Introduction
On January 1, 2004 , the third phase of the Canadian
Federal Law about Personal Information Protection and Electronic Documents
Act (PIPEDA) came into effect. This Act governs information collected
as part of commercial activity by any private sector organisation.
It states that information must be gathered with consent, collected
for a reasonable purpose, used for the limited purpose for which it
was gathered, be accurate, be open for the owner's inspection and correction,
and stored securely. Gray Line West already maintains a high level
of security with respect to the confidentiality of your personal information
but we are now obligated by law to advise and obtain consent to the
terms of collection, disclosure and storage of your data.
The
following outlines our 10 principles to which we adhere in protecting
your personal information.
1. Accountability
Gray Line West is responsible to protect all personal information under
its control or transferred to a third party for processing. Personal
information can include name, home address and phone number, age, identification
numbers, credit information, customer preferences and other items that
personally relate to you as an individual. Gray Line West has appointed
a Privacy Officer, who is responsible for our accountability and compliance.
2. Identifying Purposes
Whenever personal information is collected
by Gray Line West, we will identify why the information is being
collected and how it will be used. If we have collected information
in the past, we will not use it for any other purpose than that expressly
stated at the time of collection. The reasons personal information
is collected by Gray Line West include:
- Guaranteeing a travel reservation;
- Identifying guest preferences and improving guest service;
- Establishing guest eligibility for promotional opportunities;
- Providing requested product information;
- Informing you of new products or services that may interest you.
Type of Information Collected
The type of information we collect
from you relates to your reservation or potential booking with us.
This may include: name, address, contact information, travel insurance
requirements, travel needs (medical/dietary or physical restrictions),
preferences, identity validation on services such as traveller's
cheques, credit information for payment purposes, and publicly available
information.
How
it's Collected
Information is collected directly from
you through surveys, online registration, and requests for information.
It is also collected through our call centre or sometimes through
third party partners who have made the reservation for you (Travel
Agencies, Tour Operators, Tour Wholesalers). Personal information
may also be collected through an employment application.
3.
Consent
Your
consent will be obtained either in person, through writing,
email, telephone, or the Internet. Sometimes consent may be implied
(e.g. when transferring relevant information to a hotel partner).
Also, Gray Line West may occasionally ask for written or verbal
confirmation that the information collected and maintained
is accurate and that your consent is still provided to maintain
this information.
Under
certain circumstances Gray Line West will need to disclose
your personal information without your consent. This may include:
- A life threatening or emergency situation;
- Where required by law; or
- Where required by law enforcement, legal investigation or
a regulatory body.
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4. Limiting Collection
Information collected will only be expressly
used for the purpose outlined at the time of collection. Gray Line
West will not indiscriminately collect or maintain personal information
on its guests or employees.
5. Limiting Use, Disclosure and
Retention
Gray Line West does not disclose your personal information
for any purposes other than, for which it was originally collected,
unless we have first obtained consent from you. We do not sell
or rent your personal information and we will not retain the information
for longer than is necessary to fulfill the purpose for which it
was originally collected.
6. Accuracy
Personal information
will be maintained in an accurate, complete and up-to-date
format as is necessary and reasonably practical to fulfill the purpose
for which it was collected.
7.
Safeguards
Gray Line West protects your personal information
by security safeguards, which are appropriate to the sensitivity
of the information. These include premises security; locked
filing cabinets; information technology security such as
restricted access to specific programs, firewalls and software
security; and restricting access to personal information
only to those employees and partners to which it is necessary.
We keep our employees up-to-date on policies and procedures
regarding protecting personal information.
We
may use the services of a third party to process personal
information. However, we ensure there are confidentiality
agreements in place so that your information is protected
while in their possession.
8.
Openness
Gray
Line West will make its policies and practices that
apply to the protection of personal information available to
anyone on which it holds information.
9.
Individual Access
Upon written request, Gray
Line West will inform you if we are maintaining
any personal information about you. If so, we will provide
it for your review of accuracy and completeness
and will amend it as appropriate. However, Gray Line
West reserves the right to confirm your identity
before providing this personal information. Gray
Line West can refuse access in certain circumstances
including when granting access would have an unreasonable
impact on the personal privacy of others, when
the request is frivolous or when it may impact Gray Line
West 's rights and property.
Requests
for access to your personal information should
be made in writing to the Privacy Officer by email
at
privacy_officer@graylinewest.com or
by mail:
Privacy Officer
Gray Line West
225 East 1 st Avenue
Vancouver
, BC V5T 1A7 |
10. Challenging Compliance
Gray Line West's compliance with this
policy may be challenged by directing concerns or complaints to the
Privacy Officer by any of the above-mentioned methods.
Use
of our Web Sites
You can visit our web sites without telling
us who you are or revealing any personal information, including
your e-mail address. Our web servers automatically recognize your
domain name when you visit our site, and this information is aggregated
and used to measure statistics regarding the use of our site, such
as the number of visitors, average time spent on the site, pages
viewed and similar information. However, this information is not
disclosed or shared with third parties.
Gray Line West's
goal in collecting personal information online is to continually
improve the content of our web sites and to offer guests with
tours that best meet your preferences and desires.
Gray Line
West reserves the right to change this policy at any time.
This policy is not intended to and does not create any contractual
or other legal rights in or on behalf of any party. By using the
Gray Line West web sites, you signify your agreement with the terms
of our privacy policy.
Gray Line West's web sites
include links to third party sites that are not governed
by our privacy policy. Once you leave Gray Line West's site we
will not be responsible for other companies' privacy practices.
We suggest you review their privacy policy before providing
personal information on these sites.