedly enter personal contact or preference information. In addition, if you choose, you can perform certain functions within your account such as making maintenance payments via this website. The security of this information is addressed in security section below. You can access and review, update or deactivate the information in your account profile information online.

We treat the information you provide to us as confidential; it is, accordingly, subject to our company’s security procedures and corporate policies regarding protection and use of confidential information. Because laws applicable to personal information vary by country, additional measures that change depending on the applicable legal requirements may be put in place. Information is generally processed and stored in the United States.

Please note that Grand Residences by Marriott will never send you email requesting your user name, password, credit card number or social security number. If you receive an email that looks like it’s from Grand Residences by Marriott, but asks you for your credit card number or social security number, it is a fraudulent email, or “phish.” We recommend that you do the following:

• Forward the email to the Federal Trade Commission at spam@uce.gov or call 1-877-FTC-HELP (1-877-382-4357) to report it. The FTC uses the spam stored in this database to pursue law enforcement actions against people who send deceptive email.
• Delete the email.

If you believe “phishers” have gotten access to your personal or financial information, we recommend that you also to the following:

• Change your password.
• Contact credit reporting services and have a fraud alert attached to your credit report file. Please be aware that the perpetrator may attempt to use your information to establish accounts or obtain credit at other businesses in their name.

Learn more about fraudulent email or “phish” and how to protect your personal information.


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Securing the Transmission and Storage 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 select 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. 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.”

After information reaches Grand Residences by Marriott, it is stored on a secure server that resides behind firewalls designed to block unauthorized access from outside of Grand Residences by Marriott. Because laws applicable to personal information vary by country, our vacation resorts or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected on this site and covered by this privacy statement is generally processed and stored in the United States.

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Confidentiality of Social Security Numbers
Social Security Numbers are restricted, confidential information and legally protected data under Federal and State laws. Social Security Numbers have been collected and retained to comply with various Federal and State laws. Grand Residences by Marriott uses employee identification numbers and customer numbers that are not derived from a Social Security Number for its general information systems. We use policies, procedures, training, technology and auditing to protect the confidentiality and privacy of Social Security Numbers and to ensure that proper controls are in place concerning the collection, use and disclosure of Social Security Numbers.

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Disclosure of Information to Third Parties
Grand Residences by Marriott prohibits the sale or transfer of personal information to entities outside of the Marriott family of companies for their use without your approval and the opportunity to opt-out. Grand Residences by Marriott may share your personally identifiable information with affiliated companies that are directly or indirectly controlled by, or under common control of Marriott International, Inc. Grand Residences by Marriott may send personally identifiable information about you to non-affiliated companies that are not directly or indirectly controlled by, or under common control of, Marriott International, Inc. when we have your consent to share the information; need to share your information to provide the product or service you have requested or we need to send the information to companies who work on behalf of Grand Residences by Marriott (e.g., mailhouses) to provide a product or service to you. These companies do not have any right to use the information we provide to them for any purpose beyond what is necessary to assist us.

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Children’s Privacy
This site is not intended for children and we do not knowingly solicit or collect personal information from children.

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Cookies
This website uses “cookie” technology. “Cookies” are encrypted strings of text that a website stores on a user’s computer. This website requires the use of a cookie to keep information you enter together across multiple pages. This is an Grand Residences by Marriott “session” cookie that expires when you close your browser. We also use “persistent” cookies to measure usage of various pages on our website and to help us make our information more pertinent and easy for you to access. These persistent cookies are Grand Residences by Marriott cookies and will remain on your computer unless deleted by you. We do not use cookies to ascertain any personally identifiable information about you apart from what you voluntarily provide us in your dealings with Grand Residences by Marriott. We also use persistent cookies as part of the functionality that allows you to request to speak with a representative while you are on the website.

You may set your browser to block 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 website.

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Sweepstakes
On occasion, we conduct sweepstakes that entitle the winners to prizes. Each sweepstakes has it own terms and conditions. As part of entering a sweepstakes certain personally identifiable information such as name and email address will generally be required. We may use this information to send future communications about specials and offers.

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Other Sites
This website contains links to select third party sites that may be of interest to you (e.g., airlines, car rental companies). Grand Residences by Marriott is only responsible for the privacy statement and content of this website. We are not responsible for the privacy practices or the use of cookies on non-Grand Residences by Marriott websites that you accessed prior to or after visiting Grand Residences by Marriott websites.

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Legal Issues
This is a United States website and is subject to United States law. Grand Residences by Marriott will disclose personal information without your permission when required by law or in good faith belief that such action is necessary to investigate or protect against harmful activities to Grand Residence by Marriott owners, visitors, associates, or property (including this site) or to others. Laws related to personal identifiable information vary by country.

If you are a customer who resides in the State of California, you have the right to request, from Grand Residences by Marriott, a list of third parties with whom we shared personally identifiable information about you for their own direct marketing purposes during the previous calendar year. Grand Residences by Marriott does not share personally identifiable information with unrelated third parties without your approval. If you would like to request this list, send an email to privacy@vacationclub.com or send a letter to:

Grand Residences by Marriott
Attn: Information Protection & Privacy
9002 San Marco Court
Orlando, Florida 32819
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GrandResidenceClub.com Internet Privacy Statement Changes
In the future, we may need to change the privacy statement for grandresidenceclub.com. All changes will be made here so that you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. This statement was last updated on August 26, 2011.

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