Privacy Policy

Last Update: November 30, 2022

  1. Scope

Vientos del Caribe Private Members Club & Resort ("Vientos del Caribe", “Club”, "ClubVDC", “Service”, “we”, “us” and “our”) takes the issue of safeguarding your privacy seriously. Our Privacy Policy (the “Policy”) describes what information we collect from or receive about hotel guests, Club Members, prospective Club Members, renters and exchange guests (collectively referred to as “Guests and Members”) as well as visitors to Vientos del Caribe websites that post, refer or are otherwise subject to this Policy, and mobile App users, and the way in which Vientos del Caribe uses this information to better serve your needs.

This Policy has been adopted by all of the distinct legal entities that manage and operate Vientos del Caribe. Those entities include Vientos del Caribe Private Members Club & Hotel, C.A., Vientos del Caribe Private Members Club & Resort, LLC and its direct and indirect subsidiaries and affiliates, and all of the separate and distinct legal entities that manage Vientos del Caribe. References to “we”, “us”, “our” and “Vientos del Caribe” throughout this Policy, depending on the context, refer collectively to those separate and distinct legal entities.

We reserve the right to change this Policy at any time at our sole discretion. The effective date of the last update is at the top of this page, so visit it occasionally to see if there are any changes. 

  1. Collection of User Data

Personal information is any information that may identify or relate to you as an identifiable individual. The personal information that we collect or receive about you could include the following categories of information:

    1. Identity information – such as name, age, gender, passport information or data from government-issued identity cards or from your accounts created on our websites;
    2. Contact information – such as your home address, zip/postal code, email address and phone number;
    3. Images – such as CCTV images, publicly available photographs and images captured at events or during your stay;
    4. Financial and payment information – such as your credit card details, itemized spending, billing address, and transaction history;
    5. Reservation information – such as the type and location of the rooms you reserve and the dates of your reservations;
    6. Health information – where disclosed and relevant to the provision of services;
    7. Preference information – such as special requests, service issues and other preferences for your stay;
    8. Purchase history – details of your purchases on our websites, including on the Club VDC Online Shop, and delivery address;
    9. Public information – such as when we review public platforms to understand what you are saying about us or the hospitality industry;
    10. Technical information – such as information about the device you use to interact with us (including the unique device identifier, hardware model, IP address, geolocation, operating system and version, and mobile network information and unique device identifiers, in the case of our mobile App); and
    11. Correspondence information – when you contact us, such as to send an enquiry or make a request, any correspondence or application may be kept and added to your personal information.
  1. Use of Data

We use the collected data for the following purposes:

    1. To provide the services and/or information that you have asked for.
    2. To respond to a court order, regulatory request or legal process.
    3. To enforce our rights, carry out our obligations, prevent fraud, facilitate disputes between users.
    4. To accomplish any other purpose for which the information was provided.
  1. Disclosure of Data

In addition to sharing your data as described above, we may disclose the collected personal information as follows:

    1. To other Vientos del Caribe managed properties (including Members Club properties);
    2. Vientos del Caribe Private Memvers Club Sales Specialists.
    3. To agents, contractors or third party service providers of Vientos del Caribe who provide services to Vientos del Caribe or on our behalf, including as needed to better serve your needs as a website visitor, mobile App user, Guest or Owner.
    4. To escrow agents, third party lenders and loan-servicing agents.
    5. In case there is a sale, merger or other transfer in the ownership of our Service, the successor will receive personal information about our Service users along with the assets transferred.
    6. To our contractors, business partners, third party service providers and other entities or individuals who provide support for our Service. For example, integration and API partners.
    7. our professional advisors and auditors; and local or foreign regulators, governments, courts, law enforcement and national security authorities.
    8. If we decide that disclosure is appropriate to protect the property, safety, rights of the Service, its users or the public.
    9. Aggregated, anonymized information that does not identify any particular user can be disclosed without restriction.
  1. How Is Personal Information Affected by Business Transactions And/or Transfers?

Vientos del Caribe manages properties solely owned by Vientos del Caribe. Vientos del Caribe may disclose certain Guest or Member information as needed to implement business transactions between the property and a particular Guest or Member. All other personal information is considered to be proprietary to Vientos del Caribe, and is not shared. If we cease to manage or own a particular property, guest information required to process pending reservations and information that is historically shared with the property owner is retained by the property owner. All other personal information remains with Vientos del Caribe.

  1. Cookie Policy

Cookies are small bits of text data placed on your device when you visit sites. Cookies record data about your activity, such as which pages you view and what you click on. Cookies assist our Service to recognize your device when you return. For example, cookies can help us to remember your preferences, username, analyze the performance of our Service and recommend content that may be most relevant to your interests.

Here are the reasons we may use cookies:

    1. Analytics. This type of cookies shows us which pages users view, which links are popular, etc. These cookies only provide anonymized information that does not identify anybody personally. This information is then bundled with the similar information from the other users, so that we can analyze the general usage patterns.
    2. Essential cookies. These are necessary to provide the services that you have asked for. Without these essential cookies, our Service would not be able to operate. They are necessary to enable users to navigate through the Service and use its main features. E.g., essential cookies identify registered users so that they can access member-only areas of the site. Essential cookies keep users logged in. If a subscriber disables essential cookies, that subscriber won’t be able to get to all of the content that a subscription entitles them to. These cookies don't collect information that could be utilized for the purposes of marketing or figuring out what places on the internet you have visited.
    3. To improve your browsing experience. This type of cookies enables the site to remember users’ preferences and settings, such as geographic region or language. They can also be used to restrict the number of times an ad is shown, to remember which forms you have already filled in, so that you don’t have to do it again.
    4. To implement tracking technology on our Service. This tracking does not use your personal information; it uses deidentified data (i.e., data that cannot be tied specifically to you). We will not combine this data with your other personal information without your prior express permission.

