INFORMATION ABOUT YOU
As a global travel company, we may collect non-public, personal information directly from our customers, other persons on our customers' bookings or their agents. We define “personal information” as information that is unique to an individual and might include the following information: name, contact details, travel preferences and special needs/disabilities/dietary requirements that you supply us or is supplied to us, including any information about other persons on your booking. Your personal information is collected when you request information from us, contact us (and vice versa) or make a booking. You are responsible for ensuring that other members of your party are aware of the content of our Policy and consent to your acting on their behalf in all your dealings with us. We will update your information whenever we can or as required by law to keep it current, accurate and complete.
Our Use of Your Personal Information
(1) For the purpose of providing you with our services, including your flight, tour or insurance, etc., we may disclose and process your information outside of Canada. In order for you to travel abroad, it may be mandatory (as required by government authorities at the point(s) of departure and/or destination) to disclose and process your personal information for immigration, border control, security and anti-terrorism purposes, or any other purposes which they determine appropriate. These requirements may differ depending on your destination and you are advised to check. Even if not mandatory, we may exercise our discretion to assist where appropriate.
(2) If we do receive your personal information, we will only use it for the purposes described where it is collected, and we will not sell, license, transmit or disclose this information outside of Brightspark unless (1) you expressly authorize us to do so, (2) it is necessary to allow our service providers or agents to provide services for us, (3) in order to provide our services to you (and contacting you where necessary), (4) it is disclosed to entities that perform marketing services on our behalf or to other entities with whom we have joint marketing agreements, (5) it is necessary in connection with a sale of all or substantially all of the assets of Brightspark or the merger of into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Brightspark is not the survivor, (6) it is necessary in connection with other business purposes including, without limitation, customer care, service quality, business management and operation, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends, dispute resolution, credit checking and debt collection, or (7) otherwise as we are required or permitted by law.
Contests, Sweepstakes and Other Promotions
On our website, you may wish to participate in contests, sweepstakes and other promotions that we may offer from time to time. Through these promotions, you may choose to participate in activities such as sharing information found on our websites with others and sending email invitations. If you choose to participate in these promotions, and are eligible to do so, we may ask you for information such as your name, email address, date of birth and telephone number.
In connection with any contests, sweepstakes and other promotions that we may offer from time to time via the website, we use the information you provide to administer the contests, sweepstakes and other promotions. We also may use the information to communicate with you, or the other people you select, about our products and services or our partners may use such information to communicate with you about the contests, sweepstakes or other promotions or their products and services. In connection with such contests, sweepstakes and other promotions, we will not use information you provide about other people for any purpose except the purpose you direct without first getting their consent.
Online Tour Center/Customer Portal
The online "Tour Center/Customer Portal" is an added feature of traveling with Brightspark. On the online Tour Center/Customer Portal, our “Tour Moderators/Sponsors” have access to information that assists in the smooth running of their particular tour; this includes but is not limited to passenger and account holder contact information and account status (not including information on credit card numbers). Passengers and account holders have access to their own personal information, and can alter their profiles online. Tour Moderators/Sponsors, passengers and account holders can view the group’s Tour Center/Customer Portal using the group’s randomly generated Booking ID. The Booking ID only allows access to general information on the tour that the group will be participating in or that the passenger has signed up to join. Once registered for a tour and having created your own user name and personal password (for users under the age of 13, see COPPA compliance statement below), Tour Moderators/Sponsors, passengers and account holders can view and post photos, blog entries, and important notices and documents that can only be posted by the Tour Moderator.
Chat Rooms, Discussion Forums, Bulletin Boards
If you participate in one of our chat rooms, discussion forums, or post messages to a website bulletin board, you should be aware that the information disclosed and shared will be broadly available to other persons, both inside of and/or outside of Brightspark who have access to that chat room, forum or bulletin board. Ultimately, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you're online. In addition, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return. Please also note that a participant’s expressed opinion is his or her own and should not be considered to reflect the opinion of Brightspark.
Children's Online Privacy Protection Act of 1998 (COPPA)
Brightspark does not sell products or services for purchase by children, and will not collect or post information from a child under the age of 13 without direct notice and verifiable consent of a parent or guardian (as defined by COPPA). The term parent throughout this Policy includes legal guardians. Brightspark has implemented procedures to protect the confidentiality, security and integrity of all users' information, including those of children of whom their parents have consented to such collection.
For activities directed towards children under the age of 13, Brightspark will attempt to contact the child’s parent at the e-mail address provided in the initial request for access, alert the parent to the child’s requested use of our website and provide instructions as to how the parent can confirm or reject the child’s request to register on the website. No known child under the age of 13 will be allowed to submit personal information without verifiable parental consent to do so. After consenting, the child's parent can request access to the child's information that has been collected by Brightspark, request that it be modified or deleted, or prohibit further use of the child's personal information. Brightspark does not use personally identifying information collected from children for marketing or promotional purposes, and does not disclose such information to any third party for any purpose whatsoever.
