Hilton Grand Vacations
Applicant Privacy Notice
Last Updated: August 2019
Hilton Grand Vacations (“HGV”) values your trust and is committed to the responsible management, use and protection of personal information. This Applicant Privacy Notice (this “Notice”) applies to all the information collected by HGV to facilitate your job application and includes your use of our careers site.
Any questions or concerns about the collection, use, disclosure, retention or other Processing of Personal Information, or about this Policy, should be directed to the HGV Chief Privacy Officer at firstname.lastname@example.org.
The Careers Site is operated by HGV, 5323 Millenia Lakes Blvd. Ste. 400, Orlando, FL 32839, in order to support the recruitment functions of HGV. The Careers Site is not intended for distribution or use in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.
Please read this Notice carefully and indicate your acceptance of our collection, retention, use, transfer and disclosure of personal information as described in this Notice by clicking the “I Accept” button at the end of this Notice. For applicants residing in the European Economic Area (EEA) or Switzerland, refer to additional provisions in Appendix A before providing your express consent to HGV’s collection, handling, maintenance, and transfer of your personal data. If you do not accept the terms you will not be allowed access to apply for a position online and we may be otherwise unable to process your application. By agreeing to this Notice, you agree to the transfer of personal information about you to countries outside your home country, including countries where data protection laws may differ from those of your home country.
HGV maintains safeguards designed to protect your personal information.
To the extent the personal information you provide contains details of your: racial or ethnic origin; physical or mental health or condition; job evaluations or educational records; commission (or alleged commission) of an offence or related proceedings; political opinions or beliefs; religious beliefs; sexual orientation; membership in a trade union or political party, you expressly authorize HGV to handle such details for the purposes of your job application.
Information You Provide
This Notice covers any personal information you submit to apply or search for a position at HGV, which may include:
• Name and contact information;
• Log-in and password, for users of the Careers Site;
• CV, résumé, cover letter, previous work experience and education information;
• Employment preferences, willingness to relocate, current salary and desired salary;
• Professional and other work-related licenses, permits and certifications held;
• Language and other relevant skills;
• Awards and professional memberships; and
• Eligibility to work in country where job applied for is located and available start date.
We do not require, but you may also voluntarily choose to provide, other relevant information as part of your application. We would prefer that you avoid submitting the following sensitive information, except where such information is legally required or needed for us to comply with our legal obligations and internal policies relating to diversity and anti-discrimination: sexual orientation, race, ethnic origin, religion, beliefs, disability, marital status, creed, nationality, national origin, color and/or age.
Any information you submit must be true, complete, not misleading and you must have the lawful right to provide it. If not, this may lead to a rejection of your application during the application process or disciplinary action including immediate dismissal if you have been employed.
If you intend to provide us with details of a reference or any other third party as part of your CV/résumé, it is your responsibility to obtain consent from that third party prior to passing the personal information to us.
The provision of personal information, including on the Careers Site, is voluntary. Please note however that the failure to provide sufficient information may result in HGV being unable to consider you for employment, promotion, transfer or relocation.
Use of Personal Information
The information that you submit in your application on the Careers Site will be stored in the United States (and in the relevant jurisdiction(s) if the job relates to one of our affiliated entities outside of the United States). It will be collected, used, transferred and disclosed by employees, consultants and/or service providers of HGV around the world for HGV’s global recruitment functions and for related management and planning purposes, including, as permitted by local law, to:
• Process your application;
• Assess your capabilities and qualifications for a job;
• Provide to you any services available on the Careers Site from time to time;
• Communicate with you;
• Comply with any applicable law or regulation;
• Monitor and record services whether provided by a HGV company or a third party; and
• Conduct background checks if you are offered a job.
Personal information about you will be added to HGV’s international candidate database and will be used for the purposes of considering whether your profile is suitable for other job vacancies at HGV. If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. If you become a Team Member, any personal information that you submit may become part of your Team Member file and may be used for other employment/work-related purposes.
Disclosure of Personal Information
Personal information about you will be reviewed by HGV Team Members or agents who have a business need to access such personal information and may include recruiters, human resources personnel, technical services personnel and managers or their designees. HGV is the party responsible for management of the personal information that is jointly used.
We may share personal information about you with selected service providers or consultants acting on our behalf, such as third parties assisting HGV with the operation of the Careers Site (including Taleo at 4140 Dublin Boulevard, Suite 400, Dublin, CA 94568 USA, which hosts the Careers Site, and SHL at 1 Atwell Place, Thames Ditton, Surrey, KT7 0NE UK, which conducts job-specific candidate assessments). Those third parties will be required to use appropriate measures to protect the confidentiality and security of personal information.
