III. Types of Data We Collect
We collect information (whether online, by phone, or by paper) that enables HVM to identify or contact you (“Personal Data”) to carry out its business purposes. HVM Strategies, LLC Sites collect this information for a variety of business reasons, including but not limited to, applying for membership, registering for an event or program, purchasing HVM products or services, or otherwise interacting with HVM Strategies, LLC.
The types of Personal Data we collect include, but are not limited to:
General data (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses and mobile/landline business/personal telephone numbers that are provided by our members/customers)
Government-issued identification numbers (e.g., social security numbers, national identification numbers and tax identification numbers), for example from employees and independent contractors, but not from members unless HVM Strategies, LLC assists in obtaining financing or credit inquiries, or applying for credit cards.
Other identification information (e.g., photographs)
Financial information (e.g., credit and debit card numbers, credit reports, passwords and PIN numbers) for product sales or employment purposes
Sensitive Personal Data (e.g., racial or ethnic origin, sexual orientation and disability data) for diversity or accessibility purposes
HVM Strategies, LLC also receives Personal Data from third parties for HVM Strategies, LLC's use in marketing to potential new members, such as lists of new timeshare owners, timeshare club owners, and social media message board leads.
We collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with our Sites (“Non-Personal Data”). The types of Non-Personal Data we collect includes, but is not limited to:
Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site)
Products and services viewed, including advertisements for such products and services
Computer type, operating system and platform type
Internet service provider
Your industry and business (e.g., company size and location, job functions and seniority levels)
IV. How We Use Your Data
In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below, in order to:
Identify you when you visit our Sites
Provide service communications such as bill reminders, order confirmations, program registrations and customer service messages
Provide products, information and services you request or that we think you may be interested in
Respond to your emails or online requests for products, services, or information
Deliver and process surveys
Personalize and improve the usability of the Sites
Fulfill and/or deliver HVM Strategies, LLC products and services
Tailor content, advertising and marketing to you
Publish membership bulletins, membership lists and registration lists on the Sites and in print and digital media to allow lawyers and the public to find you; such directories and lists will not include credit card information or personal identification numbers such as social security numbers, as set forth in the “Contact Information” section below
We use Non-Personal Data to improve the usability of our Sites and for other business reasons. We or other third-party companies also use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). We do not provide Personal Data to third parties with whom we share your Non-Personal Data. Please note that, when you select an advertising link or other link that takes you to sites not operated by HVM Strategies, LLC, you may be subject to the privacy policies of these third-party sites.
V. How We Share Your Data
We share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below:
Share data with third parties to fulfill service requests and to perform business functions
Share data with third parties as required by law or to protect HVM Strategies, LLC in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on HVM Strategies, LLC (b) protect and defend HVM Strategies, LLC's rights or property; or (c) protect the personal safety of HVM Strategies, LLC personnel or members of the public in appropriate circumstances.
Share data with third parties if HVM Strategies, LLC and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if HVM Strategies, LLC undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise; information may be transferred as part of that transaction or change.
Share data with third parties to offer you products and services that may be of interest to you professionally or personally (e.g., membership renewal notices, products and services, business software solutions, or member product discounts). These third parties may include social media sites such as Facebook, LinkedIn, Twitter and others who may contact you with “targeted ads” relating to legal and other services. Users can request their information to be removed from such lists by contacting us, as set forth in the “Contact Information” section below.
Share data with third parties under other unanticipated situations, but only with your consent.
Share your email address, but only as permitted by HVM Strategies, LLC Email Policy, as follows:
Your email address will be used only by HVM Strategies, LLC, its entities and HVM Strategies, LLC's vendors performing member services, or offering products on HVM Strategies, LLC's behalf. HVM does not sell or rent email addresses to anyone outside HVM Strategies, LLC, nor does HVM Strategies, LLC share email addresses to unrelated third-parties, affiliates, or HVM Strategies, LLC members. HVM Strategies, LLC also shares your email address with third parties to enable HVM Strategies, LLC take security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Finally, HVM Strategies, LLC shares email addresses with third parties as necessary to perform certain services on our behalf, such as packaging, mailing and delivering products and processing event registrations and to respond to your service requests.
VI. How You Can Manage the Processing of Your Data
You can manage your profile and email preferences, including “opting out” of email by contacting us using the information in the “Contact Information” section below. If you prefer to receive hard copy mailings only from HVM Strategies, LLC, you can contact us and request to have your name and address removed from the list we provide to third parties. For California residents, please consult the “California Privacy Rights” section for additional considerations.
Our processing of your data is based upon your consent, contract performance (e.g., your purchase of products or membership sign-up/renewal), legitimate business interest (e.g., direct marketing of goods and services), or compliance with law. You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.
VII. California Privacy Rights
VIII. Canada Anti-Spam Law
HVM Strategies, LLC complies with the Canada Anti-Spam Law. Non-HVM Strategies, LLC members or associates who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.
We do not knowingly collect Personal Data from or market to children under the age of 18.
X. How We Protect Personal Data
XI. User ID and Password
Certain areas of the Sites require the use of a user ID, email address, or password as an additional security measure that helps protect your Personal Data. To help you protect your privacy, these Sites have tools to help you log in and log out.
XII. Linking to Other Internet Sites
XIII. How You Can Access, Change and Delete Your Personal Data
XIV. Cookies and Other Web Devices
XV. Transmission of Data to Other Countries
Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data. By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.
XVI. Right to Complain to Supervisory Authority
You, as the data subject, have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of your personal data does not comply with legal requirements.
XVII. Breach Notification
In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law.
XVIII. Contact Information
If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Data, please contact us as indicated below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.
Effective Date: April 24, 2020