PACIFIC TIER SOLUTIONS INCORPORATED (“PTS”) PRIVACY STATEMENT
PTS, a British Columbia company, is committed to protecting the privacy of users to this Website and for users of our on-line services in accordance with the requirements of Canadian federal and provincial privacy laws.
This privacy statement details how PTS collects and uses personal information of users on this Website or our on-line services and outlines our privacy commitment to you, the user, as well as our privacy practices. PTS wants all users of its Website and on-line services to understand the purposes and uses of our collection of personal information and we want to ensure that PTS has your consent to continue to collect, use and disclose your personal information for the purposes and uses as set out below.
At the same time, PTS wants its privacy statement to meet the highest commercial standards that establish a trusting relationships based on respect for personal identity and information by promoting the use of fair information practices. This privacy statement covers the Website www.bookking.ca (the “Web site”) including all sub-domains.
We want this Website and our on-line services to demonstrate our commitment to users’ privacy, and therefore we want to you to know what our information and privacy practices are with respect to the following matters:
- What personally identifiable information PTS collects.
- What personally identifiable information third parties collect through the Website.
- How PTS uses the personal information.
- With whom PTS may share user information.
- What choices are available to users regarding collection, use and distribution of the personal information.
- What types of security procedures are in place to protect the loss, misuse or alteration of personal information under PTS control.
- How users can correct any inaccuracies in their personal information.
If users have questions or concerns regarding this statement, they should first contact us by the following email address: firstname.lastname@example.org. If a user does not receive acknowledgment of their inquiry or their inquiry is not satisfactorily addressed, they should then contact PTS directly by the following contact number(s): (250) 384-8282
From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our privacy notice. If our information practices change at some time in the future we will post the policy changes to our Website to notify you of these changes and provide you with the ability to opt out of these new uses. If you are concerned about how your information is used please check back at our Website periodically.
We collect only the domain name, but not the e-mail address of visitors to our Website, aggregate information on what pages consumers access or visit and information volunteered by the consumer such as demo requests or feedback.
The information we collect is used for internal review to improve the content of our Website and is not shared with any other organizations.
If you supply us with your postal or email address, or telephone number online you may receive periodic contact from us with information on new products and services or upcoming events. If you do not wish to receive such contact, please let us know by calling us at the number provided above, e-mailing us at the above address or writing to us at the above address.
PTS is the sole owner of the information collected on http://www.bookking.ca including all sub-domains. PTS collects personally identifiable information from our users at several different points on our Website. If you request a product demonstration, product pricing or send us feedback, we ask you for your name, company affiliation, email address, mailing address, telephone number and fax number. This information allows us to ensure that we are able to contact you regarding your requests.
In order to use certain sections of this Website, a user must first login. During login process, a user is required to give contact information such as business name, business address and email address. We use this information to contact the user to verify their contact information and for the purposes of setting up a client account thereby allowing the user to access services on our Website for which he/she wishes to participate. The user is also assigned unique identifiers such as, username and password in order to fully utilized our Website.
We do not collect or request social insurance or social security numbers and do not retain credit card information in our database. Contact information, such as business address and email address from the user and financial information, such as credit card number and expiration date are used for billing purposes and if we have trouble with billing, the information is used to contact the user.
We may disclose personal information if legally required to do so such as to protect our rights and property, take emergency action regarding personal safety or where required by operation of law.
We collect and use the information to process demo requests, to improve the services and features of our products, to customize our services or delivery of information to you on the Website to make the users’ use of the Website more effective and efficient, to troubleshoot problems and enforce this privacy statement. We automatically track certain information based on the user’s use of our Website. We use this information to do internal research on our user’s demographics, interests, and behavior to better understand our client base. We track information regarding the URL that the user came from (whether from our Website or not), which URL the user may go to next (whether this URL is on our Website or not), what browser is being used and the user’s IP address.
We use this information to improve our marketing and promotional efforts, to improve our content and product offerings, and to customize our Website’s content, layout and services to better meet the needs of users. We collect information to generate statistics and aggregate reports for internal use only. These statistics and aggregate reports will not contain any personally identifiable information. Personal identity is kept anonymous.
