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Privacy Policy

Trafalgar Privacy Policy

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Last updated: July 2021

  1. ABOUT THIS POLICY

This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data collection and processing, so you are fully aware of how and why we are using your data.

This privacy notice supplements other notices and is not intended to override them.

  1. OUR COMMITMENT

We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data.

  1. OUR LEGAL BASES FOR PROCESSING

We will process your personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal data unless at least one of the following requirements are met:

  • You have given consent to the processing of your personal data for one or more specific purposes;
  • The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
  • Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
  • Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (for instance, protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders). Please find below an indicative, non-exhaustive list of processing activities for which we may rely on legitimate interest:

PROCESSING ACTIVITY

BASIS FOR LEGITIMATE INTEREST

Direct marketing activities including tracking, profiling, segmentation, and communication across multiple channels, see section 8.8

Legitimate interest in promoting relevant services and products based on your relationship and interaction with us

Record keeping and reporting, see section 8.6

Legitimate interest in understanding and improving our business

Statistical analysis of customer data, see section 8.7 & 8.9

Legitimate interest in understanding and responding to customer behaviour and preferences

Provision of customer data to insurance providers, border authorities & other law enforcement agencies, see section 11.4 & 11.7

Legitimate interest in protecting and maintaining the safety of our guests and employees; legitimate interest in taking appropriate legal action in case of disputes

Processing of guest preferences and other information volunteered by the guest prior to a trip, see section 8.3

Legitimate interest in personalizing and improving the delivery of our services and products

Processing of customer data as part of prize draws, competitions, sweepstakes, and surveys, see section 6.4 & 6.5

Legitimate interest in engaging with our customers and promoting our products

Processing of customer data in the course of administration and maintenance of our websites and systems, see section 6.8 & 8.7

Legitimate interest in running our business and improving our systems

  1. CHANGE OF PURPOSE

We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal data, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal data for unrelated purposes, based on our legitimate Interest.

  • There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
  • For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
  • We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal data by law, as you will not be directly or indirectly identified. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
  • However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
  • We will not repurpose sensitive or special category data without a lawful basis for doing so and where we rely on Legitimate Interest; will ensure we conduct legitimate interest assessments (see section 3) and data protection impact assessments DPIA, prior to carrying out the proposed processing activity.
  1. WHO OUR PRIVACY POLICY COVERS

5.1 Our customers

Our privacy policy sets out how we process personal data relating to individuals who are:

  • booking or enquiring about booking travel services with or through us; or
  • the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you); or
  • customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal data as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

5.2 Examples of who this policy covers

We include in this privacy policy personal data we process relating to:

(1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers and employees of businesses and organisations booking with or through us);

(2) individuals in respect of whom any enquiry or booking is made with us by an agent;

(3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;

(4) individuals whose personal data is obtained from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes). 

5.3 When we are data processor only

Please however note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal data on their instructions.

5.4 Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, and any such individual whose personal data we process from time to time.

When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both:

(1) all such products and services which we supply or operate ourselves (including where we sub-contract); and

(2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

  1. WHAT TYPES OF PERSONAL DATA WE MAY PROCESS

This section summarises the types of personal data about you that we process:

6.1 Data concerning you as an individual

We may collect the following:

  • name,
  • age,
  • gender,
  • address,
  • telephone,
  • mobile,
  • fax,
  • e-mail,
  • Social networking contact details, your social posts about any of our trips and travel experiences.
  • photographs,
  • proofs of identity and address, copies of passports, driving licences, and utility bills,
  • card and other payment details, and financial information,
  • health information relevant to your planned travel and travel insurances held,
  • results of searches carried out against you (such as to verify your identity, address, and credit status),
  • your preferences,
  • Frequent flyer or travel partner programme affiliation and member number.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

6.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you:

  • business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.),
  • your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and
  • your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

6.3 Enquiry and Booking information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:

  • records of enquiries and searches for holiday and travel products made by or on your behalf,
  • details of your personal interests,
  • needs and other data relevant to your enquiry;
  • details of results, quotes, proposals, estimates and other information given in response to enquiries;
  • details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about;
  • details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator);
  • dates and times of travel;
  • price;
  • payment details (including card details);
  • passport information and visa information;
  • foreign exchange requirements and arrangements; and
  • Sensitive information such as health, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us.

6.4 Survey Information

Information collected or generated out of any surveys we conduct.

6.5 Competition Information

Information collected or generated out of any competitions or promotions we run.

6.6 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

6.7 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.

6.8 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

This information may include:

  • your IP address (a unique identifier allocated to your computer for your connection to the internet);
  • your computer device details (PC, tablet, smartphone, watch etc.);
  • the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using;
  • your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc);
  • your time-zone;
  • your browser plug-ins;
  • any web-page you came from, identified as the referrer web page address by your web browser;
  • cookies (as per our cookie policy https://www.trafalgar.com/en-ca/resources/privacy-policy)
  • identifiers assigned to you by third-party advertising providers and web beacons you interact with;
  • page response times;
  • download error;
  • pages and parts of pages you visit;
  • usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.;
  • services and products you viewed;
  • length of visit to website and pages;
  • page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).

This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

This information may also include:

  • data inputted into forms and fields;
  • registrations for any accounts,
  • forum,
  • feedback mechanism,
  • social functionality,
  • newsletters or other features of our site;
  • usernames and passwords,
  • log-in / out history, and settings;
  • actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review, or other social functionality on our website.

Such information will be treated as personal data and processed according to this privacy policy.

  1. HOW WE COLLECT OR GENERATE YOUR PERSONAL DATA

This section sets out the ways in which we may collect or generate personal data concerning you.

7.1 Visiting our website

By visiting and using our website you or your computer may provide personal data. This includes:  information which is automatically provided by your browser to our servers; information recorded on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. This is more detailed in our cookie policy https://www.trafalgar.com/en-ca/resources/privacy-policy

7.2 Data you provide

Your personal data will include data you provide (or later amend), whether:

  • from correspondence with you;
  • verbally to us over the phone or in person;
  • by filing in any field or form on a website;
  • by filling in any printed form we provide you with;
  • by e-mail;
  • from documents you provide us with; and
  • from updates to any information you provide to us from time to time.

This includes when you:

  • register or subscribe for any service, account, members, or loyalty program,
  • make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise;
  • send us your comments or suggestions;
  • subscribe to any newsletter or other publication;
  • and request sales and advertising information, including brochures.

7.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let [Brand Name] and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

  • Print materials
  • on our website
  • email activities
  • social posts
  • images on our trips
  • provide images to our trade partners to use on their websites, email marketing and other marketing initiatives
  • make available in our content feeds
  • We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods
  • Any other information provided to us by or in relation to you which concerns you as an individual.

7.4 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from:

  • providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries;
  • credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations;
  • Any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

7.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including:

  • in connection with responding to and dealing with any enquiry, booking or complaint; or
  • in performing any booking or other contract with you; or
  • through the analysis of your personal data; or
  • data gained from your use of our website according to our cookie policy.

We may record telephone calls with you for training and quality purposes.

  1. WHAT DO WE USE YOUR PERSONAL DATA FOR?

This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.

