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ELDERTREKS PRIVACY POLICY
OUR COMMITMENT TO YOUR PRIVACY
Passages Exotic Expeditions Ltd (ElderTreks) is committed to maintaining the accuracy, security and privacy of personal information which is provided to us by our customers and other individuals and organizations who we do business with.
This Privacy Policy sets out the principles and practices which we will use in protecting personal information that you provide to us.
TYPES OF PERSONAL INFORMATION THAT WE COLLECT
We may collect personal information from you or about you (and those traveling with you) either directly or through authorized third parties in person, over the telephone, in written documents, on the Internet, or through surveys, promotions or incentive programs. The types of information that we collect include the following:
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Information to permit us to identify and contact you such as your name, address, telephone number, e-mail address and language preference.
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Travel-related information such as passport and citizenship identification information.
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Demographic and marketing information about you such as your age, education, occupation, marital and family status, information on your preferences, interests, traveling intentions and your experience with competitor products and services.
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Product performance and customer satisfaction information such as product surveys and your experience in using our services.
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Financial and credit information which may be collected by us and, with your consent, shared with our suppliers or with other providers of travel-related services.
MEANING OF PERSONAL INFORMATION
Personal information in this policy means information about an identifiable individual as that term is defined in applicable Canadian federal, provincial or territorial privacy legislation in effect from time to time. As a general rule, Canadian privacy legislation does not consider personal information which is business-related information - such as the information which is shown on a person’s business card - to be personal Information. Likewise, non-identifiable personal information - which means information about an individual where the personal identifiers have been removed, so that it is impossible to determine the identity of the person to whom the information relates - is not considered to be Personal information.
GIVING CONSENT
The collection and user of personal information normally requires the consent of the person giving the information. However, consent requirements vary depending up on the circumstances in which personal information is collected and the purposes that it will be used for. In many instances written consent is not required and may be implied where it is reasonable to do so. Similarly, there may be situations where consent will be legally deemed to have been given. From time to time, we may collect or use your personal information for purposes not specified in this Privacy Policy, in which case we will obtain your written consent, if legally required.
When you provide personal information to us, you agree that we may collect and use the information that you have provided in accordance with this Privacy Policy. You also represent, in the case of personal information of any other individual that is provided by you to us, that you have the authorization and consent of that individual to permit us to collect and use that individual’s personal information in accordance with this Privacy Policy.
When you provide personal information on our website you will never be added to our distribution lists for our marketing material unless you opt-in.
If you do not want to be contacted for product, service or marketing purposes, of if you want to be removed from our direct marketing programs, telemarketing, direct mail or e-mail lists, please contact our privacy office as indicated below. Except as required or permitted by applicable laws, you have the right at any time to withdraw your consent to our collection and user of your personal information. We will take steps following receipt of your written requires to amend our records to reflect your request.
Please note however, that in certain circumstances such as matters relating to law enforcement and public or personal health, safety, security or property, or for the purpose of collecting monies owed to us, applicable laws may require or allow us to collect, use or disclose your Personal information without your consent. In such circumstances, we will only disclose your Personal information to the extent that it is required.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal information in various ways.
From you: For example, when you purchase one of our travel products, participate in a contest or survey, respond to an offer or program, requires information or brochures or when you use the interactive portions of our website.
From Our Authorized Dealers or Distributors: For example, when you purchase our travel products from one of our authorized dealers or distributors.
From our contractors: We collect and use personal information, with your consent, from business organizations that we may contract with from time to time, for example, in connection with marketing and promotional activities, conducting customer surveys, etc.
From our website: We do not collect personally identifiable information on our website unless you knowingly provide it to us, for example, when you use our website to send us an e-mail message, request a brochure, etc. Our website makes use of cookies to collect information such as the type of browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average tie spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique alphanumeric identification number that identifies the visitor’s browser, but does not capture any personally-identifiable information. Our website automatically collects non-identifiable personal information on an aggregated basis. For example we may track the total number of visitors to our website during a 24-hour period, but this information does not allow us to personally identify individual visitors. If you do not agree with our Privacy Policy, please do not provide us with any Personal Information through our website.
