Applicant Privacy Notice

Facts

Travel + Leisure Co., and its Affiliates ("Company," “we,” “our,” “us”) value your trust and are committed to the responsible collection, management, use and protection of personal information.  

This Applicant Privacy Notice (“Notice”) describes our practices in connection with Processing of personal information (“Personal Information”) that we collect through the Careers section of our websites (“Careers Site”) and offline in connection with your application for a job or internship with us or one of our Affiliates.  Personal Information submitted elsewhere on our and our Affiliates’ web sites will be used in accordance with each website’s online Privacy Notice. 

We are an international business and therefore our Careers Site may be outside the country in which you reside and as a result information protection standards may differ.

All capitalized terms are defined in the Definitions section at the end of this Notice. You can find our contact details in the "Do you have any questions?" section below.

 

Applicable Law

This is a global Notice and we understand that Applicable Law can vary in many jurisdictions.  To the extent that any provision of this Notice is contrary to the laws of a jurisdiction, the laws of that jurisdiction will govern our Processing of your Personal Information. 

For a specific notice for Applicants who are residents of California, please see "California Applicant Privacy Notice and Notice at Collection" below.

 

What Information Do We Collect and From What Sources?

We may collect the following information from you in connection with your application:  

• Name, address, telephone number, e-mail address, and other contact information;
• Username and password for the Careers Site;
• Work authorization status;
• CV, résumé, cover letter, previous work experience and education information;
• Skills and related assessments; 
• Professional and other work-related licenses, permits and certifications held;
• Information relating to references;
• Interview Video and/or audio; and 
• Any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships).

In addition, we may Process Sensitive Personal Information where required or permitted by Applicable Law to do so and we may obtain additional consents for the Processing of such data at the point of collection where we are required to do so.  We ask that you avoid submitting Sensitive Personal Information, except where such information is legally required or specifically requested by us.

 

Data Accuracy

Any information you submit through the Careers Site must be true, complete and not misleading. If you provide us with Personal Information of a reference or any other individual as part of your application, it is your responsibility to obtain consent from that individual prior to providing the information to us.

 

What is the Purpose of Collecting and Legal Basis for Using Your Information?

We may need your Personal Information to comply with legal obligations or, if you are offered employment, as necessary to perform the employment relationship or to take steps prior to entering into an employment relationship and you are therefore required to provide such information to us.  The information that you submit on the Careers Site will be used for our global personnel recruitment, management and planning purposes, as permitted by Applicable Law, including:  

• Process your application;
• To assess your capabilities and qualifications for a job; 
• To conduct reference checks;
• To comply with or monitor compliance with any applicable law or regulation; 
• To conduct background checks if we offer you a position; and
• To comply with reporting obligations.

Where permitted, we are allowed to Process your Personal Information if we can rely on our legitimate interests, including where we:

• Respond to your inquiries and communicate with you about your application, and to send you information regarding the Careers Site and related material about working for us and changes to our terms and policies;
• Analyze responses to job postings, compile statistics;
• Have legal, business and contractual obligations to take steps to prevent threats to us or to our customers; 
• Must retain and access Personal Information for legal or compliance reasons; and/or
• Must protect our own justified business interests and or those of our actual or prospective customers or clients or must Process Personal Information for any such other justified business reasons directly or indirectly related to the reasons set out above.

The information about you will be added to our international candidate database and may be used to consider you for opportunities with us and our Affiliates other than the one(s) for which you apply. If you do not wish us to do this or want to learn more about such continued use, please contact us at mycareer@travelandleisure.com.  

If we hire you, Personal Information we collect in connection with your application may be incorporated into our human resources system and may be used to manage the new-hire process; any such Personal Information may become part of your employee file and may be used for other employment-related purposes. 

 

How Do We Share or Disclose Your Information?

