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Commitment to Privacy

Preferred Escapes (“Company”) delivers services relating to the establishment, administration and management of a website program (“Program” or “Programs”) in connection with certain properties listed by clients for rental by others with whom they wish to exchange information. The Programs typically provide contact information and related support services to such clients and/or their potential renters who voluntarily participate in the Programs.

Company is committed to protecting the privacy and security of Personal Information (as defined below) provided to or collected by Company. This Privacy Policy (“Policy”) explains Company’s Personal Information handling practices.

  • Personal Information is defined in this Policy as information about an identifiable individual, but not aggregated information that cannot be used to identify an individual. Under limited circumstances, such Personal Information may also include information that relates to the provision of the property for rent about an identifiable individual. However, business contact information (except business email addresses) and information available in public directories are not included in this definition.

Application

This Policy applies to the Personal Information of individuals that participate in the Programs, users of Company’s web–site and applicants who seek employment (including professional engagement) directly with Company (“Individuals” or “Individual”).

Company’s web–site may contain links to third party web–sites that are not governed by this Policy. Although Company endeavors to only link to web–sites with high privacy standards, this Policy does not apply once you leave Company’s web–site. Additionally, Company is not responsible for the privacy procedures employed by such third party web–sites. Therefore, it is suggested that users of Company’s web–site review the privacy policies of third party web–sites to learn how users’ Personal Information may be collected, used and disclosed (sometimes also referred herein collectively as &rlquo;Handling” or “Handle“).

Personal Information Handling Practices

Overview

Company takes responsibility for Personal Information under its care and/or control and has designated personnel as its Privacy Officer (contact information provided below) who is accountable for Company’s compliance with this Policy. Upon request, Company will make readily available to Individuals specific information about its policies and procedures relating to the Handling of Personal Information. If you have any questions relating to the Handling of Personal Information by Company and/or this Policy, please contact Company’s Privacy Officer at:

Privacy Officer
James Greydanus


Tel.: 001–519–266–6711
Fax: 001–519–6482
Email: jim@preferredescapes.com

Accountability

Company has implemented policies and procedures to give effect to this Policy, including training and communicating to its employees about this Policy and Company processes relating to the Handling of Individuals’ Personal Information. Company transfers Personal Information to trusted third–parties who provide services to Company, such as data processing / storing and Program web–site hosting. This may require that Personal Information be transferred across provincial and national borders, in which case, the Personal Information may become subject to the legislation of that jurisdiction to which it has been transferred. Company will only transfer Personal Information to third parties who have executed contracts requiring them to protect the privacy and confidentiality of the Personal Information provided to them for purposes of performing their functions for Company.

Collection

Prior to or at the time Personal Information is collected, Company will identify the purposes for which such information is being collected. Company will limit the collection of Personal Information to that which is reasonably required for the purposes described to the Individual providing such information and/or as described in this Policy.

Company collects Personal Information for the following purposes:

  • To establish and maintain Programs, including listings of properties and management or similar programs sponsored by Company’s clients.
  • To provide participating individuals with information about a property and to verify the integrity of any listing on its site.
  • To provide Company’s clients with aggregated rental support information.
  • To notify applicable Individuals about product related matters on behalf of Company’s clients.
  • To establish, administer and maintain Individuals’ Program profiles.
  • To market Company’s Clients’ products and services that may be of interest to Individuals.
  • To communicate with Individuals about the Programs they are registered with or new Programs that may be of interest to them.
  • To provide individuals with Program services and products.
  • To evaluate candidates who have submitted Personal Information to Company for employment or professional engagement consideration purposes.
  • To receive and respond to Personal Information access requests by Individuals.

Company collects Personal Information only for the purposes identified in this Policy. Company shall only collect Personal Information by fair and lawful means.

Company may share limited Personal Information with trusted third party organizations so that such organizations may offer goods and services that may be of interest to Individuals. Individuals may modify or withdraw their consents to any such marketing related activities at anytime.

Individuals provide Company their Personal Information voluntarily. Individuals may choose whether or not to provide Company their Personal Information; however, without some Personal Information, Company may not be able to register Individuals into Programs or consider them for employment with Company.

Company may collect usage pattern information from users of the Company’s web–site. In this regard, Company may use “Clickstreaming” or other similar technologies to track the paths of online visitors as they access the Company’s web–site.

Company will not routinely update Individuals’ Personal Information unless such a process is necessary to fulfill the purposes for which the information was collected.

Consent

In the majority of cases, Company obtains express consents directly from Individuals to Handle their Personal Information, i.e.: when an Individuals register for Programs with Company.

Company obtains the following forms of consents from Individuals:

  • Express Consent: Company shall obtain written, electronic or oral consent from the individual before collecting, using or disclosing Personal Information that is sensitive in nature, such as addresses and phone numbers.
  • Implied Consent: Company may rely on implied consent when consent may reasonably be inferred from the action or inaction of the Individual.

Company will only require Individuals to consent to the Handling of their Personal Information as a condition to the supply of services and/or products if such Handling is necessary to fulfill the identified purposes.

Individuals may modify or withdrawal their consents at any time upon reasonable notice to Company, subject to legal and contractual restrictions. If an Individual withdraws his or her consent for Company to use and/or disclose the Individual’s Personal Information, such Individual may not be able to participate in the Programs offered by Company. Furthermore, an Individual may withdraw his or her consent for the use of the Individual’s Personal Information for marketing purposes. In this case, the Individual will cease to be advised of additional services and/or products offered by Company’s clients and/or Company’s trusted third–party marketers.

