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ONLINE PRIVACY STATEMENT

This Online Privacy Statement (“Policy”) was last updated on March 3, 2021.

Para la versión en Español de nuestra Declaración de Privacidad, haga clic aquí.

Vistana Signature Experiences, Inc. is an indirect subsidiary of Marriott
Vacations Worldwide Corporation, a global vacation company that offers vacation
ownership, exchange, rental, and resort and property management, along with
related businesses, products and services.

Marriott Bonvoy, Heavenly, Heavenly Spa, WestinWORKOUT, Sheraton, St. Regis, The
Luxury Collection, Westin and their respective logos are the trademarks of
Marriott International, Inc. (“Marriott”). Vistana Signature Experiences and the
programs and products provided under the Vistana brand are not owned, developed
or sold by Marriott.

Vistana Signature Experiences, its subsidiaries and managed Owners’ associations
(together “Vistana,” “we,” “our,” or “us”) respect your privacy and are
committed to protecting it through compliance with this Policy. This Policy
describes the type of information Vistana may collect from you or that you may
provide when you visit any website, mobile applications, or property owned or
operated by Vistana. Vistana collects information about you so that we can
provide an experience that is tailored to your preferences. Vistana’s mission is
to consistently exceed expectations with respect to the products and services we
provide to our business and leisure travelers.

This Policy may not apply to information collected by Vistana offline or through
other means, including on any other website operated by Vistana or any third
party (including our parent, affiliates and subsidiaries) that do not link to
this Policy; or any third party through any application or content (including
advertising and credit card processing service providers) that may link to or be
accessible from or on Vistana websites.

Vistana is committed to providing information about the collection and use of
personal information furnished by or from you while using our websites, products
and services. If you create a personal online profile through a Vistana website,
you will be offered the choice to decline (opt-out) participation in certain
services and promotional benefits provided by Vistana and/or our carefully
selected third parties, including Marriott through the Marriott Bonvoy program
(“Strategic Marketing Partners”).

Please read this Policy carefully to understand Vistana’s policies and practices
regarding your information and how it will be used. By accessing or using
Vistana websites, you agree to this Policy. If you do not agree with the
policies and practices of Vistana, your choice is to not use our websites. This
Policy may change from time to time. Your continued use of the websites after we
make changes is deemed acceptance of those changes, so please check the Policy
periodically for updates.

The following is an explanation of the information collected by Vistana, its
use, and why the use of this information will benefit our visitors’ experience.



INFORMATION COLLECTED ON OUR WEBSITES
COOKIES AND INVISIBLE PIXELS
SOCIAL MEDIA
EMAIL
DIRECT MAIL/OUTBOUND TELEMARKETING
LINKS TO OTHER WEBSITES
ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION
CHILDREN UNDER THE AGE OF 13
DATA TRANSFERS ACROSS INTERNATIONAL BORDERS SECURITY
YOUR CALIFORNIA PRIVACY RIGHTS
YOUR PRIVACY RIGHTS IN MEXICO
PERIODIC REVIEW AND MODIFICATIONS
CONTACT US




INFORMATION COLLECTED ON OUR WEBSITES


Vistana may ask for and collect personal information in order to provide a
customized experience on our websites. The personal information we collect may
include information that you provide by filling in forms on our websites, such
as name, postal address, email address and telephone number. With these fill-in
forms, you have the ability to choose the information you wish to share with us.
You will be informed about how Vistana may use such information, including
whether it will be shared with Strategic Marketing Partners. In most cases, the
information you provide is added to our database in order for us to provide
personally tailored messages which are delivered online and offline.

Vistana may also collect information using automatic data collection
technologies to collect certain information about your equipment, as well as
your browsing activities and patterns. Our automatic data collection activities
are further described in the Cookies and Invisible Pixels section of this
Policy.

