Last Updated: February 11, 2019
Table of Contents
- About this document
- Your consent
- Copyright notice
- About us
- Third parties
- Our commitment
- What laws we comply with
- What types of personal information we collect, use, and disclose
- How we collect or generate your personal information
- What we use your personal information for
- Use of your personal information for direct marketing
- Disclosure of your personal information
- How third parties will handle your personal information
- External links
- Location of your personal information
- Our security measures
- Your security measures
- How long do we keep your personal information for?
- Your rights
- Applicable law
- Contacting us
This document, and all content of our websites is copyright of FarCloser Travel.
If you provide personal data directly to third parties (including affiliates, suppliers, tour operators, etc.) the terms of their respective privacy policies will apply to such disclosures. You should carefully review the privacy policies of these third parties prior to providing personal data to such third parties.
We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we have adopted. This way you can feel confident about how we handle your personal data that you entrust to us.
7.1 Our customers
7.2 Examples of who this policy covers
(1) individuals who are making any inquiry or booking with us or through us, and individuals in respect of whom any inquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us);
(2) individuals in respect of whom any inquiry or booking is made with us by an agent; and,
(3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors.
7.3 Terms used in this policy
We collect, use, and disclose your personal information in accordance with applicable Canadian privacy requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Information Protection Act (PIPA), and applicable Canadian Anti-Spam legislation (CASL).
This section summarizes the types of personal information about you that we collect, use, and disclose:
9.1 Data concerning you as an individual
This can include your name, age, photograph, gender, address, telephone, mobile, fax, email, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.
9.2 Business related information
If you are an individual associated with a business or other organization that is our customer, then your personal information may include the following information that we link to you: business or organization details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organization (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work email address).
9.3 Inquiry and booking
Information concerning inquiries and bookings made with or through us for FarCloser Travel Services, including where you are making the inquiry or booking or are the recipient of the FarCloser Travel Services to which the inquiry or booking relates. This information may include: records of inquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your inquiry; details of results, quotes, proposals, estimates and other information given in response to inquiries; details of the holiday, accommodation, travel, car rentals, and other FarCloser Travel Services booked or inquired about; details of the passengers travelling; details of the provider of the FarCloser Travel Services (e.g., tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and, sensitive information such as health, medical, dietary, mobility, disability, religious, or other special conditions or requirements.
9.4 Payment information
To use certain features of the FarCloser Travel Platform (such as booking or creating a Listing), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via FarCloser Travel).
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other FarCloser Travel Services, and information relating to payments to be made.
9.6 Survey information
Information collected or generated out of any surveys we conduct.
9.7 Competitions or promotions
Information collected or generated out of any competitions or promotions we run.
9.8 Account, registration, and loyalty information
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
Correspondence, communications and messages between us, through us and third parties to any booking or booking inquiry, or performance of any contract.
9.10 Website usage information
We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.
This information may also include: data inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in/out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and, posts to any forum, feedback, review or other social functionality on our website.
9.11 Location information
When you use certain features of the FarCloser Travel Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. FarCloser Travel may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
9.12 Information we may collect from third parties
If you link, connect, or login to your FarCloser Travel Account with a third-party service (e.g., Google, Facebook, Twitter), the third-party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
If someone has written a reference for you, it will be published on your FarCloser Travel public profile page with your consent.
For Members in Canada, to the extent permitted by applicable laws, FarCloser Travel may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of Canada, to the extent permitted by applicable laws and with your consent where required, FarCloser Travel may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the FarCloser Travel Platform through partnerships, or about your experiences and interactions from our partner ad networks.
This section sets out the ways in which we may collect or generate personal information concerning you.
10.1 Visiting our website
By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information recorded on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; or, information you input into forms and fields on our website.
10.2 Data you provide
Your personal information will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by email; from documents you provide us with; or, from updates to any information you provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an inquiry or booking for a holiday or other FarCloser Travel Services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; or, request sales and advertising information, including brochures.
10.3 Data obtained from third parties
We may obtain personal information concerning you from third parties, including from: providers of any holidays, accommodation, other FarCloser Travel Services which are inquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organizations; from any business or organization you are associated with; or, from telephone numbers identified by the telephone system when you call us.
10.4 Data generated by us
We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any inquiry, booking or complaint; in performing any booking or other contract with you; or, through the analysis of your personal information or data gained from your use of our website. We may record telephone calls with you.
This section sets out the uses which we make of your personal data.
11.1 Operating our website
To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our website. This includes managing any accounts or registrations you have with our website and making changes to your settings and profile at your request.
11.2 Provide information and respond to inquiries
To provide information to you about our website, systems and services, including to respond to booking inquiries and searches for holidays and travel, and to keep you updated generally.