8.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities, and functions of our websites.  This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

8.2 Provide information and respond to enquiries

To provide information to you about our website, systems, and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.3 Bookings and other contracts

To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.4 Payments

To collect and make payments due and administer our accounts.  This is necessary for the preparation of any contract between us.

8.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.6 Record Keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.  This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.

8.7 Manage and improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;

  • to carry out surveys and analyse the results;
  • to run promotions and competitions;
  • undertake product or customer research/development;
  • to assist us in and help us to improve our sales;
  • to carry out other business development and improvement activities;
  • to provide training to our staff, sub-contractors and suppliers;
  • editorial, advertising, and marketing processes, including sharing of photographs which you have voluntarily participated in during our Trips. Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;

For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.  This is done on the basis of our legitimate interests in ensuring our business runs efficiently.

8.8 Direct marketing

To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you.  We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 10.1 for the types of products we may market to you this way.

8.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

8.10 Anything you have specifically consented to

For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.

8.11 Consequences of Not Providing your Data

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.

  1. PERIOD FOR RETAINING YOUR DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you would like to know more about our data retention policy, please ask us.

  1. USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING

We do not use or disclose your personal data for direct marketing purposes unless:

  • we have obtained your consent to do so, such as through an opt-in box on any form or website of ours; and/or
  • you have made a booking with us and there is our legitimate business interest to do so for similar products or services.

If you do not want to receive direct marketing activities anymore, you can manage your communications preferences by following the link at the end of every of our electronic communications.

In addition to data protection law if we use your personal information for direct marketing purposes, we may also be subject to additional rules that regulate direct marketing, such as the EU Privacy and Electronic Communications Directive 2009/136/EC. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.

10.1 Direct marketing by us

We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services:

(1) offered by us;

(2) which can be booked with third parties through us;

(3) which can be booked with other companies within our group (i.e. the Travel Corporation Group); and

(4) offered by third parties selected by us. However, we will not pass any of your details to third parties without your prior and specific consent.

Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email or SMS). 

10.2 Direct Marketing by Third Parties

From time to time, we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number, fax number and preferences) to:

(1) other companies within our The Travel Corporation, which are bound by the same requirements set in this privacy policy; and

(2)  other companies which offer services that may enhance your travel experience or be able to help you to finalise your travel arrangements (“third parties”). Such third parties may then contact you directly with marketing information about services and products offered by them. Such third parties are not part of The Travel Corporation and are not bound by this privacy policy. However, we ensure that our partners will only contact you in the manner you agreed to (e.g. email, text) when providing your consent. 

10.3 Withdrawing from Direct Marketing

You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”

When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.

You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

  1. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We transfer your personal data to third parties in the following circumstances:

11.1 Credit Checks etc.

We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

11.2 Bookings and performance of contracts

We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;

  • to apply for visas on your behalf,
  • to collect payments to be made by you,
  • to investigate and respond to complaints, and
  • to enforce any booking or other contract with you.

Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.

11.3 Suppliers of travel and other services

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you.

We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator.  Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

11.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer.  Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

11.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.

11.6 Public forums etc.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.

11.7 Legal requirements

We may supply personal data to a government authority or regulator where required to:

  • comply with a legal requirement,
  • for the administration of justice or when required by a public enforcement body, or
  • for the purposes of customs, visas and immigration.

We may disclose your personal data where otherwise required by or permitted by law.  

11.8 Direct Marketing by third parties

We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent.  Please refer to the direct marketing section above for more information.

11.9 Business Customers who are businesses (not individuals)

If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data.  

If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

11.10 Business acquirers

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal data.

  1. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

Where we provide your personal data to a third party one of the following two circumstances will apply:

12.1 Processing on our behalf

In some cases, your personal data may be held and otherwise processed by others on our behalf.  We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy.  The sharing of your data is necessary for the performance of any contract with you and for the efficient provision of our services.

12.2 Processing on their own account

In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account.  In such case, they will have their own responsibility for your personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party and they will provide their privacy policy to you.

  1. LOCATION OF YOUR PERSONAL DATA

We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area (“EEA”) and the United Kingdom.

We will only send your personal data outside the EEA and the United Kingdom to companies either within our group or to parties with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA and the United Kingdom. You can find out about what adequate safeguards these are by contacting us using the details provided in Section 16 of this privacy notice.

  1. KEEPING YOUR DATA SECURE

14.1 Our security measures

 We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secured servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to the information;
  • using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions.

Unfortunately, transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal data to. We never contact you to ask you for your payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made.  Please let us know if you someone purports to contact you in our name.

  1. YOUR RIGHTS

You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure.  More information about your rights and our obligations can be found on https://www.priv.gc.ca. To exercise any of your rights below, please use a dedicated online form https://ttc.com/personal-data-request/, or send your request via email to compliance@ttc.com.

You may request the following information be provided to you:

  • whether we are processing personal data about you;
  • what personal data we are processing, including a request for a copy of your data;
  • what purposes we are processing data for;
  • from which sources we have collected the data;
  • who we disclose the data to;

We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case.

The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive. We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

15.1 Rectification

You have the right to have your personal data amended if it is inaccurate or incomplete.

15.2 Right to object

You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.

15.3 Erasure

You have the right to have your personal information deleted or removed in the following circumstances:

  • The data is no longer necessary for the purpose for which it was originally collected or otherwise processed;
  • Where you withdraw your consent, where consent was used as the legal basis for processing;
  • Personal data has been unlawfully processed;
  • When you object to the processing and we have no overriding legitimate interest for continuing the processing;
  • Erasure is required for compliance with a legal requirement; or
  • Data has been collected in relation to the offering of online services to a child.

When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete.

We have the right to refuse to act on a request of erasure if the data is necessary for:

  • Exercising the right of freedom of expression and information;
  • Compliance with a legal obligation;
  • The establishment, exercise or defence of legal claims;

15.4 Portability

You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller, when:

  • the processing is based on consent or on a contract; and
  • the processing is carried out by automated means.

15.5 Restrict Processing

You have the right to obtain from us the restriction of processing of your personal data where one of the following applies:

  • You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
  • The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
  • We no longer need the personal data for the purposes of the processing, but the data is necessary for you for the establishment, exercise or defence of legal claims;
  • You have objected to processing pending the verification whether our legitimate grounds override yours.

Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so.

We will inform you before the restriction of processing is lifted.

15.6 Right to withdraw your consent

You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 16 of this policy. See also section 10.3 for details as to how to object to our direct marketing communications.

15.7 Right to lodge a complaint with a supervisory authority

The laws we comply with are regulated by the Information and Privacy Commissioner of Ontario, 2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8. https://www.ipc.on.ca/.  In addition to your rights above, it is open to you, if you have a complaint or a concern, to seek assistance from this supervisory authority who has powers to compel us to comply with applicable laws and fine us for non-compliance.  However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have. You can contact us using the details provided in Section 16 of this our privacy notice.

Changes to this privacy policy

We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change.  You can check the top of the document to see the latest version in force.

Applicable Law and Disputes

Our privacy policy is subject to the law of Ontario, Canada, and disputes can be determined by the courts of Ontario, Canada.

  1. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any requests or complaints, please contact us either by e-mail to privacy.officer@travcorp.ca or by post to Attn: Privacy Officer, 33 Kern Road, Toronto, Ontario M3B 1S9.

