PRIVACY POLICY

Updated as of May 25, 2018

Vacation Auction, Inc. ("Vacation") has adopted the following privacy policy. We may amend or otherwise change the policy from time to time, (as amended, the "Privacy Policy"). By using our website or one of our services, or by registering to bid with us, you accept the Privacy Policy. Your continued use of our site or services following the posting of changes to the Privacy Policy will mean that you accept those changes. All changes to the Privacy Policy will be effective immediately upon posting by us on our web site.

We value your business and, more importantly, your loyalty. We recognize that privacy is an important issue. We have developed this Statement to explain our practices regarding the personal information we collect from you or about you on this site or via our apps, through written or verbal communications with us, or from other sources. While this Statement broadly describes the practices we have adopted, local laws vary and some jurisdictions may place restrictions on our processing activities (e.g., certain jurisdictions may require affirmative consent to send marketing messages). Therefore, our actual practices in such jurisdictions may be more limited than those described herein in order to enable us to comply with local requirements. If you are a resident of the European Economic Area (EEA), please see Appendix A for additional information regarding our use of your personal information.

Collection, Management and Use of Information

When you register to bid on www.FloridaVacationAuction.com, or otherwise use our site or services, we collect your personal information that you specifically and voluntarily provide to us. You may choose to enter contests, receive e-mail or SMS/text alerts, bid on goods or services that we offer for auction, or participate in other activities through our website. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, Florida Vacation Auction may require you to provide us with personal information, such as your name, mailing address, e-mail address, credit card information and other personal identifying information. We ask for this information as a condition to your use of our services, and if you choose not to provide this information then you can-not bid with us or otherwise use our services.

By using any of our products or services and/or by agreeing to this Statement, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Statement.

We do not share, sell or rent your personal information with or to any other person or entity, except for our own subsidiary and parent entities, and to the respective third party that are the suppliers of the goods and services purchased by you from us or accessed by you from our website, and except for the marketing purposes discussed below.

Security

Vacation takes measures to protect the security of your personal information and to ensure that your choices for its intended use are honored, and to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction, including SSL technology on all website served pages. Unfortunately, Vacation cannot, and do not, guarantee that data transmission over the Internet are secure, or that a malicious third party will not be successful at misappropriating your personal information from our servers. As a result, you provide us with your personal information at your own risk.

Vacation utilizes a secure environment for credit card transactions. Once a transaction has cleared your credit card information is not stored by Vacation.

We also do not guarantee that your communications and other personally identifiable information will never be disclosed in ways not described in this Privacy Policy, or in ways that you would not have happen if you could choose, including, but not limited to, required disclosures to the government, in response to court orders, by unlawful interception. We can (and you authorize us to) disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringement or other activity that is illegal or may expose us to legal liability. Therefore, although we will endeavor to protect your privacy as described in this Privacy Policy, we do not promise, and you should not expect, that your personally identifiable information or private communications will remain private.

Your Florida Vacation Auction account is password protected so that only you can access it and view the member information relevant to the account. We recommend that you do not divulge your password to anyone. Florida Vacation Auction will never ask you for your password in an unsolicited phone call or e-mail. Ultimately, you are responsible for maintaining the secrecy of your passwords and any account information.

If you are the successful bidder on an item that is auctioned by us, we will issue a Voucher ID to you. This is the unique identifier that entitles the holder to claim the good or service that you have purchased. We will email a receipt (called a voucher or certificate) to you, with the Voucher ID number. You have agreed to take all of the risk that this ID is not lost by or stolen from you. If it is then your goods or services may be claimed by a third party. You must assure that your own email and computer security is sufficient to guard the email and file with the ID.

Third Party Suppliers

If, by using a link from our site, you access the website or services of a third-party supplier, then the protection of your information relating to their services will be governed by the privacy policy of the third party. If you elect to Buy Direct with, or otherwise link from Vacation to, an airline, car rental agency, hotel, attraction and/or other travel or travel related advertiser, you will need to provide that entity with whatever information they require in order to make a purchase or access their services, and that information is not received or protected by Vacation.

Marketing

Unless you opt out, we will occasionally send to you in accordance with any preferences you have expressed, and with your consent where required, advertisements, marketing material, newsletters and other materials about our products and services or invite you to events via email, online advertising, social media, WeChat, WhatsApp, telephone, text message (including SMS and MMS), push notifications, in-app alerts, postal mail, phone and other means offers on our own behalf or on behalf of other businesses that we think might be of interest to you. This material is sent by Vacation, not third parties, although we may use third party service providers such as the Emma email service provider to serve our emails for example.

