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OUR 10 PRIVACY PRINCIPLES
Principle 1 - Accountability
Principle 2 - Identifying Purposes for Collection of Personal
Information
Principle 3 - Consent
Principle 4 - Limiting Collection of Personal Information
Principle 5 - Limiting Use, Disclosure of Retention of Personal
Information
Principle 6 - Accuracy
Principle 7 - Security Safeguards
Principle 8 - Openness
Principle 9 - Individual Access
Principle 10 - Handling Inquiries & Challenges
SCOPE & APPLICATION
This Privacy Policy contains ten principles that are observed by Lodging Ovations / Whistler Blackcomb regarding the collection, use and disclosure of personal information. Each principle must be read in conjunction with the accompanying commentary. The commentary in the Lodging Ovations / Whistler Blackcomb Privacy Policy has been tailored to reflect personal information issues specific to Lodging Ovations / Whistler Blackcomb. The scope and application of the Lodging Ovations / Whistler Blackcomb Privacy
Policy are as follows:
- The Policy applies to personal information about Lodging Ovations / Whistler Blackcomb's customers and other individuals that is collected, used or disclosed by Lodging Ovations / Whistler Blackcomb.
- The Policy does not apply to information about Lodging Ovations / Whistler Blackcomb's corporate customers; however, such information is protected by other Lodging Ovations / Whistler Blackcomb policies and practices and through contractual arrangements.
- The Policy does not apply to information about Lodging Ovations / Whistler Blackcomb's employees; however, such information is protected by other Lodging Ovations / Whistler Blackcomb policies and practices.
- This Policy is subject to change, and may be supplemented or modified by additional terms applicable between Lodging Ovations / Whistler Blackcomb and an individual.
DEFINITIONS
Collection - the act of gathering, acquiring, recording, or obtaining personal information. Consent - voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express, implied or deemed, and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from an individual's action or inaction. Deemed consent is consent that is deemed to be given pursuant to applicable legislation or other regulations. Disclosure - making personal information available to a third party.
Personal information - information about an identifiable
individual, but does not include aggregated information that cannot
be associated with a specific individual. Personal information also
excludes certain information as is excluded pursuant to applicable
legislation or other regulations, such as publicly available
information or business contact information, as and when
applicable.
Lodging Ovations, Whistler Mountain Resort Limited Partnership,
Blackcomb Skiing Enterprises Limited Partnership, Whistler
Blackcomb Holdings Inc. and their subsidiaries and certain
designated affiliates, as they may exist from time to time.
Third party - an individual or organization outside Lodging Ovations / Whistler Blackcomb. Use - the treatment, handling and management of personal information by and within an organization.
Principle 1 - Accountability
Lodging Ovations / Whistler Blackcomb is responsible for
personal information under its control and shall designate one or
more persons who are accountable for Lodging Ovations / Whistler
Blackcomb's compliance with the following principles.
1.1 Lodging Ovations / Whistler Blackcomb designates the Chief
Privacy Officer as the person accountable for compliance with the
Policy. From time to time, the Chief Privacy Officer is entitled to
delegate day-to-day responsibility for administration of this
Privacy Policy and related privacy policies and practices to other
employees and consultants.
1.2 Lodging Ovations / Whistler Blackcomb shall make known, upon
request, the title of the person or persons designated to oversee
Lodging Ovations / Whistler Blackcomb's compliance with the
Policy.
1.3 Lodging Ovations / Whistler Blackcomb is responsible for
personal information in its possession or under its control.
Lodging Ovations / Whistler Blackcomb shall use appropriate means
to protect personal information while information is being
processed by a third party on behalf of Lodging Ovations / Whistler
Blackcomb (see Principle 7).
1.4 Lodging Ovations / Whistler Blackcomb shall implement policies
and procedures to give effect to the Policy, including:
a) implementing procedures to protect personal information and to
oversee Lodging Ovations / Whistler Blackcomb's compliance with the
Lodging Ovations / Whistler Blackcomb Privacy Policy;
b) establishing procedures to receive and respond to inquiries or
complaints;
c) training and communicating to staff about Lodging Ovations /
Whistler Blackcomb's policies and practices; and
d) developing public information to explain Lodging Ovations /
Whistler Blackcomb's policies and practices.
Principle 2 - Identifying Purposes for Collection of Personal Information
Lodging Ovations / Whistler Blackcomb shall identify and
document the purposes for which personal information is collected
at or before the time the personal information is collected or,
when appropriate, at or before the time the personal information is
used for a new purpose.
2.1 Lodging Ovations / Whistler Blackcomb collects personal
information for the following purposes:
a) to establish and maintain a responsible commercial relationship
with customers;
b) for purposes identified to individuals or purposes obvious to
individuals, in respect of particular collections of personal
information;
c) to meet legal and regulatory requirements;
d) to understand needs and preferences of individuals;
e) to develop, enhance, market and/or provide products and
services;
f) to manage and develop Lodging Ovations / Whistler Blackcomb's
business and operations, including transfer of data among
affiliated entities.
