As a provider of travel tour operator services to clients (a “Client”), Kensington Tours collects, uses and discloses personal information of individuals authorized to travel as a Client (a “Traveller”). Anyone who submits personal information to us should understand the nature of our business and how their personal information is collected, used, disclosed or processed by Kensington Tours.
Kensington Tours is committed to a high standard of privacy. It complies with applicable Canadian, and U.S. Privacy Laws, including federal and/or provincial/state privacy legislation in these jurisdictions and adopts the ten principles for the protection of personal information as set out below. (“Privacy Principles”) The Privacy Principles for the collection, use and disclosure of personal information include:
Kensington Tours is responsible for personal information in its custody or under its control, including any personal information that has been transferred to a third party for processing. Kensington Tours requires a comparable level of protection for personal information handled by its third party contractors.
In addition, Kensington Tours has designated a corporate Privacy Manager to facilitate Kensington Tours’ privacy compliance, in conjunction with senior leadership - who has overall responsibility for Kensington Tours’ privacy compliance.
Kensington Tours shall identify the purposes for which personal information is collected, at or before the time the information is collected. When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use.
The primary purposes for which Kensington Tours collects personal information include:
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where required or permitted by law.
Kensington Tours provides travel tour operator services to clients. In order to complete these services, Kensington Tours requires personal information for authorized Travellers. The personal information collected by Kensington Tours may include, but is not limited to, name, address, age, marital status, passport and visa information, emergency contact, email, phone number, financial information and corporate data.
Kensington Tours may also collect sensitive personal information related to a Traveller’s travel arrangements (such as the Traveller’s disabilities, allergies and other medical information and special needs) to help the Traveller obtain special accommodations for travel arranged by or through Kensington Tours, but only if the Traveller submits such sensitive personal information to us. If a Traveller does not want us to collect and use such sensitive personal information, then the Traveller should not submit this information to us. Kensington Tours will not share a Traveller’s sensitive personal information with a third party unless authorized to do so by the Traveller.
In order to complete the travel arrangements requested by the Traveller, Kensington Tours may input the Traveller’s personal information into a Tour Management Tech operating system or provide the Traveller’s personal information to one of the global distribution systems or an internet booking engine (“GDS”) or other travel supplier. The GDS uses such personal information to aid in fulfilling the travel arrangements requested by a Traveller through specific travel suppliers, such as airlines, hotels and rental car agencies. Kensington Tours receives confirmation of the travel arrangements requested by a Traveller.
Upon completion, Kensington Tours provides information to the Client on travel arrangements made for a Traveller. This information may include, but is not limited to, information regarding the dates and times of travel, locations travelled to and from, classes of service provided, the names and locations of any hotels or other lodging arranged for the Traveller by Kensington Tours, the names of other travel suppliers providing services to the Traveller, and the costs incurred for all travel services selected by the Traveller. A Traveller’s personal information may also be shared with the Client for which a Traveller is making travel arrangements.
Kensington Tours may be required or permitted to disclose personal information from time to time in order to comply with legal requirements and will comply with applicable Privacy Laws in doing so.
In addition to collecting, using and disclosing personal information in connection with the provision of services, Kensington Tours may collect personal information from its employees and this personal information may be transferred among Kensington Tours and its Affiliates, and may be subject to the Privacy Laws of a foreign jurisdiction. Employee personal information is not subject to PIPEDA, however, Kensington Tours handles employee personal information in accordance with the Privacy Principles (to the extent possible) and Kensington Tours’ human resources policies.
Kensington Tours limits the collection of personal information to that which is necessary for the purposes identified by Kensington Tours. Personal information must be collected by fair and lawful means.
Kensington Tours collects, stores and processes only that personal information required to provide travel tour operator services for or to fulfil contractual obligations with regard to Travellers and Clients.
Kensington Tours shall only use or disclose personal information for the purposes for which it was collected unless the individual has otherwise consented, or when it is required or permitted by law.
Personal information is retained only for the period of time required to fulfil the purposes for which it was collected.
Personal information is maintained by Kensington Tours in as accurate, complete and up-to-date form as is necessary to fulfil the purposes for which it is to be used. Kensington Tours relies upon the accuracy of the personal information submitted by the Traveller in order to provide the specific travel services, and does not routinely update that information.
Personal information of Travellers is protected by security safeguards that are appropriate to the sensitivity of the information.
Keeping a Traveller’s personal information confidential is important to us and Kensington Tours takes reasonable steps to protect that information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. Kensington Tours employs physical, administrative and technological safeguards to protect the security of personal information. For example, Kensington Tours has implemented physical security measures to protect against unauthorized access to its central and backup data centres where personal information is stored.
Any credit card information is transmitted in an encrypted format using standard SSL (secure socket layer) encryption. Travellers should use caution when disclosing personal information by telephone or other electronic media, as Kensington Tours has no control over such third party providers.
Kensington Tours conducts periodic internal reviews of its data collection, storage and processing practices and the security measures it has implemented to ensure that such security measures provide reasonable precautions and are commensurate with those generally practiced within the travel management industry.
As with all personal information, Kensington Tours will never rent or sell a Traveller’s personal financial information.
Kensington Tours employees who have access to personal information are bound by confidentiality obligations, the violation of which will subject the employee to discipline, which may include termination of employment.
Individuals may contact us at email@example.com if they have any questions about our privacy practices. If you would prefer to contact us in person, our telephone number is 647-943-8998, extension 4245, and you may ask for the Privacy Manager.
Upon request, an individual shall be informed of the existence, use and disclosure of their personal information, and shall be given access to it. Individuals may verify the accuracy and completeness of their information, and may request that it be amended, if appropriate.
If a Traveller becomes aware of any inaccuracy in his or her personal information or if a Traveller wishes to inquire about his or her personal information, then the Traveller should notify us by contacting us at firstname.lastname@example.org. Kensington Tours will make all corrections and/or deletions of erroneous personal information brought to its attention within a reasonable time period. Kensington Tours will provide access to personal information in accordance with the requirements of applicable Privacy Laws.
A Traveller who thinks that his or her personal information has been misused should direct any questions or complaints to Kensington Tours at email@example.com, providing a written description of the complaint. After receiving a written description of the complaint a representative of Kensington Tours will contact the Traveller in order to discuss his or her concerns. Kensington Tours is interested in addressing all legitimate complaints about its adherence to applicable Privacy Laws and will make a good faith effort to resolve promptly any complaint brought to its attention.