How We Protect Credit Card Information
We may provide you with the capability of posting to the Website or Tour Center/Customer Portal or otherwise supplying to Brightspark. information, data, text, music, sound, photographs, graphics, video, messages and other materials ("User Content"). By posting User Content on or through the Website or Tour Center/Customer Portal, you agree that you are solely responsible for the origination, accuracy, completeness, ownership, publication and dissemination of, and that you, and not Brightspark, are entirely responsible for, your User Content, obtaining and maintaining all rights, licenses, permissions, releases, approvals, clearances, credit, or attribution information relating to all User Content and paying any applicable royalties or fees in connection therewith.
By submitting or sending User Content to Brightspark, or otherwise making User Content available for display on or through the Website or Tour Center/Customer Portal, you grant Brightspark, its affiliates, and any third party suppliers, vendors, contractors, licensors or service providers of Brightspark ("Suppliers") the royalty-free, world-wide, non-exclusive license for Brightspark and its Suppliers to use, reproduce, modify, adapt, publish, translate, distribute, perform and display such User Content (in whole or part) as required to operate our website and Tour Center/Customer Portal.
Brightspark does not endorse and assumes no obligation to monitor or filter any User Content posted, or otherwise made available, on or through the website or Tour Center/Customer Portal. However, Brightspark (or a designee) reserves the right (but assumes no obligation) to, at its sole discretion, refuse, edit or remove any User Content, and may take any reasonable action it deems necessary or appropriate with respect to any User Content, that, in Brightspark's sole judgment, does not comply with this provision, is illegal, or is otherwise undesirable, inappropriate or inaccurate. Brightspark is not responsible for any failure, non-failure or delay in refusing, editing or removing such User Content.
Direct Marketing Material
We may from time to time contact you with information on offers of goods and services, brochures, new products, forthcoming events or competitions from our holiday divisions and our group companies. Our website will assume you to agree to e-communications when you make a booking. You may indicate your preference regarding receiving third party direct marketing material. If do not wish to receive such information or would like to change your preference, please refer to point (2) of “Your Rights” below.
We appreciate your questions and comments about our organization and services and welcome your email messages to mailboxes listed on our website. We will share your messages with those within our organization who are most capable of addressing the issues contained in your message. We will keep a copy of your message until we have had an opportunity to address your concerns. We may archive your message for a certain period of time or discard it once it is no longer needed.
(1) On completing our Access Request form or as otherwise required by law, you are entitled to a copy of the information we hold about you and to correct any inaccuracies.
(2) You have the right to ask in writing not to receive direct marketing material from us. If available, you can amend your previous preference on our website(s), use our “unsubscribe email” or refer to our literature containing instructions. Once properly notified by you, we will take steps to stop using your information in this way. Please allow us a reasonable period of time in order to satisfy your request.
(3) For a list of our group companies or brands, please send us your request.
Write to Brightspark, 3280 Bloor Street West, Suite 901, Centre Tower, Toronto, ON M8X 2X3, Attn: Privacy Officer, by email at email@example.com, or by phone toll-free at (800) 267-6425.
Use of Tools; "Cookies"
In addition to the information we collect from cookies, we also obtain information which you provide to us online - for example, when you sign up for service updates or when you purchase services or otherwise communicate with us. In some cases, we retain both the cookie information and/or the information you provide to us online - for example, to complete a transaction you requested or to keep historical records of your past transactions. In other cases, we only retain the cookie and/or online information you give us if you request us to do so for your use in subsequent sessions.
An Internet Protocol ("IP") address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our website, we may view the IP address (which may include the city, domain address and service provider) of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what regions of the world our website visitors come. We also may use this information to enhance our website.
Certain pages on our websites contain "web beacons" (also know as Internet tags, pixel tags and clear GIFs). These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party.
To ensure that we carry out your instructions accurately, improve our service and for security, we may monitor and/or record: (1) telephone calls; (2) activities using CCTV in and around our premises; and (3) transactions and activities on our website. All recordings are and shall remain our sole property. Such monitoring activities will only be conducted where permitted by applicable law.
We restrict access to personal information collected about you at our website to our employees or others who need to know that information to provide services to you or in the course of conducting our normal business operations. While no website can guarantee security, we maintain appropriate physical, electronic, and procedural safeguards to protect your personal information collected via this website.
Changes to this Policy
We may change this Policy at any time and from time to time. Any changes to this Policy will be either posted on our website, brochure and/or made available on request. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. This Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.
Links to Other Websites
For your convenience we may provide links to other websites and web pages that we do not control. We cannot be responsible for the privacy practices of any websites or pages not under our control and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages.
If you have any questions about this Policy or would like to learn more about how we protect privacy, Please write to Brightspark 3280 Bloor Street West, Suite 901, Centre Tower, Toronto, ON M8X 2X3, Attn: Privacy Officer, by email at firstname.lastname@example.org, or by phone toll-free at (800) 267-6425.
This Policy was last updated on September 2, 2011