Vistana may contract with third-party service providers to deliver services and
customer solutions. Service providers, which may change or be added from time to
time, are required to keep confidential the information received on behalf of
Vistana and may not use it for any purpose other than to carry out the services
they are performing for Vistana. Situations in which Vistana may disclose your
information to others include:

 * When you have not objected to these types of disclosures or, in those
   jurisdictions where we are required to obtain your permission, when we have
   received your consent to do so;
 * In situations where sharing or disclosing your information is required in
   order to offer you products or services you requested (e.g., a vacation
   package);
 * When companies or service providers that perform business activities on
   behalf of Vistana require such information (e.g., credit card processing,
   customer support services, market research administration or database
   management services);
 * When a hotel or other property leaves the Vistana system, and access to your
   personal information is necessary to facilitate business operations or meet
   contractual obligations;
 * In the event Vistana is merged with or acquired by another company;
 * To comply with legal or regulatory requirements or obligations in accordance
   with applicable law, a court order or a subpoena, to enforce the right of a
   lender, owners’ association, or foreclose on a property interest; and
 * In case of emergency such as to safeguard the life, health or property of an
   individual.

If information is shared as mentioned above, we seek to limit the scope of
information that is furnished to the amount necessary for the performance of the
specific function. Unless otherwise precluded by legal process, we require third
parties to protect your personal information and abide by applicable privacy
laws and regulations.

You may choose to create a personal online account with a unique log-in. It is
necessary for Vistana to collect certain personal information from you to
establish these accounts and allow you to perform various activities within the
website. For Owners of Vistana products, you will have to provide additional
information to enable you to access your specific ownership information. If you
do not wish to share your information, please do not register and set up an
online account.

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COOKIES AND INVISIBLE PIXELS


The websites may collect personal information through behavioral tracking. As
you navigate through and interact with our websites, Vistana, its vendors and
marketing partners may use automatic data collection technologies to collect
certain information about your equipment, browsing actions and patterns by using
cookies, invisible pixels and web beacons. These help us deliver a better and
more personalized service, including by enabling us to estimate our audience
size and usage patterns; store information about your preferences, allowing us
to customize our websites according to your individual interests; and speed up
your searches.

Web Beacons and Invisible Pixels. Vistana uses invisible pixels and web beacons
to count how many people visit certain web pages. Information collected from
invisible pixels and web beacons is used and reported in the aggregate. Vistana
may use this information to improve marketing programs and content.

Cookies. Cookies are used to:

 * Remember your username and password for future visits so log in is easier and
   faster;
 * Ensure you are provided with the appropriate frames and content;
 * Ensure you obtain all requested information; and
 * Help us deliver communications that are relevant and responsive to your
   interests and location.

Vistana cookies assign your computer or other device with a unique identifier,
which in turn becomes your identification card whenever you return to a Vistana
website. Cookies are small data files that most websites store, access and
maintain on the hard drive of your computer. Most browsers now automatically
accept cookies by default, but they can be set so that all or some cookies are
rejected automatically, or are accepted or rejected on a case-by-case basis at
the user’s option.

Below we explain the different types of cookies that may be used on our
websites. For a full list of the cookies we employ, please see the Cookie
Choices section of this Policy.

 * Essential Cookies. Essential cookies are necessary for our websites to work,
   and to enable you to navigate them and use their services and features. As
   disabling these cookies would make the services and features unavailable, we
   are not required to provide you with an opt-out consent mechanism.
 * Customization Cookies. Customization or preference cookies store your choices
   and preferences, allowing us to remember language or other local settings and
   to customize our websites accordingly.
 * Analytics Cookies. Analytics cookies collect information about your use of
   Vistana websites and enable us to identify problems, determine the efficacy
   of our advertising, and understand how aggregate traffic moves on and to our
   websites.
 * Advertising Cookies. Advertising cookies allow us to show you the most
   relevant products, offers, advertisements and personalized content, and help
   us provide you with an online experience that’s tailored to your needs.

