IMPORTANT: THIS DOCUMENT CONTAINS VERY IMPORTANT INFORMATION REGARDING THE PRIVACY PRACTICES OF SPINNAKER RESORTS, INC. (SPINNAKER). READ THE ENTIRE DOCUMENT TO THE BOTTOM OF THIS PAGE. THIS SITE IS INTENDED FOR PERSONS LOCATED IN NORTH AND SOUTH AMERICA (Permitted Jurisdictions). BY USING THIS SITE, YOU ACKNOWLEDGE THAT YOU ARE USING THE SITE FROM A PERMITTED JURISDICTION.
SPINNAKER operates this site and is concerned about privacy issues and wants you to be familiar with how we collect, use, and disclose information. Spinnaker is committed to protecting your privacy. This Privacy Notice describes our practices in connection with information that we collect through websites operated by us (the “Websites”), through the software applications made available by us for use on or through computers and mobile devices (the “Apps”), through our social media pages that we control (collectively, our “Social Media Pages”), through information that we may collect through any of our offline activities, including advertising or promotions, when you provide information on the telephone or in person or from any activity from which you are accessing this Privacy Notice (collectively, including the Websites, the Apps and our Social Media Pages, the “Services”). The information you provide helps us to operate effectively and continually provide you with the best hospitality products, services, and experiences.
Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Please read the following to learn more about our privacy practices.
NOTICE TO TIMESHARE OWNERS/FINANCING CUSTOMERS: You may receive a separate notice regarding "Your Financial Privacy" by mail. If this Website provides you the ability to access your account online, and you agree to receive annual notices online, we will provide you with annual notices through this Website. Further, if we provide you with updated notices online, we will require you to acknowledge receipt of the updated notice through this Website or another identified Website.
Acceptance of Our Privacy Notice: By using the Services and Site, you accept the terms of this Privacy Notice and the ways we may use your information. If you do not accept the terms of this Notice, please do not continue to use the Services. This Privacy Notice may change from time to time. Your continued use of the Site after changes is deemed to be acceptance of those changes, so please check periodically for updates.
Spinnaker reserves the right, at its sole discretion, to change, modify, add, remove, or amend this Privacy Notice in whole or in part at any time. Notice will be provided on this site, and you are expected to carefully review the Notice from time to time so you are aware of the changes. All information regarding the changes will be addressed on this site.
We may collect personal information (which is information that identifies you or relates to you as an identifiable person) about you, such as your:
We may collect personal information from you when you interact with us such as when you:
From Other Sources: We may receive your personal information from other sources such as public databases; joint marketing partners; data firms; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your website account, certain personal information from your social media account will be shared with us, which may include personal information that is part of your profile or your friends’ profiles.
If you apply for a job at Spinnaker we may ask you for personal information as we may choose in compliance with law. This information is used to consider you for employment.
Cookies: This Website uses “cookies”. Cookies are small text files that the Website sends to your computer for record-keeping purposes and this information is stored in a file on your computer’s hard drive. Cookies make web surfing and browsing easier for you by saving your preferences so that we can use these to improve your next visit to the Website. One of the purposes of cookies is to simplify the use of the Website. A cookie may save a user’s login details, for example, so that the user does not need to login every time. Cookies, by themselves, do not provide us with your personal information. Cookies may be either “persistent” or “temporary” (or “session”) cookies. A persistent cookie retains user preferences for a particular website allowing those preferences to be used in future browsing sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies are also used for statistical purposes, to determine how the Website is used, as well as to serve ads to you while you are on the Website. These cookies are provided by us as well as by third parties (e.g., advertising partners). While we do not control or have access to the advertiser cookies, we do permit those cookies to be used on the Website to facilitate tailored advertising and to monitor patterns of buying specific goods or interest in, for example, holidays or hobbies. These cookies run advertisements tailored to the user based on his online buying habits.
“Do Not Track" Browser Settings: At this time, we do not respond to browser 'do not track' signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit our website. Please see the Interest Based Advertising section below to learn about how to exercise choice regarding their collection of such information for the delivery of interest- based advertising. Spinnaker reserves the right to honor Do Not Track signals received from browsers with Do Not Track functionality that have been configured to send Do Not Track signals.
Google Analytics: We use Google Analytics to help us get a better understanding of how visitors use the Website. The information generated by the Google Analytics cookie about your use of the Website is transmitted to and stored by Google. If you do not want your activity on the Website to be tracked by Google Analytics, you may opt out by using this link http://tools.google.com/dlpage/gaoptout?hl=en.
