TRAV TRIV INC. PRIVACY POLICY  

 

(THE “POLICY”) 

 

OUR COMMITMENT TO PRIVACY 

At Trav Triv Inc. (“Trav Triv”, “we”, “us”, or “our”) which includes our subsidiaries and affiliates), we respect  the privacy of our users and any other person (collectively, “you” or “your”) who uses our mobile, tablet  and other smart device applications and application program interfaces (collectively, our “Platform”). 

We are committed to protecting security, confidentiality and privacy of all personal information that is  provided to us.  

 

SCOPE OF POLICY

This Policy applies to our collection, use and disclosure of your personal information. However, this Policy  does not impose any limits on the collection, use or disclosure of non-identifying information of any kind,  business contact information or other publicly available information. This Policy applies only to personal  information relating to individuals and therefore does not apply to companies, partnerships, trusts,  associations and other commercial or corporate entities.  

This Policy is governed by the law of the Province of Alberta, Canada without reference to its conflicts of  law rules.  

We may make changes to this Policy from time to time to reflect changes in our legal or contractual  obligations, or in the manner in which we deal with your personal information. These changes will be  incorporated into a revised Policy. It is your responsibility to check the Policy from time to time to review  revisions as and when made. 

 

THIRD PARTY SERVICE PROVIDERS 

We may authorize third party agents, subcontractors, vendors or suppliers (each, an “Agent”) from time to  time in relation to our Platform and related business activities. If we require an Agent to deal with your  personal information, we will take reasonable steps to ensure that the Agent adheres to privacy procedures  and will keep your personal information confidential in accordance with this Policy. We will not provide more  information than is necessary to the Agent and will ensure that the information is returned to us or destroyed  once the purpose for which it was given is completed. 

 

TRAV TRIV PRIVACY OFFICER 

We have designated a Privacy Officer who is responsible for our compliance with this Policy. The contact  information for our Privacy Officer is as follows: 

Trav Triv Inc. 

124 Thicket Dr. Fort McMurray Ab Canada 

Attn: Privacy Officer  

Tel: 780 880 5623 

E-mail: robertfrost@travtriv.ca

 

PERSONAL INFORMATION 

For the purpose of this Policy, “personal information” is any information about an identifiable individual,  (other than the person’s business title or business contact information used or disclosed for the purpose of  business communications). Personal information does not include anonymous or non-personal information  (i.e., information that cannot be associated with or tracked to a specific individual). 

 

COLLECTION OF INFORMATION 

We may collect some or all of the following personal information from you directly TO THE EXTENT  REQUIRED BY US AND/OR BY LAW TO ENABLE YOU to use our Platform; create, maintain and operate  an account on the Platform; or make a booking with an Agent or other third party through, or in connection  with, our Platform: 

  • your name, age and gender;  
  • your home address, home and mobile telephone numbers and personal e-mail addresses; payment or banking information (including related payment verification information); biographical information, such as household data, preferences, and demographic information;  
  • if required of us by any third party in order to confirm a booking with it, citizenship and residency  status and/or details of your identification and travel documents, such as driver’s licenses,  passports, visas and so forth; 
  • information about how you interact with the services available on the Platform, including information  regarding your selections of products and services offered on our Platform, access dates and times,  pages viewed, and so forth; 
  • information about the devices you use to access our Platform and services; and  any other personal information you choose to provide to us, including your feedback. 

Trav Triv may also collect personal information about you from third parties to whom you have provided  your personal information and their associated and affiliated entities, as well as regulatory agencies and  governmental authorities, to the extent permitted under applicable laws and for the purposes stated in this  Policy. 

 

BY SUBMITTING PERSONAL INFORMATION TO TRAV TRIV, TRAV TRIV’S AUTHORIZED AGENTS,  VENDORS AND SUPPLIERS AND/OR THIRD PARTY SERVICE PROVIDERS, YOU AGREE THAT WE  MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH  THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW. 

 

USE AND DISCLOSURE OF PERSONAL INFORMATION 

We may use and disclose your personal information to our Agents and their associated and affiliated entities  in order to enable our services, to communicate with you as required, for payment purposes or for legal  reasons, as well as to our insurers and our other business partners, affiliates and vendors and suppliers,  relevant governmental agencies and statutory authorities, law enforcement agencies or other persons  where disclosure is authorized by law. While Trav Triv, by contract or otherwise, will use reasonable efforts  to restrict the purpose of use of your personal information by Agents and other third parties, to the extent  Trav Triv discloses your personal information with Agents and other third parties as set forth in this Policy, Trav Triv cannot control, nor is it responsible for, the use or further disclosure of your personal information  by any such Agents or third parties. 

