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Privacy Policy

Last updated:
September 18, 2026

This Privacy Policy explains how Vacancy Rewards collects, uses, discloses, and protects personal information when you visit our website, communicate with us, or use our services. It also describes the choices available to you.

1. Who We Are

This Privacy Policy is issued by Distribution Systems International LLC, a Florida limited liability company doing business as Vacancy Rewards ("VR," "Company," "we," "us," or "our"), with a registered address at 80 SW 8th Street Suite 2000, Miami, FL 33130. VR is the data controller (in the U.S. sense) and the "responsable" (in the LFPDPPP sense) for personal data collected through vacancyrewards.com, our member portal, and related services (collectively, the "Services").

This Policy applies to prospective members, enrolled members, website visitors, and B2B partner-referred consumers across the United States, Mexico, and other markets where VR operates.

2. Scope

  • This Policy covers personal data collected through VR's website(s), virtual sales sessions, managed intake and scheduling, VR Backoffice, digital executed membership documents, and related member communications.
  • It applies regardless of whether you become a paying member, remain a prospect, or interact with VR only as a B2B partner's referred consumer.
  • It applies to individuals located in the United States, Mexico, and all other countries where VR markets or provides services.

3. Information We Collect

3.1 Information You Provide Directly

  • Identifiers: full name, mailing address, email address, phone number, government-issued ID information where required for identity verification.
  • Membership and account information: tier program, enrollment date, renewal status, travel preferences, household/companion information you choose to provide.
  • Payment information: billing name and address, and payment method details, processed directly by our payment processors (Stripe and, where financing is selected, other third-party processors). VR does not store full payment card or bank account numbers on its own systems.
  • Communications: records of calls, texts, WhatsApp messages, emails, and virtual session participation, where applicable and permitted by law.
  • Signature and contract data: information captured through cloud-based electronic signature at the point of membership execution.

Minor and Dependent Traveler Information. When an adult customer makes or manages a reservation that includes a minor or dependent traveler, we may collect personal information about that traveler as provided by the adult customer — for example, name, date of birth, gender, nationality, and passport or other travel-document information reasonably required to process, confirm, administer, or service the reservation.

We collect this information from the adult customer or another authorized person managing the reservation, rather than directly from the minor, and we use and disclose it only as reasonably necessary to facilitate the requested travel arrangements, comply with applicable legal or regulatory requirements, and provide related customer support — which may include sharing it with airlines, hotels, cruise lines, tour operators, reservation systems, and other parties involved in fulfilling the reservation.

3.2 Information Collected Automatically

  • Device and usage data: IP address, browser type, device identifiers, pages viewed, referring URLs, and interaction data collected via cookies and similar technologies (see Section 7).

3.3 Information From Third Parties

  • B2B partners (resorts, HOAs, developers) that refer or transfer consumer leads to VR under a data-sharing arrangement with that partner.
  • Our tour-operator and travel-fulfillment partners (e.g., certificate-issuing partners) in connection with redemption of travel benefits.
  • Service providers described in Section 5, to the extent they return data to us (e.g., delivery/read confirmations from SMS or email providers).

4. How We Use Your Information

We use personal data for the following purposes. Consistent with LFPDPPP requirements, purposes marked Primary are necessary to the relationship and the existence of the Service; purposes marked Secondary are not necessary and you may opt out of them without affecting your membership (see Section 14.5).

  • Primary To evaluate membership eligibility, process enrollment, and execute membership agreements.
  • Primary To process payments and, where selected, coordinate installment or third-party financing.
  • Primary To administer your membership, including renewals, travel bookings, redemptions, and customer support.
  • Primary To verify identity and prevent fraud, including verifying enrollment status where applicable.
  • Primary To comply with legal, tax, accounting, and regulatory obligations.
  • Secondary To send marketing communications about new offers, referral programs (e.g., Friends & Family), or partner promotions.
  • Secondary To conduct analytics, session recording review for sales-quality purposes, and product improvement.
  • Secondary To personalize your experience on the website and during sales sessions.