HGV also may disclose personal information about you in order to:
1. Protect the legal rights, privacy, safety or property of HGV or its Team Members, agents, contractors, customers or the public;
2. Protect the safety and security of visitors to our web sites or other properties;
3. Protect against fraud or other illegal activity or for risk management purposes;
4. Respond to inquiries or requests from legal authorities;
5. Permit HGV to pursue available remedies or limit the damages that we may sustain;
6. Enforce our website Terms of Service;
7. Respond to an emergency;
8. Comply with the law or legal process;
9. Effect a license, sale or transfer of a business or assets (including in connection with any bankruptcy or similar proceedings);
10. Manage acquisitions, mergers and re-organizations
We are required to retain information relating to candidates applying for jobs within the United States. Personal information of candidates applying for jobs in other parts of the world will be retained in accordance with local law. If there is no activity in relation to the personal information, HGV may remove it from its database, subject to HGV’s data retention obligations and policies and any applicable legal or regulatory obligations or for the period of time permitted by local laws, for the purpose of considering whether your skills are suitable for other opportunities.
Note that HGV may delete personal information about you at any time (including your CV/résumé), without any reason. Therefore, please retain your own copy of the personal information provided to us.
Passive Information Collection: Cookies and Similar Technology
Access and Correction
If you choose to register on the site, you may access, review, and change some of the personal information collected about you and stored on the Careers Site by logging into the Careers Site and choosing to update your account information. The updated profile will be used as the default the next time you apply for a job using your account online. To change personal information that you already have submitted for consideration for a specific position, please resubmit your application to update personal information about you that is associated with that job application. We encourage you to promptly update your personal information if it changes or is inaccurate. Upon your request, we will deactivate or remove your personal information from our active databases, although some information may be retained as permitted or required by law.
If you have any questions or concerns about how we otherwise process personal information please contact us at the e-mail link below.
You may access, modify or object to the use of personal information as permitted by applicable local law. Please contact us at the e-mail link below with any such requests. Please note that certain personal information may be exempt from such access, correction, or objection rights pursuant to local data protection laws.
Careers Site Security
We take reasonable precautions to safeguard the personal information transmitted between visitors and the Careers Site and the personal information stored on our servers.
Unfortunately, no method of transmitting or storing data can be guaranteed to be 100% secure. Do not send sensitive information via email. It is your sole responsibility to use the appropriate level of care whenever communicating with us.
If you have reason to believe that your interaction with us is no longer secure (for example, you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us at the link below.
HGV hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliated companies and contractors for any of your information sent to our Careers Site and which is lost, misused, illegally accessed, disclosed, altered or destroyed or not integrally or timely delivered to our Careers Site.
Links to Other Websites
The Careers Site may contain links to other websites. The operators of those other websites may collect information about you, through cookies or other technologies. If you link to another website, you will leave the Careers Site and this Notice will not apply to your use of and activity on those other sites.
Links on the Careers Site to other websites are provided only as a convenience, and the inclusion of such links does not imply endorsement of the linked site. We encourage you to read the legal notice posted on those sites, including their privacy policies. We have no responsibility or liability for your visits to, or the data collection or use practices of, other sites.
Law Applicable to Job Application
The Careers Site allows you to benefit from HGV’s centralized global recruitment function, while applying for jobs world-wide. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the U.S. and will be subject to U.S. laws. However, if we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Notice. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.
The Careers Site is not intended for minors under the age of 15 or the lawful age of employment (whichever is greater) in any country in which we operate.
Changes to the Notice
We reserve the right to amend this Notice at any time without advance notice in order to address future developments of HGV, the Careers Site or changes in industry or legal trends. We will post the revised Notice on the Careers Site or announce the change on the home page of the Careers Site. You can determine when the Notice was revised by referring to the “Last Updated” legend on the top of this Notice. Any changes will become effective upon the posting of the revised Notice on the Careers Site. By continuing to use the Careers Site following such changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Notice, in whole or part, you can choose to not continue to use the Careers Site.
ADDITIONAL PROVISIONS APPLICABLE TO PROCESSING OF
PERSONAL INFORMATION OF EEA RESIDENTS
Introduction and Scope
For Applicants residing in the EEA (“Data Subjects”), this Appendix A outlines certain additional information that Hilton Grand Vacations, Inc. (“HGV”) is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal data, pursuant to applicable local laws.
Contact Details, Representative and Data Protection Office
The responsible data controller for any personal data collected and processed in connection with your HGV employment application is Hilton Grand Vacations Inc. If you have any questions with this Privacy Notice or would like to complain about our handling of your personal data or exercise any of your rights, please contact us by email at DPOffice@hgv.com or mail to:
Ordinary mail: Hilton Grand Vacations, Inc.
