PRIVACY NOTICE - August 1, 2020
Hilton Resorts Corporation ("THE COMPANY"),is aware of the importance of the legitimate, controlled and informed processing of its employees and/or job applicants’ personal data. In this sense, THE COMPANY provides the present Privacy Notice, in order to inform you how it obtains, uses, discloses and stores your personal data.
Personal data being collected - The personal data that may be collected during your recruitment and selection process or the employment relationship if hired by THE COMPANY, will belong to the following categories: (i) Identification Data: full name; gender; date of birth; marital status; country, citizenship and nationality; work visas and/or permits to work abroad; Federal Taxpayers Registration; Unique Key Population Registration; Social Security Number; images; fingerprints; identifications with photograph; weight; height; particular characteristics; signature; (ii) Contact Data: address; phone numbers; cellphone numbers; email address; (iii) Employment and Academic Data: curriculum vitae; position; labor references; personal references; information related to previous jobs; information related to level of studies; results of examinations verifying the information you provide to THE COMPANY; employment development; (iv) Data of Third Parties: data from relatives and economical dependents, such as, date of birth, contact information, and other identification and contact data of people to be called in case of emergency.
Additionally THE COMPANY may collect and/or conduct tests to collect Sensitive Data (which will be included when reference is made to “personal data”) which requires special protection such as results of psychometric tests and examinations; results of medical examinations including hearing tests and audiometric tests, blood tests, x-rays, and vision tests; medical, family, criminal, labor and employment history; health data; information regarding if you are a smoker; and your membership in a union; as well as Financial and Economic Data such as salaries, labor benefits and expenses, contributions to savings funds, social security dues; in the event of termination of the labor relationship with THE COMPANY, data related to the full payments and settlements; bank accounts; beneficiaries; results of socio-economic evaluation; other income; credits granted by the National Institute of Workers’ Housing Fund or the National Fund for Workers’ Consumption.
Additionally, THE COMPANY may request you to show original documents and to provide a copy of the same, as evidence of the truthfulness of the information you provide.
Uses and/or purposes of the processing of the personal data - The personal data collected by THE COMPANY may be used in order to fulfill the following necessary purposes: (i) in order to proceed with your recruitment process; (ii) to evaluate your experience, knowledge, aptitudes, fitness, health, and skills with those required for the position for which you are applying; and in case you are hired, (iii) to comply with any legal obligation related to the information provided; (iv) for purposes of job promotion; (v) to provide access to information about the employment relationship with THE COMPANY; (vi) compliance with the policies of THE COMPANY; (vii) to prepare all kinds of reports regarding our employees; (viii) to form and determine the work divisions we have; (ix) to determine job titles; (x) talent management; for the administration of personnel; (xi) for the administration of time and attendance; (xii) for the payment and administration of our payroll; (xiii) for the payment and administration of benefits, withholdings and payment of employer-employee fees, withholding and payment of taxes, benefits, bonuses, reimbursements, pensions, termination payments, insurance and others; (xiv) for contracting insurances; (xv) to develop and maintain THE COMPANY´S directory; (xvi) to create e-mail lists and send internal communications; (xvii) medical examinations for the detection of alcohol or drug use; for biometric interface; (xviii) to perform internal or external investigation processes; (xix) to be exhibited in national or international trial or in any administrative proceeding or of any other nature heard by a competent authority, either national or international, and in general, to comply with legal obligations and for the legal defense of the interests and rights of THE COMPANY, its affiliates, subsidiaries and any individual or legal entity with which THE COMPANY has, had or may have a commercial relationship; (xx) to protect the property and rights of THE COMPANY and of related companies, as well as the confidentiality of information of the mentioned companies; (xxi) to carry out studies, analysis and monitoring, in order to guarantee the security of the workplace and the confidentiality of the information property of THE COMPANY, as well as to prevent and detect crimes. In order to do this, THE COMPANY may carry out random monitoring of the information contained in computers and other company-owned devices or work tools, including the use of the Internet; (xxii) to carry out tests for mergers and acquisitions audits, (xxiii) to contact persons in case of emergency; (xxiv) to carry out employee opinion surveys; (xxv) to carry out relocations; (xxvi) for international mobility; (xxvii) to carry out performance management or annual reviews of development; (xxviii) for internal conference meetings; (xxix) for business travel booking; (xxx) to carry out the termination of the employment relationship and in general, to comply with legal obligations.
Personal data may be used for any purpose related to the recruitment and selection process, and in the event of you being hired, in the initiation, management and termination of your labor relationship with THE COMPANY.