 

PURPOSES 

We collect and use your personal information for the following purposes:  

  • to authenticate your identity; 
  • to protect and ensure the confidentiality of your account information and to safeguard our  business interests; 
  • for administering and monitoring compliance with contracts for the sale and purchase of  services through our Platform and maintaining accurate customer records; 
  • to process payments and collect debts owed to us or to any Service Provider; 
  • to communicate with you regarding your inquiries and bookings and for customer notifications  regarding your bookings and account information; 
  • for customer support, including directing your questions to the appropriate contact and  investigating and addressing your concerns; 
  • to establish, develop and maintain our relationship with you by personalizing your interaction  with us and our Platform, remembering your interests and preferences and providing you with  a customized shopping experience, tailoring our marketing efforts to your needs and  preferences and providing you with information and offers for other products and services,  including those offered by Service Providers or third parties, that may be of interest to you; 
  • to improve our products, services and Platform, including by seeking feedback from you in the  form of customer surveys and market research studies;  
  • to communicate with you regarding our products, services, promotions, offers, incentives and  marketing initiatives; 
  • to better understand how users access and use our website, in order to improve our website  and to respond to user preferences; 
  • at your request, to share your booking information with other potential users identified by you; to comply with legal and regulatory requirements; 
  • to share with applicable Service Providers and third parties, such as payment processors, in  respect of your bookings, the services provided to you and your payments to us and/or to the  Service Providers; 
  • to share information with our affiliates and subsidiaries (if applicable) as required to enable  them to carry out their obligations concerning your bookings; and 
  • to perform internal operations necessary to provide our services, to monitor and analyze use  and activity trends and for testing, research, analysis and product development.

 

We also use your personal information to endeavor to protect you, us and our Service Providers and their  associated and affiliated entities from fraud and error and to safeguard our business interests, to collect  debts owed to us and to comply with our contractual and legal duties and obligations.  

The above collections, uses and disclosures are a necessary part of your relationship with us. By providing  such personal information to us, you consent to us using and disclosing that information for those purposes. 

We may also collect, use and disclose your personal information to offer additional or alternate products  and services to you, and we may add your personal information to customer lists for this purpose. You may  instruct us to refrain from using or sharing your personal information in this way by providing written  notification to our Privacy Officer. We will not refuse you access to any product or service merely because  you have instructed us to stop using your personal information in this manner. 

When collected personal information is to be used for a purpose not previously identified, we will identify the new purpose to you and obtain your consent prior to using your personal information for such new  purpose, unless such use is authorized or required by law. 

We may use aggregated, non-identifiable information about our customers for promotional, advertising,  research and other commercial purposes, and we may use, license and sell such aggregated data as we  see fit. We will not sell your personal information to third parties. 

 

CONSENT 

We will obtain your consent to collect, use or disclose personal information except where we are authorized  or required by law to do so without consent. For example, we may collect, use or disclose personal  information without your knowledge or consent where: 

  • the information is publicly available, as defined by statute or regulation; 
  • we are obtaining legal advice; or 
  • we reasonably expect that obtaining consent would compromise an investigation or proceeding. 

Your consent can be express, implied or given through an authorized representative. Consent may be  provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not  wish your personal information collected/used/disclosed for various purposes after you have received  notice of those purposes) or otherwise.  

You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that  you give reasonable notice of withdrawal of consent to us. If you withdraw your consent by notifying us in  writing, we will inform you of the likely consequences of the withdrawal of consent, which may include our  inability to provide certain services in respect of which that information is necessary. 

 

RETENTION AND DESTRUCTION PERSONAL INFORMATION 

We will keep personal information used to make a decision affecting you for at least one (1) year after using  it to make the decision. 

We will destroy, erase or make anonymous documents or other records containing personal information as  soon as it is reasonable to assume that the original purpose is no longer being served by retention of the  information and retention is no longer necessary for a legal or business purpose. 

We will take due care when destroying personal information so as to prevent unauthorized access to the  information. 

 

ACCURACY 

We will make reasonable commercial efforts to ensure that personal information we are using or disclosing  is accurate and complete. If you believe that a record of your personal information is inaccurate or  incomplete, you may request in writing that we correct the record. If we refuse to make the requested  change, we will give you written reasons for that decision and will explain your further options. If appropriate,  we will send the amended information to third parties to whom the information has been disclosed. 

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we  will annotate the personal information under our control with a note that the correction was requested but  not made. 

 

SAFEGUARDING PERSONAL INFORMATION 

We use commercially reasonable security arrangements to protect the personal information in our custody  or control against unauthorized access, collection, use, disclosure, copying, modification, disposal or similar  risks. We will request, through contractual or other reasonable means, a comparable level of personal  information protection be implemented by our Agents and the Service Providers. 