We may disclose, share or otherwise distribute Personal Information to third parties, including but not limited to the following circumstances to the extent we are allowed to do so under Applicable Law (and you can contact us via the "Do you have any questions?" section below for further information):

Legal Requests and Investigations

We may disclose your Personal Information to a law enforcement agency, or by a court order, or under the discovery process in litigation, investigations, and prosecutions or in response to requests from government agencies and/or regulators and/or tax advisers, legal advisers, accountants, financial advisers and/or any other person having appropriate legal authority or justification for receipt of the same.  We may also disclose Personal Information to cooperate with law enforcement agencies or any of the above bodies, including but not limited to matters of national security, criminal charges, civil claims or as may otherwise be permitted by Applicable Law.

Third-Party Service Providers

We may provide Personal Information to vendors and third-party service providers that help us provide, support and maintain our business (e.g., cloud providers operating the Careers Site, recruiting companies and back office service providers).  We may provide the vendors and service providers with Personal Information or the vendors and service providers may collect Personal Information directly from you on our behalf.  You can contact us via the "Do you have any questions?" section below for further information about our third-party service providers. 

Group Companies

We may share your Personal Information with our Affiliates for the use or Processing described in this Notice. You can contact us via the "Do you have any questions?" section below for further information about our Affiliates. 

Business Transfers

If we are involved in a merger, acquisition, spin off, divestiture, reorganization, bankruptcy, receivership, sale of company assets, financing due diligence, or transition of service to another provider, your Personal Information may be shared or transferred as part of such a transaction.

Protection

We may disclose Personal Information when such disclosure is necessary to comply with Applicable Law or to enforce or apply our policies or other agreements; or protect our rights, property or safety and the rights, property and safety of our employees, customers, and/or others.

 

What are My Rights in Relation to My Personal Information?

In accordance with Applicable Law, you may have the following rights (subject to limitations and exemptions under Applicable Law):

Withdrawal of Consent

To Process your Personal Information we may require your consent.  You have the right to decline to provide your consent and/or, if provided, to withdraw your consent at any time with effect for the future. When we are relying on consent to process your data we will make this clear at the point of collection e.g. if we are collecting Sensitive Personal Information. 

Access

The right to access the Personal Information we Process about you.

Right to Rectification

You have the right to request that any inaccurate or incomplete Personal Information held by us or on our behalf is corrected.  It is your responsibility to ensure that you submit true, accurate and complete information to us.

Right to Erasure and to Restrict Processing

Under certain grounds you may have the right to request that we delete Personal Information that we hold about you or to restrict us from Processing. 

Right to Data Portability

You may have the right to receive your Personal Information in a format that would enable you to transmit such Personal Information to another company or to direct us to transfer directly to another company.

Right to Object to Processing

You may have the right to request that we stop Processing your Personal Information and/or stop sending you communications about other opportunities at with us and our Affiliates.  We will assess your request and determine, under Applicable Law, whether we have any justification for the continued Processing.

Please contact us via the "Do you have any questions?" section below if you want to exercise any of these rights where available under Applicable Law.

 

Security

We will take reasonable and appropriate technical and organizational measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.  

 

How Long Do We Keep Your Personal Information?

We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required or permitted by Applicable Law.    If you have any questions about our retention periods you can contact us at the below email address. 

 

Do You Have Any Questions?

If you have any questions or concerns about this Notice or would like to exercise your rights in relation to your Personal Information, you can contact us at tandlprivacy@wyn.com. 

If you have a complaint or concern about how we are Processing your Personal Information then we will endeavor to address such concern(s).  In addition, you may have the right to direct your complaint/concerns to a data protection authority.

 

Updates to This Notice and New Uses of Your Personal Information

From time to time we may revise this Notice and/or use Personal Information for new, unanticipated Processing purposes not previously disclosed in this Notice.  We will make the revised version available to you and bring any material changes to your attention.  Unless otherwise provided or required by Applicable Law (e.g., obtaining consent from you for the relevant material changes), the revised Notice will take effect immediately upon such posting. 

 

Aggregate Data

We may anonymize your Personal Information so that it does not in any way identify you as an individual. 

 

Cookies

Our Services may use “cookies” and similar technologies (collectively, “cookies”). See the Privacy Notice located on our home page for further details about our cookie usage.  

