Privacy Policy
At IFS Voyages Inc. ("IFS") we are committed to maintaining the accuracy,
confidentiality and security of your personal information. This Privacy Policy
describes the personal information that IFS collects from or about you, how we
use and to whom we disclose that information.
IFS has developed a series of documents in order to address the specific
privacy concerns of certain groupings of individuals. This Privacy Policy
applies to the personal information of all individuals, unless the personal
information is related to an individual who seeks to be, is or was employed by
IFS. Such information is dealt with in the "Employee Privacy Policy".
If you are unsure of which Privacy Policy applies to you, please contact our
Privacy Officer for more information.
Privacy Policy Effective for Canada
It is IFS's policy to comply with the privacy legislation within each of
jurisdictions in which we operate. Sometimes the privacy legislation and / or an
individual's right to privacy are different from one jurisdiction to
another. This Privacy Policy covers only those activities that are subject to
the provisions of Canada's federal and provincial privacy laws, as applicable.
This Privacy Policy has a limited scope and application. Consequently, the
rights and obligations contained in this Privacy Policy may not be available to
all individuals or in all jurisdictions. If you are unsure if or how this
Privacy Policy applies to you, please contact our Privacy Officer for more
information.
What is Personal Information?
For the purposes of this Privacy Policy, personal information is any
information about an identifiable individual, other than the person's business
title or business contact information when used or disclosed for the purpose of
business communications.
What Personal Information do we Collect?
We collect and maintain different types of personal information in respect of
the individuals with whom we interact. This includes:
- contact and identification information, such as your name, address,
telephone number and e-mail address;
- product and service related information concerning the products and services
that we provide to, or receive from, you;
- credit and financial information such as your payment preferences; and
- business relationship information, including information related to your
agreements, preferences, advisors and decision-makers, feed-back and information
requested by or provided to you.
We may also collect market-related information, which may include personal
information, concerning market trends and activities impacting our
business. This information may include contract terms, financial information and
other information for the purpose of market analysis and strategic planning. We
may also collect information related to our media, investor and public relations
activities and information related to our interactions with financial and other
analysts and advisors.
As a general rule, IFS collects personal information directly from you. In
most circumstances where the personal information that we collect about you is
held by a third party, we will obtain your permission before we seek out this
information from such sources (such permission may be given directly by you, or
implied from your actions).
From time to time, we may utilize the services of third parties in our
business and may also receive personal information collected by those third
parties in the course of the performance of their services for us or
otherwise. Where this is the case, we will take reasonable steps to ensure that
such third parties have represented to us that they have the right to disclose
your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we
may collect information about you without your knowledge or consent.
Why Do We Collect Personal Information?
IFS collects personal information to enable us to provide you with
information or travel related services (such as air, ground and sea
transportation, hotel and other accommodation, tours, meals, services and
insurance products) that are sold or reserved through us. We use and disclose
your personal information in order to provide you with the requested
information, products or services. This includes:
- to establish, maintain and manage our relationship with you so that we may
provide you with, or receive from you, the products and services that have been
requested (for example, to make airline, hotel, car, tour and other reservations
or to obtain travel insurance policies on your behalf, to obtain credit card or
other financial information for payment, or to identify you and your
preferences);
- to be able to review the products and services that we provide to you so
that we may understand your requirements regarding our products and services and
so that we may work to improve our products and services;
- to be able to review the products and services that we obtain from you so
that we may work with you and so that you may understand our requirements for
such products and services;
- to furnish you, now and in the future, with information related to our
products and services by way of personalized communication, regular newsletters
or travel alerts;
- to compile business travel reports for your employer related to destinations
traveled, costs, classes of service, hotels used and duration of stay and car
rental companies used and duration of rentals;
- to research and suggest products and services to meet your communicated
needs;
- to compile reports for the suppliers and for regulatory and industry
agencies;
- to compile statistics and conduct market research;
- to protect us against error, fraud, theft and damage to our goods and
property
- to enable us to comply with applicable law or regulatory process; and
- any other reasonable purpose to which you consent.
How Do We Use and Disclose Your Personal Information?
We may use or disclose your personal information:
- for the purposes described in this Privacy Policy; or
- for any additional purposes for which we have obtained your consent to the
use or disclosure of your personal information.
We may use or disclose your personal information without your knowledge or
consent where we are permitted or required by applicable law or regulatory
requirements to do so.
When do we Disclose Your Personal Information?
We act as the agent or intermediary for or in respect of the suppliers (the
"Suppliers") of certain travel products and services. In addition to sharing
your personal information with our employees, contractors, consultants and other
parties who require such information to assist us with managing our relationship
with you, we may also share your personal information with the Suppliers.
In addition, personal information may be disclosed or transferred to another
party during the course of, or completion of, a change in ownership of or the
grant of a security interest in, all or a part of IFS or its affiliates through,
for example, an asset or share sale, or some other form of business combination,
merger or joint venture, provided that such party is bound by appropriate
agreements or obligations and required to use or disclose your personal
information in a manner consistent with the use and disclosure provisions of
this Privacy Policy, unless you consent otherwise.
Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements;
- to comply with valid legal processes such as search warrants, subpoenas or
court orders;
- as part of IFS's regular reporting activities to its affiliates;
- to protect the rights and property of IFS;
- during emergency situations or where necessary to protect the safety of a
person or group;
- where your personal information is publicly available; or
- with your consent.
Your Consent is Important to Us
It is important to us that we collect, use or disclose your personal
information where we have your consent to do so. Depending on the sensitivity of
the personal information, your consent may be implied, deemed (using an opt-out
mechanism) or express. Express consent can be given orally, electronically or in
writing. Implied consent is consent that can reasonably be inferred from your
action or inaction. For example, when you enter into an agreement with us, we
will assume your consent to the collection, use and disclosure of your personal
information for purposes related to the performance of that agreement and for
any other purposes identified to you at the relevant time.
Typically, we will seek your consent at the time that we collect your
personal information. In certain circumstances, your consent may be obtained
after collection but prior to our use or disclosure of your personal
information. If we plan to use or disclose your personal information for a
purpose not previously identified (either in this Privacy Policy or separately),
we will endeavor to advise you of that purpose before such use or disclosure.
As we have described above, we may collect, use or disclose your personal
information without your knowledge or consent where we are permitted or required
to do so by applicable law or regulatory requirements.
Choice/Opt-Out
You may change or withdraw your consent at any time, subject to legal or
contractual obligations and reasonable notice, by contacting our Privacy Officer
using the contact information set out below. All communications with respect to
such withdrawal or variation of consent should be in writing and addressed to
our Privacy Officer.
We assume that, unless you advise us otherwise, you have consented to the
collection, use and disclosure of your personal information as explained in this
Privacy Policy.
How is Your Personal Information Protected?
IFS endeavors to maintain physical, technical and procedural safeguards that
are appropriate to the sensitivity of the personal information in
question. These safeguards are designed to prevent your personal information
from loss and unauthorized access, copying, use, modification or disclosure.
Updating Your Personal Information
It is important that the information contained in our records is both
accurate and current. If your personal information happens to change during the
course of our relationship, please keep us informed of such changes.
In some circumstances we may not agree with your request to change your
personal information and will instead append an alternative text to the record
in question.
Access to Your Personal Information
You can ask to see your personal information. If you want to review, verify
or correct your personal information, please contact our Privacy Officer.
Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may
request specific information from you to enable us to confirm your identity and
right to access, as well as to search for and provide you with the personal
information that we hold about you. We may charge you a fee to access your
personal information; however, we will advise you of any fee in advance. If you
require assistance in preparing your request, please contact the office of our
Privacy Officer.
Your right to access the personal information that we hold about you is not
absolute. There are instances where applicable law or regulatory requirements
allow or require us to refuse to provide some or all of the personal information
that we hold about you. In addition, the personal information may have been
destroyed, erased or made anonymous in accordance with our record retention
obligations and practices.
In the event that we cannot provide you with access to your personal
information, we will endeavor to inform you of the reasons why, subject to any
legal or regulatory restrictions.
Inquiries or Concerns?
If you have any questions about this Privacy Policy or concerns about how we
manage your personal information, please contact our Privacy Officer by
telephone, in writing or by e-mail. We will endeavor to answer your questions
and advise you of any steps taken to address the issues raised by you. If you
are dissatisfied with our response, you may be entitled to make a written
submission to the Privacy Commissioner in your jurisdiction.
Privacy Officer
We have appointed a Privacy Officer to oversee compliance with this Privacy
Policy. The contact information for our Privacy Officer is as follows:
E-Mail:
mailto:privacy@funsunvacations.com
Address: 1221 St-Hubert Street, Montreal, Quebec, H2L 3Y8
Phone: 514-286-9747
Contact Name: Michael Alinauskas
Revisions to this Privacy Policy
IFS from time to time, may make changes to this Privacy Policy to reflect
changes in its legal or regulatory obligations or in the manner in which we deal
with your personal information. We will post any revised version of this Privacy
Policy on our website
http://www.funsunvacations.com/privacy/
and we encourage you to refer back to it on a regular basis. This Privacy Policy
was last updated on June 5, 2008.
Interpretation of this Privacy Policy
Any interpretation associated with this Privacy Policy will be made by our
Privacy Officer. This Privacy Policy includes examples but is not intended to be
restricted in its application to such examples, therefore where the word
'including' is used, it shall mean 'including without limitation'.
This Privacy Policy does not create or confer upon any individual any rights,
or impose upon IFS any rights or obligations outside of, or in addition to, any
rights or obligations imposed by Canada's federal and provincial privacy laws,
as applicable. Should there be, in a specific case, any inconsistency between
this Privacy Policy and Canada's federal and provincial privacy laws, as
applicable, this Privacy Policy shall be interpreted, in respect of that case,
to give effect to, and comply with, such privacy laws.
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