CW Vacations is committed to protecting the privacy of its clients, employees and other individuals served by or providing services to CWVacations. The proper safeguarding of all personal information collected in the course of CWVacations day-to-day activities is the cornerstone of this commitment. Personal information is any information that identifies an individual, or by which an individual’s identity could be deduced.

CW Vacations adheres to the principles of the Canadian Standards Association Model Code for the Protection of Personal Information as well as those embodied in applicable privacy legislation to ensure that all information is properly collected, used only for the purpose for which it was collected, and disposed of in a safe and timely manner when it is no longer needed.

CW Vacations believes that your personal information deserves protection. While you can visit our websites without registering or providing any personal information, you will need to register if you want to make a purchase.

This Policy is subject to change, and may be supplemented or modified by additional terms applicable between CWVacations and an individual.

Definitions

Collection – the act of gathering, acquiring, recording, or obtaining personal information.

Consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express, implied or deemed, and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. Deemed consent is consent that is deemed to be given pursuant to applicable legislation or other regulations.

Disclosure – making personal information available to a third party.

Personal information – information about an identifiable individual, but does not include aggregated information that cannot be associated with a specific individual. Personal information also excludes certain information as is excluded pursuant to applicable legislation or other regulations, such as publicly available information or business contact information, as and when applicable.

CWVacations – CWVacations, and its subsidiaries and certain designated affiliates, as they may exist from time to time, including, but not limited to, CWVacations North America.

Third party – an individual or organization outside CWVacations.

Use – the treatment, handling and management of personal information by and within an organization.

Our Nine Privacy Principles

1. Accountability

CWVacations is responsible for maintaining and protecting the personal information under its control. CWVacations has appointed a Privacy Officer who is responsible for ensuring CWVacations compliance with its privacy obligations.

2. Identifying Purposes

CWVacations provides numerous travel services and products to a wide range of clients. CWVacations collects personal information in order to provide these services (i.e. make and book travel arrangements), establish and maintain client lists and records, establish and maintain mailing lists, identify fraud or error, to ensure regulatory compliance, for internal accounting and administration and servicing our relationship with our customers by communicating updates on promotions and services and performing market research.

For greater clarity CWVacations collects personal information for the following purposes:

a) to establish and maintain a responsible commercial relationship with customers;

b) for purposes identified to individuals or purposes obvious to individuals, in respect of particular collections of personal information;

c) to meet legal and regulatory requirements;

d) to understand needs and preferences of individuals;

e) to develop, enhance, market and/or provide CWVacations products, promotions and services;

f) to manage and develop CWVacations business and operations, including transfer of data among affiliated entities.

Further references to “identified purposes” mean the purposes identified in this Principle.

CWVacations also collects personal information from its employees for the purposes of establishing, maintaining or terminating the employment relationship including managing payroll, benefits, employee performance evaluations, making recruitment and selection decisions, and to meet legal, security or regulatory requirements.

CWVacations shall, as appropriate, specify orally, electronically or in writing the identified purposes to the individual at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within CWVacations who shall explain the purposes.

If CWVacations wishes to use personal information for a purpose not contemplated at the time of collection, the individual’s consent will be sought in advance.

3. Consent

The knowledge and consent of an individual are generally required for the collection, use or disclosure of personal information. In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual, such as in the case of an emergency where the life, health or security of an individual is threatened.

CWVacations may disclose personal information without knowledge or consent to a lawyer or other advisor representing CWVacations, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.

In obtaining consent, CWVacations shall use reasonable efforts to ensure that an individual is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the individual.

Generally, CWVacations shall seek consent to use and disclose personal information at the same time it collects the information. However, CWVacations may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.

CWVacations will require individuals to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is reasonably required to fulfill the identified purposes.

In determining the appropriate form of consent, CWVacations shall take into account the sensitivity of the personal information and the reasonable expectations of the individual.

Where consent is required for a particular use or disclosure, an individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact CWVacations for more information regarding the implications of withdrawing consent.

CWVacations primarily acts in the capacity of an agent and accordingly must disclose personal information to other companies that are involved in providing travel services and products to our clients in which case CWVacations will rely upon the express or implied consent discussed above. Companies registered in Canada may be required to provide information under the CANADIAN Act H.R. 3162. These third parties are required by CWVacations to safeguard the personal information and are not permitted to use it for any other purpose.

4. Limiting Collection

CWVacations shall only collect the personal information that is required to meet the purposes identified by CWVacations. CWVacations is committed to collecting personal information in a fair, open and lawful manner. For this reason, CWVacations does not indiscriminately collect personal information.

5. Limiting Use, Disclosure and Retention

CWVacations does not use personal information for purposes other than those for which it was originally collected, unless it has first obtained the consent of the person from whom such information was received. CWVacations retains personal information only for as long as it is needed and only for the fulfillment of the purposes for which it was originally collected.

6. Accuracy

Personal information shall be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purpose for which it was collected.

7. Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the personal information. CWVacations security safeguards include:

• premises security

• locked file cabinets

• restricted access to files containing personal information

• technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access

• internal passwords and security policies to control access to the CWVacations network and software

• policy prohibitions against unauthorized use or disclosure

If CWVacations uses the services of any third parties to process personal information, CWVacations will enter into legal agreements that require them to protect this personal information in a manner acceptable to CWVacations. In entering into these legal agreements, CWVacations does not transfer any interest in this personal information to them. Rather, the purpose of these legal agreements is to ensure that the personal information delivered to third parties is maintained at a level of security equal to that proved by CWVacations under this Policy.

CWVacations also ensures that any of its employees who deal with personal information are properly trained and are aware of the necessary and appropriate measures required to protect personal information.

CWVacations website may contain links to other sites. CWVacations is not responsible for the privacy practices or the content of such websites and encourages users to read the privacy statements of any such sites. Clients are reminded that no data transmission is 100% secure over the Internet.

8. Openness

CWVacations shall make available to individuals on whom it may keep records, all relevant information about CWVacations policies and practices that apply to the management of their personal information. This policy is available on our website at www.flightcentre.ca and can be accessed at any time. A hard copy of this policy is also available in each of our shops.

9. Individual Access

Upon request, CWVacations will inform an individual if CWVacations has any personal information about the individual under its care and control, as well as provide the individual with details about such personal information. CWVacations reserves the right to confirm the identity of the person seeking access to personal information before complying with any access request. In responding to an access request, CWVacations may charge a reasonable fee.

CWVacations is also committed to ensuring the personal information that is collected and maintained is accurate. An individual may challenge the completeness of the personal information under CWVacations care and control. Where an individual successfully demonstrates that an error in the accuracy or completeness of their personal information exists, CWVacations will amend the personal information accordingly.

CW Vacations may deny access to personal information when denial of access is required or authorized by law. Possible reasons for denying access to personal information include:

• when granting access would have an unreasonable impact on other people’s privacy

• to protect CWVacations rights and property

• where the request is frivolous or vexatious

If CWVacations is unable to provide access to all of the personal information it holds about an individual, then the reasons for the denial of access will be provided to the individual.