 

Definitions

“Affiliate” means any current, former or successor company, corporation, limited liability company, partnership, firm, association, business or organization who is or was directly or indirectly controlled, is or was controlled by or is or was under common control with us.

“Applicable Law” means any applicable regulation, statute, rule or contractual requirement (to the extent they form part of a contract between us and you or contain legal obligations). 

“Personal Information” means any information that, either by itself or in combination with other pieces of information, identifies, or can be used to identify, an individual or relates to an identifiable individual or as otherwise defined under Applicable Law.  

“Process” means the collection, use, sharing, retention, disclosure or otherwise processing of Personal Information.  

“Sensitive Data” may include information on: race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; sexual life or orientation; criminal record; health data; genetic or biometric data or as otherwise defined under Applicable Law.

 

California Applicant Privacy Notice and Notice at Collection

Purpose of This Notice

This California Applicant Privacy Notice and Notice at Collection (the “Notice”) describes our collection and use of certain personal information relating to external job applicants and candidates for positions with Company and who are California residents. (”Applicants”).  This Notice describes our collection and use of certain personal information that we collect about Applicants and is intended to satisfy our applicable notice requirements under the California Consumer Privacy Act (“CCPA”), as amended (“CPRA”).  We may provide Applicants additional notices about our data collection practices that are covered by other laws (e.g., if we conduct a background check or extend an employment offer).  

 

Scope of This Notice

This Notice applies to the personal information that we collect from and about Applicants, in the context of reviewing, assessing, considering, managing, storing or processing their applications or otherwise considering them for a position with Travel + Leisure Co.., or its Affiliates ("Company," "we," "our," "us").         

 

What is Personal Information?

In this Notice, “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.  

 

What Isn't Covered by This Notice

This Notice does not address or apply to our collection of personal information that is not subject to the CCPA, as Amended, such as protected health information (or "PHI"), consumer credit reports and background checks, publicly available data lawfully made available from state or federal government records, or other information that is exempt under the CCPA, as Amended.  This Notice also does not apply to the personal information we collect from employees (which is subject to a separate privacy notice), or the personal information that we collect from customers or end users of Company’s products and services, including Applicants, in the context of their personal use of Company products and services. In such cases, see the applicable consumer privacy notice.

 

Are Our Practices the Same for All Applicants?

The categories of personal information we collect and our use of personal information may vary depending upon the position(s) or location, as well as the associated qualifications and responsibilities.  The information in this Notice is intended to provide an overall description of our collection and use of personal information about Applicants.   

 

Categories of Personal Information Collected

Generally, we may collect the following categories of personal information (as set forth in the CCPA, as Amended) about Applicants:

• Name, Contact Info and other Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, birthday or date of birth, Social Security number, driver’s license number, passport number, or other similar identifiers.     
  
  
• Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)): paper and electronic customer records containing personal information, such as name, signature, birthday or date of birth, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
  
  
• Protected Classifications: characteristics of protected classifications under California or federal law such as race, color, sex, sexual orientation, gender identity, age, religion, national origin, disability, citizenship status, and genetic information.
  
  
• Purchase History and Tendencies: commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  
  
• Biometric Information: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including imagery of the iris, retina, fingerprint, faceprint, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
  
  
• Usage Data: internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any company device, network or other information resource.
• Geolocation Data: precise geographic location information about a particular individual or device.
  
  
• Audio/Visual Data: audio, electronic, visual, thermal, olfactory, or similar information such as, CCTV images and photographs, and audio and/or video recordings (e.g., recorded meetings, webinars and interview videos).
  
  
• Employment History: professional or employment-related information.
  
