1. Privacy Statement
Gone Sailing Adventures (GSA) is committed to respecting the confidentiality and privacy of personal information provided to us by our clients. GSA has adopted the ten privacy principles set out in the Canadian Standards Association Model Code for the Protection of Personal Information and embodied in the Personal Information Protection and Electronic Documents Act (PIPEDA). GSA observes our obligations under PIPEDA, under provincial legislation in effect in Quebec, British Columbia and Alberta to the extent applicable, and under such other applicable provincial privacy laws, which are substantially similar to PIPEDA as may come into force from time to time. GSA will collect, use and disclose personal information only for such purposes and to such extent as is necessary to enable us to provide our services as sailing school and sailing charters.
2. Definition of Personal Information
Personal information is information about an identifiable individual but does not include the name, title or business address or telephone number of an employee of a business. Personal information includes personally identifiable information such as a person’s home address and residential contact information, age, gender, income, credit rating, financial information, consumer preferences, health status and political affiliations.
3. Purposes of Use of Personal Information
GSA collects personal information for the sole purpose of enabling GSA to perform sailing instruction and charters to clients; provide emergency services in such instances as may occur; provide information to sailing organizations to award certifications, licenses and other recognitions; provide information to our customers relating to GSA programs, offerings and special promotions. In the course of performing these services, GSA will require the name, address (including both business and home addresses on occasion), business, cell, fax and home telephone numbers and email addresses of identifiable individuals. GSA may also require in certain circumstances information relating a person’s health, swimming ability, limiting conditions of identifiable individuals; as well as certain financial information such as credit card number, banking information, and such other credit information as available. GSA may also take photographs or video of individuals on board or close to the GSA property/vessels and use such images in its promotional material.
4. Manner of Collection, Use and Disclosure of Personal Information
As noted above, GSA will only collect, use and disclose personal information for the purposes of providing services to our clients, and for purposes ancillary thereto, such as billing and collection of accounts in respect of which credit has been extended or first responders and health care workers in the event of an emergency situation and sailing awarding bodies. GSA will collect personal information in personal interviews, on-line applications, and order forms. By providing us with such information, individuals are deemed to consent to its use for the purposes set out herein. GSA will not use personal information for any other or secondary purpose. Specifically, GSA will not provide personal information, either by way of sale or other disclosure, to any marketing agency, mail house, data processing agency or any other promotional entity or third party without express written consent. GSA will not collect information which GSA does not require in the course of providing our services.
5. Retention and Disposal of Personal Information
GSA will not retain personal information longer than is necessary for the purposes of serving our clients hereunder and as otherwise required by legislation. In general, GSA will retain personal information for a period of one calendar year after which time we will no longer need to retain such information other than email addresses. When GSA no longer have any use for the personal information, GSA shall dispose of it by having it shredded or destroyed in the case of physical files and documents, and by erasing the files from our hard drive or other storage medium in the case of electronic data files.
6. Protection and Security of Personal Information
GSA has implemented policies and procedures to ensure that personal information is protected from unauthorized access, use, tampering, loss or disclosure. Firstly, only those who will be involved in the provision of the services will have access to personal information as required to perform their job responsibilities. Secondly, all personal information which is retained on our computers will be stored in secure folders and will not be available for general access in our organization. All computer and information systems with internet access will be equipped with firewalls; antiviral software and power source back up to ensure the security and integrity of your personal information. In the event that GSA require the services of third parties and need to provide personal information to such third party for the purposes of providing our services, GSA will first confirm that consent has been provided to not disclose the information. Upon confirming the relevant individuals consent, GSA will not provide such information until GSA receive reasonable assurances from any such third party that they have in place a privacy policy which is substantially similar to this policy.
7. Review of Accuracy of Personal Information on File
If an individual has a concern with the accuracy or contents of their personal information which we have on file, such individual may contact our privacy officer to request particulars of his or her personal information. Any such request must be made in writing and addressed to the privacy officer at the address set out below. The privacy officer shall review such request and endeavour to respond within 30 days. The privacy officer may refuse to provide this information to the individual if so providing it would result in disclosure of personal information about a third party who has not consented to such disclosure. The privacy officer may also refuse to provide such information where such information: is protected by solicitor-client privilege; cannot be separated from confidential commercial information; the disclosure of which would result in the breach of an agreement or of a law of Canada or one of its provinces. The privacy officer may request that the individual provide documentation or evidence to support the challenge to the accuracy of the personal information on file. The privacy officer reserves the right to review such documents and evidence and shall upon being convinced of error or inaccuracy; amend the individuals’ personal information accordingly.
8. Privacy Officer
In order to review personal information, to express any concern relating to privacy or review our compliance with this privacy policy or any relevant federal or provincial privacy legislation, an individual may contact GSA by mail, email or telephone at the contact information set out below:
Attention: Privacy Officer Gone Sailing Adventures
1015-55 William St E
Oshawa ON L1G 7C9
info@gosailto.com
416 240 0202
More general information may be found on the website of the Information and Privacy Commissioner of Canada at
https://www.priv.gc.ca/.
The Commissioner can be reached by mail at112 Kent Street,Ottawa, Ontario, K1A 1H3,and toll free by phone at
1-800-282-1376.
