Revised: August 2006

Introduction and Changes to the Privacy Policy

This policy statement (the “Privacy Policy” or “Policy”) sets out the privacy policies and practices for Trendwest Resorts Canada, Inc., and its subsidiaries and affiliates (including, but not limited to, Trendwest Resorts, Inc.; WorldMark, The Club; Fairfield Resorts, Inc., and Wyndham Vacation Ownership, Inc.) (collectively, “Organization”) with respect to the collection, use, and disclosure of Personal Information collected in Canada. Additional privacy policies and practices may apply to specific divisions of the Organization.

Organization reserves the right to modify this Policy at any time and will provide reasonable notice of the revised Policy, specifically by posting at Organization’s Web site at www.trendwest.com/legal/policy-canada. This Policy may be supplemented or modified by agreements or communications entered into between Organization and an individual from time to time. Each individual accessing this Web site or any Web site linked to or document referencing this Policy (“you” or “User”) is responsible for reviewing this Policy each time the individual accesses the applicable Web site or reviews or completes a document referencing this Policy to check for updates to this Policy.

In this Policy, “Personal Information” means any information about an identifiable individual, as further defined under applicable Canadian laws.

BY SUBMITTING PERSONAL INFORMATION TO ORGANIZATION OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. Please be advised that if you exercise your right to withdraw your consent to certain permitted uses of your Personal Information, Organization may not be able to provide you with certain services or information which may be of value to you. By providing Organization or our service providers or agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such individual to enable us to collect, use and disclose such information for the purposes set forth in this Privacy Policy or any documents linked to or referencing this Privacy Policy. (Please see “Consent” section herein for further information.)

This is our Privacy Policy for Canada online and offline. This Policy is applicable to Personal Information that you provide to the Organization in Canada and that is maintained by Organization in Canada or in the United States. This Policy does not apply to Personal Information you provide to the Organization when you are outside of Canada. For our U.S. Online Privacy Policy, click here.

Table of Contents

Privacy Officer Collection and Purposes Consent Limits to the Collection of Personal Information Use, Disclosure, and Retention Accuracy Security Openness Individual Access Challenging Compliance Additional Provisions Related to Your Online Experience

Privacy Officer

The Privacy Officer is responsible for ensuring Organization’s compliance with this Policy. If you have any questions regarding this Policy or regarding Organization’s use of Personal Information, please contact our Privacy Officer:

By mail:   Privacy Officer/Legal
Trendwest Resorts Canada, Inc.
8427 SouthPark Circle
Orlando, Florida 32819

By email: privacy@trendwest.com

Collection and Purposes

Except where otherwise required or permitted by law, Organization will, prior to collecting, using or disclosing an individual's Personal Information, inform individuals of the purposes for the collection, use, or disclosure of the Personal Information.

Organization collects information about individuals through various means, including directly from individuals and from other sources that represent that they have the right to disclose the information or as otherwise permitted by law. The type of information collected will vary depending on the means through which a customer submits his or her Personal Information. The type of information collected may include contact information (such as name, residential address, e-mail address or home phone number), financial information (such as bank account or credit card numbers), demographic information (such as age, occupation or income level) and other information that is used by Organization to provide services (such as your WorldMark Credit balance and usage history). For security reasons, Organization may also utilize video or other surveillance means to monitor its premises from time to time.

Organization uses information collected from individuals to: (a) establish and maintain a responsible business relationship; (b) better understand customer needs and preferences; (c) develop market opportunities or provide products and services; (d) meet legal and regulatory requirements; and (e) satisfy additional purposes that may be identified at or before the time that the information is collected.

Consent

Requirements for consent to collection, use, or disclosure of Personal Information vary depending on the circumstances and on the type of Personal Information that is intended to be collected, used, or disclosed. In determining whether consent is required and, if so, which form of consent is appropriate, Organization will take into account both the sensitivity of the Personal Information at issue and the purposes for which Organization will use the information. Consent may be express, implied (including through use of “opt-out” consent where appropriate), or deemed. For example, if an individual provides his or her mailing address and requests information regarding a particular product, consent to use the address to mail product information to the individual is implied.

On giving reasonable written notice to Organization, an individual may withdraw consent to the collection, use, or disclosure of his or her Personal Information. However, your withdrawal of consent may limit your ability to access certain products or services. Except where otherwise required or permitted by law, Organization will then stop collecting, using or disclosing the individual's Personal Information.

Limits to the Collection of Personal Information

Except where required or permitted by law, Organization will limit the collection of Personal Information to that which is reasonably necessary to fulfill the purposes for which it is collected. Personal Information will be collected by fair and lawful means.

Use, Disclosure, and Retention

Except with the consent of the individual or as required or permitted by law, Organization will use or disclose Personal Information to other parties, including to affiliated and non-affiliated parties within and outside of Canada, only as is reasonably required to provide products, services, or information to individuals. For example, Organization may disclose mailing information to a shipping service provider in order to ship products to the individual or may provide order information to a financial institution in order to process payment for products or services. Organization will take appropriate steps to ensure that such recipients safeguard the Personal Information and use the information only for authorized purposes. Organization may also disclose Personal Information to insurers or to legal, financial, and other professional advisors or in connection with the sale or reorganization of all or part of its business or operations.