In addition, we collect other personal information in certain cases, such as:

Surveys: We may request demographic data or other personal information in customer surveys.

Social Media: If you choose to participate in Vacation-sponsored social media activities or offerings, 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. We may also allow you to enter into contests to provide photos on trips won or purchased through us, such as of your vacation, which you may share with your connections on social media for votes, shared offers or other promotions.

Forward-to-a-Friend & Refer-a-Friend: We offer the ability that allows you to send an auction by server email with a message with a friend, as well as Refer-a-Friend feature to earn credits when those friends establish their own account with us, whether via the Internet, a stand-alone kiosk or mobile device. If you choose to use this feature, we will ask you for the recipient's name and email address, along with the text of any message you choose to include. By using this feature, you represent that you are entitled to use and provide us with the recipient's name and email address for this purpose.

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from Other Information we collect.

You may change the communications you receive from us by logging on to your online account and managing your subscriptions, by writing to us (and including your email address) at Florida Vacation Auction Data Protection Officer, PO Box 61919, Fort Myers, FL 33906-1919 USA, or by emailing us at DataProtectionOffice@FloridaVacationAuction.com .

If you prefer not to receive email marketing materials from us, you may opt-out at any time by using the manage preference or the unsubscribe function in the email you receive from us. To opt out of text messages, reply "STOP" to the message you received.

To be added to our do not call list, email customer_privacy@FloridaVacationAuction.com with "Remove from Call List" in the subject line or body.

You may control whether our mobile apps send you push notifications by changing your notification settings on your mobile device. If we engage in sending you in-app messages, we will allow control for those in our apps’ settings. For more information about cookies and interest-based advertising and to learn about how to manage these technologies, please see our Cookies Statement.

Special Notification for California Residents. Individual customers who reside in California and have provided their personal information to Vacation may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following: CA_customer_privacy@FloridaVacationAuction.com or Florida Vacation Auction, PO Box 61919, Fort Myers, FL 33906-1919 USA. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to CA_customer_privacy@FloridaVacationAuction.com . Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

You can choose to unsubscribe from receiving offers and other distributions at any time by following the unsubscribe instructions found in each e-mail or by contacting our Customer Support department. If you do not want your information to be used to inform you of other products and special offers from Vacation or third parties, and you indicate this preference when you provide the information, Vacation will honor your preference. In case you change your mind or some personal information may change (such as your zip code), we provide a way to correct, update or remove your personal information both on our website and with customer service at customerservice@FloridaVacationAuction.com .

Cookies, Other Tracking Technologies and Interest Based Advertising

We may use cookies or other tracking technology, small bits of code, usually stored on a user's computer, to enable Vacation to personalize your use of our site and to market to you on other internet sites post a visit to our website. We use cookies or other tracking technology to preset certain of your preferences and information, and to track usage. We do not provide third parties with access to the information we collect this way, but if you'd rather we didn't use cookies then simply turn them off and refer to your browser Help instructions to learn more about how to manage their use.

We may also share with companies that show advertisements or auction offers on our pages general about your visits to our web site, in combination with non-personally identifiable information about your purchases and interests, and through use of pixel tags (also called clear gifs), to utilize targeted marketing strategies in providing you with services and advertising. Such advertisers do not have access to our cookies nor your personal information. If you would like more information about the information collection practices of third-party advertising companies, and to know your choices about not having this information used, contact us - including your email address - at Florida Vacation Auction Data Protection Officer, PO Box 61919, Fort Myers, FL 33906-1919 USA, or by emailing us at DataProtectionOffice@FloridaVacationAuction.com .

Contacting Us

If you have any questions about the Privacy Policy, our website or services you may contact Customer Support via email at Service@FloridaVacationAuction.com or write to:

Vacation Auctions, Inc.
Attn: Customer Data Protection
PO Box 61919
Fort Myers, FL 33906-1919


APPENDIX A

ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF PERSONAL INFORMATION OF EEA RESIDENTS

For individuals residing in the EEA, this Appendix outlines certain additional information that Vacation is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws. Per the terms of the GDPR, individuals have 8 fundamental rights effecting how Vacations can collect, store and use data, they are:

  • The right to be informed - in a completely transparent manner - how we are using personal data

  • The right of access - individuals will have the right to know exactly what information is held about them and how it is processed

  • The right of rectification - individuals will be entitled to have personal data rectified if it is inaccurate or incomplete

  • The right to erasure - also known as 'the right to be forgotten', this refers to an individual's right to having their personal data deleted or removed without the need for a specific reason as to why they wish to discontinue

  • The right to restrict processing - an individual's right to block or suppress processing of their personal data

  • The right to data portability - this allows individuals to retain and reuse their personal data for their own purpose

  • The right to object - in certain circumstances, individuals are entitled to object to their personal data being used. This includes how a company such as Vacation uses personal data for the purpose of direct marketing, scientific and historical research, or for the performance of a task in the public interest.