5. How We Share Information

VR does not sell personal data to third parties for their own independent marketing use. We share personal data as follows:

  • Service providers acting on our behalf, including payment and financing processing, CRM, scheduling, marketing communications, contract execution, cloud-based electronic signature, and SMS/WhatsApp/other messaging delivery.
  • B2B partners, where you were referred to VR by a resort, HOA, or developer partner, to the extent necessary to administer the referral relationship and your membership.
  • Travel fulfillment and tour-operator partners, to process bookings, certificates, and redemptions.
  • Professional advisors (legal, accounting, auditors) under confidentiality obligations.
  • Regulators, law enforcement, or other parties where required by law, subpoena, or valid legal process, or to protect the rights, property, or safety of VR, our members, or others.
  • A successor entity in connection with a merger, acquisition, financing, or sale of all or substantially all of VR's assets, subject to this Policy or a materially similar successor policy.

Each service provider is contractually restricted to using personal data only to perform services for VR and is prohibited from using it for the provider's own independent purposes.

6. Cross-Border Data Transfers

VR operates across many countries, and personal data may be transferred between them (and by service providers located elsewhere, including the United States). VR requires that any party receiving personal data under a transfer maintain protections consistent with this Policy and applicable law.

7. Cookies and Tracking Technologies

VR's website uses cookies and similar technologies to operate the site, remember preferences, and measure performance and marketing effectiveness.

  • Strictly necessary cookies, required for the site to function.
  • Analytics cookies, used to understand site usage.
  • Marketing/advertising cookies, used to measure and deliver advertising.

You can control cookies through your browser settings.

8. SMS, WhatsApp, and Telephone Communications

By providing your phone number and opting in, you consent to receive text messages (including via WhatsApp) and calls from VR and our service providers related to your membership, scheduled sessions, and — where you separately opt in — marketing. Message and data rates may apply. You may opt out of marketing texts at any time by replying STOP, and you may opt out of marketing calls by requesting removal; marketing opt-outs do not stop non-marketing communications that are permitted by law and necessary to administer an existing transaction or account, or operational messages necessary to service your membership or a scheduled session. Consent to receive marketing texts is never a condition of purchasing a membership, consistent with the TCPA and this Policy.

9. Email Marketing

Marketing emails from VR include a functional unsubscribe mechanism in every message, consistent with the CAN-SPAM Act. Opting out of marketing email does not affect transactional or account-related emails necessary to service your membership.

10. Data Retention

VR retains personal data for as long as needed to provide the Services, comply with legal and tax obligations, resolve disputes, and enforce agreements. After that period, we delete or de-identify the data.

11. Payment, Financing, and Renewal Disclosures

Where you select in-house installment payments or third-party financing, your payment information is collected and processed under the applicable Payment Plan Addendum and the financing provider's own privacy terms. Annual renewal is presented and confirmed through a stand-alone disclosure and consent, separate from your initial payment. Automatic-renewal terms, billing frequency, cancellation procedure, and the required consent are presented separately during enrollment. This Privacy Policy does not create or modify those billing terms.

12. Data Security

VR uses administrative, technical, and physical safeguards designed to protect personal data, including relying on PCI-DSS-compliant processors for payment data. No method of transmission or storage is completely secure, and VR cannot guarantee absolute security.

13. Your Privacy Rights — United States

13.1 General Rights

Depending on where you live, applicable law may provide you with certain rights concerning your personal information. Vacancy Rewards currently does not believe that it is subject to the California Consumer Privacy Act or similar comprehensive state privacy laws whose applicability thresholds it does not meet. Nevertheless, subject to reasonable verification and applicable exceptions, you may contact us to request access to, correction of, or deletion of personal information that we maintain about you. These voluntary practices do not constitute a representation that any particular state privacy statute applies to Vacancy Rewards.

13.2 Children's and Minors' Information

Our Services are intended for use by adults and are not directed to children under 13. We do not knowingly collect personal information directly from children under 13 through our website or Services.

We may, however, collect personal information concerning minors when that information is provided by a parent, legal guardian, or other adult in connection with a travel reservation, booking, membership benefit, or related service — for example, a minor traveler's name, date of birth, gender, passport or other travel-document information, or other information required to complete the requested travel arrangement.

We use information concerning minors only as reasonably necessary to process, administer, service, or support the applicable reservation or travel arrangement, to comply with legal or regulatory requirements, or for other purposes disclosed at the time of collection. Where necessary to provide the requested travel services, we may disclose such information to airlines, hotels, cruise lines, tour operators, reservation systems, travel-service providers, governmental or regulatory authorities, and other parties involved in processing or fulfilling the applicable reservation.

