SCOPE OF THIS POLICY
This Personal Information Protection Policy sets out the principles which West Coast Curated and its affiliates (Tourism Vancouver, Vancouver’s North Shore Tourism, Tourism Burnaby, Tourism Langley, Tourism New Westminster) observe regarding the collection, use and disclosure of personal information about any identifiable person, including its members, and members of the public who use West Coast Curated’s services and facilities, but excluding West Coast Curated employees and volunteers.
This Personal Information Protection Policy is subject to all applicable laws.
If personal information is made anonymous by removing details so that an individual is not identifiable to the user or recipient of that information, it is not governed by this Policy but will still be treated with appropriate safeguards.
DEFINITIONS
For the purposes of this Personal Information Protection Policy:
“Contact information” means information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual.
“Cookies” means small pieces of data that web pages place in devices (e.g., computers or mobile phones) to assist in returning to that page.
“Customers” and “members” includes current, past and prospective customers and members. This Policy is subject to all applicable laws; and
“Personal information” means any information about an identifiable individual, whether it was collected before or after this Policy was first published, including but not limited to the individual’s name, address, age, gender, identification numbers, income, employment, assets, liabilities, credit card numbers, credit ratings, financial plans and other finance-related information. “Personal information” may also include a physical description, habits, personality, character, marital history, immigration status, travel or movement details, lifestyle, leisure activities, professional or trade union memberships, and licences and permits held. Personal information does not include contact information. With respect to any specific individual, West Coast Curated may or may not have personal information within these enumerated categories.
PRINCIPLE 1 – WEST COAST CURATED’S ACCOUNTABILITY
West Coast Curated is responsible for all personal information under its control. West Coast Curated has designated The Tourism Vancouver Privacy Officer (the “Privacy Officer”) as the Privacy Officer for West Coast Curated. The Privacy Officer is accountable for West Coast Curated’s compliance with the principles described in this Policy, and may be contacted at:
The Privacy Officer
Tourism Vancouver
Suite 210-200 Burrard Street
Vancouver, BC V6C 3L6
Telephone : 604-682-2222
Email: [email protected]
West Coast Curated has established and implemented: (a) procedures to protect personal information; (b) procedures to receive and respond to complaints and inquiries; (c) employee and volunteer training and information programs to explain this Policy and related personal information protection procedures and practices; and (d) practices to ensure that clients and other individuals who contact West Coast Curated have access to this Policy and to other literature explaining West Coast Curated’s related personal information protection practices and procedures.
PRINCIPLE 2 – THE PURPOSES FOR (AND THE MANNER IN WHICH) WEST COAST CURATED MAY COLLECT, USE OR DISCLOSE PERSONAL INFORMATION
Subject to applicable law, West Coast Curated will identify the purposes for which personal information is collected, used or disclosed before that information is collected, used or disclosed, as the case may be.
General Purposes
The general purposes for which West Coast Curated may collect, use or disclose information concerning customers and members include the following: (a) to manage and promote West Coast Curated’s operations; (b) to better understand the needs of West Coast Curated’s customers and members, to provide promotional and other information about West Coast Curated and the Greater Vancouver area, and to respond to specific requests; (c) to fulfill requests for reservations, bookings or other arrangements with third parties; (d) to operate and fulfill contests; and; (e) to comply with legal and regulatory requirements.
Disclosure to Affiliates, Agencies and Service Providers
West Coast Curated may transfer personal information to a third party for processing or to provide services, including third parties for whom West Coast Curated acts as a booking or reservations agent, but uses contractual or other means to provide a comparable level of protection while the information is in the custody of that third party.
We may allow our service provider to place cookies on your devices and collect the IP address of your devices, which provides our service provider with your general location data. Our service provider may use this data to serve you with advertisements, on our website or elsewhere online, and to report to us on an aggregated basis on the effectiveness of our advertisements at inspiring tourists to travel to the Greater Vancouver area and provide us with statistics on visitors of the Greater Vancouver area (for instance, where they are coming from). In order to do so, our service provider may combine your IP address with other information that our service provider has obtained from other sources, as permitted by law. If you wish to opt out of third party cookies that allow us to serve advertisements and collect aggregate information on arrivals at the Greater Vancouver area click Here. If you opt-out, our service provider will also cease collecting information about your IP address from other sources.
