Effective Date: January 1, 2020
We also include specific disclosures for residents of California and Nevada.
CWGS Group, LLC
PO Box 6888
Englewood, CO 80155-6888
Types of information we collect and how we collect it
Information You Provide
Some of the Services may include features or services that permit you to enter contact information and other information about you. We collect and store any information you enter on our Services. This includes:
- Contact and demographic information when completing forms or registering to use our Services.
- Payment information and associated contact information when engaging in a transaction.
- Appointment bookings you carry out through our Services.
- Email address information when subscribing to our email newsletters.
- Any information or data you provide by interacting in our online forums and with our chatbots, or by commenting on content posted on bulletin boards and other public areas of our Services (“Public Areas”). Please note that these comments are also visible to other users of our Services.
- Information you provide when you complete a survey administered by us or a service provider acting on our behalf.
- Information you may submit to inquire about or apply for a job with us.
- Information you provide when you participate in a contest or sweepstakes that we offer.
- If you contact us, we may keep a record of that correspondence and any contact information provided.
- Medical or health information that you provide to us when requesting special accommodations or filing incident reports in the course of using our Services.
Some of this information may be collected by external parties, called service providers, on our behalf. For example, we use a payment processor when you engage in a transaction with us.
Information We Collect Automatically
When you interact with the Services, certain information about your use of our Services is collected automatically. This includes:
- Details of your visits to our site and information generated in the course of the use of our site (including the timing, frequency, and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site.
- Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system, and browser type.
- Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence.
- Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our Services), including your account ID or username and other information included in your posts.
Much of the information that we collect automatically is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. CWGS relies on partners to provide many features and to process and collect data about your use of our Services and other sites.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Firefox or Internet Explorer) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won't have access to many of our features that make your web experience more efficient.
Our HTML-formatted emails may contain a web beacon to tell us whether our emails are opened and verify any clicks through to links or advertisements within the email. We may use this information for purposes including determining which of our emails are more interesting to users. The web beacon will be deleted when you delete the email. Emails in plain text (if applicable) rather than HTML will not include the web beacon.
When accessing our website on a mobile device or using any of our mobile applications, we will have access to your location if you have enabled location services on your device. We will also have access to your mobile device ID, which is unique to your device and does not by itself contain any personally identifiable information.
How We Use the Personal Information that We Collect
When you supply us with personal information, the information you provide is added to our customer file. We may use the information we collect for the following purposes:
- To contact you regarding promotions, discounts, and other Services, provided by CWGS or our third party business partners, and when you request email bulletins or newsletters or join our club.
- To contact you in response to an inquiry, complaint, or incident report.
- To provide you with our products and services, including to complete transactions, take steps to enter into a contract for sale or for services, process payments, fulfill orders, and send service communications.
- To enable additional features on our Services and to provide you with a personalized service.
- Create custom audiences on social media sites and search engine platforms and to understand and respond to your comments and reviews of our Services on social media sites and search engine platforms.
- To provide you with the best service, improve and grow our business, and understand the effectiveness of our marketing, including by understanding our customer base and purchasing trends.
- To understand how our Services are being used, track site performance, and make improvements.
- To deliver tailored advertising on our Services based on your preferences or interests across services and devices and measuring the effectiveness of ads.
- To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.
In addition, by joining Good Sam Club, you agree and acknowledge that we may recognize your membership among our affiliated companies and on our web sites. For example, if you are a member of Good Sam Club and have also joined the RV.Net forum, we will indicate that you are a Good Sam Club member by displaying a "Good Sam" icon by your user name whenever you post content to an RV.Net forum. If you would like to remove the Good Sam Club icon in relation to your forum posts, you may do so in your forum account in the "My Profile" section.
How We Share Your Information
We engage the following types of vendors to perform functions on our behalf such as: delivery services, customer information management, customer communications and marketing services, billing and collection, order fulfillment, auditing and accounting, professional services/consultants; analytics services; security services; and IT support. These companies are restricted from using your information in any manner other than in helping us to deliver or provide you our products and services. There are limited circumstances in which the service provider collects data directly from you when their privacy policies may also apply.
On some of our sites, we provide content that is created by a third-party website. In some instances the third-party sites will collect information in order to facilitate the transaction or to make the use of their content more productive and efficient. In these circumstances the information collected is shared between our third-party sponsors and us.
Social Media Platforms
Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through cookies or other tracking mechanisms that they place on your device. In some cases, the social media company may recognize you through its digital cookies even when you do not interact with their application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and the controls they make available to you.
Third-Party Advertisers and Network Advertisers
We partner with companies that assist us in advertising about our Services to others who may be interested in the Services. These companies may use tracking technologies to collect or receive information from the Services and elsewhere on the internet and use that information to provide analytical services, interest tagging, and ad targeting.