  1. ABOUT US

This is the privacy policy of TRAFALGAR TOURS OF CANADA LIMITED. (referred to as "we", "us" or "our").  We are incorporated under the laws of Ontario, Canada. Our incorporation number is 0229915 and our incorporation address or registered office is 33 Kern Road, Toronto, Ontario, CANADA M3B 1S9. We are a member of TICO (Wholesale Registration # 1583987, Retail Registration # 50015870), ACTA, and CATO. 

  1. COPYRIGHT NOTICE

This document, and all content of our websites is Copyright© 2021 TRAFALGAR TOURS OF CANADA LIMITED. ALL RIGHTS RESERVED.

Insight Vacations Privacy Policy

Last updated: July 2019.

 

1. About this Policy

This document (our “Privacy Policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and site users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this Privacy Policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.


2. OUR COMMITMENT

We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our sites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.


3. ABOUT US

This is the Privacy Policy of INSIGHT VACATIONS (CANADA) LTD. We are incorporated under the laws of Ontario, Canada. Our incorporation number is 0492198 and our incorporation address or registered office is 33 Kern Road, Toronto, Ontario, CANADA M3B 1S9. We are a member of TICO (Wholesale Registration # 1873715, Retail Registration # 50015871), ACTA, and CATO.

 

4. WHY WE COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION

 

We will collect, use and disclose (‘process’) your personal information in accordance with applicable Canadian laws and applicable contractual obligations. More specifically, we will not process your personal information unless at least one of the following requirements is met:

    You have given consent to the processing of your personal information for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your photos/videos of experiences of our trips on social media and sharing emails of co passengers, that have agreed to stay in touch);
  1. The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
  2. Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
  3. Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip); and
  4. Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (i.e., protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders).

 

5. CHANGE OF PURPOSE

We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal information, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal information for unrelated purposes, based on legitimate interest.

  1. There are some circumstances in which personal information may be processed for purposes that go beyond the original purpose for which the personal information was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
  2. For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
  3. We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal information by law, as you will not be directly or indirectly identified. For example, we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
  4. However, if we combine or connect aggregated data with your personal information so that it directly or indirectly identifies you, we shall treat the combined data as personal information which will be processed as required under applicable Canadian laws.


6. WHO OUR PRIVACY POLICY COVERS

6.1 Our customers

Our Privacy Policy sets out how we collect, use and disclose personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal information as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

6.2 Examples of who this policy covers

We include in this Privacy Policy personal information we collect, use and disclose relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; and (4) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes).

6.3 When we are an information processor only.

This Privacy Policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

6.4 Terms used in this policy

When we refer to "you" and "your" in this Privacy Policy, we refer to you, any such individual whose personal information we collect, use and disclose from time to time. When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.


7. WHAT LAWS WE COMPLY WITH

We collect, use, and disclose your personal information in accordance with applicable Canadian privacy requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

 

8. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarizes the types of personal information about you that we collect, use, and disclose:

8.1 Data concerning you as an individual

This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

8.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

8.3 Enquiry and Booking Information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

8.4 Performance Information

Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

8.5 Survey Information

Information collected or generated out of any surveys we conduct.

8.6 Competition Information

Information collected or generated out of any competitions or promotions we run.

8.7 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

8.8 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

8.9 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

This information may include:

  1. your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies (as per our cookie policy page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; Page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).
  2. This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our Privacy Policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally.
  3. This information may also include data inputted into forms and fields; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this Privacy Policy.

 

9. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION

This section sets out the ways in which we may collect or generate personal information concerning you.-

9.1 Visiting our website

By visiting and using our sites you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

9.2 Data you provide

Your personal information will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

9.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let Insight Vacations (Canada) Ltd. and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives

Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.

9.4 Data obtained from third parties

We may obtain personal information concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

9.5 Data generated by us

We and any suppliers or subcontractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or data gained from your use of our website. We may record telephone calls with you, but we will advise you of this fact in advance.


10. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

This section sets out the uses which we make of your personal information:

10.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

10.2 Provide information and respond to enquiries

To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

10.3 Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to collect, use, and disclose any transactions authorised or made with us which relate to you.

10.4 Payments

To collect and make payments due and administer our accounts.

10.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

10.6 Record keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

10.7 Manage and Improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, subcontractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

10.8 Direct marketing

To carry out direct marketing to you. See next section below for further information.

10.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

10.10 Anything you have specifically consented to.

For any purpose which we have obtained your consent to.

10.11 Consequences of not providing your Data

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Subject to applicable law, we may be legally required to provide your data to authorities when you travel.


11. USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in on any form or website of ours in compliance with applicable Canadian law.

11.1 Direct marketing by us

Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide, or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will always have the opportunity to "unsubscribe" from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to • or at the following telephone number: 1 866 747 8120.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive service-related messages.

11.2 Direct marketing by third parties

Subject to applicable Canadian law, where you have expressly consented to this, we may disclose your personal information which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements and promotions relating to products and services they offer, or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.


12. DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your personal information to third parties in the following circumstances:

12.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 Bookings and performance of contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or subcontractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

12.3 Suppliers of travel and other services

We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

12.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

12.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

12.6 Public Forums etc.

Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

12.7 Legal Requirements

We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

12.8 Customer Representatives

If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.9 Business acquirers

If our business is ever acquired by a third party, then your personal information will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this Privacy Policy to protect your personal information.


13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL INFORMATION

Where we provide your personal information to a third party one of the following two circumstances will apply:

13.1 Collecting, using and disclosing on our behalf

In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this Privacy Policy.

13.2 Collecting, using and disclosing on their own account

In other cases, your personal information may need to be provided to them to be held and collected, used or disclosed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own Privacy Policy, and we will not be responsible for what they do with it following disclosure.


14. LOCATION OF YOUR PERSONAL INFORMATION

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use and disclose that information anywhere in the world.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from those in Canada or the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.


15. KEEPING YOUR DATA SECURE

15.1 Our security measures

15.1.1 Our general commitment

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or subcontractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

15.1.2 Transmissions between your web browser and our servers

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

15.1.3 Storage of your personal information

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

15.2 Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.


16. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability, we may have to you. If you would like to know more about our data retention policy, please contact us.

 

17. YOUR RIGHTS

We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

17.1 Access to your personal information

You may request us to tell you whether we are collecting, using, and disclosing personal information about you, to tell you what personal information we are collecting, using and disclosing and for what purposes, and to provide you with a copy of your personal information that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

If we refuse to provide you with access to information, we hold about you, we will provide reasons for such refusal.

17.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing and electronic communications

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

 

18. CHANGES TO THIS PRIVACY POLICY

We keep our Privacy Policy under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.

 

19. APPLICABLE LAW AND DISPUTES

This Privacy Policy is subject to the law of Ontario, Canada, and you must bring any claims against us exclusively in the courts of Ontario, Canada.

 

20. CONTACTING US

If you have any questions about our Privacy Policy or about how we process your personal information, including any complaints, please contact us either by e-mail to privacy.officer@travcorp.ca, telephone on 1 (416) 322-8468, or by mail to Attn: Privacy Officer, 33 Kern Road, Toronto, Ontario M3B 1S9. For all compliance related matters, email privacy.officer@travcorp.ca.

