Sunwing (“Sunwing”) is committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose your Personal Information (as defined below).
The purpose of this Privacy Policy is to inform you about Sunwing practices relating to the collection, use and disclosure of Personal Information that may be provided through access to or use of our websites, services or products (if applicable), or that may otherwise be collected by us. By using any of Sunwing websites (“Website”), you consent to the collection, use and disclosure of your Personal Information in accordance with the following terms and conditions.
This Privacy Policy also explains how you can contact us if you have a question about, want to access, or correct any Personal Information that Sunwing may be holding about you. As one of our users or someone else with whom we do business, you understand and agree that we collect, use and disclose your Personal Information in accordance with this Privacy Policy. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference.
For the purpose of this Privacy Policy, “Personal Information” means information about you that is personally identifiable but does not include business contact information of an employee of an organization such as name, position, title, business address, phone, email of fax.
We may collect your Personal Information during your dealings with us or while you visit our Website, for example when you request a quote, make a reservation, contact us by e-mail or phone, or subscribe to our updates or newsletters. The types of information we may collect and process include, but is not limited to:
- your name and surname, gender, personal and work contact details (such as address, telephone number, e-mail address) business title, date and place of birth, age, marital status, image, nationality, and passport and visa information;
- information regarding your transactions with Sunwing, its affiliates, or third parties such as air carriers, hotels, transportation and other service providers;
- guest stay information, including the hotels where you have stayed, dates of arrival and departure, goods and services utilized, special requests made, observations about your service preferences (including room and vacation preferences) and information concerning any incident;
- your credit card or debit card details or other means of payment accepted by Sunwing;
- any information necessary to fulfil special requests (i.e. health conditions that require specific accommodation or services);
- information, feedback or content you provide regarding your marketing preferences, in surveys, contests, or promotional offers, or to our websites and those of third parties that have a commercial relationship with Sunwing;
- social media profile and information (e.g. friend lists, people you follow, email address, birthday, your history, likes and pages you follow, content viewed) whether or not you use social networking plug-ins on our social media sites;
- your mobile devices information (e.g. your unique device identifier, unique device token to facilitate push notifications through mobile apps, identifiers associated with equipment or systems, mobile manufacturer or carrier, mobile or data network systems, location or GPS/geo-location, mobile number, passwords and payment information, stored photos and videos if you choose to share them with us);
- other information collected while you access our Website (we describe this in more detail in Section 9 below).
The Personal Information we process is information that you or someone acting on your behalf knowingly provides to us or information that we receive from a third party. In case of Personal Information belonging to minors or mentally incapables, we will seek consent of parents, legal guardians or legal representatives, as appropriate. Parents, legal guardians or legal representatives shall exercise data protection rights on behalf of such minors or mentally incapable people.
This Privacy Policy also applies to the Personal Information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.
We may use, collect and disclose your Personal Information to:
- book your vacation package, travel arrangements, flights, special requests, hotel accommodation, cruise, car rentals, and other goods and services requested by you, including those services requested to third parties with a commercial relationship with Sunwing;
- respond to requests for information and services, including services from a third party (such as transportation providers and providers of excursions);
- fulfil contractual obligations to you or anyone involved in the process of making your travel arrangements (i.e. travel agents, group travel organizers or your employer) and vendors (i.e. credit card companies, airline operators, transportation or excursion providers);
- provide you with timely and reliable quotes through third parties;
- process claims we receive in connection with our services;
- provide customer support and respond to and communicate with you about quotes and your requests, questions and comments;
- administer general record keeping;
- meet legal and regulatory requirements;
- verify your identity and prevent fraud;
- advise you about new products and services that may be of interest to you, subject to your consent;
- communicate about, and administer your participation in, special events, programs, surveys, contests and other offers or promotions, subject to your consent;
- develop and maintain our relationship with you and communicate with you;
- bill you for our products and services and collect outstanding debts; and
- perform data analyses and conduct other research (such as market and consumer research and trend analysis) to develop, manage, protect and improve our products and services, website, and business (including analyzing the effectiveness of our marketing, sales and advertising).
Except with your consent, we will not transfer or assign in any form your Personal Information to or with third parties. From time to time, we may disclose your Personal Information as set out below. We would always make that disclosure as permitted by law. When you agree to this Privacy Policy, you are, to the extent permitted by law, granting your consent to the transfer of your Personal Information to third parties for the purposes set out in this Privacy Policy and to the extent stated in this section and as described in Section 3 above. Circumstances where we might make such disclosure (in addition to those described in Section 3 above) include:
Our affiliates and subsidiaries
Sunwing may disclose and you authorize Sunwing to disclose your Personal Information with its affiliates and subsidiaries.
