COMMITMENT TO YOUR PRIVACY

“ASTORIA VACATION AND LEISURE CLUB, INC.” or “We” in this Privacy Notice refers to ASTORIA VACATION AND LEISURE CLUB, INC. (“AVLCI”).

This Privacy Notice outlines how we collect, use, maintain, and disclose your personal information in respect to commercial transactions and how we safeguard your personal information.

We assure you that your personal information will be handled with the strictest confidentiality and in full compliance with Republic Act No. 10173 otherwise known as the Data Privacy Act of 2012.

THE IMPORTANCE OF YOUR CONSENT

By joining our raffle, you certify that all the information you provide us is true and accurate to the best of your knowledge.

By clicking “Submit” and submitting your information or joining our giveaway or when you enter into any commercial transaction with us, you may be required to provide your personal information. In doing so, you consent to its use in accordance with this Privacy Statement. Your personal information may have otherwise been provided to us by a third party (e.g., your spouse, your relative, your co-worker) for products or services that these third parties have sought from us pursuant to commercial transaction entered into with AVLCI. In this context, the term “you” or “your” in this Privacy Notice extends to any individual whose personal information has been provided to AVLCI and/or has been collected in other circumstances.

We may collect your sensitive personal information (including but not limited to, data relating to your name, birthday, race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations, etc.) if you apply for certain products and services, which will require you to disclose such sensitive personal information to us. We will only use your sensitive personal information to provide the service(s) you signed up for. If we collect, use, maintain or disclose your sensitive personal information, we will ask for your explicit consent.

You have the choice, at any time, not to provide your personal information/sensitive personal information or to revoke your consent to AVLCI processing of your personal information/sensitive personal information. However, failure to provide such personal information/sensitive personal information or revocation of your consent to process personal information/sensitive personal information provided may result in your disqualification from the giveaway or in AVLCI being unable to provide you with effective and continuous products and services.

PURPOSE OF PROCESSING YOUR PERSONAL INFORMATION.

We may process your personal information for the following reasons:

• Enhance your customer experience by delivering products and/or services that match your needs and preferences.
• To provide you information about AVLCI products and services that may be of interest to you.
• To deliver the products or services you have purchased through the website. We may pass your personal information on to a third party to ensure the delivery of the product or service to you (for example to our courier or supplier).
• To compare information and verify with third parties to ensure that the information is accurate.
• To respond to your inquiries and complaints and to resolve disputes.
• To comply with legal obligations, prevent imminent harm to the public, or ensure public security, safety, or order.
• For internal functions such as evaluating the effectiveness of marketing, market research, statistical analysis and modelling, reporting, audit, and risk management; and/or
• Further, we will use the information you provide to administer your account (if any) with us; verify and carry out financial transactions in relation to payments you make online; audit the downloading of data from the website; improve the layout and/or content of the pages of the website and customize them for users; identify visitors on the website; carry out research on our users’ demographics and behavior; provide you with information we think you may find useful or which you have requested from us, including information about our or third party sellers’ products and services, provided you have indicated that you have not objected to being contacted for these purposes.

In addition, we may also use your personal information for the fulfillment of any regulatory requirements, compliance with any legal proceedings such as court orders and for any other reasons connected with providing you the services you require and fulfillment of any commercial transactions entered into by you with AVLCI.

From time to time, we may share your personal information with other entities within the Astoria Group, our agents or subject to your consent, strategic partners with whom we have a relationship with for specific products and services (“Other Entities”) as AVLCI deems fit and you may receive marketing communication from us or from these other entities about products and services that may be of interest to you. If you no longer wish to receive these marketing communications, please notify us to withdraw your consent and we will stop processing and sharing your personal information with these other entities for the purpose of sending you marketing communications.

In sharing your personal information with them, we endeavor to ensure that the third parties and our affiliates keep your personal information secure from unauthorized access, collection, use, disclosure, or similar risks and retain your personal information only for as long as they need your personal information to achieve the abovementioned purposes.

