Viaggio Privacy Policy
Effective as of 5th May, 2023
Diamond Hart Properties Inc. dba Viaggio (“Viaggio”,
“we”, “our”,
and “us”) understands
the importance of protecting the personal information of individuals and the
importance of securing confidential information of all types. We have created
this Privacy Policy (the “Policy”)
to demonstrate our commitment to protecting your privacy. This Policy explains:
· 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.
1. Consent.
By providing Viaggio with your personal
information, accepting the Privacy Policy when you register for an account, or
by using the Services, you expressly consent to the collection, use, and
disclosure of such information in accordance with this Policy or for the
purposes identified to you at the time you provided the personal information.
Any secondary use of the personal information will only be processed with your
express consent, except as required by law. You have the opportunity to
withdraw your consent, or to opt-out at any time from our email or mailing
list. If you wish to withdraw your consent or to opt-out at any time, please
contact us as set out in Section 11 below.
2. Your Rights and Access
1. 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.
2. 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.
3. 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.
4. Deletion. You
may request that we delete your personal information in accordance with
applicable laws.
3. What Personal Information We Collect and Why We
Collect It
1. 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:
Categories of Personal Information
|
Description of the Category
|
Collection Purposes
|
Account Data
|
If you register for
an account, you will be asked to provide certain basic information about
yourself, such as your full name, telephone number, email, and country of
residence. Where possible, we indicate which fields are required and which
fields are optional.
|
We use this
information to provide you with the Services requested by you and to provide
you with travel booking confirmations and updates.
|
Identity Verification Data
|
When you book a
reservation through the Website, we may ask you to provide government-issued
identification required for booking or identity verification, such as passport
or driver’s license.
|
We use this
information to provide you with the Services requested by you.
|
Travel-Related Data
|
When you book a
reservation through the Website, we may ask you for your travel-related
preferences and requests, such as your favourite destination and
accommodation types and any special dietary and accessibility needs.
|
We use this
information to provide you with more relevant service offerings, and to
maintain your search and travel history, accommodation and travel
preferences, and other similar information about your use of the Services.
|
Third Party User Data
|
If you purchase
Services or book a reservation for your travel companion or third parties,
you may be asked to provide Account Data, Identity Verification Data, and/or
Travel-Related Data with respect to such third parties. You must ensure that
you acquire the appropriate consent from the third parties to allow their
information to be collected and used by us, in accordance with this Privacy
Policy.
|
We use this
information to provide you with the Services requested by you.
|
Payment and Purchase Data
|
When you purchase
Services through our Website, you will be asked to provide your payment and
billing information. Your personal information will be processed by a
third-party payment processor.
|
We use this
information to process your payment for the Services requested by you, to
manage any payment disputes, and to detect and protect us against error,
fraud, and other criminal activity.
|
Communications Data
|
You may provide us
with contact information for the purpose of receiving marketing
communications, including your name, email, and phone number. You can
unsubscribe from these communications at any time by using the unsubscribe
mechanism or by contacting us as set out in Section 11 below.
|
Viaggio uses your
contact information to send you newsletters and other information requested
by you regarding Viaggio news, offers, and promotions, and to inform you about online and offline offers, products,
services, events, product news, and updates.
|
Surveys and Customer Research Data
|
From time to time, we
may offer you the opportunity to participate in one of our surveys or other
customer research.
|
We use this
information to help us measure consumer interest in our Services, and to
enhance our product and service offerings and promotions.
|
Loyalty Rewards Data
|
We may offer a
loyalty rewards program, which offers special promotions and discounts to
loyalty rewards members. To enroll in a loyalty rewards program, you may be
asked to provide certain basic information about yourself, such as your name,
email address, mailing address, date of birth, and phone number.
|
We use this
information to administer your participation in any Viaggio loyalty rewards
program.
|
Contests, Sweepstakes, and Promotions Data
|
When you enter a
contest, sweepstakes, or participate in a promotion, we may collect your
name, address, phone number, email address, and other information you
provide. If a contest, sweepstakes, or promotion is jointly sponsored by us
and one or more sponsors, your personal information may be shared with such
sponsors, as specified at the time you enter or participate in the contest,
sweepstakes, or promotion.
|
We use this
information to administer your participation in the contest, sweepstakes, or
promotion.
|
Customer Service Data
|
When you contact us
with a comment, question, or complaint, you may be asked for information that
identifies you (such as your name, address, and phone number) along with
additional information we need to help us promptly answer your question or
respond to your comment or complaint.
|
We use this
information to respond to your inquiry and to understand, diagnose,
troubleshoot, and fix issues with the Services. We may also retain this
information to assist you in the future and to improve our customer service,
product and service offerings, and promotions.
|
2. 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.
3. Third Party Sources.
The table below describes the personal
information collected by Viaggio from third party sources and why we collect it:
Categories of Personal Information
|
Description of the Category
|
Collection Purposes
|
Authentication Partners
|
We work with third
party authentication partners such as Facebook or Gmail to allow you to
register for or log into the Services using third party credentials.
|
We import your
information from such third parties to help create your account with Viaggio.
|
Technical Service Partners
|
We work with
technical service partners that provide us with certain data, such as mapping
IP addresses to non-precise location data (e.g. city, province), as further
described in Section 5.
|
We use this
information to learn about the demographic of our users and for market
research and analysis.
|
Advertising Data
|
From time to time, we
may place advertisements on third party sites (such as Facebook and
Instagram). When you view or otherwise interact with our advertisements, we
may use various technologies to collect and store advertising data.
|
We use this
information to learn how our customers use our Services, to grow our
business, and to inform our marketing strategy.
|
3. 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.
