1. Introduction

This Privacy Notice is provided by Rolling Oaks Splendid, LLC d/b/a/ The Residences at Margaritaville Resort Orlando (referred to in this Privacy Notice as “MRO”, “we”, “us” and “our”). MRO is based in Kissimmee, FL. Our headquarters are located at 3297 Margaritaville Blvd, Kissimmee, FL 34747.

This Privacy Notice describes how MRO collects, uses, shares, and retains personal information that you provide to us, or that we collect, when you use the MRO website located at Margaritavillevillasorlando.com/privacy-policy/ and any website operated MRO or its affiliates or subsidiaries on which this Privacy Notice is posted (collectively, the “Site”), when you use or purchase any of our products or services, or when you interact with our content, or any related events, trade shows, sales or marketing, social media pages, or mobile applications made available on the Site (the Site, services, content and applications are collectively defined in this Privacy Notice as the “Service”).

2. What Data Does MRO Collect?

2.1 – General Description

We collect personal information and non-personal user data from the Service, as further described in this Privacy Notice.  The specific data MRO collects, stores and processes depends on which of our products and service you use and how you use them.

Personal information means information that identifies, describes, or is reasonably capable of being associated with a particular consumer, and includes identifiers such as a name, online identifiers such as device ID, and email address.

2.2 – Data You Voluntarily Provide through the Service

We collect personal information that you voluntarily provide to us when you use our Service. For example, we collect information in the following ways:

• If you register for a MRO Membership Account, we may collect any Personal Information that you provide through completing the online form.
• If you contact us through the Websites, we will keep a record of our correspondence.
• When setting up new users, we collect Personal Information, such as name and e-mail address, to provide them with Services.

2.3 – Information Automatically Collected Through the Service Including Location Information

We may automatically collect information about you when you use the Service. For example, we will automatically collect information, which may not be personal information, such as your browser type and version, computer and connection information and standard web log information. If you access the Service through a mobile device, we may also be able to identify the location of your mobile device.  You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

2.4 – Information That You Post

If you post information on public areas of the Service, that information will be collected and used by MRO, other users of the Service, and the public generally. We strongly recommend that you do not post any information through the Service that allows strangers to identify or locate you or that you otherwise do not want to share with the public.

3. What Data Do Third Parties Collect through the Service?

3.1 – Google Analytics

We may use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Site and how we can improve it. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Site to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Site, please review “How Google uses information from sites or apps that use our services” (located here or any successor URL).

3.2 – Information Collected by Third Parties through Third Party Links and Content

The Service includes links to other websites and other content from third party businesses. These third-party businesses may collect information about you. MRO does not have access to or control over these third parties or the cookies, web beacons or other technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third-party website. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on our Service (also please see our Cookie Policy below for additional information about Online Advertising).

4. Cookies

We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. They also allow us to collect information such as the IP address, browser, email client type and other similar details. We use this information to measure the performance of our email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send emails to you, so we may collect and review that information.  We, and/or our third party service providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience. This data helps us and our third party service providers improve our respective products and services.

Below is a detailed list of the cookies we use on our Website. Our Website is scanned with our cookie scanning tool regularly to maintain a list as accurate as possible. We classify cookies in the following categories:

• Strictly Necessary Cookies
• Statistics Cookies

You can opt-out of each cookie category (except strictly necessary cookies) by clicking on the “cookie settings” button.

4.1 – Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not work. These cookies do not store any personally identifiable information.

4.2 – Statistics Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us know which pages are the most and least popular and see how visitors move around the site. They may be set by us or by third party providers whose services we have added to our pages. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites.

They do not store personal information directly but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

5. How Do We Use Your Information?

5.1 – Fulfilling Requests

If you provide your information to us for a particular purpose we will use the information you provide for the applicable purpose and for any other purposes about which we notify customers and users. For example:

• To provide you with information you have requested about our Services.
• To set up a user/membership account.
• To process and complete transactions, and send related information, including transaction confirmations and invoices.
• To respond to inquiries and comments and provide customer service and support.

5.2 – Operating the Service

We use the information we gather through the Service to help us better understand how the Service and our products and services are being used. By identifying patterns and trends in usage, we are able to better design the Service to improve your experience. The information we gather may be used to:

• To administer our Site and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purpose.
• To improve our Site to ensure that content is presented in the most effective manner for you and for your computer.
• Provide, operate and maintain the Services.
• Send customers technical alerts, updates, security notifications, and administrative communications.