 

21. COPYRIGHT NOTICE

This document, and all content of our sites is Copyright© 2019 Insight Vacations (Canada) Ltd. ALL RIGHTS RESERVED.

Contiki Privacy Policy

PRIVACY POLICY

Last updated: September 28, 2019

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1. ABOUT THIS POLICY
This document (our “Privacy Policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and site users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this Privacy Policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.

2. OUR COMMITMENT
We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our sites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.

3. ABOUT US
This is the Privacy Policy of CONTIKI HOLIDAYS (CANADA) LIMITED. We are incorporated under the laws of Ontario, Canada. Our incorporation number is 0532455 and our incorporation address or registered office is 33 Kern Road, Toronto, Ontario, CANADA M3B 1S9. We are a member of TICO (Wholesale Registration # 2058256, Retail Registration # 2759979), and CATO.

4. WHY WE COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION
We will collect, use and disclose (‘process’) your personal information in accordance with applicable Canadian laws and applicable contractual obligations. More specifically, we will not process your personal information unless at least one of the following requirements is met:

  • You have given consent to the processing of your personal information for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your photos/videos of experiences of our trips on social media and sharing emails of co passengers, that have agreed to stay in touch);
  • The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
  • Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
  • Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip); and
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (i.e., protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders).

5. CHANGE OF PURPOSE
We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal information, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal information for unrelated purposes, based on legitimate interest.

  • There are some circumstances in which personal information may be processed for purposes that go beyond the original purpose for which the personal information was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
  • For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
  • We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal information by law, as you will not be directly or indirectly identified. For example, we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
  • However, if we combine or connect aggregated data with your personal information so that it directly or indirectly identifies you, we shall treat the combined data as personal information which will be processed as required under applicable Canadian laws.

6. WHO OUR PRIVACY POLICY COVERS
6.1 Our customers
Our Privacy Policy sets out how we collect, use and disclose personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal information as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.


6.2 Examples of who this policy covers
We include in this Privacy Policy personal information we collect, use and disclose relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; and (4) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes).


6.3 When we are an information processor only.
This Privacy Policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.


6.4 Terms used in this policy
When we refer to "you" and "your" in this Privacy Policy, we refer to you, any such individual whose personal information we collect, use and disclose from time to time. When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

7. WHAT LAWS WE COMPLY WITH
We collect, use, and disclose your personal information in accordance with applicable Canadian privacy requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

8. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS
This section summarizes the types of personal information about you that we collect, use, and disclose:


8.1 Data concerning you as an individual
This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.


8.2 Business Related Information
If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder,
employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).


8.3 Enquiry and Booking Information
Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.


8.4 Performance Information
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.


8.5 Survey Information
Information collected or generated out of any surveys we conduct.


8.6 Competition Information
Information collected or generated out of any competitions or promotions we run.


8.7 Account, Registration and Loyalty Information
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.


8.8 Correspondence
Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.


8.9 Website Usage Information
We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.


This information may include:

  • your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; Page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).
  • This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our Privacy Policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally.
  • This information may also include data inputted into forms and fields; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this Privacy Policy.

9. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION
This section sets out the ways in which we may collect or generate personal information concerning you.


9.1 Visiting our website
By visiting and using our sites you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.


9.2 Data you provide
Your personal information will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.


9.3 User Generated Content (UGC)
We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let Contiki Holidays (Canada) Limited. and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives


Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.


9.4 Data obtained from third parties
We may obtain personal information concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.


9.5 Data generated by us
We and any suppliers or subcontractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or data gained from your use of our website. We may record telephone calls with you, but we will advise you of this fact in advance.

10. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?
This section sets out the uses which we make of your personal information:


10.1 Operate our website
To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.


10.2 Provide information and respond to enquiries
To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.


10.3 Bookings and other contracts
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to collect, use, and disclose any transactions authorised or made with us which relate to you.


10.4 Payments
To collect and make payments due and administer our accounts.


10.5 Communication with customers
To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.


10.6 Record keeping
To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

10.7 Manage and Improve our business
To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, subcontractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

10.8 Direct marketing
To carry out direct marketing to you. See next section below for further information.

10.9 Advertising
To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

10.10 Anything you have specifically consented to.
For any purpose which we have obtained your consent to.

10.11 Consequences of not providing your Data
You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Subject to applicable law, we may be legally required to provide your data to authorities when you travel.

11. USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING
We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in on any form or website of ours in compliance with applicable Canadian law.

11.1 Direct marketing by us
Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide, or which can be booked with third parties through us.
Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will always have the opportunity to "unsubscribe" from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to • or at the following telephone number: •.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive service-related messages.

11.2 Direct marketing by third parties
Subject to applicable Canadian law, where you have expressly consented to this, we may disclose your personal information which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements and promotions relating to products and services they offer, or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

12. DISCLOSURE OF YOUR PERSONAL INFORMATION
We disclose your personal information to third parties in the following circumstances:

12.1 Credit Checks etc.
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 Bookings and performance of contracts
We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or subcontractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

12.3 Suppliers of travel and other services
We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

12.4 Insurance
If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

12.5 Business Function Outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

12.6 Public Forums etc.
Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

12.7 Legal Requirements
We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

12.8 Customer Representatives
If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.9 Business acquirers
If our business is ever acquired by a third party, then your personal information will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this Privacy Policy to protect your personal information.

13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL INFORMATION
Where we provide your personal information to a third party one of the following two circumstances will apply:

13.1 Collecting, using and disclosing on our behalf
In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this Privacy Policy.

13.2 Collecting, using and disclosing on their own account
In other cases, your personal information may need to be provided to them to be held and collected, used or disclosed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own Privacy Policy, and we will not be responsible for what they do with it following disclosure.

14. LOCATION OF YOUR PERSONAL INFORMATION
We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use and disclose that information anywhere in the world.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from those in Canada or the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. KEEPING YOUR DATA SECURE


15.1 Our security measures


15.1.1 Our general commitment
We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.


We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or subcontractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.


15.1.2 Transmissions between your web browser and our servers
We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

15.1.3 Storage of your personal information
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

15.2 Your security measures
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

16. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability, we may have to you. If you would like to know more about our data retention policy, please contact us.

17. YOUR RIGHTS
17.1 Access to your personal information
You may request us to tell you whether we are collecting, using, and disclosing personal information about you, to tell you what personal information we are collecting, using and disclosing and for what purposes, and to provide you with a copy of your personal information that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.
If we refuse to provide you with access to information, we hold about you, we will provide reasons for such refusal.

17.2 Use causing substantial distress or damage
You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing and electronic communications
You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies
You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

18. CHANGES TO THIS PRIVACY POLICY
We keep our Privacy Policy under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.

19. APPLICABLE LAW AND DISPUTES
This Privacy Policy is subject to the law of Ontario, Canada, and you must bring any claims against us exclusively in the courts of Ontario, Canada.

20. CONTACTING US
If you have any questions about our Privacy Policy or about how we process your personal information, including any complaints, please contact us either by e-mail to privacy.officer@travcorp.ca, telephone on 1 (416) 322-8468, or by mail to Attn: Privacy Officer, 33 Kern Road, Toronto, Ontario M3B 1S9. For all compliance related matters, email compliance@ttc.com.