6355 Metrowest Blvd.
Orlando, FL 32835, USA
ATTN: Data Protection Office
Categories of Data, Purposes of the Processing and Legal Basis
We process the following personal data we collect from you or from third parties (e.g., public resources) in connection with your employment application as detailed in the following:
|Purpose of the Processing
||Categories of Personal Data
||Legal Basis for the Process
|HGV’s global recruitment functions and for related management and planning purposes, including, as permitted by local law, to: Process your application; Assess your capabilities and qualifications for a job; Provide to you any services available on the Careers Site from time to time; Communicate with you; Comply with any applicable law or regulation; Monitor and record services whether provided by a HGV company or a third party; and Conduct background checks if you are offered a job.
||Name and contact information; Log-in and password, for users of the Careers Site; CV, résumé, cover letter, previous work experience and education information; Employment preferences, willingness to relocate, current salary and desired salary; Professional and other work-related licenses, permits and certifications held; Language and other relevant skills; Awards and professional memberships; and Eligibility to work in country where job applied for is located and available start date.
||Required for the performance of a contract (Art. 6 (1) (b) GDPR), Compliance with a legal obligation (Art. 6(1) (c) GDPR, and legitimate interests (Art. 6 (1) (f) GDPR).
|Compliance with legal obligations, resolving disputes, and enforcement of our agreements;
||Name, title and address; Personal contact information (phone, email, fax, etc.); Login information such as login name and password; Service requests and orders placed; User profile information (for registered users); Service requests and orders placed
||Legitimate interests (Art. 6 (1) (f) GDPR) and compliance with a legal obligation (Art. 6 (1) (c) GDPR).
You may choose not to provide certain types of personal data to us, unless the provision of personal data is required for the performance of a contract you conclude with us. By not providing certain types of personal data, our ability to provide you/your ability to make use of, the services may be affected.
Recipients and Categories of Recipients
Any access to your personal data at HGV is restricted to those individuals that have a need to know in order to fulfill their job responsibilities. HGV will transfer your personal data for the respective purposes to the recipients and categories of recipients listed below, if and to the extent permitted or required by law:
HGV Team Members or agents who have a business need to access such personal information and may include recruiters, human resources personnel, technical services personnel and managers or their designees.
We may share personal data about you with selected service providers or consultants acting on our behalf, such as third parties assisting HGV with the operation of the Careers Site (including Taleo at 4140 Dublin Boulevard, Suite 400, Dublin, CA 94568 USA, which hosts the Careers Site, and SHL at 1 Atwell Place, Thames Ditton, Surrey, KT7 0NE UK, which conducts job-specific candidate assessments). Those third parties will be required to use appropriate measures to protect the confidentiality and security of personal data.
Governmental authorities, courts, external advisors, and similar third parties that are public bodies as required or permitted by applicable law, in order to: (i) ensure compliance with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of HGV, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.
Cross-Border Data Transfer
Some of the recipients of your personal data will be located or may have relevant operations outside of your country and the EU, where the data protection laws may provide a different level of protection compared to the laws in your jurisdiction and with regard to which an adequacy decision by the European Commission does not exist. Recipients in the US may be certified under the EU-U.S. Privacy Shield and thereby recognized as providing an adequate level of data protection from a European data protection law perspective.
We may also provide adequate level of data protection by other means. By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC) as referred to in Art. 46 (5) GDPR or other adequate means, we have established that all other recipients located outside the EEA will provide an adequate level of protection for the Personal Data and that appropriate technical and organizational security measures are in place to protect Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by applicable law.
Your personal data is stored by HGV and/or our service providers, strictly to the extent necessary for the performance of our obligations and strictly for the time necessary to achieve the purposes for which the personal data is collected, in accordance with applicable data protection laws. In addition, if a judicial or disciplinary action is initiated, the personal data may be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
If you have declared your consent for any personal data procssing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal. Under the conditions set out under applicable law, you have the following rights (which might be limited under the applicable national data protection law):
a) Right of access: You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, to request access to the personal data. You have the right to obtain a copy of the personal data undergoing processing. For additional copies requested by you, we may charge a reasonable fee based on administrative costs.
b) Right to rectification: You have the right of rectification of your inaccurate personal data. Depending on the purposes of the processing, you have the right to have incomplete personal data completed.
c) Right to erasure (right to be forgotten): You have the right to ask us to erase your personal data.
d) Right to restriction of processing: You have the right to request the restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
e) Right to data portability: You have the right to receive the personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit those personal data to another entity without hindrance from us.
f) Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data by us. If you have a right to object and you exercise this right, your personal data will no longer be processed for such purposes by us. Such a right to object may not exist, in particular, if the processing of your personal data is necessary to take steps prior to entering into a contract or to perform a contract already concluded.