Effective as of 5th May, 2023
what personal information we collect and why we collect it;
how we use your personal information;
who we share your personal information with; and
the choices you have to access, update, and remove your personal information.
This Policy is incorporated into and subject to our Terms and Conditions of Use, which is available here: Terms. Unless otherwise defined herein, all capitalized terms in this Policy shall have the meanings indicated in the Terms.
This Policy describes the information that we collect from users of our Website and Services (“you” and “your”). Our Policy regarding how personal information entrusted to us is collected, used, disclosed, and retained reflects the principles set forth in Canada’s Personal Information Protection and Electronic Documents Act, SC 2000, c 5. This personal information may be obtained directly from you or collected from third parties that have the right to disclose this information to us. We created this Policy to give you confidence as you make use of the Website and the Services and to demonstrate our commitment to fair information practices and the protection of user privacy.
Your Rights and Access
Privacy Settings. If you create an account on the Website, you may manage your privacy settings through the account. You may modify or remove any of the information in your account at any time by logging into your account and making the desired changes. For technical reasons, any modifications or deletions which you request may take a short period of time to take effect.
Access. You have the right to access the personal information that Viaggio processes about you. You can request from us information about: (i) the personal information we hold about you; (ii) the categories of personal information concerned; (iii) the purposes of the processing; (iv) details to whom your personal information has been/will be disclosed; (v) how long we retain your personal information; (vi) if we did not collect the information directly from you, information about the source; and (vii) how to lodge a complaint with the correct supervisory authority.
Correction of Inaccuracies. Viaggio, to the best of its ability, will strive to collect and maintain the most accurate personal information available. You have the right to request the update and correction of inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request the updating and correction of inaccuracies in your personal information we have in our custody or control by emailing or writing to us at the contact information set out in Section 11 below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
Deletion. You may request that we delete your personal information in accordance with applicable laws.
What Personal Information We Collect and Why We Collect It
Types of Personal Information and Collection Purposes. Viaggio collects and processes personal information in accordance with this Policy. We will not sell, share, or rent this information to others, except as set out in this Policy or in accordance with your consent. The table below describes the categories of personal information that Viaggio collects and why we collect it:
Additional Collection Purposes.
In addition to the collection purposes set out in Section 3.1, we may also collect your personal information for the following general purposes: (i) to help us enforce our Terms; (ii) to evaluate and develop new features, technologies, and improvements to the Services; (iii) to conduct business planning, reporting, and forecasting; and (iv) to provide you with system or administrative messages.
Third Party Sources.
The table below describes the personal information collected by Viaggio from third party sources and why we collect it:
How We Collect Your Personal Information.
You may give us your personal information by filling in online fields through the Website or by corresponding with us by mail, phone, email, or otherwise. This includes, but is not limited to, personal information you provide when you: (i) sign up for the Services by creating an account; (ii) book a reservation or purchase travel goods or services through the Website; (iii) submit User Content through the Services; (iv) sign-up to receive our email newsletter or other communications; (v) participate in one of our surveys or other customer research; (vi) contact us with a question, comment, or complaint; (vii) react to marketing posts on our social media forums or pages; or (viii) provide us with feedback.
Use and Disclosure of Personal Information
Personal information submitted to Viaggio, including through the Services or a prescribed form, is kept confidential unless disclosed in accordance with your express consent or legal requirements. In any event, any personal information provided through the Services by a user is voluntary. Please note that revoking your consent may result in not being able to access or utilize certain features offered by Viaggio, including the Services.
Publicly Available Information.
All of your activities in the public areas of the Website (e.g. public chat rooms, discussion groups, forums, etc.) will be identifiable to your username, if applicable, and other users will be able to see your published content.
Information We May Share.
Viaggio may disclose your personal information to the following categories of recipients for the reasons set out in the table below:
What Device Information We Collect.
When you visit the Website, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device (“Device Information”). Additionally, Device Information also includes information we collect as you browse the Website, including information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with our Website.
Why We Collect Device Information.
We use Device Information to: (i) generate analytics about how users browse and interact with the Website; (ii) help us understand our Website activity and to monitor and improve our Website; (iii) detect any attempts at tampering or interfering with the Website; and (iv) perform internal research on our users' demographics, interests, and behavior to better understand, protect, and serve you and our community.
How We Collect Device Information.
We automatically collect Device Information by using the following technologies:
“Cookies” are data files that are placed on your device and often include an anonymous unique identifier, as further described in Section 5.4.
“Log files” track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Website.
Security & Breach
Viaggio has employed reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. It is important to remember that no method of transmitting or storing data is completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies, where applicable to guard against unauthorized access and unnecessary retention of personal information in our systems. Our servers on which your personal information resides are located in Canada and follow industry standards pertaining to security.
Your password protects your user account, so we encourage you to use a strong password that is unique to your account. You can prevent unauthorized access to your account and personal information by selecting and securing your access password properly and limiting access to your computer, device, and browser. You should always log out after accessing your account.
Viaggio shall comply with, and provide Viaggio users with reasonable assistance in complying with, applicable laws with respect to any unauthorized use, access, or disclosure of personal information.
Data Retention and Deletion
We keep your personal information only as long as necessary to provide you with the Services and for legitimate and essential business purposes, such as maintaining the performance of the Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. When personal information is no longer required for these purposes, it is securely destroyed or deleted. For further details on our data retention periods, please contact us.
If you request, we will delete or anonymize your personal information so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal information, including situations such as the following:
if there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute, we will retain the necessary personal information until the issue is resolved;
where we need to retain the personal information for our legal, tax, audit, and accounting obligations, we will retain the necessary personal information for the period required by applicable law; and/or
where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users, we will retain the necessary personal information for the period required by applicable law.
We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins, and applications. When you engage with our content on or through third-party social networking websites, plug-ins, and applications, you may allow us to have access to certain information associated with your social media account (e.g. name, username, email address, profile picture, gender). When you provide information from your social media account, we may use this information to personalize your experience through the Services and on the third-party social networking websites, plug-ins, and applications.
If you voluntarily submit or post any information, photographs, or other content to any Viaggio social media forums or other social networking pages/sites, certain elements of your personal information may be automatically included in the posting, including your user name and email address, and this information may be collected and used by others. Viaggio has no control over, and is not liable for, the collection, use, or disclosure of any personal information posted by users of such forums and social media networking pages. For further clarity, any personal information posted, used, or disclosed via such sites is not subject to this Policy.
Changes to this Policy. Please note that Viaggio reserves the right to update or change this Policy at any time. When we make material changes to this Policy, we will provide you with prominent notice as appropriate under the circumstances (e.g. by displaying a prominent notice on the Website or by sending you an email). Please make sure you read any such notice carefully. The most current version of this Policy will govern Viaggio’s use of your personal information. By continuing to access the Services after changes are made to this Policy, you agree to be bound by the revised terms.
Access, Questions, and Concerns. Any questions regarding this Policy may be directed to our Privacy Officer. To review or update your personal information in Viaggio’s possession, or to withdraw consent for the collection, use, and/or disclosure of your personal information or name from an email or other mail list, please contact our Privacy Officer at: firstname.lastname@example.org