Further references to "identified purposes" mean the purposes
identified in this Principle.
2.2 Lodging Ovations / Whistler Blackcomb shall, as appropriate,
specify orally, electronically or in writing the identified
purposes to the individual at or before the time personal
information is collected. Upon request, persons collecting personal
information shall explain these identified purposes or refer the
individual to a designated person within Lodging Ovations /
Whistler Blackcomb who shall explain the purposes.
Principle 3 - Consent
The knowledge and consent of an individual are generally
required for the collection, use or disclosure of personal
information. In certain circumstances personal information can be
collected, used or disclosed without the knowledge and consent of
the individual, such as in the case of an emergency where the life,
health or security of an individual is threatened.
Lodging Ovations / Whistler Blackcomb may disclose personal
information without knowledge or consent to a lawyer or other
advisor representing Lodging Ovations / Whistler Blackcomb, to
collect a debt, to comply with a subpoena, warrant or other court
order, or as may be otherwise required or authorized by law.
3.1 In obtaining consent, Lodging Ovations / Whistler Blackcomb
shall use reasonable efforts to ensure that an individual is
advised of the identified purposes for which personal information
will be used or disclosed. Purposes shall be stated in a manner
that can be reasonably understood by the individual.
3.2 Generally, Lodging Ovations / Whistler Blackcomb shall seek
consent to use and disclose personal information at the same time
it collects the information. However, Lodging Ovations / Whistler
Blackcomb may seek consent to use and disclose personal information
after it has been collected, but before it is used or disclosed for
a new purpose.
3.3 Lodging Ovations / Whistler Blackcomb will require individuals
to consent to the collection, use or disclosure of personal
information as a condition of the supply of a product or service
only if such collection, use or disclosure is reasonably required
to fulfill the identified purposes.
3.4 In determining the appropriate form of consent, Lodging
Ovations / Whistler Blackcomb shall take into account the
sensitivity of the personal information and the reasonable
expectations of an individual.
3.5 Where consent is required for a particular use or disclosure,
an individual may withdraw consent at any time, subject to legal or
contractual restrictions and reasonable notice. Individuals may
contact Lodging Ovations / Whistler Blackcomb for more information
regarding the implications of withdrawing consent.
Principle 4 - Limiting Collection of Personal Information
Lodging Ovations / Whistler Blackcomb shall limit the collection
of personal information to that which is necessary for the purposes
identified by Lodging Ovations / Whistler Blackcomb and as
permitted by law.
4.1 Lodging Ovations / Whistler Blackcomb collects personal
information primarily from the individual to whom the information
relates.
4.2 Lodging Ovations / Whistler Blackcomb may also collect
personal information from other sources including credit bureaus or
other third parties who represent that they have the right to
disclose the information, or as otherwise permitted by law.
Principle 5 - Limiting Use, Disclosure & Retention of Personal Information
Lodging Ovations / Whistler Blackcomb shall not use or disclose
personal information for purposes other than those for which it was
collected, except with the consent of the individual or as required
by law. Lodging Ovations / Whistler Blackcomb shall retain personal
information only as long as necessary for the fulfillment of those
purposes or as required or permitted by law.
5.1 Lodging Ovations / Whistler Blackcomb may disclose an
individual's personal information to:
a) a person who in the reasonable judgment of Lodging Ovations /
Whistler Blackcomb is seeking the information as an agent of the
individual;
b) a company or individual employed by Lodging Ovations / Whistler
Blackcomb to perform functions on its behalf, such as but not
limited to research or data processing;
c) another company or individual for the development, enhancement,
marketing or provision of any of Lodging Ovations / Whistler
Blackcomb's products and services;
d) an agent used by Lodging Ovations / Whistler Blackcomb to
evaluate the individual's creditworthiness or to collect the
individual's account;
e) a credit reporting agency;
f) a public authority or agent of a public authority, if in the
reasonable judgment of Lodging Ovations / Whistler Blackcomb, it
appears that there is imminent danger to life or property which
could be avoided or minimized by disclosure of the
information;
g) another entity as part of a merger, a sale of assets or all or
part of a business, or any other corporate change or
re-organization;
h) a third party or parties, where the individual consents to such
disclosure or disclosure is required or permitted by law.
5.2 Only Lodging Ovations / Whistler Blackcomb employees with a
business need to know, or whose duties reasonably so require, are
granted access to personal information about individuals.
5.3 Depending on the circumstances, where personal information has
been used to make a decision about an individual, Lodging Ovations
/ Whistler Blackcomb shall retain, for a reasonable period of time,
either the actual information or the rationale for making the
decision.
5.4 Lodging Ovations / Whistler Blackcomb shall maintain
reasonable and systematic controls, schedules and practices for
information and records retention and destruction which apply to
personal information that is no longer necessary or relevant for
the identified purposes or required or permitted by law to be
retained. Such information shall be destroyed, erased or made
anonymous.
5.5 Where appropriate, Lodging Ovations / Whistler Blackcomb may
communicate updates of personal information to third parties.