Confidentiality and security are not assured when information is transmitted through e-mail or other wireless  communication. We will not be responsible for any loss or damage suffered as a result of a breach of  security and/or confidentiality when you transmit information to us by e-mail or other wireless  communication or when we or you transmit such information to our Agents and service providers. Please  notify our Privacy Officer in writing if you do not want Trav Triv to communicate with you through these  means. 

 

PROVIDING ACCESS 

You have a right to access your personal information held by us. If you request access, then after we  authenticate your identity, we will provide you with your personal information under our control (unless  prohibited by applicable law). We will also give you information about how that information is being used  and a description of the organizations to whom that information has been disclosed. We may charge you  a reasonable fee for doing so. We will make a reasonable effort to make the information available within 30  days of receiving a written request or provide written notice where additional time is required to fulfil the  request. 

In some situations, we may not be able to provide access to certain personal information (e.g., if disclosure  would reveal personal information about another individual, the personal information is protected by  solicitor/client privilege, the information was collected for the purposes of an investigation or where  disclosure of the information would reveal confidential commercial information that could harm the  competitive position of Trav Triv). We may also be prevented by law from providing access to certain  personal information. 

Where an access request is refused, we will notify you in writing, document the reasons for refusal and  outline further steps that may be available to you. 

 

CONTACT 

We will, on request, provide information regarding our complaints procedure. Any inquiries, complaints or  questions regarding this Policy should be directed in writing to Trav Triv’s Privacy Officer. 

 

CROSS-BORDER TRANSFERS 

We may transfer your personal information across national borders to fulfil any of the above purposes  (including, for example, for air services that include flights outside of Canada) and to comply with applicable 

local laws. You may contact our Privacy Officer to obtain information about our policies and practices  regarding our transfer of personal information outside of Canada, or to ask questions about the collection,  use, disclosure or storage of personal information by us or our service providers.  

 

NON-IDENTIFIABLE INFORMATION RELATED TO PLATFORM USE  

At any time that you visit or use our Platform, we, our Agents or third party service providers may gather  certain non-identifiable information regarding your use of our Platform. Such information may include the  type and version of your browser; the operating system, hardware version, device settings, file and software  names and types, battery and signal strength, and device identifiers of the device you use to access the  Platform; device location, including specific geographic locations, such as through GPS, GLONASS,  Bluetooth, or wireless or WiFi signals; your service provider, your IP address, pages visited and requests  made, and day and time of connection and any search engine you may have used to locate our site.  

All non-identifiable information is collected on an aggregated basis for statistical purposes only and at no  time is your identity revealed. We use this non-identifiable information to help diagnose problems with our  server, administer the Platform, and compile broad statistical data. In addition, we gather certain  navigational information about where you go on our Platform to help us continually improve the user  experience and tailor our Platform to the needs of our users. The amount of information that is sent by your  web browser or by third party service providers depends on the browser and settings you use, including  your cookie settings. 

To help us ensure that our Platform contains content that is useful to our users and potential users, we may  use certain tools on our website1 that allow us to review anonymous data regarding the gender, age and  interests of Platform users and customize the Platform to better reflect our users’ needs. This information  is not collected in a personally-identifiable format and we cannot identify what information is about you. 

 

COOKIES 

We may use cookies to collect all or certain of your personal information. Cookies are unique identifiers  which are used to customize our Platform, authenticate users and remember preferences and settings.  Most web browsers automatically accept cookies, but allow you to change your browser settings to prevent  or notify you whenever you are sent a cookie. This gives you the opportunity to decide whether or not to  accept the cookie. We use the information in cookies to help us monitor our Platform’s performance and  improve our Platform. In order to use the Platform, you are not obligated to accept cookies, and you can  still access many of the Platform features if you do not accept cookies, but there may be limitations on your  use of some Platform functions. 

 

THIRD-PARTY CONTENT (e.g., social media links): Some of the content on our Platform may include  links or applications made available by third parties, which could include social media buttons or links that  allow you to access third party content or websites or share content or links to our Platform through the  relevant third-party applications. These third-party applications themselves may facilitate the collection of  personal information by those third parties, through your interaction with the applications. We are not  responsible for, and do not accept any liability in relation to the technical operation of these applications or  the collection and use practices of the relevant third parties. Please visit the relevant third-party websites  to understand their privacy practices and the options they may make available to you in relation to their  collection of your personal information. 

 

1 For example, the demographics and interest reporting features of Google Analytics 

 

CAN: 35542065.1