California Consumer Privacy Act

This Privacy Notice for California Consumers (“Notice”), provided by Westgate Resorts, Inc. and its affiliated operated companies that link to this Notice (“Affiliates”)(collectively “Westgate,” “Company,” “we,” or “our”), supplements, and is expressly made part of, the information contained in Westgate’s Online Privacy Policy (https://www.allgatlinburg.com/privacy-policy/) and applies solely to those who are consumers (“you” or “your”) as defined in Section 1798.140(g) of the California Consumer Privacy Act of 2018 (“CCPA”). We adopt this Notice in compliance with the CCPA and any terms defined in the CCPA have the same meaning when used in this Notice.

Westgate collects information that identifies, relates to, describes, references are reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). As a consumer, you have certain rights regarding your personal information as defined in the CCPA. This Notice provides you with information on how Westgate collects, uses, and shares personal information. It also outlines the rights you have regarding the personal information that we collect from you and describes how you can exercise those rights.

Collection and Use of Personal Information

Westgate recognizes the eleven (11) broad categories of personal information referenced in the CCPA that a business may collect about a consumer. In particular, Westgate has collected the following categories of personal information from consumers within the last twelve (12) months:

As a company that conducts activities that are financial in nature, Westgate is a “financial institution” as that term is defined in the Gramm-Leach-Bliley Act (“GLBA”). While the CCPA does not exempt financial institutions, Section 1798.145(e) of the CCPA does exempt personal information collected by a financial institution pursuant to the GLBA.

Personal information does not include publicly available information from government records, de-identified or aggregated consumer information, or information otherwise excluded from the CCPA’s scope, such as information collected pursuant to the GLBA.

We have obtained the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.

• Indirectly from you. For example, from the information, we obtain in the course of providing our services to you, or from observing your actions on our website.

• From third-party business partners including, but not limited to, social media sites, ad networks, and analytics providers.

Westgate may use this information to:

• Provide you with the information, products, or services you request from us.

• Fulfill the reason you provided the information.

• Create, maintain, customize, and secure your account with us.

• Personalize your website experience and deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent where required by law).

• Advertise and market products and services to you from both affiliated and non-affiliated entities, which includes sending promotional communications, target advertising, and presenting you relevant offers (with your consent where required by law).

• Help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.

• Process your requests, purchases, transactions, and payments.

• Provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

• For testing, research, analysis, and product development, including to develop and improve our website, products, and services.

• Prevent fraud or misconduct.

• Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

• Westgate will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing notice to you. Such notice may be delivered, for example, by posting an updated California Privacy Notice.

Sharing Personal Information

Westgate may disclose your personal information to a third-party service provider for business purposes. When we do so, Westgate enters into a contractual arrangement that describes the business purpose and requires the recipient to both: (A) keep that personal information confidential, and (B) not use it for any purpose except performing the obligations under the contract.

We share your personal information with the following categories of third parties for a business purpose:

• Affiliates.

• Service providers.

• Social media companies

• Internet cookie data recipients (e.g., Google Analytics)

Disclosure of Personal Information for a Business Purpose

The CCPA requires Westgate to provide you with a statement on its personal information disclosures for a business purpose that reference the eleven (11) categories of information reflected in the chart above. In the preceding twelve (12) months, Westgate has disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.

• Category B: California Customer Records personal information categories.

• Category C: Protected classification characteristics under California or federal law.

• Category D. Commercial information.

• Category F. Internet or other similar network activity.

Sale of Personal Information.

The CCPA similarly requires Westgate to provide you with a statement on its personal information sales. Westgate has not sold personal information within the proceeding twelve (12) months. Westgate reserves the right to change its policy on the Sale of Personal Information in the future. If Westgate’s Sale of Personal Information policy changes, Westgate will notify all consumers prior to the sale of any personal information.

Please note that Westgate is providing you with a “Do Not Sell My Personal Information” Request Form as a mere courtesy and in the event that Westgate’s Sale of Personal Information policy changes in the future. To exercise the right to request that Westgate does not sell your personal information, please refer to the “Right to Opt-Out of Sale of Personal Information” below.

Notice Regarding Your Rights

Access & Data Portability Rights

You have the right to request that Westgate disclose what personal information we collect, use, and disclose. If we receive and confirm your consumer request as verifiable and no exception applies, we will provide you with:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you.

• If we sold or disclosed your personal information for a business purpose, two lists disclosing:

– Sales, identifying the personal information categories that each category of recipient purchased; and

– Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

Subject to certain exceptions, you have the right to request that we delete any of your personal information that we collected from you and retained. If we receive and confirm your consumer request as verifiable unless an exception applies we will delete (and direct our service providers to delete) your personal information from our records.

The CCPA provides a number of reasons why a deletion request may be denied. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of Sale of Personal Information

Please note that Westgate has not sold personal information within the proceeding twelve (12) months. Westgate is providing you with a “Do Not Sell My Personal Information” Request Form as a mere courtesy, and in the event that Westgate’s Sale of Personal Information policy changes in the future. To exercise the right to request that Westgate does not sell your personal information, please click here: Do Not Sell My Personal Information (https://www.westgateresorts.com/ccpa-do-not-sell) or call us toll-free during business hours at 1-(800) 925-9999 option 4.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Westgate by:

• Calling us toll-free during business hours 1-(800) 925-9999 option 4.

• Filling out the California Consumer request form available at (https://www.westgateresorts.com/ccpa-access-deletion-request) by clicking here.

Only you or someone registered with the California Secretary of State and legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. 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 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.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must:

• Provide sufficient information that allows Westgate to verify, to a reasonable degree of certainty, that you are the person about whom Westgate collected personal information (or your authorized representative), which may include multi-factor authentication of identifying information provided by you. Such authentication may be conducted and verified independently or in combination with a comparison of personal information already maintained by Westgate, if any; and

• Describe your request with sufficient detail that allows Westgate to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us, but we must also be able to confirm the personal information relates to you. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to the personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

Westgate endeavors to respond to a verifiable consumer request within forty-five (45) days of receiving it. If Westgate requires additional time to process your request, up to a maximum total of ninety (90) days from the date the request is received, we will notify you of this and inform you of the reason for requiring the additional time.

If you have an online account with us, we will deliver our written response to your online account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request or have denied a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

Westgate will not discriminate against you for exercising any of your CCPA rights as described above. Unless permitted by the CCPA, Westgate will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Third-Party Cookies & Similar Technologies Disclosures

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 allow 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.

California Do Not Track Disclosures

How do we respond to Web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services?

We respond to and respect your DNT signals.

May other parties collect personally identifiable information about an individual consumer’s online activities over time and across different websites when they visit any of the Westgate Websites, as defined in the Privacy Policy?

Yes.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits certain individuals that are California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at privacyprogram@wgresorts.com or write to us at the address below.

Changes to Our Privacy Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on our website and update the Notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Contact Information

Westgate is committed to responding promptly to any questions or concerns you may have about this Notice. If you have questions concerning the methods by which Westgate collects or uses your personal information as explained in this Notice and our Online Privacy Policy, the rights granted to you under the CCPA, or how to exercise your rights, or if you are a consumer with a disability and you wish to receive a copy of this Notice, you can contact us by calling, writing, or emailing us:

Westgate Resorts Privacy Program
2801 Old Winter Garden Road
Ocoee, FL 34761-2965
Email: privacyprogram@wgresorts.com

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