  • Rights of automated decision making and profiling - safeguards to protect individuals against the risk that a potentially damaging decision is made without human intervention. For example, individuals can choose not to be the subject of a decision where the consequence has a legal bearing on them, or is based on automated processing.

This Appendix will control to the extent it conflicts with any provision in the main body of this Statement.

Data Protection Officer: Vacation's Data Protection Officer may be contacted by email at DataProtectionOffice@FloridaVacationAuction.com , or at the following address:

Florida Vacation Auction Data Protection Officer

PO Box 61919
Fort Myers, FL 33906-1919 USA

Purposes and Legal Basis for Processing: Vacation processes your personal information for the purposes set forth in our Collection, Management and Use of Information section of the main body of this Statement.

The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:

Vacation Participation: We process the personal information obtained in connection with your participation and use of our FloridaVacationAuction.com on the basis of our Terms & Conditions contractual relationship with you and in furtherance of our business interests, including to personalize your use of our services and applications, to communicate news and promotional items, and to deliver personalized advertising and content.

Surveys: Completion of surveys is voluntary - we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.

Social Media: Participation in Vacation-sponsored social media activities and offerings is voluntary - we process information obtained from social media participation on the basis of your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization, as described in our Privacy Statement (above).

Promotions and Sweepstakes: Participation in sweepstakes, contests and other promotional offerings is voluntary - we process the information obtained from such participation based on your consent and as necessary to administer the offering. We also use certain data for our business purposes, including for marketing, and analytics and service personalization, as described in our Global Privacy Statement (above).

Direct Marketing: We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at customer_privacy@FloridaVacationAuction.com or by following the unsubscribe instructions in the marketing message, or by logging in to your Vacations account and updating your communication preferences.

Retention: We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.

Data Subject Rights: Residents of the EEA have the following rights:

Access, Correction and Erasure Requests: You have the right to:

  • ask us to confirm whether we are processing your personal information

  • receive information on how your data is processed

  • obtain a copy of your personal information

  • request that we update or correct your personal information

  • request that we delete personal information in certain circumstances

Right to Object to Processing: You have the right to request we cease processing of your personal information:

  • for marketing activities, including profiling

  • for statistical purposes

  • where such processing is based on our legitimate business interests, unless we can demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim

Right to Restrict Processing: You have the right to request that Vacation limit the processing of your personal information:

  • while Vacation is evaluating or in the process of responding to a request by you to update or correct your personal information

  • where such processing is unlawful and you do not want Vacation to delete your data

  • where Vacation no longer requires such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim

  • where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request

  • Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.

Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

Submitting Requests: your requests may be submitted by writing to at Florida Vacation Auction Data Protection Officer, PO Box 61919, Fort Myers, FL 33906-1919 USA, or by emailing us at DataProtectionOffice@FloridaVacationAuction.com .

We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.

If you have concerns about our data practices or the exercise of your rights, you may either contact Vacation at Florida Vacation Auction Data Protection Officer, PO Box 61919, Fort Myers, FL 33906-1919 USA, or by emailing us at DataProtectionOffice@FloridaVacationAuction.com , or the supervisory authority in the Member State of your residence.

Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails, or by contacting Vacation at Florida Vacation Auction Data Protection Officer, PO Box 61919, Fort Myers, FL 33906-1919 USA, or by emailing us at DataProtectionOffice@FloridaVacationAuction.com . For any other activities for which you have previously consented, you may contact DataProtectionOffice@FloridaVacationAuction.com to withdraw such consent.

Segmentation (also referred to as profiling) and Automated Decision Making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behavior, or demographics.

With your consent, we make automated decisions, meaning without human interference, using segmentation and/or your specific personal information to offer you certain benefits based on your characteristics (such as discounted room rates or other special offers based on your geography, behavior, or demographics). For example, we may send you special offers for hotels in Orlando, FL.

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