Pixels, Beacons: We and/or our third-party service providers may use invisible pixels or beacons on this Website to count how many users visit certain pages. This information is collected and reported in the aggregate. We may use this information to improve our marketing programs and content and to target advertisements at this Website and/or on other sites.
Interest Based Advertising: We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Services and other websites, apps or online services, based on information relating to your access and use of our Services and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit http://networkadvertising.org/managing/optout.asp and http://www.aboutads.info/choices/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. You may opt out in Twitter by going to your account privacy settings and unchecking the box next to “Tailor ads based on information shared by ads partners.”
Mobile Devices: When you use or access our Services from a mobile device, we may collect information such as your unique device ID and your location information. When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number, as well as any other information specified by the App in its terms or notices.
Information Provided by you: We collect other information from you when you voluntarily provide it, such as stay, trip, product, service or related information; communication, product, service or other customer preferences; special needs or conditions that may impact your stay; and demographic information.
IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
The information we collect from you helps us to identify ways that we can continue to serve you in the best way possible and provide you with personalized products and services that suit your lifestyle.
We use personal information for the following purposes:
Your personal information may be disclosed as follows, except that Spinnaker does not rent or sell your information:
Affiliates: We may disclose your personal information to other businesses including our “Affiliates or Subsidiaries”, officers, directors, agents, employees, and assigns who may jointly use the personal information for the purposes described in this Privacy Notice.
Business Partners & Sponsors: We may disclose your Personal Information to third party business partners or sponsors, as described below and elsewhere in this Privacy Notice. In the event and to the extent that there are additional uses of your Personal Information by Spinnaker Resorts business partners or sponsors (which additional uses are not otherwise described in or contemplated by this Notice), any such additional uses will be specifically described to you prior to or at the time such Personal Information is collected or prior to any transfer of such Personal Information to the business partners or sponsors. We may share your personal information with third parties, subject to any choices you have made. Many promotions offer opportunities for you to request additional information from such business partners and sponsors. By requesting additional information, you signify your consent to Spinnaker Resort’s transfer of your Personal Information to the applicable business partners or sponsors so that they can respond to or fulfill your request. Although, in many instances, only your email address will be shared with these business sponsors and partners, Spinnaker Resorts is not limited to the type of Personal Information that it may disclose, provided that you requested the additional information, and that Spinnaker Resorts has otherwise complied with this Privacy Notice. Vacation rentals: We may share your information with the owners and Business Partners of resorts we do not own, property owners’ associations and those with whom we have a sales and marketing relationship, in order to provide you with services.
Vendors and Service Providers: We may disclose your information to vendors and service providers retained by us in connection with our business such as: travel services companies and providers; financial services companies; credit bureaus; property owners’ associations; vacation insurance companies; companies providing website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery services; tax and financial advisers; legal advisers; accountants; and auditors.
Message Boards: We may make message boards, blogs, and other such user-generated content facilities available to users. Any information that is 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.
Merger or Acquisition: We may disclose your personal information to a third party who acquires any part of Spinnaker Resorts itself or any of its Affiliates, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets (including in connection with a bankruptcy or similar proceedings).
Disclosure Permitted by Law: We may disclose your personal information to law enforcement authorities, government or public agencies, regulators, insurers and/or to any other person or entity having appropriate legal authority or justification for receipt of your information, if we believe that we are required or permitted to do so by law or legal process, to respond to claims, or to protect our rights, interest, privacy, property or safety and/or that of our Affiliates, you or others.
Anonymized/Aggregated Information: Because aggregated or anonymized information does not personally identify you, we may use and disclose it for any purpose.
Security of Your Information: We take reasonable steps to help protect your personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. Unfortunately, no security system is 100% secure, thus we cannot ensure the security of information that you provide to us via the Services.
Information Provided on Someone Else’s Behalf: If you provide us with information about someone else, you represent that you have the person’s permission to do so for the purposes detailed in this Privacy Notice.
Links to Websites: The Services may have links to other websites that are not operated by us. We have no control over how these websites may collect your information and no responsibility or liability for the practices, policies and security measures implemented on these websites. You should read the privacy notices on those other websites before you submit your information through them. This Privacy Notice applies only to this website.