21. COPYRIGHT NOTICE
This document, and all content of our sites is Copyright© 2019 Contiki Holidays (Canada) Limited. ALL RIGHTS RESERVED.

Luxury Gold Privacy Policy

Last updated: July 2019.

 

1. About this Policy

This document (our “Privacy Policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and site users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this Privacy Policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.


2. OUR COMMITMENT

We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our sites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.


3. ABOUT US

This is the Privacy Policy of INSIGHT VACATIONS (CANADA) LTD. We are incorporated under the laws of Ontario, Canada. Our incorporation number is 0492198 and our incorporation address or registered office is 33 Kern Road, Toronto, Ontario, CANADA M3B 1S9. We are a member of TICO (Wholesale Registration # 1873715, Retail Registration # 50015871), ACTA, and CATO.

 

4. WHY WE COLLECT, USE AND DISCLOSE YOUR PERSONAL INFORMATION

 

We will collect, use and disclose (‘process’) your personal information in accordance with applicable Canadian laws and applicable contractual obligations. More specifically, we will not process your personal information unless at least one of the following requirements is met:

    You have given consent to the processing of your personal information for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your photos/videos of experiences of our trips on social media and sharing emails of co passengers, that have agreed to stay in touch);
  • The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
  • Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
  • Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip); and
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (i.e., protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders).

 

5. CHANGE OF PURPOSE

We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal information, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal information for unrelated purposes, based on legitimate interest.

  • There are some circumstances in which personal information may be processed for purposes that go beyond the original purpose for which the personal information was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
  • For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
  • We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal information by law, as you will not be directly or indirectly identified. For example, we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
  • However, if we combine or connect aggregated data with your personal information so that it directly or indirectly identifies you, we shall treat the combined data as personal information which will be processed as required under applicable Canadian laws.


6. WHO OUR PRIVACY POLICY COVERS

6.1 Our customers

Our Privacy Policy sets out how we collect, use and disclose personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal information as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

6.2 Examples of who this policy covers

We include in this Privacy Policy personal information we collect, use and disclose relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; and (4) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes).

6.3 When we are an information processor only.

This Privacy Policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

6.4 Terms used in this policy

When we refer to "you" and "your" in this Privacy Policy, we refer to you, any such individual whose personal information we collect, use and disclose from time to time. When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.


7. WHAT LAWS WE COMPLY WITH

We collect, use, and disclose your personal information in accordance with applicable Canadian privacy requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

 

8. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarizes the types of personal information about you that we collect, use, and disclose:

8.1 Data concerning you as an individual

This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

8.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

8.3 Enquiry and Booking Information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

8.4 Performance Information

Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

8.5 Survey Information

Information collected or generated out of any surveys we conduct.

8.6 Competition Information

Information collected or generated out of any competitions or promotions we run.

8.7 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

8.8 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

8.9 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

This information may include:

  • your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies (as per our cookie policy page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; Page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).
  • This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our Privacy Policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally.
  • This information may also include data inputted into forms and fields; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this Privacy Policy.

 

9. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION

This section sets out the ways in which we may collect or generate personal information concerning you.-

9.1 Visiting our website

By visiting and using our sites you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

9.2 Data you provide

Your personal information will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

9.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let Insight Vacations (Canada) Ltd. and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives

Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.

9.4 Data obtained from third parties

We may obtain personal information concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

9.5 Data generated by us

We and any suppliers or subcontractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or data gained from your use of our website. We may record telephone calls with you, but we will advise you of this fact in advance.


10. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

This section sets out the uses which we make of your personal information:

10.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

10.2 Provide information and respond to enquiries

To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

10.3 Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to collect, use, and disclose any transactions authorised or made with us which relate to you.

10.4 Payments

To collect and make payments due and administer our accounts.

10.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

10.6 Record keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

10.7 Manage and Improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, subcontractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

10.8 Direct marketing

To carry out direct marketing to you. See next section below for further information.

10.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

10.10 Anything you have specifically consented to.

For any purpose which we have obtained your consent to.

10.11 Consequences of not providing your Data

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Subject to applicable law, we may be legally required to provide your data to authorities when you travel.


11. USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in on any form or website of ours in compliance with applicable Canadian law.

11.1 Direct marketing by us

Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide, or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will always have the opportunity to "unsubscribe" from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to • or at the following telephone number: 1 866 747 8120.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive service-related messages.

11.2 Direct marketing by third parties

Subject to applicable Canadian law, where you have expressly consented to this, we may disclose your personal information which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements and promotions relating to products and services they offer, or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.


12. DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your personal information to third parties in the following circumstances:

12.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 Bookings and performance of contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or subcontractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

12.3 Suppliers of travel and other services

We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

12.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

12.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

12.6 Public Forums etc.

Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

12.7 Legal Requirements

We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

12.8 Customer Representatives

If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.9 Business acquirers

If our business is ever acquired by a third party, then your personal information will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this Privacy Policy to protect your personal information.


13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL INFORMATION

Where we provide your personal information to a third party one of the following two circumstances will apply:

13.1 Collecting, using and disclosing on our behalf

In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this Privacy Policy.

13.2 Collecting, using and disclosing on their own account

In other cases, your personal information may need to be provided to them to be held and collected, used or disclosed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own Privacy Policy, and we will not be responsible for what they do with it following disclosure.


14. LOCATION OF YOUR PERSONAL INFORMATION

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use and disclose that information anywhere in the world.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from those in Canada or the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.


15. KEEPING YOUR DATA SECURE

15.1 Our security measures

15.1.1 Our general commitment

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or subcontractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

15.1.2 Transmissions between your web browser and our servers

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

15.1.3 Storage of your personal information

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

15.2 Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.


16. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability, we may have to you. If you would like to know more about our data retention policy, please contact us.

 

17. YOUR RIGHTS

We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

17.1 Access to your personal information

You may request us to tell you whether we are collecting, using, and disclosing personal information about you, to tell you what personal information we are collecting, using and disclosing and for what purposes, and to provide you with a copy of your personal information that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

If we refuse to provide you with access to information, we hold about you, we will provide reasons for such refusal.

17.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing and electronic communications

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

 

18. CHANGES TO THIS PRIVACY POLICY

We keep our Privacy Policy under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.

 

19. APPLICABLE LAW AND DISPUTES

This Privacy Policy is subject to the law of Ontario, Canada, and you must bring any claims against us exclusively in the courts of Ontario, Canada.

 

20. CONTACTING US

If you have any questions about our Privacy Policy or about how we process your personal information, including any complaints, please contact us either by e-mail to privacy.officer@travcorp.ca, telephone on 1 (416) 322-8468, or by mail to Attn: Privacy Officer, 33 Kern Road, Toronto, Ontario M3B 1S9. For all compliance related matters, email privacy.officer@travcorp.ca.

 

21. COPYRIGHT NOTICE

This document, and all content of our sites is Copyright© 2019 Insight Vacations (Canada) Ltd. ALL RIGHTS RESERVED.

Costsaver Privacy Policy

Twitter @CostsaverTours
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Last updated: July 2021

  1. ABOUT THIS POLICY

This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data collection and processing, so you are fully aware of how and why we are using your data.

This privacy notice supplements other notices and is not intended to override them.

  1. OUR COMMITMENT

We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data.