5.6 Lodging Ovations / Whistler Blackcomb may engage affiliates or
third party service providers for the purpose of providing services
or processing information on behalf of Lodging Ovations / Whistler
Blackcomb, and we may transfer or disclose personal information to
such parties in connection with such purposes. Some divisions,
affiliates or third party service providers may be located in other
jurisdictions, and information in their custody (i) may or may not
be subject to privacy legislation similar to that applicable to
Lodging Ovations / Whistler Blackcomb, and (ii) may be subject to
laws applicable in such jurisdictions that permit access to such
information by foreign governments or law enforcement agencies or
by others.
Principle 6 - Accuracy
Lodging Ovations / Whistler Blackcomb shall take steps to ensure
that personal information is as accurate, complete and up-to-date
as is appropriate for its purposes.
6.1 Personal information used by Lodging Ovations / Whistler
Blackcomb shall be sufficiently accurate, complete and up-to-date
to minimize the possibility that inappropriate information may be
used to make a decision about an individual.
6.2 Lodging Ovations / Whistler Blackcomb shall take all
reasonable steps to update personal information about individuals
as and when reasonably necessary to fulfill the identified purposes
or as reasonably requested by the individual.
Principle 7 - Security Safeguards
Lodging Ovations / Whistler Blackcomb shall protect personal
information by security safeguards appropriate to the sensitivity
of the information.
7.1 Lodging Ovations / Whistler Blackcomb shall take appropriate
and reasonable steps to protect personal information against such
risks as loss or theft, unauthorized access, disclosure, copying,
use, modification or destruction.
7.2 Lodging Ovations / Whistler Blackcomb shall take appropriate
and reasonable steps to protect personal information disclosed to
third parties, for example by contractual agreements stipulating
the confidentiality of the information and the purposes for which
it is to be used.
Principle 8 - Openness
Lodging Ovations / Whistler Blackcomb shall make readily
available to individuals specific information about its policies
and practices relating to the management of personal
information.
8.1 Copies of the Policy will be made available upon
request.
8.2 Lodging Ovations / Whistler Blackcomb shall make information
about its policies and procedures easy to understand,
including:
a) the title and addresses of the person or persons accountable
for Lodging Ovations / Whistler Blackcomb's compliance with the
Policy and to whom inquiries or complaints can be forwarded;
b) the means of gaining access to personal information held by
Lodging Ovations / Whistler Blackcomb; and
c) a description of the type of personal information held by
Lodging Ovations / Whistler Blackcomb, including a general account
of its use.
Principle 9 - Individual Access
Upon request, Lodging Ovations / Whistler Blackcomb shall inform
an individual of the existence, use and disclosure of his or her
personal information, at a minimal or no cost to the individual. An
individual shall be able to challenge the accuracy and completeness
of the information and have it amended as appropriate.
9.1 In certain situations, Lodging Ovations / Whistler Blackcomb
may not be able to provide access to all the personal information
that it holds about an individual. For example, Lodging Ovations /
Whistler Blackcomb may not provide access to information if doing
so would likely reveal personal information about a third party or
could reasonably be expected to threaten the life or security of an
individual. Also, Lodging Ovations / Whistler Blackcomb may not
provide access to information if disclosure would reveal
confidential commercial information, if the information is
protected by solicitor-client privilege, if the information was
generated in the course of a formal dispute resolution process, or
if the information was collected in relation to the investigation
of a breach of an agreement or a contravention of a law. If access
to personal information cannot be provided, Lodging Ovations /
Whistler Blackcomb shall, upon request, provide the reasons for
denying access.
9.2 In order to safeguard personal information, an individual may
be required to provide sufficient identification information to
permit Lodging Ovations / Whistler Blackcomb to authorize access to
the individual's file.
9.3 Individuals can seek access to their personal information by
contacting the Privacy Office at Lodging Ovations / Whistler
Blackcomb.
9.4 Lodging Ovations / Whistler Blackcomb will endeavor to respond
to all requests within 30 days or, in any event, as required or
permitted by applicable law.
Principle 10 - Handling Inquiries & Challenges
An individual shall be able to address a challenge concerning
compliance with the above principles to the designated person or
persons accountable for Lodging Ovations / Whistler Blackcomb's
compliance with the Policy.
10.1 Lodging Ovations / Whistler Blackcomb shall maintain
procedures for addressing and responding to all inquiries or
complaints from individuals about Lodging Ovations / Whistler
Blackcomb's handling of personal information.
10.2 Lodging Ovations / Whistler Blackcomb shall inform its
customers about the existence of these procedures as well as the
availability of complaint procedures.
10.3 The person or persons accountable for compliance with this
Policy may seek external advice where appropriate before providing
a final response to individual complaints.
QUESTIONS?
If you have questions or concerns about our privacy
policy or practices, or would like changes to the
communications we send you, please contact our Privacy
Office.
Email: yourprivacy@lodgingovations.com
Phone: (604) 938-7372
Mail: Chief Privacy Officer
Lodging Ovations / Whistler Blackcomb
2036-London Lane
Whistler, BC
Canada V0N 1B2
Policy Update: February 8, 2011
