Privacy Statement

Generally, we collect your Personal Information directly from you, whether over the telephone, in writing, or electronically, including through any of our Websites, online products or services that link to this Privacy Policy. We may also collect it from a third-party service provider (including, without limitation, your financial institution, or, where you use our mobile application, your mobile device manufacturer or mobile service provider), or someone acting on your behalf (like a travel agent, family member or employer who books a ticket or other services for you). Unless and until we are advised otherwise, we will consider a third party booking on your behalf to have your authority to provide us with your Personal Information in the same manner as if you were providing that information yourself. In the case of Personal Information of minors or those incapable of providing consent on their own behalf, those consenting on their behalf must be parents, legal guardians or legal representatives, as appropriate. Parents, legal guardians or legal representatives shall exercise privacy and data protection rights on behalf of such individuals.

For the purpose of this Privacy Policy, “Personal Information” means any information that can reasonably be used to identify a person, directly or indirectly. but does not include anonymous information or information that relates to a group of people rather than individuals where the information does not otherwise contain identifying information.

We may collect your Personal Information during your dealings with us or while you visit our Website, or where necessary to provide you with the products and services we offer, for example when you request a quote, make a reservation, contact us by e-mail or phone, or subscribe to our updates or newsletters. The types of information we may collect and process include, but is not limited to:

• your name and surname, gender, personal and work contact details (such as address, telephone number, e-mail address) business title, date and place of birth, age, marital status, image, nationality, and passport, permanent residence card and visa information, which you (or someone acting on your behalf) provide when you purchase our products or services from us or create an account on our Website;

• information regarding your transactions with SellOffVacations, its affiliates, or third parties such as air carriers, hotels, transportation and other service providers. We may collect this information directly from you or through these affiliates or third parties;

• guest stay information, including the hotels where you have stayed, dates of arrival and departure, goods and services utilized, special requests made, observations about your service preferences (including room and vacation preferences) and information concerning any incident. We may collect this information directly from you or through our affiliates or third parties;

• your credit card or debit card details or other means of payment information accepted by SellOffVacations which you (or someone acting on your behalf) provide when you purchase our products or services;

• any information necessary to fulfil special requests, including health conditions that require specific accommodation or services, dietary requests and/or special equipment you need to bring with you to accommodate a medical condition. We may collect this information directly from you or through our affiliates or third parties service providers;

• information, feedback or content you provide regarding your marketing preferences, in surveys, contests, or promotional offers, or to our Websites and those of third parties that have a commercial relationship with SellOffVacations. We may collect this information directly from you or through these third parties;

• social media profile and information (e.g. friend lists, people you follow, email address, birthday, your history, likes and pages you follow, content viewed) whether or not you use social networking plug-ins on our social media sites. We may collect this information directly from you or through our affiliates or third parties service providers;

• how you interact with the applications and technologies that we employ on our Website and cookies and other technologies enabled on your computer or device. (as described further below, including your computer or your mobile device’s information (e.g. your unique device identifier, unique device token to facilitate push notifications through mobile apps, identifiers associated with equipment or systems, mobile manufacturer or carrier, mobile or data network systems, location or GPS/geo-location when you activate location functions, mobile number, passwords and payment information, stored photos and videos if you choose to share them with us);

• other information collected while you access our Website (we describe this in more detail in Section 10 “Links to Third Party Sites” below).

This Privacy Policy also applies to the Personal Information about you that we receive from a third party, in accordance with applicable laws, unless specifically covered by such third party’s privacy policy. In such case, any inquiries about the privacy practices of third parties should be directed to them. Any such third party is responsible for obtaining your consent for the collection, use and disclosure of your Personal Information by SellOffVacations as described in this Privacy Policy, and advising you of this Privacy Policy, including any amendments hereto.

SellOffVacations collects Personal Information about you only when you voluntarily provide it. You may always choose what Personal Information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).

The way we use your Personal Information may differ depending upon how you interact with us, and what services or products you request, and we provide. The sections below provide details on specific ways that we may use your Personal Information.

We may use your Personal Information to:

• book your vacation package, travel arrangements, flights, special requests, hotel accommodation, cruise, car rentals, and other goods and services requested by you, including those services requested to third parties with a commercial relationship with SellOffVacations;

• manage your account on our Website, mobile applications or other digital platforms;

• respond to requests for information and services, including services from a third party (such as transportation providers and providers of excursions);

• fulfil contractual obligations to you or anyone involved in the process of making your travel arrangements (i.e. travel agents, group travel organizers or your employer) and vendors (i.e. credit card companies, airline operators, transportation or excursion providers);

• provide you with timely and reliable quotes through third parties;

• process claims we receive in connection with our services;

• provide customer support and respond to and communicate with you about quotes and your requests, questions and comments;

• administer general record keeping;

• meet legal and regulatory requirements, and where required by Canadian or foreign government authorities in accordance with applicable law;

• verify your identity and prevent fraud;

• advise you about new products and services that may be of interest to you, subject to your consent;

• communicate about, and administer your participation in, special events, programs, surveys, contests and other offers or promotions, subject to your consent;

• develop and maintain our relationship with you and communicate with you;

• bill you for our products and services and collect outstanding debts; and

• perform data analyses and conduct other research (such as market and consumer research and trend analysis) to develop, manage, protect and improve our products and services, Website, and business (including analyzing the effectiveness of our marketing, sales and advertising);

• as otherwise or permitted under applicable data protection laws.