  1. OUR LEGAL BASES FOR PROCESSING

We will process your personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal data unless at least one of the following requirements are met:

  • You have given consent to the processing of your personal data for one or more specific purposes;
  • The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
  • Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
  • Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (for instance, protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders). Please find below an indicative, non-exhaustive list of processing activities for which we may rely on legitimate interest:

PROCESSING ACTIVITY

BASIS FOR LEGITIMATE INTEREST

Direct marketing activities including tracking, profiling, segmentation, and communication across multiple channels, see section 8.8

Legitimate interest in promoting relevant services and products based on your relationship and interaction with us

Record keeping and reporting, see section 8.6

Legitimate interest in understanding and improving our business

Statistical analysis of customer data, see section 8.7 & 8.9

Legitimate interest in understanding and responding to customer behaviour and preferences

Provision of customer data to insurance providers, border authorities & other law enforcement agencies, see section 11.4 & 11.7

Legitimate interest in protecting and maintaining the safety of our guests and employees; legitimate interest in taking appropriate legal action in case of disputes

Processing of guest preferences and other information volunteered by the guest prior to a trip, see section 8.3

Legitimate interest in personalizing and improving the delivery of our services and products

Processing of customer data as part of prize draws, competitions, sweepstakes, and surveys, see section 6.4 & 6.5

Legitimate interest in engaging with our customers and promoting our products

Processing of customer data in the course of administration and maintenance of our websites and systems, see section 6.8 & 8.7

Legitimate interest in running our business and improving our systems

  1. CHANGE OF PURPOSE

We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal data, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal data for unrelated purposes, based on our legitimate Interest.

  • There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
  • For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
  • We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal data by law, as you will not be directly or indirectly identified. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
  • However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
  • We will not repurpose sensitive or special category data without a lawful basis for doing so and where we rely on Legitimate Interest; will ensure we conduct legitimate interest assessments (see section 3) and data protection impact assessments DPIA, prior to carrying out the proposed processing activity.
  1. WHO OUR PRIVACY POLICY COVERS

5.1 Our customers

Our privacy policy sets out how we process personal data relating to individuals who are:

  • booking or enquiring about booking travel services with or through us; or
  • the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you); or
  • customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal data as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

5.2 Examples of who this policy covers

We include in this privacy policy personal data we process relating to:

(1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers and employees of businesses and organisations booking with or through us);

(2) individuals in respect of whom any enquiry or booking is made with us by an agent;

(3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;

(4) individuals whose personal data is obtained from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes). 

5.3 When we are data processor only

Please however note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal data on their instructions.

5.4 Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, and any such individual whose personal data we process from time to time.

When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both:

(1) all such products and services which we supply or operate ourselves (including where we sub-contract); and

(2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

  1. WHAT TYPES OF PERSONAL DATA WE MAY PROCESS

This section summarises the types of personal data about you that we process:

6.1 Data concerning you as an individual

We may collect the following:

  • name,
  • age,
  • gender,
  • address,
  • telephone,
  • mobile,
  • fax,
  • e-mail,
  • Social networking contact details, your social posts about any of our trips and travel experiences.
  • photographs,
  • proofs of identity and address, copies of passports, driving licences, and utility bills,
  • card and other payment details, and financial information,
  • health information relevant to your planned travel and travel insurances held,
  • results of searches carried out against you (such as to verify your identity, address, and credit status),
  • your preferences,
  • Frequent flyer or travel partner programme affiliation and member number.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

6.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you:

  • business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.),
  • your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and
  • your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

6.3 Enquiry and Booking information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:

  • records of enquiries and searches for holiday and travel products made by or on your behalf,
  • details of your personal interests,
  • needs and other data relevant to your enquiry;
  • details of results, quotes, proposals, estimates and other information given in response to enquiries;
  • details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about;
  • details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator);
  • dates and times of travel;
  • price;
  • payment details (including card details);
  • passport information and visa information;
  • foreign exchange requirements and arrangements; and
  • Sensitive information such as health, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us.

6.4 Survey Information

Information collected or generated out of any surveys we conduct.

6.5 Competition Information

Information collected or generated out of any competitions or promotions we run.

6.6 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

6.7 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.

6.8 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

This information may include:

  • your IP address (a unique identifier allocated to your computer for your connection to the internet);
  • your computer device details (PC, tablet, smartphone, watch etc.);
  • the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using;
  • your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc);
  • your time-zone;
  • your browser plug-ins;
  • any web-page you came from, identified as the referrer web page address by your web browser;
  • cookies (as per our cookie policy https://www.costsavertour.com/en-ca/resources/privacy-policy)
  • identifiers assigned to you by third-party advertising providers and web beacons you interact with;
  • page response times;
  • download error;
  • pages and parts of pages you visit;
  • usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.;
  • services and products you viewed;
  • length of visit to website and pages;
  • page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).

This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

This information may also include:

  • data inputted into forms and fields;
  • registrations for any accounts,
  • forum,
  • feedback mechanism,
  • social functionality,
  • newsletters or other features of our site;
  • usernames and passwords,
  • log-in / out history, and settings;
  • actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review, or other social functionality on our website.

Such information will be treated as personal data and processed according to this privacy policy.

  1. HOW WE COLLECT OR GENERATE YOUR PERSONAL DATA

This section sets out the ways in which we may collect or generate personal data concerning you.

7.1 Visiting our website

By visiting and using our website you or your computer may provide personal data. This includes:  information which is automatically provided by your browser to our servers; information recorded on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. This is more detailed in our cookie policy https://www.costsavertour.com/en-ca/resources/privacy-policy

7.2 Data you provide

Your personal data will include data you provide (or later amend), whether:

  • from correspondence with you;
  • verbally to us over the phone or in person;
  • by filing in any field or form on a website;
  • by filling in any printed form we provide you with;
  • by e-mail;
  • from documents you provide us with; and
  • from updates to any information you provide to us from time to time.

This includes when you:

  • register or subscribe for any service, account, members, or loyalty program,
  • make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise;
  • send us your comments or suggestions;
  • subscribe to any newsletter or other publication;
  • and request sales and advertising information, including brochures.

7.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let [Brand Name] and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

  • Print materials
  • on our website
  • email activities
  • social posts
  • images on our trips
  • provide images to our trade partners to use on their websites, email marketing and other marketing initiatives
  • make available in our content feeds
  • We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods
  • Any other information provided to us by or in relation to you which concerns you as an individual.

7.4 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from:

  • providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries;
  • credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations;
  • Any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

7.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including:

  • in connection with responding to and dealing with any enquiry, booking or complaint; or
  • in performing any booking or other contract with you; or
  • through the analysis of your personal data; or
  • data gained from your use of our website according to our cookie policy.

We may record telephone calls with you for training and quality purposes.

  1. WHAT DO WE USE YOUR PERSONAL DATA FOR?

This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.

8.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities, and functions of our websites.  This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

8.2 Provide information and respond to enquiries

To provide information to you about our website, systems, and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.3 Bookings and other contracts

To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.4 Payments

To collect and make payments due and administer our accounts.  This is necessary for the preparation of any contract between us.

8.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.6 Record Keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.  This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.

