Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation. In addition, due the nature of the travel agency business, we also include in our policies and staunchly protect therein an individual’s financial information including checking account information and credit card information.

Our travel agency, TIL American Express Travel , is a full service agency business, and we arrange travel products and services for our clients with a wide spectrum of industry suppliers. Accordingly, we deal with a number of consultants and third parties that may, in the course of their duties, have limited access to personal information we hold. These include airlines, railroads, cruise lines, tour operators, computer reservations system providers, and other travel-related vendors. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles in accordance with their own policies under the Personal Information Protection and Electronic Documents Act (PIPEDA).

Like all travel agencies, we collect, use and disclose personal information in order to serve our clients. For our clients, the primary purposes for collecting personal information are as follows: to make and secure reservations, to issue transportation documents and vouchers, and to provide travel suppliers with information to complete the necessary purchasing arrangements for a wide array of travel and tourism products. Examples of the type of personal information we collect for those purposes include the following: name, address, telephone, age, credit card information, passport or visa information, Social Insurance Number, web site cookies, and similar personal information necessary to properly identify our clients and their entitlement to the services we arrange. We also collect personal information from our employees and contractors to assure our proper compliance with employment laws, remuneration, tax payments, and other employee/contractor functions.

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

• Paper information is either under supervision or secured in a locked or restricted area.
• Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers. All of our cell phones are digital, which signals are more difficult to intercept.
• Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either through a direct line or is anonymized or encrypted.
• Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
• External consultants and agencies with access to personal information must enter into privacy agreements with us or acknowledge that the abide by PIPEDA.

We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We keep our client files for about 7 years. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our clients, newsletters, seminars and marketing activities for about 6 months after the newsletter, seminar or marketing activity is over. We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or all of the client file to our client.

With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., various industry forms, technical language, etc.).

We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests. If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.

Our Privacy Policy Manager, Karen Franklin, can be reached at 905-274-5858 to address any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Privacy Policy Manager. S/he will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:

112 Kent Street, Ottawa, Ontario K1A 1H3 as well as by:
Phone: (613) 995-8210
Toll-free: 1-800-282-1376
Fax: (613) 947-6850
TTY: (613) 992-9190
E-mail: info@privcom.gc.ca.