We may also work with vendors and marketing partners to help deliver
advertisements and personalized content that we believe will be of interest to
you. These vendors and marketing partners include advertisers, advertising
agencies, advertising networks, audience segment providers, data exchanges,
analytics providers and other similar providers. Please click here for a current
list of the agencies and providers with which we work. These partners and
vendors use cookies and web beacons to collect information about your online
activity (e.g., the sites and pages you have visited at Vistana and other
third-party websites) in order to help Vistana and third-party advertisers
deliver personalized content and advertising to you while you are on Vistana or
other websites. For example, if you go to a Vistana website to look at one of
our properties or to book a villa, you may later see an advertisement from us
when you visit another website. We may also engage one of these vendors to
deliver our advertisements to consumers whose online behaviors on websites other
than the Vistana websites indicate that they may be interested in travel. In
other instances, we engage in special arrangements with certain advertisers with
which we think our website visitors would have an interest. We allow these
advertisers to deliver co-branded messages (e.g., Vistana and the advertiser)
directly to consumers who have visited our websites. These types of co-branded
advertisements may appear on Vistana or on third-party websites. In general, you
can click here to opt out of our vendors’ use of cookies to tailor personalized
content or advertising, or visit:

networkadvertising.org/managing/opt_out.asp and aboutads.info/choices.

We also work with vendors to deliver our advertisements directly to those who
are traveling or about to travel. For example, when you print your boarding pass
online, one of our vendors may drop a cookie on your computer, identifying your
computer with a unique identifier and a code indicating your destination. We use
this vendor to deliver advertisements to you indicating our available properties
in the destination indicated on your boarding pass.

Cookie Choices

You can disable cookies by setting your preferences at any time in the
Advertising Preferences link at the bottom of our website. To see a complete
list of the companies that use these cookies and technologies, and to tell us
whether or not they can be used on your device, please click here. However, you
should also understand that rejecting cookies might affect your ability to
perform certain transactions on our websites and our ability to recognize your
browser from one visit to the next.

You may also adjust your internet browser to treat cookies in different ways.
Depending upon the type of browser you are using, you may be able to configure
your browser so that: (i) you are prompted to accept or reject cookies on an
individual basis or (ii) you may be able to prevent your browser from accepting
any cookies at all. You should refer to the supplier or manufacturer of your web
browser for specific details about cookie security.

To learn more about cookies, please visit the following site, which is not
affiliated with Vistana: allaboutcookies.org/.

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SOCIAL MEDIA


Profile If you connect with a social media service, or log in through a social
media service, we may collect information that is publicly available through
that service and the basic account information that is automatically passed to
us by the service. For example, on Facebook, this could include your name,
profile pictures and URL, cover photos, username, user ID, your friends’ user
IDs, network, gender, birthday, language and current city.



Social Content We may also collect content that you provide to be published on
those social media services, such as your likes and your social media
activities, like check-ins or tweets. We also collect such other information as
you and the social media service provide to us, including information regarding
or provided by your friends. This includes, for example, check-ins, events,
travel wishes, interests, posts, locations and photos (including photos you or
your friends have been tagged in). If you have turned on your device’s location
services, your location may be included in that content.



Social Media Content Sharing The information collected from or about you by
social media networks with which you connect are governed by the policies of
those social media networks. Be aware that sharing content on a social media
service may lead to it being shared to your friends (or contacts on those
networks). Please consult the privacy settings on these services to update any
of your sharing settings.

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EMAIL


From time to time, Vistana may ask you for your email address in order to
provide relevant information such as reservation confirmations and offers. Email
addresses may be joined with other information provided at our website and may
also be augmented with other data sources. By providing your email address to
us, you may receive periodic offers and information from Vistana or one of its
Strategic Marketing Partners. If you do not want to receive marketing
information from Vistana and/or one of our Strategic Marketing Partners in the
future, you may opt out of receiving email communication by following the
directions posted in the email, or by contacting us in any of the ways outlined
in the Contact Us section of this Policy.

Once a visitor has opted out, they can choose to opt in again by changing the
preferences selected in their personal online profile or by contacting us in any
of the ways outlined in the Contact Us section of this Policy. If you ask us to
make these changes for you, we may not be able to change your personal
information without deleting your account.