Changed Purposes
From time to time, West Coast Curated may wish to use or disclose personal information for a purpose other than that for which it was initially collected. West Coast Curated will ensure that personal information is not used or disclosed for that new purpose unless the individual is informed of the new purpose and gives his or her consent.
PRINCIPLE 3 – CONSENT
Subject to applicable legal exceptions, West Coast Curated will make a reasonable effort to ensure that the individual is advised in advance of the purposes for which his or her personal information will be collected, used or disclosed, and that his or her consent to those activities is obtained. As required by applicable law, consent may be express or implied.
West Coast Curated does not, as a condition of the supply of products or services require an individual to consent to the collection, use or disclosure of personal information beyond that required to fulfill West Coast Curated’s explicitly specified, and legitimate purposes.
An individual may withdraw his or her consent to collection, use or disclosure at any time, subject to legal or contractual restrictions and the provision of reasonable notice to West Coast Curated. If an individual withdraws his or her consent to the collection, use or disclosure of personal information, he or she may be unable to access West Coast Curated’s products or services.
From time to time, West Coast Curated may also collect information from external sources such as credit reporting agencies, credit grantors and income sources and personal references identified to West Coast Curated for this purpose.
PRINCIPLE 4 – LIMITING COLLECTION
West Coast Curated limits the amount and type of personal information collected to that which is necessary for the purposes identified by West Coast Curated.
PRINCIPLE 5 – LIMITING USE, DISCLOSURE AND RETENTION
West Coast Curated does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information is retained only as long as necessary for the fulfillment of those purposes.
Personal information that has been used by West Coast Curated to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made.
PRINCIPLE 6 – ACCURACY
West Coast Curated aims to keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. However, West Coast Curated does not routinely update personal information, unless such updating is necessary to fulfill the purposes for which the information was collected.
West Coast Curated generally relies upon individual customers and members to provide updated information, such as changes to addresses and other contact information, and changed financial information.
If an individual successfully demonstrates to West Coast Curated that personal information is inaccurate, incomplete, out of date, or irrelevant, West Coast Curated will revise the personal information. If necessary, West Coast Curated will disclose the revised personal information to third parties which were provided with the wrong information to permit them to revise their records as well.
PRINCIPLE 7 – SAFEGUARDS
West Coast Curated has implemented appropriate security safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards varies depending on the sensitivity of the personal information that has been collected, the amount, distribution, and format of the information, and the method of storage. The more sensitive personal information is safeguarded at a higher level of protection.
The methods of protection employed by West Coast Curated include: (a) physical measures, including locked filing cabinets and restricted access to offices; (b) organizational measures, such as security clearances and limiting access on a “need to know” basis; and (c) technological measures, such as the use of passwords and encryption.
West Coast Curated takes care to inform employees and volunteers about West Coast Curated’s policies and procedures for protecting personal information and emphasizes the importance of complying with them. Employees and volunteers are required to conform to West Coast Curated’s policies and procedures concerning the security of personal information.
West Coast Curated uses care in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.
PRINCIPLE 8 – OPENNESS
West Coast Curated strives to be open about its policies and procedures with respect to the management of personal information. West Coast Curated makes this information available in a form that is generally understandable. Copies of this Personal Information Protection Policy are by contacting the Privacy Officer.
PRINCIPLE 9 – INDIVIDUAL ACCESS
Upon an individual’s request in writing, West Coast Curated will inform that individual of the existence, use, and disclosure of his or her personal information and the individual will be given access to that information, except where the law requires or permits West Coast Curated to deny access. West Coast Curated may require the individual to provide sufficient information to permit West Coast Curated to provide an account of the existence, use, and disclosure of personal information.
West Coast Curated will respond diligently to a proper request and in any case not later than 30 days after receipt of the request unless that time is extended according to applicable law. As permitted by applicable law, certain charges may be applicable in respect of certain requests.
PRINCIPLE 10 – CHALLENGING COMPLIANCE
Any individual may direct a challenge concerning compliance with this Personal Information Protection Policy to the West Coast Curated Privacy Officer. West Coast Curated has established procedures to receive and to respond to complaints or inquiries about West Coast Curated’s policies and practices relating to the handling of personal information.
West Coast Curated investigates all complaints. If West Coast Curated finds that a complaint is justified, West Coast Curated will take appropriate measures, including, if necessary, amending its policies and practices.