We collect and use information from messages, users may have posted on our Website. We also collect and use personal correspondence, such as emails or letters, or if other users or third parties send correspondence about your activities or postings on the Website.
We store information that we collect through cookies, log files, and/or third parties to create a profile of our users. A profile is stored information that we keep on individual users that details their viewing preferences. Consequently, collected information is tied to the users personally identifiable information to provide offers and improve the content of the Website for the user. This profile is used to tailor a user’s visit to our Website and to direct pertinent marketing promotions to them. We do not share your profile with other third parties.
A cookie is a piece of data stored on a user’s computer tied to information about the user. Usage of a cookie is in no way linked to any personally identifiable information while a user is on our Website.
With respect to cookies: We do not set any cookies. If you do not want to receive e-mail from us in the future, please let us know by sending us e-mail at the above address, calling us at the above telephone number or writing to us at the above address.
Third Party Advertising
With respect to Ad Servers: We do not partner with or have special relationships with any ad server companies.
We do not have any external advertisements. We do not aggregate (gather up data across all user accounts) information and provide information in a non-personally identifiable manner to advertisers or other third parties for promotional purposes.
Like most standard Website servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the Website, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. IP addresses are tied to personally identifiable information to enable our Web-based service.
Clear Gifs (Web Beacons/Web Bugs)
We do not employ the use of Clear Gifs.
On rare occasions it may be necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via email or phone, in accordance with the users wishes.
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our Website.
Aggregate Information (non-personally identifiable)
We do not share aggregated demographic information with our partners or advertisers.
Third Party Advertisers
We do not share Website usage information about users with third party advertisers.
Sharing of Personal Information with Third Parties
We DO NOT share personal information with third parties.
In the event PTS goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on our Website for 30 days prior to a change of ownership or control of their personal information. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given a choice consistent with our notification of changes section.
We may disclose personal information of a user to an agent when in the reasonable judgment of PTS, the individual is seeking information as an agent of the user.
Subject to applicable regulatory requirements, we may disclose personal information of a user to a credit reporting agency.
We may disclose personal information of a user to a public agency when in the reasonable judgment of PTS, there is imminent danger to a person or property to which such disclosure would avoid or minimize the danger.
We do not use our users’ information for other purposes other than related to our Website.
We would like to continue to have you, the user’s consent for the purposes and uses of personal information as set out in this privacy statement, however, you may choose to refuse or withdraw your consent by refusing to give us personal information or withdrawing such consent subject to any applicable contractual or notice provisions by emailing us at email@example.com.
Users who no longer wish to receive our newsletter and promotional communications may opt-out of receiving these communications by following instructions given in the footer of the email or email us at firstname.lastname@example.org.
This Website contains links to other Websites. Please be aware that we, PTS, are not responsible for the privacy practices of such other Websites. We encourage our users to be aware when they leave our Website and to read the privacy statements of each and every Website that collects personally identifiable information. This privacy statement applies solely to information collected by this Website.
Surveys & Contests
From time-to-time our Website requests information from users via internal or in-house surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and shipping address) and demographic information (such as postal or zip code). Contact information will be used to notify the winners and award prizes and shared with the contest and survey sponsors. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this Website. Users’ personally identifiable information is not shared with third parties as all surveys and contests are internal and or in-house.
If a user elects to use our referral service for informing a friend about our products, we may ask them for their friend’s name and email address. We will automatically send the friend a one-time email inviting them to visit the Website. We store this information for the sole purpose of sending this one-time email and to track the success of our referral program. The friend may contact us at email@example.com to request the removal of this information from our database.
With respect to security: We have appropriate security measures in place in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you at our Website.
This Website takes every precaution to protect our users’ information. When users submit sensitive information via the Website, their information is protected both online and off-line.
We protect personal information and the user’s right to privacy by:
- Only collecting personal information for the purposes set out in this privacy statement.
- Ensuring appropriate security measures are in place.
- Ensuring appropriate confidentiality measures are in place for personal information when dealing with a third party.
