following policy statement (hereby referred to as the policy),
outlines the privacy policies and practices for SkyLink Travel, its
subsidiaries and affiliates (collectively referred to as, SkyLink)
with respect to the collection, use and disclosure of personal
information. This policy may be amended by SkyLink giving reasonable
notice of the revised policy (including by email or by positing on
SkyLink websites) and this policy may be supplemented or modified by
agreements entered into between SkyLink and an individual from time
information is any information about an identifiable individual, as
defined under the Canadian Privacy Act and the Personal Information
Protection & Electronic Documents Act (PIPEDA) or other
Use and Disclosure
where otherwise required or permitted by law, SkyLink will inform
individuals of the purpose for the collection, use or disclosure of
the individual’s personal information, prior to the collecting,
using or disclosing that personal information.
collects information from clients and potential clients through
various means including application forms, web-form registrations,
marketing campaign, purchase/sale agreements and survey responses.
The type of information collected will vary depending on the means
through which an individual submits his/her personal information.
The type of information collected may include an individual’s
name, residential address, email address, home phone number, age
group, preferences, credit information and specific comments.
uses information collected from clients and potential clients to
provide services or products, in respond to the requests for
information or the purchase of SkyLink’s products &
services; for mailing contacts for SkyLink publications, marketing
materials, special events or other marketing activity and for
additional purposes that may be identified at or before the time that
the information is collected. SkyLink also uses personal information
from purchasers for accounting and transactional completion purposes.
may disclose personal information to legal, financial and other
professional advisors or in connection with the sale or
reorganization of all or part of or its business or operations.
for consent to the collection, use or disclosure of personal
information vary depending on circumstances and on the type of
personal information that is intended to be collected, used or
disclosed. In determining whether consent is required and, if so,
which form of consent is appropriate, SkyLink will take into account
both the sensitivity of the personal information at issue and the
purposes for which SkyLink will use the information.
may be express, implied through the use of opt-out consent where
applicable or deemed. On giving reasonable written notice to
SkyLink, an individual may withdraw consent to the collections, use
or disclosure of his or her personal information. Upon receipt of
this withdrawal, SkyLink will notify the individual of the likely
consequences of withdrawing their consent. Except where otherwise
required or permitted by law, SkyLink will then cease collecting,
using or disclosing the individual’s personal information.
to the Collection of Personal Information
where required or permitted by law, SkyLink will limit the collection
of personal information to that which is necessary to fulfill the
purpose for which it is collected. Personal information will be
collected by fair and lawful means.
Disclosure and Retention
will not use or disclose personal information for purposes other than
those for which it was collected, except with consent of the
individual or as required or permitted by law.
the information is no longer required to fulfill its intended
purpose, and is no longer required or permitted to be retained for
legal or business purpose, it will be destroyed, erased or made
may disclose certain information to third party service providers and
to affiliated entities in order to carry out work on behalf of
SkyLink. Prior to making this disclosure, SkyLink will take
appropriate steps to ensure that such recipients safeguard the
personal information and use the information only for authorized
will make reasonable efforts to ensure that any personal information
collected by it, or on its behalf, is accurate and complete if the
personal information is likely to be used by SkyLink to make a
decision that affects the individual to whom the personal information
relates or if the information is likely to be disclosed to a third
will protect personal information with security safeguards
appropriate to the sensitivity of the information. Security
safeguards are employed to protect personal information against loss,
theft and unauthorized access, collections, use, disclosure, copying,
modifications or disposal or similar risks. The nature of these
safeguards will vary depending on the sensitivity of the personal
information that has been collected. The methods of safeguards
clearance and limiting access
measures such as user ID and passwords
will inform employees about SkyLink’s policies and practices
for protecting personal information and employees are required to
written request, with sufficient detail to enable SkyLink to identify
the individual and the personal information being sought, SkyLink
will inform an individual of the existence, use and the disclosure of
his or her personal information under SkyLink’s control and
will provide access to such information, unless otherwise prohibited
or permitted by law. SkyLink will respond to all requests within 30
days. SkyLink may extend the time limit for a further 30 days, or
for a longer period with the Privacy Commissioner’s consent or
as otherwise permitted by law.
individual may direct a complaint concerning compliance with the
policy to SkyLink’s Privacy Officer.
complaint must be in writing. Within a reasonable time of receipt of
the complaint, the Privacy Officer will conduct an investigation into
a reasonable time of conclusion of the investigation, the Privacy
Officer will inform the complainant, either verbally or in writing,
of their findings. If the Privacy Officer finds merit in the
complaint, SkyLink will take appropriate measures necessary to
rectify the source of the complaint.
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