Unless otherwise prohibited by law or our contractual obligations, we may disclose Personal Information if required to do so by law, court order, or as requested by a governmental or law enforcement authority, or in the good faith belief that disclosure is otherwise necessary or advisable. Situations may include: to perform, maintain or enforce contracts with our customers, to protect the rights or properties of our business affiliates, our customers or others, or when we have reason to believe that disclosing the Personal Information is necessary to identify, contact or bring legal action against someone who may be causing or who may be threatening to cause interference with or damage to our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

Once Personal Information is no longer required to fulfill its intended purposes, and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed, erased, or made anonymous.

Accuracy

Organization will make reasonable efforts to ensure that any Personal Information collected by it, or on its behalf, is accurate and complete, particularly where the Personal Information is likely to be used by Organization to make a decision that affects the individual to whom the Personal Information relates or if the information is likely to be disclosed to a third party.

Upon written request, an individual may request Organization to correct an error or omission in the Personal Information that is under Organization's control. If Organization is satisfied on reasonable grounds that a correction should be made, Organization will amend the information as requested as soon as reasonably possible, and it will send the corrected information to each organization to which it has disclosed that information during the year prior to the date of correction.

Security

Organization will protect Personal Information with security safeguards appropriate to the sensitivity of the information. Security safeguards are employed to protect Personal Information against loss, theft, and unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. The nature of the safeguards will vary depending on the sensitivity of the Personal Information, and may include physical security measures and technological measures.

Organization will inform employees about Organization's policies and procedures for protecting Personal Information and employees will be required to comply with this Policy.

Openness

Upon request, Organization will make information available about its Personal Information policies and practices and about its complaint process.

Individual Access

Upon written request, with sufficient detail to enable Organization to confirm the identity of the individual and to identify the Personal Information being sought, Organization will inform an individual of the existence, use, and disclosure of his or her Personal Information that is under Organization's control and will, unless otherwise prohibited or permitted by law, provide the individual with access to such information. Organization will respond to all requests within 30 days. Organization may extend the time limit with the Privacy Commissioner’s permission or as otherwise permitted by law. Organization may charge a fee for access to the individual’s Personal Information.

Challenging Compliance

An individual may direct a complaint concerning compliance with this Policy to Organization’s Privacy Officer, and the complaint must be in writing.

Within a reasonable time of receipt of the complaint, the Privacy Officer will conduct an investigation into the complaint. The format of the investigation will vary depending on the circumstances and may or may not involve an interview of the complainant or Organization employees conducted by the Privacy Officer.

Within a reasonable time of conclusion of the investigation, the Privacy Officer will inform the complainant, either verbally or in writing, that the complaint is either: (a) denied (if, in the Privacy Officer’s reasonable opinion, it has no merit) or (b) allowed (if, in the Privacy Officer’s reasonable opinion, the complaint is valid).

If the Privacy Officer allows the complaint, Organization will take appropriate measures to correct its Personal Information practices.

Additional Provisions Related to Your Online Experience

Usage Tracking

Use of Internet Protocol (“IP”) Addresses: An IP address is a unique number that is automatically assigned to your computer whenever you're surfing the Internet so that your computer can be identified by the main computers, known as “Web servers,” that “serve up” Web pages.

Brands collect IP addresses for the purposes of system administration, to report aggregated information to our advertisers, and to audit the use of our site. When Customers request pages from our Web sites, our servers log the Customers’ IP addresses. We do not normally link IP addresses to anything personally identifiable, which means that a Customer's session will be logged, but the Customer will remain anonymous to us. However, this Web site may offer a “live chat” feature that will allow you to communicate almost instantly with a Brand representative. If this Web site offers a live chat feature and if you access that feature, we may link your Personal Information (e.g., name, address, email address) with the IP address to provide you with the appropriate services, including, but not limited to, answering questions regarding your account. We can and will use IP addresses to identify a Customer when we feel it is necessary to enforce compliance with our site terms of use or terms of service or to protect our service, site, customers or others.

Use of Cookies: We may place a “cookie” on your web browser. A cookie is a very small text file that a Web site sends to your computer for record-keeping purposes, which information is stored in a file on your computer. Cookies make Web-surfing easier for you by saving your preferences so that we can use the saved information to facilitate your use of our Web site when you return to the site. Cookies do not tell us your individual identity unless you have chosen to provide it to us. We never save passwords or credit card information in cookies. The use of cookies is an industry standard, and as such, you’ll find that most major Web sites use them.

By showing how and when Customers use a site, cookies help us see which areas are popular and which are not. Many improvements and updates to the site are based on such data as total number of visitors and pages viewed. This information is most easily tracked with cookies. We use the information from cookies to provide services better tailored to our Customers’ needs.

Most cookies expire after a defined period of time, or you can delete your cookie file at any time. Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or indicate when a cookie is being sent. However, note that some parts of our web sites and/or our Affiliates’ services will not function properly or may be considerably slower if you refuse cookies. For example, without cookies, you will not be able to set personalized preferences, and/or may have difficulty completing marketing transactions.

We may use a third party advertising technology to serve ads when you visit our Web site. This technology uses information about your visits to this site (not including your name, address, or other personal information) to serve our ads to you. In the course of delivering our advertisements to you, a unique third party cookie may be placed or recognized on your browser. You may occasionally get cookies from our advertisers. Neither our Affiliates nor we control these cookies. The use of advertising cookies sent by third-party servers is standard in the Internet industry. If you do not want to activate these third party cookies, do not click on the advertising.

We may also provide Web site usage information about visitors to our Web site to a reputable third-party servicer for the purpose of targeting our Internet banner advertisements on this site and other sites. To do this, we would use Web beacons and cookies provided by our third-party ad server on this site. The information we collect and provide through this technology is not personally identifiable and would be used by this ad server only for this purpose.