- Ensuring that personal information is kept up-to-date and current for the purposes in which it is being used.
- Honoring any user request for access to their personal information.
- When our payment form asks users to enter sensitive information (such as credit card number), that information is encrypted and is protected with the best encryption software in the industry – SSL. While on a secure page, such as a payment form, the lock icon on Web browsers becomes locked, as opposed to un-locked, or open, when users are just ‘surfing’.
While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. This includes all of our users’ information, not just the sensitive information mentioned above. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. As well, any time new policies are added, our employees are notified and or reminded about the importance we place on privacy, and what they can to do to ensure our users’ information is protected. Finally, the servers that store personally identifiable information are in a secure environment, our servers are located in an access-controlled facility in Victoria, BC. The servers are physically secured within a locked room within the facility to ensure no unauthorized physical access.
If users have any questions about the security of our Website, users can send an email to firstname.lastname@example.org.
Supplementation of Information
In order for this Website to properly fulfill its obligation to users it may be necessary for us to supplement the information we receive with information from 3rd party sources.
We do not combine information about the purchasing habits of our users with other third parties.
Enhancement of Marketing Profile
We currently purchase third party marketing data and add it to our existing user database to better target our advertising and provide pertinent offers we think users would be interested in.
Correcting/Updating/Deleting/Deactivating Personal Information
If a user’s personally identifiable information changes (such as name, postal code, zip code, phone, email or postal address), or if a user no longer desires our service, we provide a way to correct, update or delete/deactivate users’ personally identifiable information. This can usually be done from a profile page or by emailing our Customer Support at email@example.com
Notification of Changes
If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email. Users will have a choice as to whether or not we use their information in this different manner. However, if users deleted/deactivated their account, then they will not be contacted, nor will their personal information be used in this new manner. In addition, if we make any material changes in our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our Website notifying users of the change. In some cases where we post a notice we will also email users, who have opted to receive communications from us, notifying them of the changes in our privacy practices.
Upon request we provide Website visitors with access to all information [including proprietary information] that we maintain about them. Consumers can access this information by calling us at the number provided above, e-mailing us at the above address or writing to us at the above address. See our Privacy Code for further information concerning our privacy practices and procedures here: https://www.bookking.ca/privacy-policy
If users have any questions, concerns or suggestions regarding our privacy practices, please contact us at: https://www.bookking.ca/contact-us/
Otherwise, we assume that you, by using of our Website and or on-line services, hereby consent to collect, use and disclose your personal information for the purposes and uses identified in this privacy statement.
PIPA PRIVACY PRACTICE GUIDELINES FOR HANDLING PERSONAL INFORMATION
Guidelines for staff in responding to inquiries regarding personal information pursuant to PIPA:
PTS responds to public inquiries regarding our privacy policies by referring the individual to our privacy code available on our Website or by providing a copy of the code upon request and advising the individual that the process for making inquiries is set out in our Privacy Code and involves making a written request to the President of PTS regarding the individual’s personal information with sufficient detail to allow PTS to respond;
When collecting, using and disclosing personal information of any employee, member or individual PTS shall seek wherever possible explicit oral or written consent from the individual prior to collecting personal information and in all cases prior to using or disclosing such personal information.
Personal information is all identifiable information regarding an individual and whenever a PTS staff is in doubt regarding whether or not a request is being made from an individual concerning their personal information, the staff member shall refer the matter to the President and or his/her designate in order for the President and or his/her designate to determine whether the request should be processed as a request for personal information pursuant to PTS’s Privacy Code.
The President and or his/her named designate are responsible for handling any complaints made from individuals regarding PTS’s handling of personal information of an individual and all such complaints received from staff are to be referred to the President and or his/her named designate.
When handling complaints under the PTS Privacy Code, PTS staff will differentiate between a complaint and an inquiry. In responding to a request for personal information, PTS staff will advise the individual of any costs for retrieval. In responding to a request for personal information, PTS staff will ensure that information is in a form generally understandable i.e. need to explain abbreviations, codes and the organization needs to consider whether it needs to offer personal information in an alternate form such as Braille or audio tapes.
