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Our Commitment to Your Privacy

PRIVACY POLICY
Your use of this Web site constitutes your agreement to the terms of this Privacy Policy as detailed below.

OUR COMMITMENT TO YOUR PRIVACY
At Travel Edge (USA) Inc. and Travel Edge (Canada) Inc. (collectively, “Travel Edge”), we are committed to protecting the privacy of personal information in our custody or control. This Privacy Policy explains how Travel Edge collects, uses and discloses personal information and the measures we have implemented to protect the personal information provided to us. This Privacy Policy applies to the personal information collected, used, disclosed or processed by Travel Edge in the course of its business. Travel Edge and its affiliated companies, including, without limitation, Kensington Tours Ltd., Travel Edge (Bermuda) Inc., Travel Edge ULC, and Century Travel Inc. (collectively, the “Affiliates”, and together with Travel Edge, the “Travel Edge Group”) operate in Canada, the United States and Bermuda.

As a provider of travel tour operator services to clients (a “Client”), Travel Edge collects, uses and discloses personal information of individuals authorized to travel as a Client (a “Traveller”). Anyone who submits personal information to us should understand the nature of our business and how their personal information is collected, used, disclosed or processed by Travel Edge.

In addition to this Privacy Policy, Travel Edge is subject to the requirements of applicable legislation and regulations relating to privacy, which may include the privacy laws of a foreign jurisdiction (“Privacy Laws”). Nothing in this Privacy Policy will limit Travel Edge’s rights and obligations pursuant to such Privacy Laws.

Travel Edge is committed to a high standard of privacy. It complies with applicable Canadian, and U.S. Privacy Laws, including federal and/or provincial/state privacy legislation in these jurisdictions and adopts the ten principles for the protection of personal information as set out below (“Privacy Principles”). The Privacy Principles for the collection, use and disclosure of personal information include:

1. Accountability
2. Identifying Purposes
3. Consent
4. Limiting Collection
5. Limiting Use, Disclosure and Retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual Access
10. Challenging Compliance

1. ACCOUNTABILITY

Travel Edge is responsible for personal information in its custody or under its control, including any personal information that has been transferred to a third party for processing. Travel Edge requires a comparable level of protection for personal information handled by its third party contractors.

Each Travel Edge office is responsible for maintaining and protecting the personal information of Travellers under its control. In fulfilling this mandate, each Travel Edge office has designated an individual or individuals who are accountable for compliance with this Privacy Policy.

In addition, Travel Edge has designated a corporate Privacy Manager to facilitate Travel Edge’s privacy compliance, in conjunction with senior leadership – who has overall responsibility for Travel Edge’s privacy compliance.

2. IDENTIFYING PURPOSES

Travel Edge shall identify the purposes for which personal information is collected, at or before the time the information is collected. When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use.

The primary purposes for which Travel Edge collects personal information include:

to establish and maintain responsive relationships with Clients and Travellers;
to provide travel tour operator services to its Clients including, without limitation, making travel arrangements on behalf of Travellers, providing travel policy compliance services, and collecting and reporting on Client travel data;
to understand Client and Traveller needs and preferences, including special requirements;
to obtain payment for services;
to develop, enhance, market or provide products and services, including, without limitation, to market or provide products and services through the Travel Edge Group;
to manage and develop Travel Edge’s business and operations;
to conduct surveys and promotions; and
to meet legal and regulatory requirements.

3. CONSENT

The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where required or permitted by law.

Travel Edge provides travel agent and tour operator services to clients. In order to complete these services, Travel Edge requires personal information for authorized Travellers. The personal information collected by Travel Edge may include, but is not limited to, name, address, age, marital status, passport and visa information, emergency contact, email, phone number, financial information and corporate data.

Travel Edge may also collect sensitive personal information related to a Traveller’s travel arrangements (such as the Traveller’s disabilities, allergies and other medical information and special needs) to help the Traveller obtain special accommodations for travel arranged by or through Travel Edge, but only if the Traveller submits such sensitive personal information to us. If a Traveller does not want us to collect and use such sensitive personal information, then the Traveller should not submit this information to us. Travel Edge will not share a Traveller’s sensitive personal information with a third party unless authorized to do so by the Traveller.

In order to complete the travel arrangements requested by the Traveller, Travel Edge may input the Traveller’s personal information into a unique proprietary operating system or provide the Traveller’s personal information to one of the global distribution systems or an internet booking engine (“GDS”) or other travel supplier. The GDS uses such personal information to aid in fulfilling the travel arrangements requested by a Traveller through specific travel suppliers, such as airlines, hotels and rental car agencies. Travel Edge receives confirmation of the travel arrangements requested by a Traveller.

Upon completion, Travel Edge provides information to the Client on travel arrangements made for a Traveller. This information may include, but is not limited to, information regarding the dates and times of travel, locations travelled to and from, classes of service provided, the names and locations of any hotels or other lodging arranged for the Traveller by Travel Edge, the names of other travel suppliers providing services to the Traveller, and the costs incurred for all travel services selected by the Traveller. A Traveller’s personal information may also be shared with the Client for which a Traveller is making travel arrangements.

Travel Edge does not exercise any control over personal information that has been transmitted to the GDS or other travel suppliers. By submitting personal information to Travel Edge, the Traveller authorizes the use and disclosure of such personal information to complete the travel arrangements requested by the Traveller. Personal information transferred to a travel supplier will be used by such supplier in accordance with their privacy policies, many of which contain provisions similar to the provisions contained in this Privacy Policy. Personal information transferred to a supplier may be subject to the Privacy Laws of a foreign jurisdiction. In addition, United States or other government and law enforcement authorities may have access to a Traveller’s personal information under certain security screening protocols.