In addition, some advertisements on our site are promoting products and services from third-party companies. These companies are called "network advertisers." Network advertisers collect information when you visit our site. The information is collected using technology, so you may not realize it is being collected. The network advertisers collect this information so that they can show you ads that are more relevant and interesting to you.
Business Partners and Sponsors
To enhance your experience on our Services, we provide information to a select group of companies that offer products and services that may be of interest to you (our “business partners”).
On occasion, we offer promotions – such as sweepstakes or free camping – in conjunction with a sponsor. We may share your information with the sponsors if they need it to send you a product, such as a magazine subscription or fulfill the offer of a free night camping. We may share your information with those sponsors that can send you other special promotions. In addition, we will occasionally send e-mail promotions to our users on behalf of third-party sponsors regarding lifestyle-related products or services.
Sale of Businesses
We may sell certain of our businesses or assets to other companies in connection with a merger, acquisition, or bankruptcy. When such transactions take place, visitor information (including personal information) may constitute a part of the transferred business assets. In the event that we, or any of our affiliates, sell some, all or substantially all of our assets to another company, visitor information (including personal information) likely will be disclosed and transferred as an asset to such company.
Organizations That Help Protect the Security and Safety of our Users and our Sites
We will disclose personal information as required by law, for example, to comply with a court order or subpoena; to enforce our Terms of Service, sweepstakes/contest rules, or assert or defend other legal claims; to a regulator or consumer protection authority with jurisdiction over us, or to protect the safety, integrity, and security of our Services, users, and information.
We are not responsible for what third parties do with any information that you make available in public areas of our Services. As such, we advise that you exercise great care in determining what information you choose to make publicly available through our services.
Additional Information About Our Data Practices
Sharing of Aggregated Data
We may share aggregated or deidentified data at our discretion, including with marketing agencies, media agencies and analytics providers. These other companies will not be able to relate this data to identifiable individuals.
Combination of Information
We may combine information from the Services together and with other information we obtain from our business records. Additionally, information collected about you from a particular browser or device may be linked to information collected from another computer or device that we believe relates to you.
Sharing of Medical or Health Information
To the extent that we receive health information about you, that information is subject to electronic disclosure to extent permitted by applicable law.
Choices You Have About Our Collection, Usage and Sharing of Your Information
How You Can Access Your Account Information
If you have established an account with one of our business units, you can review your communication preferences through the "My Account" section of our websites. Communication preferences are permissions that you have granted us to communicate with you on specific areas of interest. You may make modifications to your communication preferences directly through this section of "My Account".
If you don't have an account, can't find your account, or some of our Services do not provide an account section, you can simply contact us via email by clicking "Contact Us" located at the bottom of all of our web pages or send an email directly to [email protected] Please include information in the email that will help us identify your account so we can assist you with your inquiry or request.
When you register with us or give us your contact information, you may have an opportunity to limit e-mail communications from us and our third-party marketing partners. At any time you can request that we not send e-mails to you either by unsubscribing from the communication or by contacting us at [email protected]
Direct Mail Communications
When you subscribe to our publications, join the Good Sam Club, or otherwise do business with us, please tell us if you do not want to receive our direct mail marketing offers for any or just certain products and/or services. We will mark your account for a three-year period. You will not receive any direct mail offers from us during this three-year period for those products and/or services that you have indicated to us that you are not interested in receiving. If you change your mind, just get in touch with us and ask that we include you in future offerings. Please note that because marketing campaigns are planned a few months ahead of time, you may continue to receive marketing offers for two to four months after making a request. Write to us at Good Sam Mail Preference Service, P.O. Box 6888, Englewood, CO 80155-6888 to opt out from specific future mailings.
Third-Party Ad Tracking and Serving
Our third-party advertising and business partners may provide you with ways to choose not to have your information collected. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") by following instructions on the NAI's website: https://www.networkadvertising.org
The Type of Security We Provide
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
There are some things that you can do to help protect the security of your information as well. For instance, never give out your password, since this is what is used to access all of your account information. Also remember to sign out of your account and close your browser window when you finish surfing the web so that other people using the same computer won't have access to your information.
Our site is operated and hosted in the United States. Information that you provide to us and the data that we collect as a result of your visiting and using our site will be collected, processed in and transferred to the U.S. and is subject to U.S. law. The privacy and data protection laws in the U.S. may not be equivalent to or adequate under the laws in your country of residence or from which you access this site. By visiting this site or by providing us with your personal information you consent to this collection, transfer, storage, and processing of information to and in the U.S.
California and Nevada Privacy Rights
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at [email protected]
California Shine the Light
California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to [email protected] Our website currently does not honor browser “do not track” signals.
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
Right to Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.
- Personal Identifiers:
- We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Services, respond to your requests, and send information and advertisements to you.
- We collect your social media handle and basic account information when you interact with our Services through social media. We may also collect your social media handle if you post reviews or comments relating to our Services through social media.
- We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our Services in order to identify you, provide the Services, keep you logged in to the Services, prevent fraud, and provide you with targeted information and offers.