Guidelines for staff when transferring personal information to third parties, such as payroll administrators. Staff must ensure to:
- Name a person to handle all privacy aspects of the contract;
- Limit use of personal information to the purposes specified to fulfill the contract;
- Limit disclosure of information to what is authorized by PTS or required by law;
- Refer any people looking for access to their personal information to PTS;
- Return or dispose of the transferred information upon completion of the contract;
- Use appropriate security measures to protect the personal information;
- Allow PTS to audit the third party’s compliance with the contract as necessary.
PTS staff shall only collect, use and disclose personal information of PTS employees, members, subcontractors or individuals for the following purposes:
- To meet the terms, conditions and obligations of employment with our employees, such as payroll administration;
- To meet, maintain, monitor and regulate contractual obligations with the customer;
- To promote PTS programs to its customers and the public.
PTS staff shall ensure an individual is advised of their choices regarding PTS’s collection, use or disclosure of the personal information at the time of collection or prior to the use or disclosure of such personal information including the right to decline to provide personal information and the process to withdraw consent.
Guidelines for obtaining consent from an individual for the collection, use and disclosure of their personal information:
All forms and contracts under which personal information is collected shall include explicit consent clauses regarding the collection, use and disclosure of personal information including employment agreements, good news stories, forms regarding program participants, subcontractors agreements and project management reports. Staff shall make all efforts to obtain consent from an individual whose personal information is being collected, used or disclosed by PTS at the time that the personal information is collected. Express consent will be sought for any resumes solicited or received by PTS. When obtaining consent, staff shall normally obtain express consent in writing or orally and ensure that the individual clearly understands why and how the information will be collected, used and disclosed by PTS. Express consent should be used by staff whenever possible and in all cases where the personal information is sensitive. Consent can be obtained by staff in a variety of forms i.e. mail, Internet, phone etc. and the form of consent used by staff should take into consideration the reasonable expectations of the individual, the circumstances surrounding collection and the sensitivity of the information.
Guidelines for the retention and disposal of personal information:
Wherever possible, staff shall reduce the amount of personal information collected and will be guided by asking the following question: Do we need to collect the personal information? If the answer is no, then staff should not collect the personal information. PTS staff shall destroy erase or make anonymous, personal information that is no longer required for the purpose it was collected or it is required by law. PTS staff shall generally destroy or erase information rather than to make personal information anonymous. PTS’s timetable for retaining and disposing of personal information is generally as follows:
- Employee information in manual and electronic files is retained for as long as the employee is employed with PTS and for an additional two year period in case of any action or claim by the departing employee.
- All other resume information solicited or received by PTS shall only be retained for a period of one year and then it will be destroyed.
- Financial information concerning employees and legal contracts are retained in PTS’s financial records for a period of 7 years as required by CCRA guidelines for retention unless specifically requested by the employee to destroy the information and it is permitted by operation of the law.
- PTS staff will conduct regular reviews to help determine whether personal information is still required and to make adjustments in the retention schedule as needed to make this determination easier.
- PTS will make adjustments or amendment to its information systems, including adding fields to the database, to facilitate the retrieval and accurate reporting of personal information, including recording consent and disclosures to third party organizations.
Guidelines for updating of personal information collected, used and disclosed by PTS:
- PTS staff will take all appropriate steps to update personal information of employees, members, subcontractors and program participants on an on-going basis when new information is obtained.
- PTS staff will take appropriate steps to ensure that all data entry into the database is updated regularly and that the database is updated regularly.
- PTS staff will ensure that all required data fields including those for recording consent obtained are completed for all new entries of personal information.
- In determining if information needs to be updated, PTS staff will consider the impact on the individual is information is not updated i.e. harm to the individual.
PTS staff will ensure that all personal information is held only in the database and within secured manual files.
Guideline for assessing the accuracy of personal information. In assessing the accuracy of personal information PTS staff will consider the following checklist:
- List specific items of personal information required to meet PTS’s program needs;
- List the location where all related personal information can be retrieved;
- Record the date when the personal information was obtained or updated; and
- Record the steps taken to verify accuracy, completeness and timeliness of the information.