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DIRECT MAIL/OUTBOUND TELEMARKETING


As part of the service that Vistana provides, Vistana may mail, text message or
call you to inform you of enhancements, changes in offerings, special events or
other relevant information responsive to your interests. If you provide Vistana
with your postal address, cellular or telephone number, you may receive periodic
mailings or phone calls from us with information on new Vistana products and
services or upcoming Vistana special offers/events. You may also receive
mailings/calls from one or more of our Strategic Marketing Partners. Vistana
complies with Federal and State “Do Not Call” legislation and offers you the
option to decline these communications. You can opt out of receiving certain
communications from Vistana when setting up an online account, or by submitting
your request or contacting us in any of the ways outlined in the Contact Us
section of this Policy.

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LINKS TO OTHER WEBSITES


In order to anticipate your needs, Vistana provides links to other websites for
your convenience and information. Vistana is not responsible or liable for any
content presented by or contained on any third-party website, including but not
limited to any advertising claims or marketing practices. Please note that while
Vistana will protect your information on Vistana-owned and -operated websites,
Vistana cannot control and will not be responsible for the privacy policies of
third-party websites, including websites owned or controlled by independent
Owners’ associations, vendors, service providers, travel providers that may have
a business relationship with Vistana, or other websites not controlled or
authorized by Vistana. Third-party websites that are accessed through links on
Vistana’s websites have separate privacy and data collection practices and
security measures. We have no responsibility or liability for the practices,
policies and security measures implemented by third parties on their websites.
We encourage you to contact them to ask questions about their privacy practices,
policies and security measures before disclosing any personal information. We
recommend that you review the privacy statements and policies of linked websites
to understand how those websites collect, use and store information.

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ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION


We respect your privacy and maintain your personal information on a secure
server. If you create a personal online profile for which you have a unique
log-in, you can review and change your personal information and online
communication preferences by logging into that website and visiting your account
profile. If you request us to make changes to your personal account, we may not
be able to change your personal information without deleting your account.

Occasionally, information you request to be changed or removed will be retained
in certain files in order to properly resolve disputes or to troubleshoot
problems. In addition, information is never completely removed from our
databases due to technical and legal constraints, including stored “back-up”
systems. Therefore, you should not expect that all of your personal information
will be completely removed from our databases in response to such requests.

Data collected by Vistana is an asset. It is possible that Vistana, its parent,
subsidiaries, affiliates, joint venture companies, or any combination of the
foregoing, could merge with or be acquired by another legal entity. In such
event, you should expect that Vistana may share some or all of the data
collected from its visitors with such other entity, provided that such other
entity will be notified of the practices which apply to personal information
under this Policy.

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CHILDREN UNDER THE AGE OF 13


Our websites are not intended for children under 13 years of age. No one under
age 13 may provide any personal information on our websites. We do not knowingly
collect personal information from children under 13. If you are under 13, do not
use or provide any information on this or any other website owned or operated by
Vistana; do not use any of the interactive or public comment features; do not
provide any information about yourself to us, including your name, address,
telephone number, email address or any screen name or username you may use. If
we learn we have collected or received personal information from a child under
13 without verification of parental consent, we will delete that information. If
you believe we might have any information from or about a child under 13, please
contact us.

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DATA TRANSFERS ACROSS INTERNATIONAL BORDERS


Vistana does not currently store data collected through this website in any
location outside of the United States. However, if at any time Vistana does
store personal information of our customers outside of the United States, the
nature of our business and our operations may require us to transfer that
personal data to our parent, subsidiaries, affiliates and Strategic Marketing
Partners located in countries outside of your own, including into the United
States. By providing your personal information on this or any of our parent,
subsidiary or affiliate websites, you are acknowledging that such transfer may
occur and expressly grant permission to do so. Although the data protection
requirements and other laws of these various countries may not be as
comprehensive as those in your own country, Vistana will take appropriate steps
to ensure that your personal data is protected and handled as described in this
Policy.

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SECURITY


Vistana recognizes the importance of information security and is constantly
reviewing and enhancing our technical, physical, and logical security rules and
procedures. Vistana-owned and -operated websites and servers utilize security
measures to help protect your personal information against accidental loss,
misuse, unlawful or unauthorized access, disclosure and alteration while under
our control. Online payment transactions will be tokenized. We also strive to
ensure our Strategic Marketing Partners and service providers with which we
share your personal information exercise reasonable efforts to maintain its
confidentiality and security. Although “guaranteed security” does not exist
either on or off the internet, we safeguard your information using appropriate
administrative, procedural and technical safeguards, including password
controls, firewalls, the use of encryption and tokenization.

