What specific steps must Camp Margaritaville take to safeguard Confidential Information?
Camp_Margaritaville Franchise · 2025 FDDAnswer from 2025 FDD Document
ties' aggregate reservations data, as long as the CRS Supplier ensures that such marketing, use and disclosure is solely in anonymized and aggregate form and that such aggregate data are blended with substantial other aggregated data, collected from other Margaritaville and CRS Supplier customers and maintained by the CRS Supplier in an anonymized format ("Supplier Aggregate Data"). CRS Supplier has assured Margaritaville that: (i) such Supplier Aggregate Data does not include any Guest Information or other personal data, (ii) such Supplier Aggregate Data does not include any information from which one could identify Customer or any of its Properties or guests, and (iii) CRS Supplier's use or disclosure of such Supplier Aggregate Data is in compliance with all applicable laws and regulations, as applied to either Customer, Customer's Properties, Margaritaville or CRS Supplier.
- B. CRS Supplier has assured Margaritaville that it will implement and maintain appropriate administrative, technical and physical safeguards designed to ensure the security or integrity of Customer Confidential Information including any Guest Information and Reservation Data and shall protect against unauthorized access to or use of such Customer Confidential Information including Guest Information and Reservation Data.
- C. In the event of a data security incident involving Guest Information and Reservation Data, the CRS Supplier has assured Margaritaville that it shall be responsible for the reasonable and documented costs incurred by Customer in connection with such incident, including,
but not limited to, the following items: (a) costs of any required forensic investigation to determine the cause of the data security breach, (b) providing notification of the security breach to applicable government and relevant industry self-regulatory agencies, to the media (if required by applicable Law) and to individuals whose personal information may have been accessed or acquired, (c) providing credit monitoring service (if required by applicable law or any enforcement order, decree or consent) to individuals whose personal information may have been accessed or acquired for a period of one year, and (d) operating a call center to respond to questions from individuals whose personal information may have been accessed or acquired for a period not to exceed one year.
- D. Customer acknowledges that CRS Supplier has set forth certain protections for Margaritaville with respect to Guest Information and Reservation Data in connection with the matters set forth in this Section 10 and in these CRS Terms of Use, and that Margaritaville has extended the same to Customer pursuant to this Section 10 on a passthrough basis. Notwithstanding the foregoing, Customer is not a third-party beneficiary of any commitment by or agreement with CRS Supplier, and only Margaritaville maintains privity with CRS Supplier for any matter set forth in these CRS Terms of Use. In no event shall Margaritaville be held liable to the extent a commitment or obligation of CRS Supplier has not been fulfilled through no fault of Margaritaville. Margaritaville will reasonably assist Customer with respect to any issues, questions or conflicts with the CRS Supplier arising under these CRS Terms of Use and the CRS Supplier Agreement, including, but not limited to, enforcing the CRS Supplier's obligations with respect to a data security breach affecting Customer.
- E. Customer's use of the CRS Services shall at all times be subject to the terms of the Branding Agreement.
Source: Item 23 — RECEIPTS (FDD pages 72–406)
What This Means (2025 FDD)
According to Camp Margaritaville's 2025 Franchise Disclosure Document, the CRS (Central Reservation System) Supplier has assured Margaritaville that it will implement and maintain appropriate administrative, technical, and physical safeguards designed to ensure the security or integrity of Customer Confidential Information including any Guest Information and Reservation Data and shall protect against unauthorized access to or use of such Customer Confidential Information including Guest Information and Reservation Data.
In the event of a data security incident involving Guest Information and Reservation Data, the CRS Supplier has assured Margaritaville that it shall be responsible for the reasonable and documented costs incurred by Customer in connection with such incident, including, but not limited to, the following items: (a) costs of any required forensic investigation to determine the cause of the data security breach, (b) providing notification of the security breach to applicable government and relevant industry self-regulatory agencies, to the media (if required by applicable Law) and to individuals whose personal information may have been accessed or acquired, (c) providing credit monitoring service (if required by applicable law or any enforcement order, decree or consent) to individuals whose personal information may have been accessed or acquired for a period of one year, and (d) operating a call center to respond to questions from individuals whose personal information may have been accessed or acquired for a period not to exceed one year.
Camp Margaritaville customers are responsible for, and remain liable to, Margaritaville for the actions and omissions of all employees, contractors or other representatives who are engaged by Customer concerning the treatment of Guest Information and Reservation Data as if they were Customer's own actions and omissions. Customers must notify Margaritaville of (i) any act or omission that compromises either the security, confidentiality or integrity of Guest Information and Reservation Data collected from end users or (ii) a breach or alleged breach of relating to the privacy practices of Customer in accordance with the terms of the Branding Agreement. Customers must also promptly notify Margaritaville any suspicious or malicious activity, potential vulnerabilities, or security weaknesses of which it becomes aware by emailing Margaritaville contact and in accordance with the terms of the Branding Agreement.
In the event of any unauthorized access to and acquisition of Guest Information and Reservation Data by a third party while in the possession of Customer or in transit from Customer, which materially compromises the security, confidentiality or integrity of such Guest Information and Reservation Data ("Data Security Breach"), Customer shall promptly investigate the cause of such Data Security Breach and shall at its sole expense take all reasonable steps to: (i) mitigate any harm caused to affected individuals, (ii) prevent any future reoccurrence, and (iii) comply at its sole expense with applicable data breach notification laws.