8.7 Manage and improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;

  • to carry out surveys and analyse the results;
  • to run promotions and competitions;
  • undertake product or customer research/development;
  • to assist us in and help us to improve our sales;
  • to carry out other business development and improvement activities;
  • to provide training to our staff, sub-contractors and suppliers;
  • editorial, advertising, and marketing processes, including sharing of photographs which you have voluntarily participated in during our Trips. Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;

For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.  This is done on the basis of our legitimate interests in ensuring our business runs efficiently.

8.8 Direct marketing

To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you.  We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 10.1 for the types of products we may market to you this way.

8.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

8.10 Anything you have specifically consented to

For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.

8.11 Consequences of Not Providing your Data

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.

  1. PERIOD FOR RETAINING YOUR DATA

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you would like to know more about our data retention policy, please ask us.

  1. USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING

We do not use or disclose your personal data for direct marketing purposes unless:

  • we have obtained your consent to do so, such as through an opt-in box on any form or website of ours; and/or
  • you have made a booking with us and there is our legitimate business interest to do so for similar products or services.

If you do not want to receive direct marketing activities anymore, you can manage your communications preferences by following the link at the end of every of our electronic communications.

In addition to data protection law if we use your personal information for direct marketing purposes, we may also be subject to additional rules that regulate direct marketing, such as the EU Privacy and Electronic Communications Directive 2009/136/EC. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.

10.1 Direct marketing by us

We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services:

(1) offered by us;

(2) which can be booked with third parties through us;

(3) which can be booked with other companies within our group (i.e. the Travel Corporation Group); and

(4) offered by third parties selected by us. However, we will not pass any of your details to third parties without your prior and specific consent.

Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email or SMS). 

10.2 Direct Marketing by Third Parties

From time to time, we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number, fax number and preferences) to:

(1) other companies within our The Travel Corporation, which are bound by the same requirements set in this privacy policy; and

(2)  other companies which offer services that may enhance your travel experience or be able to help you to finalise your travel arrangements (“third parties”). Such third parties may then contact you directly with marketing information about services and products offered by them. Such third parties are not part of The Travel Corporation and are not bound by this privacy policy. However, we ensure that our partners will only contact you in the manner you agreed to (e.g. email, text) when providing your consent. 

10.3 Withdrawing from Direct Marketing

You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”

When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.

You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

  1. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We transfer your personal data to third parties in the following circumstances:

11.1 Credit Checks etc.

We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

11.2 Bookings and performance of contracts

We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;

  • to apply for visas on your behalf,
  • to collect payments to be made by you,
  • to investigate and respond to complaints, and
  • to enforce any booking or other contract with you.

Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.

11.3 Suppliers of travel and other services

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you.

We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator.  Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

11.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer.  Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

11.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.

11.6 Public forums etc.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.

11.7 Legal requirements

We may supply personal data to a government authority or regulator where required to:

  • comply with a legal requirement,
  • for the administration of justice or when required by a public enforcement body, or
  • for the purposes of customs, visas and immigration.

We may disclose your personal data where otherwise required by or permitted by law.  

11.8 Direct Marketing by third parties

We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent.  Please refer to the direct marketing section above for more information.

11.9 Business Customers who are businesses (not individuals)

If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data.  

If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

11.10 Business acquirers

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal data.

  1. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

Where we provide your personal data to a third party one of the following two circumstances will apply:

12.1 Processing on our behalf

In some cases, your personal data may be held and otherwise processed by others on our behalf.  We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy.  The sharing of your data is necessary for the performance of any contract with you and for the efficient provision of our services.

12.2 Processing on their own account

In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account.  In such case, they will have their own responsibility for your personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party and they will provide their privacy policy to you.

  1. LOCATION OF YOUR PERSONAL DATA

We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area (“EEA”) and the United Kingdom.

We will only send your personal data outside the EEA and the United Kingdom to companies either within our group or to parties with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA and the United Kingdom. You can find out about what adequate safeguards these are by contacting us using the details provided in Section 16 of this privacy notice.

  1. KEEPING YOUR DATA SECURE

14.1 Our security measures

 We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secured servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to the information;
  • using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions.

Unfortunately, transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal data to. We never contact you to ask you for your payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made.  Please let us know if you someone purports to contact you in our name.

  1. YOUR RIGHTS

You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure.  More information about your rights and our obligations can be found on https://www.priv.gc.ca. To exercise any of your rights below, please use a dedicated online form https://ttc.com/personal-data-request/, or send your request via email to compliance@ttc.com.

You may request the following information be provided to you:

  • whether we are processing personal data about you;
  • what personal data we are processing, including a request for a copy of your data;
  • what purposes we are processing data for;
  • from which sources we have collected the data;
  • who we disclose the data to;

We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case.

The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive. We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

15.1 Rectification

You have the right to have your personal data amended if it is inaccurate or incomplete.

15.2 Right to object

You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.

15.3 Erasure

You have the right to have your personal information deleted or removed in the following circumstances:

  • The data is no longer necessary for the purpose for which it was originally collected or otherwise processed;
  • Where you withdraw your consent, where consent was used as the legal basis for processing;
  • Personal data has been unlawfully processed;
  • When you object to the processing and we have no overriding legitimate interest for continuing the processing;
  • Erasure is required for compliance with a legal requirement; or
  • Data has been collected in relation to the offering of online services to a child.

When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete.

We have the right to refuse to act on a request of erasure if the data is necessary for:

  • Exercising the right of freedom of expression and information;
  • Compliance with a legal obligation;
  • The establishment, exercise or defence of legal claims;

15.4 Portability

You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller, when:

  • the processing is based on consent or on a contract; and
  • the processing is carried out by automated means.

15.5 Restrict Processing

You have the right to obtain from us the restriction of processing of your personal data where one of the following applies:

  • You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
  • The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
  • We no longer need the personal data for the purposes of the processing, but the data is necessary for you for the establishment, exercise or defence of legal claims;
  • You have objected to processing pending the verification whether our legitimate grounds override yours.

Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so.

We will inform you before the restriction of processing is lifted.

15.6 Right to withdraw your consent

You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 16 of this policy. See also section 10.3 for details as to how to object to our direct marketing communications.

15.7 Right to lodge a complaint with a supervisory authority

The laws we comply with are regulated by the Information and Privacy Commissioner of Ontario, 2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8. https://www.ipc.on.ca/.  In addition to your rights above, it is open to you, if you have a complaint or a concern, to seek assistance from this supervisory authority who has powers to compel us to comply with applicable laws and fine us for non-compliance.  However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have. You can contact us using the details provided in Section 16 of this our privacy notice.

Changes to this privacy policy

We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change.  You can check the top of the document to see the latest version in force.

Applicable Law and Disputes

Our privacy policy is subject to the law of Ontario, Canada, and disputes can be determined by the courts of Ontario, Canada.

  1. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any requests or complaints, please contact us either by e-mail to privacy.officer@travcorp.ca or by post to Attn: Privacy Officer, 33 Kern Road, Toronto, Ontario M3B 1S9.

  1. ABOUT US

This is the privacy policy of TRAFALGAR TOURS OF CANADA LIMITED. (referred to as "we", "us" or "our").  We are incorporated under the laws of Ontario, Canada. Our incorporation number is 0229915 and our incorporation address or registered office is 33 Kern Road, Toronto, Ontario, CANADA M3B 1S9. We are a member of TICO (Wholesale Registration # 1583987, Retail Registration # 50015870), ACTA, and CATO. 