We do not knowingly use personal information concerning minors for independent marketing or advertising directed to the minor. If we become aware that personal information has been submitted directly to us by a child under 13 rather than by a parent, legal guardian, or other authorized adult, we will take reasonable steps to address the information in accordance with applicable law.

14. Aviso de Privacidad Integral — Mexico (LFPDPPP)

This Section is intended to provide the integral privacy-notice information required by Article 15 of Mexico's Federal Law on Protection of Personal Data Held by Private Parties.

14.1 Identity and Address of the Responsable

Distribution Systems International LLC (d/b/a Vacancy Rewards), domiciled at 80 SW 8th Street Suite 2000, Miami, FL 33130, is responsible ("responsable") for the collection and use of your personal data.

14.2 Personal Data Collected

As described in Section 3: identification data (name, address, email, phone, and, where required, government ID data), financial/billing data limited to that necessary to process payment through our processors, membership and transaction data, and, if provided by you, travel-companion or household data. VR does not intentionally collect sensitive personal data (as defined by LFPDPPP Article 3, Section VI) through the Services and asks that you not submit such data unless specifically requested.

14.3 Primary Purposes (Necessary to the Relationship)

The purposes marked "(Primary)" in Section 4 are the primary purposes for which your data is required; VR cannot provide the Services without processing data for these purposes.

14.4 Secondary Purposes (Not Necessary to the Relationship)

The purposes marked "(Secondary)" in Section 4 are secondary purposes. You may deny or revoke consent to secondary purposes without affecting your ability to receive the Services, by using the mechanism in Section 14.5 or contacting us at privacy@vacancyrewards.com. If you do not express a denial through this mechanism within the period stated at the point of collection, VR will understand your consent to be granted for secondary purposes, consistent with Article 8 LFPDPPP.

14.5 Mechanism to Limit Use or Disclosure

You may limit the use or disclosure of your data by:

  • Contacting VR directly at privacy@vacancyrewards.com; and
  • Registering with Mexico's Public Registry to Avoid Advertising (Registro Público para Evitar Publicidad, "REPEP"), administered by PROFECO, to limit receipt of commercial advertising.

14.6 ARCO Rights (Access, Rectification, Cancellation, Opposition)

You have the right to:

  • Access the personal data VR holds about you and the details of its processing (Acceso);
  • Request correction of inaccurate or incomplete data (Rectificación);
  • Request deletion of your data where VR is not legally required to retain it (Cancelación); and
  • Object to processing of your data for specific purposes (Oposición).

You may also revoke your consent to processing at any time.

To exercise ARCO rights, submit a request to privacy@vacancyrewards.com including: (a) your full name and contact information; (b) documents proving your identity or, where applicable, your legal representative's authority; (c) a clear description of the personal data and the right(s) you wish to exercise; and (d) any supporting documentation. VR will respond within 20 business days of receipt, as required by LFPDPPP Article 31, and, if the request is granted, will implement it within 15 business days thereafter.

14.7 Transfers of Data

Your data may be transferred as described in Sections 5 and 6 to VR's service providers and, in the case of B2B-referred consumers, to the referring partner, for the purposes described in this Policy. These transfers do not require your consent to the extent they fall within the exceptions of LFPDPPP Article 36 (e.g., transfers necessary for the relationship's performance, or to service providers acting under contract on VR's behalf).

14.8 Use of Cookies and Tracking Technologies

See Section 7. VR's website uses cookies and similar technologies, and Mexican data subjects may control these through the mechanisms described there.

14.9 Procedure for Notice of Changes

Any changes to this Aviso de Privacidad will be published at vacancyrewards.com/privacy-policy, with the "Last Updated" date revised accordingly. For material changes, VR will provide additional notice as described in Section 16.

15. Contact Us

For any question about this Policy, or to exercise the rights described above:

Distribution Systems International LLC d/b/a Vacancy Rewards

Address80 SW 8th Street Suite 2000, Miami, FL 33130

16. Changes to This Policy

VR may update this Policy from time to time. We will post the revised Policy with an updated "Last Updated" date, and, for material changes affecting how we use previously collected data, we will provide additional notice (such as email or an in-portal notice) before the change takes effect.