Revised 5/24/2018

ONLINE PRIVACY POLICY

Breckenridge Grand Vacations (“BGV”) is committed to protecting the privacy of our online visitors. This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website. This document sets forth the online privacy policy of Breckenridge Grand Vacations, its subsidiaries and affiliates (collectively “BGV”) for users of www.breckenridgegrandvacations.com, www.bgvconfirmations.comwww.sharebreck.com, www.bgvfriendsandfamily.com, www.goldpoint.com, www.grandtimber.com, www.grandlodgeonpeak7.com, www.gl7owners.com and www.breckenridgediscountlodging.com (the “Site” or “Sites”).

IF YOU HAVE OBJECTIONS TO THE PRIVACY POLICY, YOU SHOULD NOT USE THIS SITE. THIS PRIVACY POLICY DOES NOT GOVERN PRIVACY PRACTICES ASSOCIATED WITH OFFLINE ACTIVITIES.

Information Usage and Sharing

BGV values your patronage and respects your right to privacy. Because we are committed to protecting your privacy, personal data relating to an identified or identifiable individual that is submitted through our web page will be collected, processed, stored, and disposed of in accordance with applicable federal law of the United States and the laws of the State of Colorado that may apply. The submission of personal data constitutes the user’s acknowledgement that he/she has read and understood this notice and agrees to its terms. In order to facilitate the purchase of goods online or to update visitors of new products or services, BGV may share certain individual information with its partners, related or affiliated companies or third parties. BGV will act on the advice of counsel should its records be subpoenaed. In connection with any contest or promotion, BGV reserves the right to post all information regarding contest and promotion winners that may be legally required or as is otherwise disclosed in the contest rules. We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or utilize certain other site features.

GDPR

In compliance with General Data Protection Regulations as of 5/25/2018; for inquiries regarding your personal data or to have your personal data expunged from our systems you may contact our data controller at customerservice@breckenridgegrandvacations.com. Our data controller is represented as Breckenridge Grand Vacations the company. We do utilize the personal information collected in automated communications including but not limited to email, phone and SMS contact. Personal information is not mandatory to be collected however important communications may be compromised without the collection of personal information. Communications including but not limited to marketing communications, product updates, lodging confirmations, lodging notifications, preview tour confirmations, preview tour updates. The aforementioned communications are the reason for collecting and processing personal information. Personal information is not transferred internationally. Our family of websites utilize Google Analytics which uses cookies to track and analyze how visitors use our websites. Our usage of Google analytics maintains the end website users anonymity and the GA policy in full can be read below in the Google Analytics clause.

Security

BGV takes your information security very seriously. As such, we have generally accepted security measures in place to protect against the loss or misuse of any electronic information we may collect. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your personal information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

 Revised 5/24/2018

Information Collection

In a few areas on our Site, we ask you to provide information that will enable us to enhance your site visit, process your request correctly, and if necessary, follow up with you before or after your visit. Owners of BGV properties may, at their choice, provide personal account information online to maintain updated personal contact or preference information.

From time to time we may ask questions, or we may use data collected for order processing, to better understand our customers’ preferences. This information allows us to improve our services, and to offer you specially tailored deals when appropriate. We will request information from you when you:

  1. Plan a trip to Breckenridge.
  2. Place a request with a BGV property.
  3. Provide feedback in an online survey.
  4. Participate in a sweepstakes or other promotional offer.
  5. Subscribe to a newsletter or a mailing list.

If you don’t want to receive promotional material or special offers from us, we ask that you opt out where indicated. Please note that in the case of newsletters or mailing lists, you will be able to “unsubscribe” to these mailings at any time.

Information Use

Certain information obtained by BGV will be used for different purposes. Some personal information is required to process your request. We may also use the personal account information to generate statistics and aggregate reports for internal use. Aggregate information may be used to design programs and promotions that we think would be of interest to an identified group of customers. In addition, we may use the detailed profiles to target special offers and promotions more effectively.

This Site does not collect personally identifiable information from your computer when you browse and request pages from our servers. This means that, unless you voluntarily and knowingly provide us with personally identifiable information, we will not know your name, your email address, or any other personally identifiable information.