There is a way to turn off cookies by going to your browser’s Help or Settings menu. However, keep in mind that disabling cookies may limit your use of the Service and/or delay or affect the way in which it operates.

  1. Data Security

Only our administrators are allowed to access our Service’s password-protected server where your personal information is stored.  We utilize SSL. However, any transmission of information over the Internet has its inherent risks, so we cannot guarantee the absolute security of your personal information. Transmit personal information over the Internet at your own risk. We shall not be liable for circumvention of security measures or privacy settings on the Service. It is your responsibility to keep your login credentials, if any, confidential.

  1. Children’s Privacy

We do not knowingly collect any personal information about children under the age of 13. Our Service is not directed to children under the age of 13. If we become aware that a child under 13 has provided any personal info, it will be erased from our database as soon as reasonably possible, except when we need to keep that information for legal purposes or to notify a parent or guardian. However, portions of this data may remain in back-up archives or web logs even after we erase it from our databases. If a parent or guardian believes that a child has sent us personal information, send us an e-mail.

  1. Users’ Rights, CCPA
    1. We will not share your personal information with third parties for their direct marketing purposes to the extent it is forbidden by law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance. California law requires that operators of online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the online service that a user visits, indicating that the user does not wish to be tracked. At this time we do not respond to Do Not Track signal. 
    2. You can request disclosure of your information collected by us by writing to the email at the end of this Policy. We will then provide the requested information, its sources and purposes of use, in a portable and easily accessible format within 45 days of the request.
    3. You have the right to request deletion of your personal information from our systems by submitting a request to the email at the end of this Policy.
    4. You have the right to nondiscrimination for exercising your rights. That means you cannot be denied goods or services, charged different prices, or provided different quality of goods/services for asserting your legal rights.
  1. Right to Decline Marketing Communications

If you do not wish to receive marketing communications from Vientos del Caribe, you may indicate your wishes on your registration card when you stay with us or send an e-mail to: You will always have the ability to accept or decline any form of communication from Vientos del Caribe. You may unsubscribe from electronic marketing communications at any time by selecting the “unsubscribe” link included in such communications. Please note that you may not be able to opt out of service-related communications (e.g., account verification, transactional communications, technical and security and notices).

  1. International Transfer

We process your personal information in the Unites States and Venezuela.  This is where it can be transferred in case you are located somewhere else. By submitting any personal information to us, you agree to its transfer to and processing in the aforementioned jurisdictions.

  1. EU Users’ Rights

This section of our Privacy Policy applies to the users of our Service in the European Union. We would like to inform you about your GDPR rights and how we safeguard them.

    1. Your GDPR rights to be informed, to access, rectify, erase or restrict the processing of your personal information. You have the right to obtain free information about what personal data we have obtained about you, where it is stored, for how long, for what purposes it is used, to whom it was disclosed. You have the right to have us, without undue delay, rectify of inaccurate personal data concerning you. That means you can request we change your personal data in our records, or have your incomplete personal data completed. You have the “right to be forgotten,” i.e. to have us delete your personal information, without undue delay, if the data is no longer necessary in relation to the purposes for which it was collected. However, GDPR gives us the right to refuse erasure if we can demonstrate compelling legitimate grounds for keeping your information.
    2. GDPR gives you the right to restrict processing if any of the following applies:
      1. If you contest the accuracy of your personal data, we will restrict processing it for a period enabling us to verify its accuracy.
      2. The processing is unlawful and you oppose its erasure and request instead the restriction of its use.
      3. We no longer need your personal data for the purposes of the processing, but you require us to restrict processing for the establishment, exercise or defense of legal claims.
      4. You have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether our legitimate grounds override yours.
    3. Right to data portability. Upon request, we will provide you your personal data in our possession, in a structured, commonly used and machine-readable format. You have the right to transmit that data to another controller if doing so does not adversely affect the rights and freedoms of others.
    4. Right to object. You can object, on grounds relating your particular situation, at any time, to processing of your personal information, if based on point (e) or (f) of Article 6(1) of the GDPR.  We will then have to stop processing, unless we can demonstrate compelling legitimate grounds for the processing. If you object to the processing for direct marketing purposes, we will have to stop processing for these purposes.
    5. Right to withdraw consent. GDPR grants you the right to withdraw your earlier given consent, if any, to processing of your personal data at any time.
    6. Rights related to automated decision making. As a responsible business, we do not rely on any automated decision making, such as profiling.
  1. Accessing and Correcting Your Personal Information

You can view and edit some of your account information yourself after logging in. If you terminate account, we may retain some information for as long as necessary to evaluate Service usage, troubleshoot issues, resolve disputes and collect any fees owed.  If you have any questions or wish to ask to access, modify or delete any of your personal data on our Service, please contact us. Note that we can deny your request if we think it would violate any law or cause the information to be incorrect.

If you have any questions or concerns regarding this Privacy Notice, please contact our Chief Privacy Officer by writing to the following address:

Chief Privacy Officer

Vientos del Caribe Private Members Club & Resort, LLC

30 N Gould St
Ste R
Sheridan, WY 82801