Consent may be withdrawn or modified by contacting Company at the contact information provided in this Policy. Please be advised that it may take up to 30 days to complete such request. Prior to the changes taking effect, Individuals may still be contacted due to the Program and/or marketing efforts that commenced prior to the modification of their consents.

Except to the extent required or permitted by law, when Company uses or discloses Individual’s Personal Information for a purpose not previously identified, Company will reasonably identify and obtain consent for the new purpose prior to Company using or disclosing such Personal Information.

Use of Personal Information

Company restricts the use of Personal Information to the purposes identified in this Policy and for which Company has obtained explicit or implicit consent from the Individual. In accordance with established industry practices, industry standards and applicable legislation, Company retains Personal Information for only as long as necessary to fulfill the identified purpose.

In accordance with established industry practices, standards and/or applicable legislation, Company will destroy, erase or make unidentifiable any Personal Information that is no longer required for the identified purpose. However, Company may be required to retain the Personal information for a period of up to seven (7) years after the cessation of a Program or after an Individual has withdrawn from a Program. In this event and depending on the consent of the Individual, Company will not use or disclose Personal Information for any purpose or any other purpose unless required by applicable legislation.

Disclosure to Third Parties

In accordance with applicable legislation, Company discloses Personal Information to third parties only for the purposes identified in this Policy and with the appropriate consent of the Individual. Under some circumstances, Company may be required to disclose certain information to regulatory authorities to comply with law. In these circumstances, only the information specifically requested will be disclosed, and Company will take reasonable measures to ensure that such authorities are entitled to receive the requested Personal Information.

There are circumstances where the use and/or disclosure of Personal Information may be justified or permitted without the consent of the Individual. Such circumstances may include:

  • Where required by law or by order of a court, administrative agency or other governmental authority.
  • Where it is alleged by an appropriate authoritative body that the Individual concerned is being investigated for a criminal offence.
  • Where it is necessary for Company to pursue available legal remedies against an Individual.
  • Where the information resides in the public domain.

Access to Personal Information

Company provides Individuals with access to their Personal Information for review and update. Upon request, Company will inform an Individual of the existence, use and disclosure of his or her Personal Information and shall give access to that information. An Individual may challenge the accuracy of the Personal Information in Company’s care and control, provided that the Individual can reasonable demonstrate the inaccuracy of such information.

An Individual may access his or her Personal Information by writing to Company’s Privacy Officer at the contact information provided in this Policy. Access to Personal Information shall be provided in accordance with Company’s established policies and procedures.

Normally, there is no cost for reasonable access to Personal Information. Company shall advise Individuals of the cost, if any, prior to providing access to the Personal Information. In order to provide access to Personal Information, Company may require additional forms of information, including other Personal Information to validate the requester’s entitlement to the requested Personal Information. Such other Personal Information collected will only be used to process the access request.

Company will assist any Individual who needs help in preparing an access request to his or her Personal Information. For example, if the requester has a sensory disability and upon request, Company will provide access to the Personal Information in an alternative format.

Company will provide a response within 30 days of receiving an access request to Personal Information. If Company is unable to provide the requested access to Personal Information, Company will explain the reasons and any recourse available to the Individual. For example, if Company is unable to separate the requester’s Personal Information from that of others, Company will not be able to provide access to such information.

Where Personal Information has been used to make a decision about an Individual, Company shall retain the Personal Information for a period of time that is reasonably sufficient to allow such individual to access his or her Personal Information.

Company has procedures in place to address privacy related issues. In this regard, Individuals may address privacy related issues in writing by contacting Company’s Privacy Officer who is accountable for Company’s compliance with this Policy. In this event, Company’s Privacy Officer will work with such Individuals in an effort to resolve any privacy related concerns they may have.

Company takes privacy matters very seriously. As such, Company shall respond to every privacy related enquiry or complaint within a reasonable amount of time, but not exceeding thirty (30) days. In the event of a privacy related complaint, Company shall acknowledge, record and investigate the substance of the privacy complaint. If a complaint is found to be justified, appropriate measures will be taken, including but not limited to, amending this Policy.

Safeguards

Company protects Personal Information against unauthorized access. In accordance with established industry practices and standards, Company has security measures in place to protect Personal Information. Personal Information shall be protected by security measures appropriate to the sensitivity of the information.

Company’s security measures include:

  • Physical – Locking doors and filing cabinets. Secure destruction of Personal Information, regardless of the storage medium (i.e., paper shredding);
  • Technological – Password–protected computer systems and files; and
  • Organizational – Employee privacy training.

Individuals are reminded to take reasonable measures to protect themselves against unintended access to their Personal Information. For example, Individuals should only disclose Personal Information to organizations they trust.

Privacy Assistance

Company updates this Policy accordingly to ensure it reflects Company’s most current Personal Information Handling practices. Given this, Individuals are encouraged to review this Policy on a regular basis by visiting www.preferredescapes.com.

Company is committed to upholding this Policy. If you have any questions about Company’s Personal Information Handling practices that have not been answered in this Policy, please contact Company’s Privacy Officer at the contact information provided in this Policy.

Regulatory Authorities

The regulatory authorities that oversee Company’s administration of Individuals’ Personal Information are the Office of the Privacy Commissioner of Canada and the Office of the Information and Privacy Commissioner of Ontario.

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