These data may be also used for non-necessary or secondary purposes such as (i) communications (including emails) about THE COMPANY; (ii) to prepare and keep a database for future job opportunities with THE COMPANY and (iii) to provide work references of the employee to prospective employers.
To limit the use of these non-necessary purposes, you may file a written request to Hilton Grand Vacations, Legal Department, Attn: Chief Privacy Officer, 5323 Millenia Lakes Blvd. Ste. 120, Orlando, Fl 32839 or electronically to the email DPOffie@hgv.com, and your written request will be registered in the Exclusion List.
Communications of your personal data - THE COMPANY may share with third parties, domestic or foreign, your personal and/or sensitive data in order to fulfill the purposes described above and in the event we sell or transfer all or a portion of our business or assets, for which national or international transfer of personal data might be required either before, during or after the transaction is made. The third parties to whom THE COMPANY may communicate your personal data may be, for example, other affiliated companies or subsidiaries acting under the same policies and procedures of THE COMPANY, external professional advisers acting in the name and pursuant to the instructions of THE COMPANY, service providers hired to fulfill the purposes described above acting in the name and pursuant to the instructions of THE COMPANY, potential purchasers of the business or assets of THE COMPANY, or insurance companies from which insurance is obtained. Additionally, THE COMPANY may transfer your personal data in case it is necessary for the administration of justice and the recognition of a right in a judicial process.
THE COMPANY commits to transfer only the absolutely and strictly necessary information. When THE COMPANY shares your information with third parties, it will use its best efforts to ensure that these third parties take the necessary measures to protect the confidentiality and security of your personal data. THE COMPANY will require such third parties to comply with applicable privacy laws, THE COMPANY’s policies and its Privacy Policy and will forbid them from using your personal data for other purposes than those for which they were hired.
THE COMPANY shall take reasonable measures in order to ensure that the information shall be protected according to the principles of personal data protection contained in the Federal Law on the Protection of Personal Data in the Possession of Private Parties and its Regulations (the “Law”) and that the individual or entity receiving the data assumes the same obligations of THE COMPANY.
THE COMPANY does not sell, assign or transfer your personal data to third parties with no relation to THE COMPANY, without your previous consent, except as otherwise provided above. However, THE COMPANY may transfer your personal data when said transfer is provided by the Law.
Security measures - THE COMPANY has the administrative, technical and physical security measures it deems appropriate to protect your personal data against damage, loss, alteration, destruction or unauthorized use, access or processing.
Access to your personal data held by THE COMPANY will be limited to individuals who need to access such personal data to carry out the purposes described in this Privacy Notice.
Legal rights of the data subject - As data subject, you may exercise before the Responsible Party for Personal Data Protection at THE COMPANY (“Responsible Party”), as provided below, the rights of access, rectification, cancellation and objection (“ARCO rights”) established by the Law. Also, you may revoke, at any time, the consent granted and needed for the processing of your personal data.
You may submit a request for ARCO rights by contacting via email dpoffice@hgv.com.
Changes to the Privacy Notice - In case there are changes or modifications to this Privacy Notice, the updated version will be made available to you through the COMPANY INTRANET SITE.
Contact - If you have questions or comments regarding the Privacy Notice or if you wish to exercise any of the rights recognized by the Law, please contact the Responsible Party: Hilton Grand Vacations Privacy Team, at the following e-mail address: privacyhgv@hgvc.com, or by mail to Hilton Grand Vacations, Legal Department, ATTN: Chief Privacy Officer, 5323 Millenia Lakes Blvd. Ste. 120, Orlando, FL 32839, USA.
I declare that I have read and understood this Privacy Notice and
I give my consent for the processing of my personal data, including sensitive and financial data for the necessary and non-necessary purposes under the terms provided above.
I give my consent, when needed, for the transfer of my personal data, including sensitive and financial data under the terms provided above.
Also, I acknowledge that I have informed the persons from whom I have provided personal data about the processing to which their data will be subjected and that I have their consent for providing their personal data.
In terms of the Federal Law on the Protection of Personal Data in the Possession of Private Parties and its Regulations, we inform you that in the case of a refusal to respond to an application of ARCO rights, or in the case that you disagree with the response, you may file before the National Institute of Transparency, Access to Information and Personal Data Protection the corresponding Application for the Protection of Rights within the deadlines and terms established by chapter VII and other related chapters, as well as the ones relevant from the Regulations to the Law.
