Own Your Day Travel – Personal Information Protection Policy
Effective Date: 2026-03-24

At Own The Day Limited o/a Own Your Day Travel (“Own Your Day Travel,” “we,” “us,” or “our”), protecting the personal information of our members, clients, and independent advisors is a top priority. This policy outlines how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and British Columbia’s Personal Information Protection Act (PIPA). This policy applies to all personal information handled by Own Your Day Travel, including information collected by our service providers acting on our behalf.

1. Definitions

• Personal Information – Information about an identifiable individual, including:

• For independent advisors: name, home address, phone number, personal email, Social Insurance Number (SIN), banking or payment information, passport number, date of birth, and other information needed to manage advisor accounts.

• For travel clients/members: name, contact details, payment information, passport number, date of birth, and other information needed to provide travel services.

• Contact Information – Information that allows an individual to be contacted at a place of business, such as name, title, business phone number, business email, or business fax. Contact information is not subject to PIPEDA or PIPA.

• Privacy Officer – The individual responsible for ensuring Own Your Day Travel’s compliance with this policy, PIPEDA, and PIPA.

• Member – An authorized representative of Own Your Day Travel or an individual participating in an Own Your Day Travel member program.

• Client – A recipient of travel or travel-related services and information through an authorized Own Your Day Travel member.

2. Collection of Personal Information

• We only collect personal information that is necessary to provide our services or meet regulatory requirements.

Examples of purposes for collection include:

• Verifying identity;

• Identifying preferences;

• Opening and managing accounts;

• Delivering requested products or services;

• Guaranteeing travel reservations;

• Enrolling members or clients in programs;

• Sending membership or travel information;

• Ensuring high-quality service;

• Processing membership or travel payments;

• Meeting regulatory or legal obligations.

• We inform individuals of the purposes for which personal information is collected, either in writing or orally, at or before the time of collection, unless the purpose is obvious.

3. Consent

• We obtain consent before collecting, using, or disclosing personal information, except where otherwise authorized by law.

• Consent may be:

• Express (oral, written, or electronic);

• Implied, where the purpose is obvious, and the individual voluntarily provides information;

• Implied for marketing materials if the individual has been given notice and a reasonable opportunity to opt-out.

• Individuals may withhold or withdraw consent at any time, subject to legal or contractual restrictions. Withdrawing consent may limit our ability to provide certain products or services.

• We may collect, use, or disclose personal information without consent in limited circumstances, including:

• Where required or permitted by law;

• In emergencies that threaten life, health, or personal security;

• From publicly available sources;

• To obtain legal advice;

• For debt collection;

• To prevent fraud or investigate potential legal breaches.

• Marketing communications: We will only send marketing emails to individuals who have provided express consent, in accordance with Canada’s Anti-Spam Legislation (CASL).

4. Use and Disclosure

• Personal information is used or disclosed only to fulfill the purposes identified at collection or for purposes reasonably related to those purposes.

• Examples include:

• Conducting surveys to improve services;

• Communicating about products or services that may be of interest;

• Sharing with service providers acting on our behalf (e.g., payment processors, travel partners, insurers).

• Personal information is never sold to third parties.

• International transfer: Some personal information may be stored or processed outside Canada (e.g., cloud services). We ensure that adequate safeguards are in place for such transfers.

5. Retention

• Personal information is retained only as long as necessary to fulfill the purposes for which it was collected or to meet legal or business requirements.

• If personal information is used to make a decision that directly affects an individual, it will be retained for at least one year to allow access or correction requests.

6. Accuracy of Personal Information

• We make reasonable efforts to ensure that personal information is accurate and complete, particularly when used to make decisions or shared with other organizations.

• Individuals may request corrections to their personal information in writing, providing sufficient detail to identify the information and requested corrections.

• If personal information is corrected, we will send updates to any organization to which it was disclosed in the previous year. If corrections are not made, we will note the request in our records.

7. Security of Personal Information

• We protect personal information from unauthorized access, collection, use, disclosure, copying, modification, or disposal using appropriate physical, organizational, and technological safeguards, including:

• Locked filing cabinets;

• Physically secured offices;

• User IDs, passwords, encryption, firewalls;

• Restricting employee access on a need-to-know basis.

• When destroying personal information, we use secure methods such as shredding documents or deleting electronic records.

• We continually review and update our security policies as technology evolves.

• Data breaches: In the event of a breach posing a risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by law.

• Bot/spam protection: We use Google reCAPTCHA for security purposes. IP addresses and related data are processed by Google and our technical service providers strictly for security purposes and are not used for advertising.

8. Access to Personal Information

• Members and clients have the right to access their personal information, subject to limited exceptions (e.g., solicitor-client privilege, another individual’s personal information, health and safety concerns).

• Requests must be made in writing with sufficient detail to identify the information sought.

• We will respond within 30 business days, or provide written notice if additional time is required.

• A minimal administrative fee may be charged for providing access, and the individual will be informed of the cost before proceeding.

• If access is refused in full or in part, written notice will be provided explaining the reasons and recourse options.

9. Privacy Officer and Complaints

• The Privacy Officer ensures compliance with this policy and applicable privacy legislation.

• Members and clients may direct complaints, questions, or concerns in writing to the Privacy Officer. If unresolved, individuals may contact the Office of the Information and Privacy Commissioner of British Columbia.
  
  Privacy Officer Contact:
  Own Your Day Travel
  Att: Privacy Officer
  10 Earls Court, Thornton, ON L0L 2N0
  Ph: 1-888-688-9438
  

10. Policy Updates

• This policy may be updated from time to time. Material changes will be communicated to members and clients via email or posted on our website.