11.3 Bookings and other contracts
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to collect, use, and disclose any transactions authorized or made with us which relate to you.
To collect and make payments due, and to administer our accounts.
11.5 Communication with customers
To communicate with you concerning any inquiries, bookings, FarCloser Travel Services provided, problems and complaints, and to respond to any submissions, inquiries or requests from you.
11.6 Record keeping
To keep internal records and maintain reasonable archives on inquiries, bookings, contracts, FarCloser Travel Services, and complaints.
11.7 Managing and improving our business
To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; to undertake product or customer research/development; to assist us in and help us to improve our sales, editorials, advertising and marketing; to carry out other business development and improvement activities; and, to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our website and booking FarCloser Travel Services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.
11.8 Direct marketing
Your personal information helps us to bring our direct marketing to you. See section 12.1.
To report, aggregate, and inform concerning usage of our website to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
11.10 Anything you have specifically consented to
For any purpose which we have obtained your consent to.
FarCloser Travel adheres to Canada’s Anti-Spam Legislation. We do not use or disclose your personal information for direct marketing purposes unless we have obtained your consent to this. Additionally, we will have an opt-out box to ensure that you can unsubscribe from future marketing communications.
12.1 Direct marketing by us
Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to FarCloser Travel Services we provide, or which can be booked with third parties through us.
12.2 Direct marketing by third parties
Where you have expressly consented to this, we may disclose your personal information which is contact data (such as name, email, postal address, telephone, mobile or fax number) to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisements and promotions relating to products and services they offer, or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e., we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.
We disclose your personal information to third parties in the following circumstances:
13.1 Credit checks
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention, and to pursue debtors.
13.2 Bookings and performance of contracts
We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking inquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g., airlines, coach, ferry or train companies, hoteliers, car rental companies, cruise companies, tour operators, etc.).
13.3 Suppliers of travel and other services
We may disclose your personal information to any third party (e.g., supplier or sub-contractor) we make any inquiries with to perform any booking or other contract, including to provide any travel, tour, or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any inquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third-party tour operators or other third parties who will be responsible for or supply you with the FarCloser Travel Services booked or inquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
13.5 Business function outsourcing
Where we use third parties to host, provide, operate, or supply any part of our website, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.
13.6 Public forums
Where any facility on our website is clearly designed to make certain of your personal information public (e.g., posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.
13.7 Legal requirements
We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the purposes of customs, visas and immigration, or where reasonably required to protect your interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.
13.8 Direct marketing by third parties
We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See section 12.2.
13.9 Customer representatives
If our customer is a business or organization, and we are holding your personal information in your capacity as an associate of that business or organization (including as an agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking inquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or inquiry or the subsequent performance of or payment for any booking made.
13.10 Business acquirers
If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.
Where we provide your personal information to a third party one of the following two circumstances will apply:
14.1 Collecting, using, and disclosing on our behalf
14.2 Collecting, using, and disclosing on their own account
In other cases, your personal information may need to be provided to them to be held and collected, used, and disclosed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policies, and we will not be responsible for what they do with it following disclosure.
We (and any affiliate, sub-contractor, or other person collecting, using, and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use, and disclose your personal information anywhere in the world.
Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use, and disclose that information anywhere in the world.
In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise collected, used, or disclosed on our behalf, our security measures (as detailed below) will also apply.
Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.
17.1 Our general commitment
We are committed to doing what we reasonably can to keep your personal information secure. We are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.
We maintain administrative, technical, and physical safeguards designed to protect against unauthorized use, disclosure, or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g., service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.
FarCloser Travel will rely on you telling us if you experience any unusual events that may indicate a breach in your information security. We will then seek to investigate whether this was related to the data transmissions from or to FarCloser Travel and will let you know what steps can be taken and have been taken to help rectify the problem.
17.2 Transmissions between your web browser and our servers
We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). One way to verify if this is working is by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and by checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.
17.3 Storage of your personal information
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology, and other reasonable security measures.
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any emails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
20.1 Access to your personal information
You may request us to tell you whether we are collecting, using, and disclosing personal information about you, to tell you what personal information we are collecting, using and disclosing and for what purposes, and to provide you with a copy of your personal information that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.
20.2 Use causing or damage or distress
You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted damage or distress.
20.3 Use for direct marketing and electronic communications
You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.
20.4 Correction of inaccuracies
You have the right to ask a court to order us to rectify, block, erase, or destroy any inaccurate personal information we hold about you.
You have the right to claim compensation for damage (in certain cases) you suffer if we do not comply with the laws referred to above.
This policy is subject to the law of Alberta, Canada, and you must bring any claims against us exclusively in the courts of Alberta, Canada.
FarCloser Travel, Inc., Legal Department, 3553 31 St NW #140, Calgary, AB T2L 2K7 Canada