- We collect payment information when you provide it to us, which may include your credit card number or a bank account number, when you complete a transaction. You may have the option to store this information to your account or set up a recurring transaction. We use this information to streamline and facilitate payments and transactions.
- We may collect your Social Security number, Driver’s License number. We use this information to identify you, authenticate and collate information about you, to prevent fraud, and to conduct background checks or other screening activities.
- We may collect medical information and health information about you if you provide that information to us as part of a complaint, claim or incident report. We use this information to address and resolve your concerns or claims regarding our Services.
- We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and serve targeted advertisements based on your online activities.
- We collect your Device ID automatically when you use our Services. We use this information to monitor your use and the effectiveness of our Services, to identify you, and to provide you with targeted information and offers.
- Protected Classifications: We collect your gender and date of birth to verify identity and extend personalized offers. We also collect citizenship and marital status to facilitate offers of credit. We do not collect your racial or ethnic origin, or sexual orientation. We may collect your disability status if you request an accommodation, or provide that information as part of a claim or incident report.
- Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. We may combine this information with other information to make inferences regarding your preferences. We use this information to measure the effectiveness of our Services, advertising, and promotions, and to provide you with targeted information, advertisements and offers.
- Biometric Information: We do not collect information about your physiological, biological, and behavioral characteristics.
- Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize our Services. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements and offers based on your online activities.
- Geolocation Data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. We also collect your precise location (e.g., your GPS coordinates), through your device. If you allow your device to provide us with this information, we use it to make improvements to our products and services, measure the effectiveness and use of our Services, and to provide recommendations and deliver relevant advertising.
- Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We also collect the content of public posts or reviews that you make available through social media or other websites. We collect your photographic or video image if you visit one of our facilities. We use this information to respond to specific issues, claims, or complaints, to monitor our customer service, maintain the security of our systems and physical locations, aid in theft detection and monitoring, and train employees. We also collect photographic and video images in connection with customer testimonials for marketing and promotional advertising.
- Professional or employment-related information: We collect information about your current employer and your employment history if you apply for a job with us. We use this information to conduct background and other screening activities. We also collect information about your current employer and your employment history if you apply for a credit card or to facilitate other offers of credit.
- Education information: We collect information about the institutions you have attended and the level of education you have attained if you apply for a job with us. We use this information to conduct background and other screening activities.
- Inferences drawn to create a profile about a consumer reflecting the consumer's preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile. We also collect this information from our advertising and business partners. We use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of our Services, applications, and tools, and to provide you with targeted information, advertisements, and offers.
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
We also sell information to third parties, as described below. To opt out of the sale of your information visit our Do Not Sell My Info page.
Right to Know/Access Information
You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our customers' Personal Information, we are required to verify your identify before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
How to Submit a Request
You may submit a request to exercise your rights to know/access or delete your Personal Information through any one of three means:
- By filling out a Consumer Data Request Form available here.
- By calling us at (866) 890-2810
- By Requesting a Consumer Data Request Form at any of our locations in California.
In order to process your request to know/access or delete Personal Information we collect, disclose, or sell, we must verify your request. We do this by:
- Asking you to
- provide personal identifiers we can match against information we may have collected from you previously; or
- provide a Good Sam Club Member number, recent order number, or other transactional information if you've purchased a product or service from us; and
- confirm your request using the email or telephone number stated in the request.
You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf. Parents of minor children may submit a birth of the child certificate in lieu of an affidavit, in order to make requests on the child’s behalf. Sample forms will be provided in the verification process.
Right to Opt Out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your Personal Information by CWGS to third parties.
We sell information to third parties. To “sell” information means to disclose it to a company for monetary or other benefit. A company may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes.
We sell the following information:
- Personal Identifiers: We provide your name, email address, mailing address, IP address, and Device ID to our advertising partners and business partners.
- Internet or Other Electronic Network Activity Information: We exchange your browsing history, search history, information regarding your interaction with websites, and applications or advertisements with our advertising and business partners.
- Inferences drawn to create a profile about a consumer reflecting the consumer's preferences or characteristics: We exchange information about your actual or likely preferences with our advertising and business partners.
To exercise your right to opt out of the sale of your Personal Information, please visit our “Do Not Sell My Info” webpage or call us at (866) 890-2810.
Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.
Right to Information Regarding Participation in Data Sharing for Financial Incentives
You have the right to be free from discrimination based on your exercise of your CCPA rights. We offer promotions whereby we incentivize a consumer to share certain pieces of information with us, or to register for a club or service, by offering a financial incentive, such as a discount. For example, we may offer a one-time discount if consumers sign up for our email marketing list. Participation in all promotions and clubs is voluntary, and you may opt out of the sale of your personal information at any time.
Special Information for Nevada Residents
Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. To make a request, please contact us at [email protected] or complete our Consumer Data Request Form.