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1. Who We Are
We have a legal duty to protect personal information that we collect under the British Columbia Personal Information Protection Act (PIPA) and the Canadian federal Personal Information Protection and Electronic Documents Act (PIPEDA) that came into effect on January 1st, 2004. This Act governs information collected as part of commercial activity by any private sector organization.
We also have a legal obligation to protect personal information that we collect under the Data Protection Act 1998 (and any law which replaces it, including the new UK Data Protection Bill) (DPA) and the General Data Protection Regulation (EU), (GDPR). For the purpose of the DPA and GDPR, we (Discover Holidays) are the data controller (in other words, the organization that determines how your personal information is used) and are located at 1200-675 West Hastings St, Vancouver, British Columbia, V6B 1N2, Canada.
2. How We Use and Collect Personal Information, and Our Lawful Basis for Processing
We will collect personal information by lawful and fair means, and, where appropriate, with the knowledge or consent of the individual concerned. Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
Inquiries and Bookings
We will collect personal information from you when you make an inquiry or request itinerary information from us. This includes your name and contact information, details about the materials or itinerary information that you request and any additional details of your travel plans which you voluntarily give to us. We may also collect details about the best time to contact you and any in-person appointments that you request as well as what prompted you to contact us and any other requests or comments that you may make.
If you book trips with us, we will ask you to provide certain details about your travel arrangements. This is likely to include details of your passports, preferences and special requirements, and flights (if you arrange your own flights). This will also include details of any other friends or family who are accompanying you as part of your booking. We will use this information to help us organize your trip, make bookings on your behalf and ensure that you (and any other friends or family accompanying you) receive the products and services set out in your itinerary.
We collect this information so we can fulfil our contract with you and provide you with the quality of service we strive to provide. If you are a regular customer, we may retain some of this personal information so that we can use it when you make your next booking with us as we have a legitimate interest to improve our client experience and ensure we look after our regular customers.
For any inquiries that you may have made with us, or booked a trip with us, we may send you our marketing emails. We send you these marketing emails on the basis of our legitimate interests, but you always have a right to object to our e-mails if you do not want to receive them, please let us know by unsubscribing from our mailing list or by contacting us.
Websites, Marketing and Advertising
We will collect certain technical information about you when you visit our website by using cookies. This is likely to include: the internet domain you use, your IP address or other device identifier, your browser type and version (Chrome or Internet Explorer), the operating system and platform that you are using (Windows or Mac), the screen resolution of your device, the dates and times when you access our website, the full URLs of the pages you visit and the websites or links that you use to access our website, login information, details of products or services that are viewed and the length of visits to certain pages of the website.
We use this information for site management and security purposes (such as troubleshooting and testing) as well as to help us improve our website. We do not try to identify individual users or their usage habits from this data. Raw data logs are retained temporarily as required for security and site management purposes only.
We collect this information so we can fulfil our legitimate interests as a business to ensure that our website is fit for purpose and promotes our services appropriately for our customers, including by displaying information that our customers are interested in. We also rely on our legitimate interest in measuring customer satisfaction and troubleshooting any website issues. Where required by law, we may also seek and rely on your consent.
We may collect and use information from various sources in connection with the marketing and advertising of our services. This may include your contact details (and your marketing preferences) to contact you with certain marketing messages such as marketing e-mails. We may also use data we collect from you (either directly or via our website or advertising) to help us measure the effectiveness of our advertising and to establish what interests you and what doesn't.
We rely on your consent to contact you directly about our offering. In other scenarios in carrying out efficient and appropriate marketing and advertising for our services, we will rely on our legitimate interests, while always ensuring that your rights are protected. You can withdraw your consent or opt out of our direct marketing at any time through our marketing preference center or through the 'unsubscribe' option in any marketing email.
We may collect your contact details when you enter into contests or promotions, or complete surveys. We will rely on your consent or on our legitimate interests (depending on whether we are marketing or carrying out market research), while always ensuring that your rights are protected.
We may collect details about you, such as your user name, when you engage with us on social media such as Facebook or Instagram (by mentioning or tagging us in a post or contacting us directly) this is so that we can respond to any comments and queries you have. We rely on our legitimate interests to do this as we want to ensure our customers have the best possible experience, while always ensuring your rights are protected.