  
• Education Information: information about education history or background that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
  
  
• Sensitive Personal Information: Social security, driver’s license, state ID, or passport number; racial or ethnic origin; union membership; biometric information; personal information concerning health, sex life, or sexual orientation. 
• Profiles and Inferences: inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

 

Purposes for Collecting and Using Personal Information

Generally, we may use the above categories of personal information for the following purposes:

• Management of Job Applications, Recruiting and Hiring. To review, assess, recruit, consider or otherwise manage applicants, candidates and job applications, including:
  • Scheduling and conducting interviews
  • Identifying candidates, including by working with external recruiters
  • Reviewing, assessing and verifying information provided, to conduct criminal and  background checks, and to otherwise screen or evaluate Applicants’ qualifications, suitability and relevant characteristics
  • Extending offers, negotiating the terms of offers, and assessing salary and compensation matters
  • Satisfying legal and regulatory obligations
  • Communicating with Applicants regarding their applications and about other similar position(s) for which they may be interested
  • Maintaining Applicant personal information for future consideration
  • In support of our equal opportunity employment policy and practices
    
    
• Security and Monitoring. In order to monitor and secure our resources, network, premises and assets, including: 
  • Monitoring for, preventing and investigating suspected or alleged misconduct or violations of work rules
  • Monitoring for, preventing investigating, and responding to security and privacy incidents
  • Providing and managing access to physical and technical access controls
  • Monitoring activities, access and use to ensure the security and functioning of our systems and assets
  • Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring
     
• Auditing, reporting corporate governance, and internal operations. Relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.
  
  
• M&A and Other Business Transactions. For purposes of planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.  
  
  
• Defending and Protecting Rights. In order to protect and defend our rights and interests and those of third parties, including to manage and respond to employee and other legal disputes, to respond to legal claims or disputes, and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.
  
  
• Compliance with Applicable Legal Obligations. Relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance. 

 

Rights to Know Your Information

Right to Know

As a California consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure, or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following: 

• The categories of Personal Information that we have collected on you.
• The categories of sources from which the Personal Information is collected
• Our business or commercial purpose for collection, use or disclosure of that Personal Information.
• The categories of third parties with whom we sell or share that Personal Information. 

Right to Data Portability

You have the right to request a copy of Personal Information collected and maintained about you in the past 12 months. The CCPA allows you to request this information from us up to twice during a 12-month period. We will provide our response in a readily useable (in most cases, electronic) format. 

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records unless an exception applies. For example, we may deny your deletion request if retention of the Personal Information is: 

• Necessary to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; 
• Reasonable anticipated within the context of your employment or application for employment with us; 
• For solely internal uses that are reasonable aligned with your expectations based on  your relationship with us; 
• Necessary to comply with a legal obligation; or 
• Otherwise necessary for internal use in a lawful manner that is compatible with the context in which you provided the Personal Information.

Right to Correct

You have the right to request the correction of any Personal Information we maintain about you. 

Right to Limit the Use or Disclosure of Sensitive Personal Information

You have the right to limit the use or disclosure of your Sensitive Personal Information (“SPI”) if we are using your SPI beyond what is reasonable and proportionate within the context of your relationship with us as an employee of job applicant. You can make a request for us to limit the use or disclosure of your SPI by emailing us at TandLprivacy@wyn.com. 

Right to Nondiscrimination

You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. 

 

Exercising Your Rights

To exercise your rights described above, please submit a request by filling out and submitting the following forms:

Opt-Out Form: https://prod.respondselfserve.com/aca369877fa948399916431966375bb4/a2623cebabf44e13a45cb41ddb20e2f1/index.html

Access/Delete Form:  https://prod.respondselfserve.com/aca369877fa948399916431966375bb4/221f7bc5717344fa85cc67ef148ec8fb/index.html

or by contacting us at 1-800-914-8253 or TandLprivacy@wyn.com.

After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. 

When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request. 

Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. If you are making a request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf. 

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. We may contact you within 45 days from the date you contacted us to inform you if we need more time to respond. 

 

Contacting Us About This Notice

If you have any questions or concerns regarding our use of personal information as described in this Notice, please contact TandLprivacy@wyn.com.

 

Effective Date: April 13, 2018

We reserve the right to modify, add or remove portions of this notice at any time. If we decide to change this notice, we will post the updated Notice.

Last Updated Date: December 30, 2022 (Revised for California Applicant Privacy Notice)