Social Media Sites: Please note that we are not responsible for the information collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal information you disclose to such other organizations through or in connection with the Apps or our Social Media Pages.
Changes to Our Privacy Notice: From time to time we may revise this Notice to reflect new uses of personal information, to meet changes in the regulatory or business environment, or to satisfy the needs of our customers and service providers. Updated and date stamped versions will be posted on the Services, and, by using the Services following any such revision, you agree to the revised Notice.
Minors: We do not knowingly collect, maintain or use personal information from children under 18 years of age, and no part of Services is directed to individuals under the age of 18. If you are under 18 do not use or provide any information of the Sie or provide any information about yourself to Spinnaker.
International Transfers: The Services are controlled and operated by us from the U.S. and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the U.S. For example, your information may be stored on servers located in other jurisdictions. By using the Services, you consent to the transfer of information to countries outside your country of residence and back, including to the U.S.
Retention Period: We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Marketing: We may contact you by email, telephone, SMS or postal mail with information about products or services offered by Spinnaker Resorts or a third party that may be of interest to you. You can opt-out of receiving such marketing communications at any time.
Access to Information We Hold about You: If you would like to access, update, correct or request that we suppress or delete any of the personal information we have collected from you or if you require further information from us about how we use your information please contact us at webmarketing@spinnakerresorts.com. In some jurisdictions, you may be charged a reasonable fee for access to your information.
This Privacy Policy and disputes related thereto shall be governed by and construed in accordance with the laws of the State of South Carolina, and venue with respect to any disputes shall be exclusively in the State and Federal Courts of South Carolina, and the place of performance of this Privacy Notice is agreed by you to be the State of South Carolina.
Notice to California Residents: If you are a resident of California, please see our Supplemental Privacy Notice for California Residents, which can be found below.
Spinnaker provides this supplemental privacy notice (“CCPA Notice”) for consumers that reside in California (“you,” or “your”) as required under California privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”). This CCPA Notice applies to Spinnaker and its affiliated operating companies (“Affiliates"). Spinnaker and its Affiliates (collectively referred to in this CCPA Notice as “we,” “our,” or “us”) provide this CCPA Notice to inform you about how we collect, use or disclose your personal information. Under the CCPA, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. It does not include publicly available data as defined by the CCPA. This CCPA Notice supplements our Privacy Policy. In the event of a conflict between our Privacy Policy and this CCPA Notice, this CCPA Notice will prevail for California residents and their rights under California law.
Personal information we collect, use, or disclose that is governed by the federal Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, or the federal Fair Credit Reporting Act, such as consumer credit reports or information relating to your financing of a vacation ownership product, is not subject to the CCPA and this CCPA Notice.
The type of personal information we collect, use, and disclose will depend on your interaction or relationship with us. The chart below generally identifies the personal information we may collect based on the categories of personal information set forth in the CCPA. Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.
| Categories of personal information as set forth in the CCPA | Personal information we collect |
| Name, Contact Information and other Identifiers: Identifiers such as a real name, alias, address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. | We may collect information such as your name, address, email address, telephone numbers, date of birth, owner number, and IP address. In more limited circumstances, such as when you purchase or finance a vacation ownership product, we may collect information such as social security number, driver’s license number, or passport number. |
| Customer Records: Paper and electronic customer records containing personal information, such as name, signature, physical characteristics or description, address, telephone number, education, current employment, employment history, social security number, passport number, driver’s license or state identification card number, insurance policy number, bank account number, credit card number, debit card number, or any other financial or payment information, medical information, or health insurance information. | We may collect information such as your name, address, email address, telephone numbers, owner number, and credit or debit card information. In more limited circumstances, such as when you purchase or finance a vacation ownership product, we may collect information such as current employment, employment history, social security number, passport number, driver’s license, or state identification, and other financial or payment information. |
| Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information. | We may collect information such as your gender or age. In more limited circumstances, we may collect disability information to provide you with appropriate accommodations or services at our resorts. |
| Purchase History and Tendencies: | We may collect information such as the products or services you purchased or utilized. |
| Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. | We may collect voice recordings when we monitor and record telephone calls. |
| Usage Data: Internet or other electronic network activity information, including, but not limited to, browsing history, clickstream data, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement. | We may collect this information as part of your interaction with our Websites (as defined in our Privacy Policy) or mobile application, and through advertisements. |
| Geolocation Data: Precise geographic location information about a particular individual or device. | We may collect information such as your postal address, zip code, or the location associated with an IP address or particular device. |
| Audio, Video and other Electronic Data: Audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recording (e.g., recorded meetings and webinars). | We may collect voice recordings when we monitor and record telephone calls, photos or videos that are tagged or shared with us through social media posts, or audio, video, or images captured in security footage of our resorts. |
| Professional or employment-related information: Employment history, qualifications, licensing, disciplinary record. | In limited circumstances, such as when you purchase or finance a vacation ownership product, we may collect information such as employment history. |
| Education Information: Information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). | We do not collect this information. |
| Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes. | We may collect or derive information such as your preferences, characteristics, predispositions, attitudes, and behavior based on other information we have about you. |
We collect these categories of personal information from the sources described in our Privacy Policy and for the purposes described in the “Information We Collect and Its Uses” section of our Privacy Policy. We disclose your personal information to third parties, such as our service providers, as described in our Privacy Policy. We do not collect personal information directly from children under the age of eighteen (18) but may receive such information from parents and guardians when, for example, making resort, cruise, or other travel reservations.