BGV may collect non-personal information from our online visitors, such as the visitor’s type of browser, page hits, the number of visits, web pages viewed, operating system and domain names, and may use cookies to obtain other non-personal information. Cookies are pieces of data sent from a web server to a web browser that enables a web server to identify users that visit a site hosted by that server. Our Sites may use cookies in order to identify you to our Site so that we can provide more customized information and services to you. In general, if you choose, you can disable the use of cookies by reviewing your browser’s performance and options. The non-personal information we collect enables us to track the total number of visitors to each of our sites in an aggregate form and may be used by BGV to improve and update our sites, products and services. Aggregate (nonpersonal) information may be shared with third parties. By using the Sites, you grant BGV a

perpetual, irrevocable, worldwide, royalty-free, sub-licensable (through multiple users) license to use, reproduce, store, modify, publicly perform, publicly display, distribute and transmit such nonpersonal information for any purpose, and waive any moral rights and publicity rights in such nonpersonal information. BGV does not tie this non-personal information to your personal information.

Revised 5/24/2018

 THIRD PARTY ACCESS TO INFORMATION 

Access and use by third party service providers

From time to time, BGV enters into arrangements with companies whose expertise is essential for our own services to function properly. For example, in accordance with standard industry practice, and as allowed under federal and state law, we work with specialized firms that service our loans, provide escrow services, process collections or provide certain owner demographics. As permitted by law, we disclose to these service providers only such nonpublic personal information of the type described above as is reasonably necessary to perform these functions. As with all of our business partners, these companies are required to safeguard your information and use it only for authorized purposes.

Access and use by joint marketing partners

 BGV enters into joint marketing arrangements with carefully selected business partners to provide our owners with specialized products and services. Although these partners are not owned by or affiliated with BGV, they work closely with us to meet your needs. If appropriate, we may disclose to these marketing partners the nonpublic personal information about you described above; however, we do not share your account number, owner number, contract number, social security number, any access codes or credit information with nonaffiliated third parties. Our partners must agree to safeguard fully the confidentiality of owner information, and they are not allowed to disclose such information to anyone else without our permission.

Access by other nonaffiliated third-party companies

We may, in the future, share your nonpublic personal information with nonaffiliated third-party companies other than those described above. You may choose not to have your information disclosed to these companies (see opt out instructions below).

BGV reserves the right to cooperate with local, provincial, federal, and international officials in any investigation requiring either personal information (including any information provided on-line through any of the BGV Sites noted above) or reports about lawful of unlawful user activity on this site. BGV also reserves the right to disclose any information in an individual’s account to satisfy any law, regulation, or government request or protect the rights or property of Gold Point Lodging and Realty, Inc. or Peak 7, LLC.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. Google AdWords policy. We use Google AdSense Advertising on our website. Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

  • Remarketing with Google AdSense
  • Google Analytics

Revised on 5/24/2018

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify you via email

  • Within 7 business days

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute noncompliance by data processors.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out penalties for violations.

We collect your email address in order to:

  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to the following:

  • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at:

mktgadmin@breckgv.com

Revised 5/24/2018

  • As well as follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

Children’s Privacy

BGV does not knowingly solicit data from, or about, people under the age of 25 years for the purposes of selling directly to these individuals. Note: BGV assumes that visitors to our site are adults. We do not require any visitor to provide date of birth at registration, though we do ask for an age when applicable for enter-to-win promotions. U.S. federal law prohibits discrimination in public accommodations based on age, so when we send out information on lodging bookings we are required to treat all site members equally, regardless of age. We will send real estate offers only to customers 21 years old and older.

Other Sites

This Site and the other Sites contain links to select third party sites that may be of interest to you (e.g., events, mortgage servicers). BGV is only responsible for the privacy statement and content of this Site and affiliated Sites. We are not responsible for the privacy practices or the use of cookies on non-BGV Sites that you have accessed prior to or after visiting this Site.

Policy Changes

As our web sites grow and new features are added, or as legal requirements change, our online privacy policy may be modified. All information submitted to BGV is subject to the terms and conditions of this policy and any modifications. If you have any questions about our online privacy statement, the practices of our web site, or your dealings with our web site, please contact us at Breckenridge Grand Vacations, PO Box 6879, Breckenridge, Colorado 80424.

Legal Liability

Under no circumstances, including, but not limited to, negligence, shall BGV be liable for any direct, indirect, special, incidental or consequential damages, including, but not limited to, loss of data or profit, arising out of the use, or the inability to use, the materials on this site, even if BGV has been advised of the possibility of such damages.

Who we are

Our website address is: https://infinityspagrandcolorado.com.

What personal data we collect and why we collect it

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Analytics

Who we share your data with

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.

Your contact information

Additional information

How we protect your data

What data breach procedures we have in place

What third parties we receive data from

What automated decision making and/or profiling we do with user data

Industry regulatory disclosure requirements