Guidelines for providing and maintaining security of personal information. PTS staff will consider the following factors in selecting appropriate safeguards for sensitivity of information
- Amount of information
- Extent of distribution
- Format of information i.e. paper or electronic
- Type of storage
PTS will use the following security safeguards to protect personal information:
- Physical measures i.e. locked filing cabinets;
- Restricting access to the office;
- Alarm systems;
- Technological tools i.e. passwords, encryption, firewalls;
- Limiting access to a need to know basis;
- Staff training;
- Confidentiality agreements.
PTS will use confidentiality agreements with all staff to ensure confidentiality of personal information forms part of the employee orientation checklist and ensure confidentiality provisions are incorporated in PTS’s contractual agreements with subcontractors, policy and procedures manual, and information systems access and security policy. PTS will ensure that access to personal information is on a need to know basis and only that information that is necessary for an employee or third party organization to undertake their responsibilities or services will be accessible by that employee. PTS staff will regularly review and update security measures to make sure personal information that has no relevance to the services provided by PTS is either removed or masked when providing copies of information to others and keep sensitive information in a secure area or computer system and limit access to need to know basis only. PTS staff will ensure that any personal information stored by any third party on its behalf is protected to the same extent as personal information held by PTS.
Guidelines to ensure PTS maintains open and transparent privacy practices:
PTS staff will ensure that it’s Privacy Code and policies and practices are made available to an individual in person, in writing, by telephone, or via download from our website and will include the following information:
- Name or title and address of person who is accountable for PTS’s privacy policies and practices;
- Name or title and address of the person to whom access requests should be sent;
- How an individual can gain access to his or her personal information;
- How an individual can complain to PTS;
- Brochures or other information that explain PTS’ policies, standards or codes;
- A description of what personal information is made available to other organizations and why it is disclosed.
- PTS staff will be oriented and trained to respond to inquiries, requests and complaints regarding PTS’s Privacy Code and policies and practices.
Guidelines regarding granting individual access to personal information:
- PTS wherever possible will provide any help the individual needs to prepare a request for access to personal information;
- PTS staff will comply with the PTS internal procedures as a guide for the process of changing, adding or deleting personal information subject to the requirements of PTS’s Privacy Code;
- PTS staff where applicable will request the individual provide enough information to enable PTS to account for the existence, use and disclosure of personal information;
- PTS staff will respond as quickly as possible to a request for personal information and no later than 30 days unless there is a need for a time extension as the request would unreasonably interfere with the activities of PTS or additional time is necessary to conduct consultations or to convert the personal information to an alternate format;
- PTS staff will give access to personal information at minimal or no cost to the individual and notify the individual of approximate costs prior to processing the request;
- PTS staff will make sure the response to the request is understandable by explaining acronyms, abbreviations, codes;
- PTS staff will send amended personal information where applicable to third party organizations;
- PTS staff will keep personal information in one place to make retrieval easier or record where the information can be found;
- PTS staff will never disclose personal information unless PTS is sure of the identity of the requester and that person’s right of access.
Guidelines for compliance and complaint processes under PTS’s Privacy Code:
- PTS staff will ensure that compliance and complaint procedures are kept simple and easily accessible;
- PTS staff will record the date of a complaint is received and the nature of the complaint;
- PTS staff will ensure that there is an acknowledgment of the complaint promptly and where appropriate contact the individual for clarification of the complaint;
- PTS staff will ensure that an individual is advised of all venues of recourse regarding their complaint as set out in PTS’s Privacy Code;
- In investigating a compliance complaint, the President and or her named designate will assign the investigation to a person in the organization with the skills necessary to conduct the investigation fairly and impartially and give this person access to all relevant records or information concerning how and who has handled the personal information;
- In completing the investigation, PTS will notify the individual of the outcome of the investigation and the steps taken where applicable in a clear and prompt fashion and ensure that any inaccurate personal information is corrected and where appropriate amend PTS’s privacy policies and practices or its internal procedures.