Where we have given you or where you have chosen a password for access to
certain parts of our websites, you are responsible for keeping this password
confidential. We ask that you not share your password with anyone.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we do our best to protect your personal information,
we cannot guarantee the security of your personal information transmitted to our
websites. Any transmission of personal information is at your own risk. We are
not responsible for circumvention of any privacy settings or security measures
contained on our websites.

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YOUR CALIFORNIA PRIVACY RIGHTS


1. California Consumer Privacy Act of 2018

The California Consumer Privacy Act of 2018 (“CCPA”) requires that we provide
consumers that reside in California (“you,” or “your” as used in this Your
California Privacy Rights section) certain information 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.

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 or this section.

Categories of Personal Information that We Collect, Use, and Disclose

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 collect based on the categories of personal
information set forth in the CCPA.

    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: Commercial information including records of personal property,
products or services purchased, obtained, or considered, or other purchasing or
use histories or 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,
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 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 and for the
purposes described in this Policy. We disclose your personal information to
third parties, such as our service providers, as described in this Policy. We do
not collect personal information directly from children under the age of sixteen
(16), but may receive such information from parents and guardians when, for
example, making resort or other travel reservations.

Third-Party Cookies & Similar Technologies

We may also use standard internet technology, such as cookies, web beacons,
pixels, and other similar technologies (“third-party cookies”), to track your
use of our websites. 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. Data that is collected through network advertising or social media
third-party 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. See the “Cookies and Invisible Pixels” section of this Policy for more
information. While there is currently no industry consensus, we do not consider
these additional disclosures to be our sale of personal information under the
CCPA. You can click here, however, if you do not want information collected by
third-party cookies, or visit www.aboutads.info and www.networkadvertising.org
to opt out.

California Resident Rights

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) 980‑2582 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 not able 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.

We are not permitted to nor do we discriminate against California residents who
exercise their rights under the law. 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.

2. Shine the Light Law

California Civil Code Section 1798.83 provides certain privacy rights to
individual customers who are California residents. If you are a California
resident and have provided personal information to Vistana, you may request
information about our disclosures of certain categories of personal information
to third parties, if such disclosures were for the direct marketing purposes of
the recipient of that information. Because your privacy is important to us,
Vistana does not share your personal information with unaffiliated third parties
for the third parties’ direct marketing purposes, except as stated herein.
Vistana does share customer information with and among its parent, affiliate and
subsidiary companies for the purpose of marketing the various Vistana resorts,
vacation and travel products and services, and shares certain information about
the Owners of vacation ownership interests with Marriott, as operator of the
Marriott Bonvoy™ program and as owner of the Sheraton, Westin, St. Regis and The
Luxury Collection brands, and with the external vacation exchange companies
(Interval International and/or Resort Condominiums International) that are
affiliated with the Vistana resorts. If you want to opt out of sharing this
information, please submit your request by writing to the addresses listed in
the Contact Us section below.

Civil Code Section 1798.83 provides certain privacy rights to individual
customers who are California residents. If you are a California resident and
have provided personal information to Vistana, you may request information about
our disclosures of certain categories of personal information to third parties,
if such disclosures were for the direct marketing purposes of the recipient of
that information. Because your privacy is important to us, Vistana does not
share your personal information with unaffiliated third parties for the third
parties’ direct marketing purposes, except as stated herein. Vistana does share
customer information with and among its parent, affiliate and subsidiary
companies for the purpose of marketing the various Vistana resorts, vacation and
travel products and services, and shares certain information about the Owners of
vacation ownership interests with Marriott, as operator of the Marriott Bonvoy
program and as owner of the Sheraton, Westin, St. Regis and The Luxury
Collection brands, and with the external vacation exchange companies (Interval
International and/or Resort Condominiums International) that are affiliated with
the Vistana resorts. If you want to opt out of sharing this information, please
submit your request by writing to the addresses listed in the Contact Us section
below.