We may also use standard internet technology, such as cookies, web beacons, pixels, and other similar technologies (collectively “cookies”) to track your use of our Websites as defined in our Privacy Policy. We may include web beacons in promotional email messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. See the “Cookies & Related Technologies” section of our Privacy Policy for more information. Data that is collected through network advertising or social media cookies may be disclosed by such network advertisers or social media to other network advertisers that allows those advertisers to also display ads to you. While there is currently no industry consensus, we do not consider these additional disclosures to be our sale of personal information under the CCPA. If you do not want information collected by cookies, however, please visit www.aboutads.info and www.networkadvertising.org to opt-out.
If you are a California resident, you have certain rights with respect to your personal information as set forth below. Request to Delete: You may request that we delete personal information we have collected about you, subject to certain exemptions provided by law. Request to Know: You may request, subject to certain exemptions, that we disclose to you the categories of personal information collected; the categories of sources of personal information; the business or commercial purposes for collecting and selling your personal information; the categories of third parties with whom we have shared your personal information; the categories of personal information that we have disclosed or shared with a third party for a business purpose; the categories of third parties to whom your personal information has been sold and the specific categories of personal information sold to each category of third party; and the specific pieces of personal information that we have collected about you in the prior 12 months. Request to Opt-out of Our Sale of Your Personal Information: We do not sell your personal information. Submitting Requests: To make a Request to Delete or a Request to Know, please contact us at 844-711-2582 or privacy@mvwc.com. Please include your full name, postal address, email address, and your owner number (if applicable). If you designate an authorized agent to make a request on your behalf, we require you to provide a written and signed authorization of your agent’s permission to exercise your rights on your behalf as provided for in this section. Please include your full name, postal address, email address, and your owner number (if applicable) along with your agent’s full name, postal address, email address, and relationship to you. If we are unable to verify your identity based on this information, we will take additional steps to verify your identity before responding to your request. We will respond to verifiable requests received from California residents or their authorized agents in accordance with the law, which provides certain exemptions for disclosure or deletion. For example, if you are an owner of a vacation ownership product, we may retain your personal information as permitted by law to maintain and service your ownership and account. These rights do not apply to personal information we collect about job applicants, independent contractors, or our current or former full-time, part-time and temporary employees and other staff, or information we collect when we act as a service provider. Non-Discrimination: We are not permitted to nor do we discriminate against California residents who exercise their rights under the law.
We do not permit personal information as defined by California’s Shine the Light law that we share with third parties to be utilized for their marketing activities. If you are a customer who resides in the State of California, however, you have the right to request from us a list of third parties with whom we shared personal information about you for their own direct marketing purposes during the previous calendar year by contacting us at Spinnaker Resorts Corporate Compliance Officer 35 DeAllyon Ave Hilton Head Island, SC USA.arketing@spinnakerresorts.com or send a letter to:
Privacy rights under Shine the Light and the CCPA are provided under different legal rules and must be exercised separately. At this time, we do not respond to browser “do not track” signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites.
If after reviewing this Notice, you have any questions or privacy concerns please send an email to webmarketing@spinnakerresorts.com or send a letter to:
Spinnaker Resorts Corporate Compliance Officer 35 DeAllyon Ave Hilton Head Island, SC USA
This CCPA Notice was last updated on March 16, 2022.