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal Information to:
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Identify and communicate with you.
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Provide you with marketing, product, service and incentive offers and information from ourselves and our business partners.
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Conduct market surveys, research and analysis.
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Manage our relationship with you.
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Comply with safety, security, legal and regulatory requirements.
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Protect our reasonable and legitimate business interests.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We do not sell or rent your personal information for profit to any third party. We only disclose your Personal Information to fulfill the purposes that it was collected for or to satisfy legal requirements. Examples of this include the following:
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We may provide your personal information to other travel organizations that we deal with in connection with your bookings and reservations. Examples of this would include airlines, steamship lines, tour bus tour lines, hotels, travel agents, local tour group operators, etc.
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We may provide your personal Information to authorized third party contractors who perform services on our behalf, such as conducting market research, performing product satisfaction surveys, etc. We require all of our contractors who have access to your personal Information to keep the information confidential and to restrict its use to those purposes for which we have engaged them.
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Our records of your personal Information may be periodically updated by our third party contractors or by our own communications with you. This updated personal Information may be shared by us with our authorized dealers, distributors and/or suppliers in order to better serve you.
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In emergency situations, we may be required to share your personal information with health care providers, doctors, nurses, hospital, air ambulance operators, etc.
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As we continue to develop our business, we may at some future date become involved in a transaction in which one of our business units may be acquired or considered for acquisition by a third party. In such circumstances, your personal Information would be transferred and/or could be the subject of due diligence investigations by the third party.
SECURITY OF YOUR PERSONAL INFORMATION
Your personal Information is stored at secured locations either at our offices or at the offices of tour authorized contractors. We retain your personal Information for as long as we require it to fulfill the purpose that it was collected for.
To protect the confidentiality of your personal Information, we employ administrative and technological safeguards appropriate to sensitivity of your personal Information. For instance, we operate computer systems which are protected by industry standard firewall and password protection systems. Lastly, we take steps to ensure that your personal information is only accessible by personnel who have legitimate business need to have access to it.
UPDATING YOUR PERSONAL INFORMATION
We make reasonable efforts to keep your personal Information current and accurate. For example, we use contracted third parties to update our records from time to time. We also update our records based on information provided to us by our Dealers.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You can access and correct your personal Information by sending a written requires to our office at the address indicated below. At the time of your request, we may request you to provide specific information in order to permit us to verify your identity. In the event that any of your personal Information is found to be incomplete or inaccurate, we will take reasonable steps to correct your personal Information record.
Please note that there may be instances where we may not be able to permit you to access or correct your personal Information. Examples of this could include personal Information which:
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Contains references to another person(s),
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Which would involve the disclosure of confidential information,
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Could result in harm or loss to another person(s),
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Could interfere with the activities of law enforcement agencies or statutory bodies,
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Is not readily retrievable, or where the cost of retrieving it would be prohibitive or disproportionate to its value or usefulness,
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Has already been destroyed due to legal requirements, or because its continued retention was unnecessary,
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Is subject to solicitor-client or litigation privilege, or
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Cannot be disclosed for legal reasons.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy we will post the revised policy on our website where it will be available to you.
APPLICATION OF THIS POLICY
This Privacy Policy does not apply to personal Information that we may collect from employees of ElderTreks, the protection of which is governed by other ElderTreks policies.
This Privacy Policy also does not apply to products or services which we may make available to our customers but which are supplied by independently owned and operated third party business organizations. These organizations are not owned or controlled by ElderTreks and may have their own personal Information privacy policies which may apply to your personal Information. For further information, you should consult with the applicable organization.
FURTHER INFORMATION
For information on ElderTreks' privacy practices, or if you have any questions or concerns, please write us at:
ElderTreks (Passages Exotic Expeditions Ltd.)
23 Clinton Street
Toronto, Ontario, Canada M6J 2N9