DISCLOSURE OF COLLECTED INFORMATION

• Affiliates and Resorts Partners: We may share Personal Information with our affiliated resort owners and operators in order to provide you with services, facilitate a booking you requested, to facilitate owners’ exchange history and utilization, or to respond to your inquiry for further information about vacations at resorts where a resort tour is either required or requested by the resort owner or operator.
• Service Providers and Vendors: We may disclose your personal information to service providers and vendors we retain in connection with our business such as: travel services, financial and insurance services, property owners’ associations, data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, credit card processing, tax and financial advisers, legal advisers, accountants, auditing services or others.
• Sponsors, Business Partners and Other Third Parties: We may disclose your Personal Information to business partners, co-sponsors of promotions, and other third parties in order to provide you with services that may interest you. Further, we may share your Personal Information with third party providers located on-site at hotels or resorts, such as spa, golf, concierge, and dining providers. If you provide additional information to any of these third parties, such information will be subject to such third parties’ privacy practices.
• Message Boards: We may make reviews, message boards, blogs, and other such user-generated content facilities available to users. Any information disclosed in these areas becomes public information and you should always be careful when deciding to disclose your Personal Information. We are not responsible for privacy practices of other users including website operators to whom you provide information.
• Disclosure Permitted by Law as follows:
  • to comply with a court order, subpoena, search warrant or other legal process
  • to comply with legal, regulatory, or administrative requirements of any governmental authorities
  • to protect and defend the company, its parent, subsidiaries, and affiliates, and all of their officers, directors, employees, attorneys, agents, contractors, and partners, in connection with any legal action, claim or dispute
  • to enforce the terms of our website
  • to prevent imminent physical harm
  • to businesses that we may use for purposes of performing its functions
  • in connection with the sale, assignment, or transfer of any subsidiary or affiliate hotel and resorts or website.
• Except as outlined in this Privacy Policy, we will not sell or trade to third parties any personal information obtained through its website without your consent.

HOW WE COLLECT OTHER DATA

• BROWSING – We collect general information about you or your activities through which you cannot be identified. When you use the Internet, your web browser or client software may transmit certain kinds of information to the servers that host the websites you visit. The information may include the IP address or unique numbers assigned to your server or Internet connection, the capabilities and features of your computer, your geographic location, and your movement within and interaction with the website, including what pages you look at and what information you download. When you visit our website, its servers collect such general information and uses this general information to generate aggregate statistics about visitors to its website. In situations where it is possible to do so, general information may be linked to personal information.
• COOKIES – Our website uses cookie technology. Cookies are identifying pieces of information that are transferred to your computer hard drive by our website. Cookies helps identify you when you access its website. Cookies do not allow to access any personal information about you, but they do allow it to better understand your use of our website so that it may improve its website. Our website uses cookies to provide a unique identifier to your computer so that it can generate statistics about usage of its website, such as the percentage of repeat visitors and other general statistics. The unique identifiers are not matched with any personal information. Cookies do not store any personal information about you. You can configure your browser to allow you to browse the Internet and website without cookies or to notify you when each cookie is offered so that you can accept or reject each cookie. You may not be able to use some services on our website if you disable your browser from accepting cookies.
• PHISHING AND MALWARE – We strive to maintain the highest standards of decency, fairness, and integrity in all its operations. Likewise, it is dedicated to protecting its customers’ and online visitors’ privacy on its website. Browsing website will not result in your computer getting infected by spyware, adware, viruses, or other forms of hostile or intrusive software. We do not phish, harm, or participate in any illicit or identity theft activities.
• GOOGLE ANALYTICS – We use Google Analytics to help us get a better understanding of how visitors use our Website and to facilitate interest-based advertising associated with your Google Account and other devices you use. The information generated by the Google Analytics cookie about your use of our Website is transmitted to and stored by Google.
• MOBILE DEVICE – When you use or access our Services from a mobile device, we may collect information such as your unique device ID and your location. If you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number, as well as any other Personal Information specified by the App in its terms or notices.

CHOOSING TO PROVIDE INFORMATION

Providing personal information is required through our website to be able to provide you with our products and services we offer. You may opt not provide any personal information; however, we cannot guarantee the limits of services offered through our website.

If you submit any personal information in behalf of another person, you represent that you have the authority to provide such information and to permit us to use said personal information in accordance with this Privacy Notice.

SOCIAL MEDIA ACCOUNT LINK

If you sign up for an account using your social media account or use certain other social media features from our site, we may access information about you which you have voluntarily provided under your social media provider in accordance with the provider’s policies and we will manage your personal data which we have collected in accordance with our Privacy Statement.

RETENTION

We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you.
• Whether there is a legal obligation to which we are subject to certain laws that require us to keep records of your transactions for a certain period before we can delete them.
• Whether retention is advisable considering our legal position such as, for statutes of limitations, litigation, or regulatory investigations

REQUEST TO ACCESS, CHANGE, DELETE, RESTRICT THE USE OR OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA

If you would like to request to access, change, delete, restrict the use or object to the processing of your Personal Data that you have previously provided to us, or if you would like to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent these rights are provided to you by law), please complete access form.