Administrative or Other Business Purposes
We may collect and use certain other personal information when we correspond with you (whether by telephone, e-mail or otherwise). For example, we may record or collect information when you use our live chat software (Tawk) to speak with our Travel Advisors to ensure quality of service and for training purposes. We collect this information so we can fulfil our legitimate interests as a business to ensure that our Travel Advisors are trained to the highest level so that our customers receive the very best travel advice and trip booking experience possible. It is in our legitimate interests as a business to use your data in this way so we have a clear interest in ensuring that our website works properly and in ensuring that we operate our business efficiently. We will always ensure that your rights are protected.
We also collect personal information in regards to demographic, geographic, and technological data, as well as interests, from third parties such as Google Analytics and Facebook. We may also collect and use certain personal information about you, namely specific details of any relevant health conditions, disabilities, access requirements and special dietary requirements that you may have. We collect this information directly from you to try to ensure that your trip is appropriate for your needs and to try and keep you safe during any trip that you plan through us. We may need to ask for your explicit consent in order to process this information.
3. How We Share Personal Information
In order to make sure that we run our business efficiently, and to make sure that you get the service that you expect, we will need to share your personal information, from time to time, as necessary, with the following third parties:
Trusted third party business partners (such as the local businesses we partner with in the locations our customers travel to) and service providers (such as Mail Chimp, SurveyMonkey and Salesforce) to perform services related to the contracts we enter into with you.
We collect personal information in Mail Chimp which is one of your processors to collect and hold personal data such as sign up forms, in order to allow you to create and use distribution lists, send marketing email campaigns, and place online and Facebook advertisements, and the transfer of personal data to certain of Mail Chimp’s sub-processors.
Third parties if necessary to comply with legal obligations or enforce agreements, for example, we are required to provide hotels with a guest’s mobile phone number and email contact details for the hotel to inform the guest of any operational difficulties.
Subsidiaries and affiliates, and with service providers who perform services for us, these services include but are not limited to the provision of online and digital advertising which may involve anonymous profiling in order to find similar prospects to you or showing you relevant ads based on your interest in our products and services.
We do not share your personal information with third parties for them to use for the purposes of sending you marketing information or for those third parties to use your information for their own purposes.
4. Automated Decisions and Profiling
We may on occasion use automated decision making or profiling on customer data that has been provided through consented channels to ensure delivery of relevant marketing content.
5. Where We Transfer and Store Personal Information
From time to time we may process (or ask, or permit a third party to process) your personal information outside of the European Economic Area (EEA) where local laws may not provide legal protection for your information in the same way as is applicable in the EEA.
For example, when you book a trip, we will need to provide your information to local accommodation or service providers. In other cases, we may need to share your information with a service provider such as our local partners who host you during your wilderness experience, and the provider of a cruise or train excursion.
Whenever we send (or permit a third party to send) your personal data outside of the EEA, we will make sure that we take steps necessary to protect your data as required by applicable laws. For example, we may require the overseas recipient to enter into particular contract terms, or we will make sure that the information that we give to them will be limited to what is needed to perform our contract with you.
6. Security of Your Personal Information
We take the security of your information seriously and have put physical, technical, operational and administrative strategies, controls and measures in place to help protect your personal information from unauthorized access, use or disclosure as required by law and in accordance with accepted good industry practice. We will always keep these under review to make sure that the measures we have implemented remain appropriate.
7. Retention of Personal Information
We will keep your personal information for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal information. This means that the retention periods will vary according to the type of personal information. For example, some transaction information will be kept for a number of years in order to comply with various finance and tax related obligations.
8. Your Rights in Your Personal Information
You have certain rights in respect of the personal information that we hold about you. Details of these rights are set out below. To exercise any of these rights, please contact us.
Your rights include:
Access: At your request, we will confirm to you whether or not we are processing and using personal information about you, and, if so, provide you with access to and a copy of such personal information and the other details to which you are entitled to.
Rectification: We will correct any inaccurate personal data and complete any incomplete personal data (including by providing a supplementary statement) that we hold about you.
Prevention of processing likely to cause damage or distress: We will respect your rights to require us to cease or not to begin processing your personal information for a specific purpose, or in a specific way, that is likely to cause you or any third parties unwarranted damage or distress.
Erasure: We will erase your personal information at your request without undue delay where there is no good reason for us to continue to use it.
Restriction: We will restrict the processing of your personal information in certain circumstances, if you ask us to do so.
Data portability: We will provide you or third parties on your behalf with a copy of any personal information that we hold about you which you have provided to us in a structured, commonly used and machine readable format.
Objection (including objection to direct or e-mail marketing): We will respect your general rights to object to the processing of your personal information in certain circumstances, including for direct and e-mail marketing purposes.
Automated decisions and profiling: We do not make automated decisions or profile you based on your data.
How You Can Contact Us