Shell Vacations LLC Canadian Privacy Notice
May 2008

WE RESPECT YOUR PRIVACY: Shell Vacations LLC and its affiliates and subsidiaries (collectively “SVC”) consider your privacy important. As further described herein, we use security safeguards and support the principles set forth in Canadian federal and provincial privacy legislation to protect your personal information. To better protect your privacy and personal information, SVC is providing you with this notice regarding our information-handling practices and the choices you have about the way your personal information is collected, used and shared. SVC is committed to providing you with the finest vacation ownership and vacation club membership products backed consistently by first class service. We fully recognize the importance of keeping personal and account information secure when we collect information about you that is necessary to provide our products and services. To further allow us to offer you products and services that may interest you and best meet your needs, whether they are available directly from SVC or through our relationships with other companies, SVC may, subject to applicable privacy laws, share information about you both within SVC and its affiliated companies and with non-affiliated companies.

INFORMATION SVC COLLECTS: SVC may collect and use certain nonpublic personal information (“NPI”) about you to conduct our business and to consistently deliver the high-quality service you can expect from us. Sources of this information include the following: (1) Information we receive from you on applications and other forms or through your correspondence or communication with us, including through the mail, by telephone, facsimile or over the Internet. This information may include, but is not limited to, your name, address and e-mail address; your credit card information; medical or health information (e.g., personal preferences such as smoking needs and disability requirements); and other information related to the service(s) you request; (2) Information we receive from third parties (located within or outside of Canada), such as consumer credit and other reporting agencies, to verify statements you have made to us, regarding your employment, credit, or other information; and (3) Information about your transactions with SVC and with other companies unaffiliated with SVC.

COOKIES:  We use "cookies" on this website. A cookie is a piece of data stored on a site visitor's hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any personally identifiable information on our site.

THIRD-PARTY LINKS:  This website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

THE WAY WE USE INFORMATION: The information you provide about yourself when accepting an offer to tour SVC properties, applying for credit through SVC, making reservations, utilizing resort services or Member benefits, or purchasing SVC points and products is used by SVC to offer you the widest range of products and services, as well as to service your membership or relationship with SVC. We do not share this information with non-affiliated third parties except to the extent necessary to evaluate creditworthiness, register the transaction, make a reservation, service loan accounts, fulfill an exchange, Point & Play™ , SVCLifeStyles, SVC Collections, SVC Elite® or SVC Premium Perks request, contact you regarding future SVC offers, or as otherwise indicated in this notice, or in compliance with applicable laws. We use return email addresses to answer the email we receive and to communicate special offers with SVC Owners, Members, employees or SVC-affiliated website subscribers. Such addresses are not used for any other purpose and are not shared with unaffiliated outside parties. We use non-identifying and aggregate information to better design our website and to share with advertisers. For example, we may tell an advertiser that a certain number of individuals visited a certain area on our website or purchased a particular product, but we would not disclose anything that could be used to identify those individuals. Finally, we do not use or share the personally identifiable information provided to us in ways unrelated to those described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses..

SVC SECURITY PROCEDURES: SVC understands and appreciates the importance of protecting and securing NPI and using it appropriately. We maintain physical, electronic, and procedural safeguards that comply with applicable federal or provincial standards for the security of information. These security procedures are tested and monitored on a regular basis in order to make certain all security procedures are being followed. Access to information about you is restricted to the representatives of SVC who require it to provide products or services to you. If we no longer need to retain your information, we will dispose of it in a secure manner. When SVC shares information about you with non-affiliated companies outside of SVC, we require that they impose similar safeguards, use it only for a permitted purpose, and to return it to us or destroy it once that purpose is served. SVC requires a non-affiliated company receiving information from SVC to sign an agreement containing confidentiality requirements and obligating that company to protect the information. Although the trans-border flow of information is subject to the Canadian Personal Information Protection and Electronic Documents Act, as well as the laws of the receiving country, the data protection regulations and other laws of other countries may not provide the same protection as those in Canada do.

INFORMATION WE SHARE WITHIN SVC AND AFFILIATES: We may share the personal nonpublic information we collect about you with other affiliated companies within SVC to offer additional products or services that may interest you and best meet your needs. To do so, we share identification information (such as name, address phone, fax or e-mail), transaction and experience information (such as purchases and payments), credit eligibility information (such as credit reports and applications), and other similar information. The decision to purchase any such products or services is yours alone. In the event that SVC merges with or is acquired by another legal entity, you should expect that we may share some or all of the data and information collected from you with such other entity; provided, that such other entity will be notified of the practices which apply to personal information under our applicable privacy policies and/or practices.

INFORMATION WE SHARE WITH OTHERS: SVC does not share NPI with third parties for third-party direct marketing purposes. We may disclose certain NPI about you to the following types of third parties for the purposes of SVC-related offers or activities: (1) Financial services providers, such as mortgage bankers, securities broker-dealers, insurance agents and companies and credit card companies; (2) Franchisees and their affiliated and subsidiary companies; (3) Non-financial companies, such as retailers, direct marketers (in conjunction with marketing affiliations and joint marketing efforts) manufacturers, service companies, communications companies, travel agencies, airlines, cruise lines, rental car companies, hotels and publishers; and (3) Others, such as non-profit organizations. We may also disclose nonpublic personal information about you to nonaffiliated third parties as permitted or required by law, including, but not limited to, in accordance with applicable Canadian laws, providing personal information to consumer reporting agencies in the course of determining financial status.  We may also disclose all of the information we collect as described above to companies that perform marketing services on our behalf or to other financial institutions with whom we have marketing or similar agreements.

PRIVACY POLICY NOTICE AND UPDATES: SVC will provide notices to you about our privacy policy as long as you maintain a customer relationship with us. If there are any changes to this policy, which may occur from time to time, SVC will provide you with notice of those changes and you will be permitted to change your privacy preferences as long as you remain our customer.

HOW YOU CAN CORRECT YOUR INFORMATION: You can correct factual errors in your personally identifiable information by sending us a request that shows the error and correction. To protect your privacy and security, we will also take reasonable steps to verify your identity before making corrections. PLEASE NOTE THAT REQUESTS TO CHANGE PERSONALLY IDENTIFIABLE INFORMATION MUST BE MADE IN WRITING TO THE FOLLOWING ADDRESS:

Shell Vacations LLC
Attn:  Privacy Officer
40 Skokie Blvd., Suite 350
Northbrook, IL  60062  USA

Should you wish further information concerning your privacy rights in Canada, please visit the website of the Office of the Privacy Commissioner of Canada at: www.privcom.gc.ca  or call them toll free at 1-800-282-1376.