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YOUR PRIVACY RIGHTS IN MEXICO


The Mexican Federal Law for the Protection of Personal Data Held by Private
Parties and its Regulations (“Mexican Privacy Regulations”) provide certain
privacy rights to individual customers who are Mexican residents. If you are a
Mexican resident, Vistana has appointed Jeff Driscoll with Turistica Cancun, S.
de R.L. de C.V. as the person in charge of your personal data.

Vistana does not ask for nor collect personal data considered sensitive by
Mexican Privacy Regulations.

You have the right to request access to, rectify, cancel and oppose the
management of your personal data (your “ARCO Rights”). Furthermore, you have the
right to request the revocation of your given consent, as well as limit the use
of your personal data.

In order to exercise your rights, we ask that you send your request in a letter
or an email to the addresses below.

For security purposes, and in compliance with the Mexican Privacy Regulations,
it is mandatory that all requests be accompanied by the information necessary
for us to identify the applicant and, if applicable, his or her legal
representative. As a result, your request form should be accompanied with the
following documents:

 1. Name and address, or other means to communicate the answer to your request;
 2. Documents proving their identity or, where appropriate, legal
    representation;
 3. A clear and precise description of the personal information as to which you
    wish to exercise any of the ARCO rights;
 4. An express statement to revoke your consent to the processing of personal
    information and for what they may not be used; and
 5. Any other factor that facilitates the tracking of personal information.

Vistana keeps a record of all the submitted requests. Furthermore, in case the
request form should be found incomplete, we have the right to reject your
request.

You guarantee that the given information is exact, complete and authentic.
Vistana is not responsible for any damage and/or harm caused by falsified
information or identity impersonation.

Your request shall be processed in accordance with the manner and time
established in the Mexican Privacy Regulations. If applicable, Vistana will
provide a response no later than 20 (twenty) business days after we have
received your request. The waiting period could be extended by another 20
(twenty) business days if and when it’s justified, and provided we notify you of
said extension.

If you request access to your personal data, it shall be given digitally. Only
upon express request, and provided you cover any reasonable expenses, will
Vistana furnish hard copies and send them to your home address.

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PERIODIC REVIEW AND MODIFICATIONS


This Policy may be revised from time to time. Updated versions will be posted to
our websites and date stamped so that you are always aware of when the Policy
was last updated.

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CONTACT US


Vistana provides all visitors with the option to contact us with any further
questions or concerns.

You can contact us these ways:

By email: privacy@mvwc.com

By writing to us at: Vistana Signature Experiences, Inc. Attention: Privacy
Office 9002 San Marco Court Orlando, Florida 32819

By calling a customer service representative at: (800) 847-8262

To opt out of receiving communications from Vistana by telephone and be placed
on the Vistana Do Not Call list: (800) 611-5701

To delete your Online Account: Please click here to send an email with your
request.

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©2022 Vistana Signature Experiences, Inc. (“Vistana”) and Marriott
International, Inc. (“Marriott”). All Rights Reserved. Vistana, its logo,
Vistana Signature Network, VSN, StarOptions, A Better Way To See The World and
Friendship Rewards Program are the trademarks of Vistana or its affiliates.
Marriott Bonvoy, Sheraton, St. Regis, The Luxury Collection, Westin, Heavenly,
Heavenly Spa, WestinWORKOUT and their logos are the trademarks of Marriott or
its affiliates and are used by Vistana, an authorized partner of the Marriott
Bonvoy program, under license from a subsidiary of Marriott. Vistana and the
programs and products it provides are not owned, developed, or sold by Marriott
or its affiliates. Vistana is solely responsible for its advertising, marketing,
privacy and data collection practices.

This material is intended to encourage the sale of Vistana Signature Experiences
all-villa resort interests classified by state legislation as timeshare sales.
This is neither an offer to sell nor a solicitation of offers to buy in any
state or other jurisdiction in which registration requirements have not been
met. Vistana Signature Network™ is a registered Exchange Program.

THIS ADVERTISING MATERIAL IS BEING USED FOR THE PURPOSE OF SOLICITING SALES OF
TIMESHARE INTERESTS.

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