5.3 – Direct Marketing Communications

If you sign up for our mailing list, participate in a sweepstakes or contest, sign up for our newsletter, purchase goods or services, stay at an affiliated property, or create an account through the website, we will use the personal information and other information you provide for trend monitoring, marketing and advertising purposes including to send you marketing communications relating to the Service, of our parent company, and the similar products and services of our subsidiaries and corporate affiliates, joint venturers and licensees. If you no longer wish to receive these marketing materials, please follow the instructions contained in our marketing materials that allow users to unsubscribe from receiving these types of communications from us. If you unsubscribe from our direct marketing communications, we will remove your email information from our marketing list.

5.4 – Administering Sweepstakes and Contests

To the extent permitted by applicable law, we will also use the personal information and other information you provide to send you marketing communications for us and our affiliate companies, joint ventures and licensees. If you no longer wish to receive these marketing materials, please follow the instructions contained in our marketing materials that allow users to unsubscribe from receiving these types of communications from us. If you unsubscribe from our direct marketing communications, we will remove your email information from our direct marketing list, but we may still send you emails for other purposes, such as to complete a transaction.

5.5 – Security

We may use the information we collect as part of our efforts to keep our Site safe and secure and to investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities.

6. How Do We Share Your Information?

We share your personal information and other information with third parties in some circumstances as follows:

6.1  –  Margaritaville Enterprises, LLC and Affiliates

We share your personal information with our Licensor/Franchisor, Margaritaville Enterprises, LLC and its affiliates for purposes such as customer relations management, administering a customer loyalty program, and general Margaritaville brand updates and communications.

6.2 – Third-Party Processors and Third-Party Service Providers

MRO engages other companies to perform functions on our behalf (collectively, “Service Providers”), such as operating and supporting the Service, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform these limited functions on our behalf but are prohibited by contract from using the information for other purposes, except as permitted by law or upon your consent.

6.3 – Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies

To the extent permitted by law, we will disclose your information to government authorities or third parties if:  (a) required to do so by law, or in response to a subpoena or court order; (b) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; (c) we believe that you have abused the Service by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws; (d) in response to a request from law enforcement authorities or other government officials, including to meet national security requirements; or (e) when we believe disclosure is reasonably necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or illegal activity.

6.4 – Business Transfers; Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any user information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected to third parties.

6.5 – Aggregate & Deidentified Information

We may share aggregate information relating to users of the Service with affiliated or unaffiliated third parties. We also may use and share some information that has been deidentified in accordance with applicable legal standards.

6.6 – Marketing Partners

As permitted by applicable law or based on your consent, we may share your personal information with our business partners for marketing purposes. If you would like us to stop providing your personal information as described above, you may opt-out by emailing us at CottageSales@mroresorthomes.com.

6.7 – Digital Millennium Copyright Act Notices

We will share your information with third parties if you submit a Digital Millennium Copyright Act (“DMCA”) Notification (or Counter Notification) as described in our DMCA Policy located at https://thecoveatmargaritavilleresortorlando.com/terms-of-use/, or if you are the person responsible for uploading the material addressed in a notification that is submitted to us.

6.8 – To Protect You, Us, or Others

We may share your personal information if we believe, in good faith, that such disclosure would protect your interests or rights, safety, or the interests or rights of others, including MRO and its personnel.

7. Where is the Data Processed & Stored?

Personal information processed by MRO is processed and stored by MRO in the United States. MRO implements and maintains reasonable security procedures and practices such as physical, technical and administrative measures to safeguard all personal information that MRO processes. Please be aware that no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal information that we process.

8. Responding to Concerns

We take your privacy concerns seriously. If you believe that MRO has not adhered to this Privacy Notice, please contact us by sending an email to: CottageSales@mroresorthomes.com with the subject line: “Privacy Concern”. In your email, please describe the ways in which you believe that this Privacy Notice has not been complied with or does not comply with applicable law. We will respond to you within forty-five (45) days of receipt of your email.

9. Children

Our Services are not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (“COPPA”) and will not knowingly collect personal information from any child under the age of 13, unless a parent or guardian consents to our collection and use of this information. If a parent or guardian becomes aware that his or her child has provided us with personal information without his or her consent, he or she should contact us at CottageSales@mroresorthomes.com if we become aware that a child under 13 has provided us with personal information, we will take steps to delete the information from our files.