  1. COPYRIGHT NOTICE

This document, and all content of our websites is Copyright© 2021 TRAFALGAR TOURS OF CANADA LIMITED. ALL RIGHTS RESERVED.

Lion World Travel Privacy Policy

Last Updated: July 2021

Canada Privacy Policy

1. About this Policy

This document (our “Privacy Policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and site users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this Privacy Policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.

2. Our Commitment

We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our sites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.

3. About Us

This is the privacy policy of LION WORLD TRAVEL LIMITED (referred to as "we", "us" or "our"). We are incorporated under the laws of Ontario, Canada. Our incorporation number is 449471 and our incorporation address or registered office is 33 Kern Road, Toronto, Ontario, CANADA M3B 1S9. We are a member of TICO (Wholesale Registration #: 1004818, Retail Registration #: 1031815) and USTOA.

4. Why We Collect, Use and Disclose Your Information

We will collect, use and disclose (‘process’) your personal information in accordance with applicable Canadian laws and applicable contractual obligations. More specifically, we will not process your personal information unless at least one of the following requirements is met:

• You have given consent to the processing of your personal information for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your photos/videos of experiences of our trips on social media and sharing emails of co passengers, that have agreed to stay in touch);

• The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);

• Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);

• Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip); and

• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (i.e., protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders).

5. Change of Purpose

We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal information, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal information for unrelated purposes, based on legitimate interest.

• There are some circumstances in which personal information may be processed for purposes that go beyond the original purpose for which the personal information was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.

• For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.

• We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal information by law, as you will not be directly or indirectly identified. For example, we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.

• However, if we combine or connect aggregated data with your personal information so that it directly or indirectly identifies you, we shall treat the combined data as personal information which will be processed as required under applicable Canadian laws.

6. Who Our Privacy Policy Covers

6.1 Our customers

Our Privacy Policy sets out how we collect, use and disclose personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal information as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

6.2 Examples of who this policy covers

We include in this Privacy Policy personal information we collect, use and disclose relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; and (4) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes).

6.3 When we are an information processor only

This Privacy Policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

6.4 Terms used in this policy

When we refer to "you" and "your" in this Privacy Policy, we refer to you, any such individual whose personal information we collect, use and disclose from time to time. When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

7. What Laws We Comply With

We collect, use, and disclose your personal information in accordance with applicable Canadian privacy requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA). Our data collection and use policies are also in compliance with European GDPR standards.

8. What Types Of Personal Information We Process

This section summarizes the types of personal information about you that we collect, use, and disclose:

8.1 Data concerning you as an individual

This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

8.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

8.3 Enquiry and Booking Information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

8.4 Performance Information

Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

8.5 Survey Information

Information collected or generated out of any surveys we conduct.

8.6 Competition Information

Information collected or generated out of any competitions or promotions we run.

8.7 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

8.8 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

8.9 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

This information may include:

• your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies (as per our cookie policy; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; Page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).

• This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our Privacy Policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally.

• This information may also include data inputted into forms and fields; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this Privacy Policy.

9. How We Collect Or Generate Your Personal Information

This section sets out the ways in which we may collect or generate personal information concerning you.

9.1 Visiting our website

By visiting and using our sites you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

9.2 Data you provide

Your personal information will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

9.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let LION WORLD TRAVEL LIMITED and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives

Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.

9.4 Data obtained from third parties

We may obtain personal information concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

9.5 Data generated by us

We and any suppliers or subcontractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or data gained from your use of our website. We may record telephone calls with you, but we will advise you of this fact in advance.

10. What Do We Use Your Personal Information For?

This section sets out the uses which we make of your personal information:

10.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

10.2 Provide information and respond to enquiries

To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

10.3 Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to collect, use, and disclose any transactions authorised or made with us which relate to you.

10.4 Payments

To collect and make payments due and administer our accounts.

10.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

10.6 Record keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

10.7 Manage and Improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, subcontractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

10.8 Direct marketing

To carry out direct marketing to you. See next section below for further information.

10.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

10.10 Anything you have specifically consented to.

For any purpose which we have obtained your consent to.

10.11 Consequences of not providing your Data

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Subject to applicable law, we may be legally required to provide your data to authorities when you travel.

11. Use of your personal information for direct marketing

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in on any form or website of ours in compliance with applicable Canadian law.

11.1 Direct marketing by us

Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide, or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will always have the opportunity to "unsubscribe" from receiving any of our e-mail or other communications at any time and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us. We provide an on-going opportunity to unsubscribe or opt-out of contact by us by accessing our Site or by e-mail to marketing@lionworldtravel.com or at the following telephone number: 1-800-387-2706.

If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive service-related messages.

11.2 Direct marketing by third parties

Subject to applicable Canadian law, where you have expressly consented to this, we may disclose your personal information which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements and promotions relating to products and services they offer, or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

12. Disclosure of your personal information

We disclose your personal information to third parties in the following circumstances:

12.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 Bookings and performance of contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or subcontractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

12.3 Suppliers of travel and other services

We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

12.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

12.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistant advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

12.6 Public Forums etc.

Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

12.7 Legal Requirements

We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

12.8 Customer Representatives

If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.9 Business acquirers

If our business is ever acquired by a third party, then your personal information will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this Privacy Policy to protect your personal information.

13. How Third Parties Will Handle Your Personal Information

Where we provide your personal information to a third party one of the following two circumstances will apply:

13.1 Collecting, using and disclosing on our behalf

In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this Privacy Policy.

13.2 Collecting, using and disclosing on their own account

In other cases, your personal information may need to be provided to them to be held and collected, used or disclosed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own Privacy Policy, and we will not be responsible for what they do with it following disclosure.

14. Location of your personal information

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use and disclose that information anywhere in the world.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from those in Canada or the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. Keeping your data secure

15.1 Our security measures

15.1.1 Our general commitment

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or subcontractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

15.1.2 Transmissions between your web browser and our servers

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

15.1.3 Storage of your personal information

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

15.2 Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

16. How long do we keep your personal information for?

We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability, we may have to you. If you would like to know more about our data retention policy, please contact us.

17. Your Rights

17.1 Access to your personal information

You may request us to tell you whether we are collecting, using, and disclosing personal information about you, to tell you what personal information we are collecting, using and disclosing and for what purposes, and to provide you with a copy of your personal information that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

If we refuse to provide you with access to information, we hold about you, we will provide reasons for such refusal.

17.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing and electronic communications

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

18. Changes to this Privacy Policy

We keep our Privacy Policy under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.

19. Applicable Law And Disputes

This Privacy Policy is subject to the law of Ontario, Canada, and you must bring any claims against us exclusively in the courts of Ontario, Canada.

20. Contacting Us

If you have any questions about our Privacy Policy or about how we process your personal information, including any complaints, please contact us either by e-mail to privacy.officer@travcorp.ca, telephone on 1 (416) 322-8468, or by mail to Attn: Privacy Officer, 33 Kern Road, Toronto, Ontario M3B 1S9. For all compliance related matters, email compliance@ttc.com.

21. Copyright Notice

This document, and all content of our websites is Copyright© 2021 LION WORLD TRAVEL LIMITED. ALL RIGHTS RESERVED.