4. Use and Disclosure of Personal Information
1. 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.
2. 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.
3. 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:
Categories of Recipients
|
Reason For Sharing
|
Travel Suppliers
|
We share personal information with travel-related
suppliers such as hotels, vacation-rental property owners and managers, and
where available, activity providers who fulfill your booking. Please note
that travel suppliers may contact you to obtain additional information if and
as required to facilitate your booking or to otherwise provide the travel or associated
services.
|
Service Providers
|
We may transfer (or
otherwise make available) your personal information to our affiliates and
other third parties who provide services on our behalf. For example, we may
use service providers to host our websites, operate certain features on our
websites, serve advertisements on our websites, send emails or other
communications, or conduct customer research. Our service providers are given
the information they need to perform their designated functions, and we do
not authorize them to use or disclose personal information for their own
marketing or other purposes.
To the extent that
any personal information is provided to these third party service providers,
Viaggio requires that the provider be bound by obligations consistent with
this Policy and that such providers only collect, use, or disclose users’
personal information for the purposes of providing Viaggio the services set
out in this section. For more information about the way in which our
third-party service providers handle your personal information, contact us as
set out below in Section 11 below.
Presently, Viaggio
uses and discloses personal information to the following service providers:
· We use Stripe to process credit card payments made
through the Services.
· We use Travelomatix, a travel booking platform, to provide us
with application programming interfaces with travel suppliers.
· We use Hotelbeds to provide us with application
programming interfaces with travel suppliers.
|
Advertising Partners
|
We work with
advertising partners to enable us to customize the advertising content you
may receive on the Services. These partners help us deliver more relevant ads
and promotional messages to you, which may include interest based advertising
(also known as online behavioral advertising), contextual advertising, and
generic advertising on the Services. We and our advertising partners may
process certain personal information to help Viaggio understand your
interests or preferences so that we can deliver advertisements that are more
relevant to you.
|
Research
|
We may share your
personal information for activities such as statistical analysis and internal
research purposes but only in an aggregated and de-identified format.
|
Purchase or Sale
|
We may transfer any
information we have about you as an asset in connection with a merger or sale
(including transfers made as part of insolvency or bankruptcy proceedings)
involving all or substantially all of Viaggio’s assets or as part of a
corporate reorganization or other change in corporate control. If we do this,
the disclosure will be subject to confidentiality arrangements customary in
such transactions.
|
Law Enforcement and Data Protection Authorities
|
We cooperate with law
enforcement inquiries and demands for information that are made under force
of law. We are also cognizant of the need to address emergencies. Therefore,
we may disclose your personal information: (i) to any governmental authority
as part of an investigation to determine our compliance with any applicable
law, rule, or regulation (including privacy laws, rules, and regulations);
(ii) in response to a court order, subpoena, discovery request, or other
lawful judicial or administrative proceeding; (iii) as otherwise required
under any applicable law, rule, or regulation; and (iv) in good faith, to
protect or defend our rights or property or those of our users.
|
5. Device Information
1. 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.
2. 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.
3. How We Collect Device Information.
We automatically collect Device Information by
using the following technologies:
a. “Cookies” are data files that are placed on your device and often
include an anonymous unique identifier, as further described in Section 5.4.
b. “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.
c. “Web beacons”, “tags”, and “pixels” are electronic files used to
record information about how you browse the Website.
4. Cookies.
A cookie is a small text file sent from a
website and stored on the user’s computer by the user’s web browser. Upon
visiting a site that uses cookies, a cookie is downloaded onto your computer or
mobile device. The next time you visit that site, your device will remember
useful information such as preferences, visited pages, or logging in options.
Cookies are widely used to add functionality to websites, or to ensure they
work more efficiently. Our Services rely on cookies to optimize the user
experience and ensure the Services function properly. Most web browsers allow
some control to restrict or block cookies through the browser settings;
however, if you disable cookies you may find this affects your ability to use
certain parts of the Services. For more information about cookies please visit https://www.aboutcookies.org.
6. Security & Breach
1. 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.
2. 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.
3. 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.
7. Data Retention and Deletion
1. 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.
2. 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:
a. 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;
b. 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
c. 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.
8. Social Media
1. 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.
2. 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.
9. Third Party Links and Travel Suppliers. We may display advertisements from third
parties, including travel suppliers, and other content that links to
third-party websites. These links are not intended as an endorsement of or
referral to the linked websites. Furthermore, this Policy does not apply to
personal information that you share with travel suppliers directly. The linked
websites and travel suppliers have separate and independent privacy statements,
notices, and terms of use, which we recommend you read carefully. We do not
have any control over such travel suppliers or third party websites, and,
therefore, we have no responsibility or liability for the manner in which the
travel suppliers or organizations that operate such linked websites may
collect, use, disclose, or otherwise treat your personal information.
10. 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.
11. 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: customerservice@viaggio.com