Our agents, service providers and suppliers
Sunwing may share Personal Information with third parties engaged in providing services to you, or to carry out one or more of the purposes described above. These service providers are prohibited from using your Personal Information for any purpose other than to provide this assistance and are required to protect Personal Information collected by them or disclosed to them by Sunwing and to comply with the general privacy principles described in this Privacy Policy. These third parties may not process or otherwise use your Personal Information, except in accordance with Sunwing's Privacy Policy and as permitted by law.
Legal requirements
Sunwing reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so or in the context of discovery procedures or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property. We also reserve the right to retain Personal Information collected and to process such Personal Information to comply with accounting and tax rules and regulations and any specific record retention laws.
Business transfers
Sunwing also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Sunwing or of any of the business or assets or shares of Sunwing or a division thereof in order for you to continue to receive the same products and services from the third party to the extent permitted by law and you consent to such disclosure and/or transfer.
Sunwing collects Personal Information about you only when you voluntarily provide it. You may always choose what Personal Information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
We will seek consent for the use or disclosure of your Personal Information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified, when is required by law or in an emergency situation that threatens an individual’s life, health or personal security). The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations of the individual in the circumstances.
You have the right to access to and correct your Personal Information at any time. In such case, please contact our Privacy Officer as described below under “Contacting Us”.
We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.
Your Personal Information will be used for the purposes described in this Privacy Policy. Many of the purposes described in this Privacy Policy are necessary for the existence, maintenance or fulfilment of the relationship between you and Sunwing. We also use your Personal Information for purposes that may not necessary for the existence, maintenance or enforcement of your relationship with Sunwing. These non-necessary purposes include sending you promotional materials, customizing your visits to our sites and social media channels, delivering content tailored to your interests, and participating in interest-based advertising.
If you have subscribed to receive Sunwing’s updates or newsletters, we may also use (but will not disclose) your Personal Information to send you relevant information based on your subscription preferences, including by means of direct marketing. We may also disclose your Personal Information to our affiliates so that they can send you promotional materials directly.
You may unsubscribe at any time by clicking the unsubscribe link embedded at the Sunwing email communications. Note, however, that clients of Sunwing will continue to receive periodic emails that relate to their business relationship with us. You can also choose not to allow us to use your Personal Information for marketing purposes by contacting us as outlined below (see “Contacting Us”).
When you visit our Website, we or one of our third party service providers places a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve information. The cookie cannot be read by any website other than the one that placed the cookie. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this website may not function properly.
These third party service providers use cookies on our behalf to collect and store Internet log information, such as what time the visits occurred, whether the visitor has been to this site before, and what site referred the visitor to the web page. Geographic data is also determined by the IP Address of the visitor’s computer. This information collected by the cookie is transmitted to our third party service providers and is then used to evaluate visitors’ behaviour and to generate statistical reports for the website activity on Sunwing’s website and may be used for marketing purposes.
You can choose to disable cookies in your browser at any time by following the procedure described in the Tools or Preferences menu in your browser. If you choose to modify your browser in this manner, some pages of the Website may not function properly. Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
Sunwing makes commercially reasonable efforts to ensure that Personal Information collected from you is protected against loss, theft and unauthorized access, disclosure, copying, use, or modification. This protection applies in relation to information stored in both electronic and hard copy form. Access to your Personal Information is restricted to selected employees or representatives. In addition, Sunwing employs generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect Personal Information against loss and unauthorized access.
This Website may offer links to other third party websites. You should be aware that operators of linked websites may also collect your Personal Information (including information generated through the use of cookies) when you link to their websites. Sunwing is not responsible for how such third parties collect, use or disclose your Personal Information, so it is important to familiarize yourself with their privacy policies before providing them with your Personal Information.
Sunwing retains your Personal Information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains valid after termination of our relationship with you.
For the purposes set out in this Privacy Policy, we or one of our affiliates or an unaffiliated service provider may process and store your Personal Information outside of the province in which you reside and/or outside of Canada, and under the laws of those other jurisdictions, in certain circumstances courts, law enforcement agencies, regulatory agencies or security authorities in those other provinces or foreign jurisdictions may be entitled to access your Personal Information.
Sunwing reserves the right to modify this Privacy Policy at any time without notice to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with Personal Information. This Privacy Policy posted at any time or from time to time via this Website shall be deemed to be the Privacy Policy then in effect.
This Privacy Policy is effective as of November 01, 2017
You can help us maintain the accuracy of your Personal Information by notifying us of any changes to this information. You may contact Sunwing Privacy Officer as set out below to request access to (subject to exceptions), correct or update your Personal Information.
A request to access personal information must be made in writing providing details of the personal information being sought. A minimal fee may be charged and we will inform you about the total cost.
If you have any questions about Sunwing’s Privacy Policy or if you have any concerns regarding the administration of this Privacy Policy, you may contact our Privacy Officer via mail at 27 Fasken Drive, Toronto, Ontario, Canada, M9W 1K6.
We may require you to confirm your identity (such as by providing government-issued identification) before processing any request in relation with your Personal Information.