A Traveller may choose not to have any of his or her personal information disclosed or transferred to third parties in accordance with the terms of this Privacy Policy. However, if a Traveller chooses not to submit his or her personal information to Travel Edge or allow Travel Edge to provide such personal information to a GDS or other travel supplier, then Travel Edge may not be able to provide the travel services requested.

By contacting Travel Edge and requesting travel services information, a Client is consenting to the collection, use or disclosure of Traveller personal information in accordance with the purposes identified in Section 2 of this Privacy Policy. Travel Edge 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. A Traveller may withdraw their consent to the collection, use or disclosure of their personal information by the Travel Edge Group at any time by contacting us at privacy@traveledge.com. This will be subject to legal or contractual restrictions and reasonable notice. Travel Edge will inform the Traveller of the implications of withdrawing Traveller’s consent. Withdrawal of consent does not have retroactive effect.

Travel Edge may be required or permitted to disclose personal information from time to time in order to comply with legal requirements and will comply with applicable Privacy Laws in doing so.

In addition to collecting, using and disclosing personal information in connection with the provision of services, Travel Edge may collect personal information from its employees and this personal information may be transferred among Travel Edge and its Affiliates, and may be subject to the Privacy Laws of a foreign jurisdiction. Employee personal information is not subject to PIPEDA, however, Travel Edge handles employee personal information in accordance with the Privacy Principles (to the extent possible) and Travel Edge’s human resources policies.

4. LIMITING COLLECTION

Travel Edge limits the collection of personal information to that which is necessary for the purposes identified by Travel Edge. Personal information must be collected by fair and lawful means.

Travel Edge collects, stores and processes only that personal information required to provide travel tour operator services for or to fulfil contractual obligations with regard to Travellers and Clients.

5. LIMITING USE, DISCLOSURE AND RETENTION

Travel Edge shall only use or disclose personal information for the purposes for which it was collected unless the individual has otherwise consented, or when it is required or permitted by law.

Personal information is retained only for the period of time required to fulfil the purposes for which it was collected.

Personal information is only used by Travel Edge Group employees or agents who have a business need to know such information or whose duties so require, and only as necessary to fulfil that function. Travel Edge Group employees are subject to this Privacy Policy and any Travel Edge Group employee who utilizes personal information improperly may be subject to discipline, up to and including termination of employment.

6. ACCURACY

Personal information is maintained by Travel Edge in as accurate, complete and up-to-date form as is necessary to fulfil the purposes for which it is to be used. Travel Edge relies upon the accuracy of the personal information submitted by the Traveller in order to provide the specific travel services, and does not routinely update that information.

7. SAFEGUARDING INFORMATION

Personal information of Travellers is protected by security safeguards that are appropriate to the sensitivity of the information.

Keeping a Traveller’s personal information confidential is important to us and Travel Edge takes reasonable steps to protect that information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. Travel Edge employs physical, administrative and technological safeguards to protect the security of personal information. For example, Travel Edge has implemented physical security measures to protect against unauthorized access to its central and backup data centres where personal information is stored.

Any credit card information is transmitted in an encrypted format using standard SSL (secure socket layer) encryption. Travellers should use caution when disclosing personal information by telephone or other electronic media, as Travel Edge has no control over such third party providers.

Travel Edge conducts periodic internal reviews of its data collection, storage and processing practices and the security measures it has implemented to ensure that such security measures provide reasonable precautions and are commensurate with those generally practiced within the travel management industry.

As with all personal information, Travel Edge will never rent or sell a Traveller’s personal financial information.

Travel Edge employees who have access to personal information are bound by confidentiality obligations, the violation of which will subject the employee to discipline, which may include termination of employment.

8. OPENNESS

Travel Edge makes information available to individuals concerning the policies and practices that apply to the management of their personal information, including as set out in this Privacy Policy.

Individuals may contact us at privacy@traveledge.com if they have any questions about our privacy practices. If you would prefer to contact us in person, our telephone number is 647-943-8998, extension 4245, and you may ask for the Privacy Manager.

9. ACCESS

Upon request, an individual shall be informed of the existence, use and disclosure of their personal information, and shall be given access to it. Individuals may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.

Travel Edge will use good faith efforts to provide its Clients, Travellers, and others from whom it obtains personal information the opportunity to review and revise the personal information Travel Edge has collected. Any review and revision of personal information by such persons is subject to the provisions of this Privacy Policy.

If a Traveller becomes aware of any inaccuracy in his or her personal information or if a Traveller wishes to inquire about his or her personal information, then the Traveller should notify us by contacting us at privacy@traveledge.com. Travel Edge will make all corrections and/or deletions of erroneous personal information brought to its attention within a reasonable time period. Travel Edge will provide access to personal information in accordance with the requirements of applicable Privacy Laws.

10. HANDLING COMPLAINTS AND SUGGESTIONS

Individuals may direct any questions or enquires with respect to this Privacy Policy or about our practices by writing to privacy@traveledge.com or calling 647-943-8998, extension 4245, and asking for the Privacy Manager, or by contacting the designated person accountable for privacy in each Travel Edge office.

A Traveller who thinks that his or her personal information has been misused should direct any questions or complaints to Travel Edge at privacy@traveledge.com, providing a written description of the complaint. After receiving a written description of the complaint a representative of Travel Edge will contact the Traveller in order to discuss his or her concerns. Travel Edge is interested in addressing all legitimate complaints about its adherence to applicable Privacy Laws and will make a good faith effort to resolve promptly any complaint brought to its attention.