10 – Data Subject Rights – California Residents

This portion of our Privacy Notice advises California residents of the applicable rights as provided in the California Consumer Privacy Act (“CCPA”) and how to exercise these rights by communicating with us. We provide you with the rights described below when you use our Services. Please note that we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your personal information.

For purposes of this section, “Personal Information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

If a California resident wishes to make any of the requests described below, such as access and deletion, he or she may contact us as provided in Section 13 (How to Contact Us) below.

10.1 – Right to Deletion of Personal Information

California residents have the right to request the deletion of Personal Information as prescribed in Section 1798.105(a) of the CCPA. MRO may not delete some or all Personal Information if such Personal Information is necessary for us, or our service providers or affiliates, to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of MRO’s ongoing business relationship with the consumer, or otherwise perform a contract between MRO and the consumer,
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity,
• Debug to identify and repair errors that impair existing intended functionality,
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law,
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code,
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with MRO,
• Comply with a legal obligation, or
• Otherwise use the consumer’s Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the Personal Information.

10.2 – Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices

You may request to receive details about how we collect, use, and share your Personal Information.  Specifically, you may request to receive the specific pieces of information that we have collected about you by contacting us as provided in Section 13 (How to Contact Us) below.

You may also request to receive:

• the categories of Personal Information that we have collected about you,
• the categories of Personal Information that we have disclosed for a business purpose,
• the categories of sources from which we collected the Personal Information,
• our purposes for collecting that Personal Information, and
• the categories of parties with whom we share your Personal Information.

10.3 – Right to not be Discriminated Against for Exercising your Rights

We do not discriminate against you for exercising any of your CCPA rights, such as your access and deletion rights described above. However, we may offer you rewards (such as through our loyalty program) or benefits (such as customizing your experience at a resort) which we need your data to provide, but we will only provide those rewards or benefits if their value to you is reasonably related to the value provided to MRO by your Personal Information.

10.4 – Categories of Personal Information Collected about California Consumers and the Purposes of Such Collection

We collect identifiers that you may choose to provide to us, such as your name, email address, mailing address, phone number, birthday, and age.  We use this information to communicate with you, market goods and services, and to provide you with goods and services.

We collect and use identifiers (such as a username) you may choose to provide to us, and the content of your communications when you post information on our online message boards or online public forums.  We use this information to run our online message boards or online public forums.

10.5 – Categories of Personal Information Sold about California Consumers

10.6 – Categories of Personal Information Disclosed for a Business Purpose

MRO discloses identifiers (e.g., name or email address), internet activity, consumer history, and consumers’ preferences to provide marketing and analytics services to its business partners.

10.7 – Removing Content on Public Forums

If you are a California resident between the age of 13 and 18 and are a registered user on the Service and participate in the online public forums offered through the Service, you may request that we remove content or information about you that you posted by (a) submitting a request in writing to 3297 Margaritaville Blvd, Kissimmee, FL 34747 with the subject:  “Deletion Request”, and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to erase or otherwise eliminate content or information if (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that you cannot be individually identified; (iv) you do not follow the instructions posted in this Privacy Notice on how to request removal of your content or information; or (v) you have received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain the applicable content or information.

10.8 – Responding to Do not Track Requests

We are required to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Privacy Notice and do not monitor or follow any Do Not Track browser requests.

11. Data Retention

We will retain your personal information only for as long as reasonably necessary for the purposes described in this Privacy Notice. Please be aware that we may also be required to retain your personal information for legal and accounting reasons.

12. Changes to this Privacy Notice

We reserve the right, in our discretion, to amend this Privacy Notice at any time without notice and, unless otherwise indicated, such changes will become effective immediately upon posting; therefore, please check this Privacy Notice periodically for changes. We will display the effective date of this Privacy Notice at the top of this page. If you do not agree with the changes and if you are a registered user, you may cancel your account with us by contacting us at CottageSales@mroresorthomes.com. The version of this Privacy Notice posted Margaritavillevillasorlando.com on each respective date you visit the System shall be the Privacy Notice applicable to your access and use of the System on that date. Our electronically or otherwise properly stored copy of this Privacy Notice shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Notice which was in force on each respective date you visited the System.  This Privacy Notice is not a contract and does not create any legal rights or obligations.

13. How to Contact Us

If you have any questions or concerns about this Privacy Notice or would like to make a request for access or deletion, please contact us by sending an email to CottageSales@mroresorthomes.com or by using the page at Margaritavillevillasorlando.com/contact-us/.