Except with your consent, we will not transfer or assign in any form your Personal Information to or with third parties. From time to time, we may disclose your Personal Information as set out below. We would always make that disclosure as permitted by law and in accordance with applicable data protection laws. When you agree to this Privacy Policy, you are, to the extent permitted by law, granting your consent to the transfer of your Personal Information to third parties for the purposes set out in this Privacy Policy and to the extent stated in this section and as described in Section 4 “How We Use Your Personal Information” above. Circumstances where we might make such disclosure (in addition to those described in Section 4 “How We Use Your Personal Information” above) include:

5.1. Our affiliates and subsidiaries

SellOffVacations may disclose and you authorize SellOffVacations to disclose your Personal Information with its affiliates and subsidiaries, for the business purposes described in this Privacy Policy.

5.2. Our agents, service providers and suppliers

SellOffVacations may share Personal Information with third parties engaged in providing services to you, or to carry out one or more of the purposes described above, including third party suppliers who offer their products or services through our Websites (such as air carriers, hotels, ground transportation and excursion providers, car rental companies, cruise operators and destination management companies) and third parties or SellOffVacations’ affiliates who provide us with information technology, data processing, data storage and other services which assist us with delivering products and services to you. These service providers are prohibited from using your Personal Information for any purpose other than to provide this assistance and are required to protect Personal Information collected by them or disclosed to them by SellOffVacations and to comply with the general privacy principles described in this Privacy Policy. These third parties may not process or otherwise use your Personal Information, except in accordance with SellOffVacations’ Privacy Policy and as permitted by applicable laws.

5.3. Legal requirements

SellOffVacations reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so or in the context of discovery procedures or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property. We also reserve the right to retain Personal Information collected and to process such Personal Information to comply with accounting and tax rules and regulations and any specific record retention laws.

5.4. Business transfers

SellOffVacations also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or completed corporate reorganization and to a related party or third party in the event of a proposed or completed purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, license, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance, financing, the taking of security on, or securitization of all or any portion of SellOffVacations or of any of the business or assets or shares of SellOffVacations or a division thereof in order for you to continue to receive the same products and services from such related party or third party to the extent permitted by applicable laws.

5.5. Other

We may also disclose aggregated and anonymized information, which no longer allows an individual to be directly or indirectly identified, for study or research purposes, for the production of statistics, and such other purposes as permitted by applicable law.

If you have subscribed to receive SellOffVacations’ email marketing communications, updates or newsletters, we may also use (but will not share) your Personal Information to send you relevant information based on your subscription preferences, including by means of direct marketing. With your prior consent, we may share your Personal Information to our affiliates so that they can send you promotional materials directly.

You may unsubscribe at any time by clicking the unsubscribe link embedded at the SellOffVacations email communications. Note, however, that clients of SellOffVacations, regardless of their opt-in preferences, will continue to receive periodic emails that relate to their business relationship with us. You can also choose not to allow us to use your Personal Information for marketing purposes by contacting us as outlined below in Section 14 (see “Contacting Us”).

When you visit our Website, we or one of our third party service providers may place a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve information. The cookie cannot be read by any website other than the one that placed the cookie. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this Website may not function properly.

Upon your activation, these third party service providers may use cookies on our behalf to collect and store Internet log information, such as what time the visits occurred, whether the visitor has been to this site before, and what site referred the visitor to the web page. Geographic data may also determined by the IP Address of the visitor’s computer. If you activate such function, this information collected by the cookie may be transmitted to our third party service providers and may then be used to evaluate visitors’ behaviour and to generate statistical reports for the website activity on SellOffVacations’ Website and may be used for marketing purposes.

You can choose to disable cookies in your browser at any time by following the procedure described in the Tools or Preferences menu in your browser. If you choose to modify your browser in this manner, some pages of the Website may not function properly. Further information about cookies and other similar technology and how they work is available at https://allaboutcookies.org/.

SellOffVacations makes commercially reasonable efforts to ensure that your Personal Information is protected against loss, theft and unauthorized access, communication, copying, use, or modification. This protection applies in relation to information stored in both electronic and hard copy form. Access to your Personal Information is restricted to selected employees or representatives on a “need to know” basis. SellOffVacations employs generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect Personal Information against loss and unauthorized access.

In addition, SellOffVacations has implemented a comprehensive set of policies and practices to protect your Personal Information. These measures take into account the volume, sensitivity, intended use, and format of the information, and generally include the following:

• A comprehensive privacy framework that defines the roles and responsibilities of our employees throughout the data lifecycle, from collection to secure disposal, and includes a process for handling privacy complaints in a timely and effective manner. We also conduct regular privacy and data security training to keep our employees up-to-date with the latest practices and to promote a culture of privacy awareness within our organization.

• Internal policies and technical measures to limit access to your personal information within our organization to employees who need access to that information to perform their job functions. For example, depending on the nature and context of our interaction with you, certain types of information may be accessed by our customer support team to respond to complaints and inquiries.

• A dedicated Privacy Officer responsible for monitoring our compliance with applicable privacy laws and regulations and responding to privacy inquiries and complaints.

This Website may offer links to other third party websites. You should be aware that operators of linked websites may also collect your Personal Information (including information generated through the use of cookies) when you link to their websites. SellOffVacations is not responsible for how such third parties collect, use or disclose your Personal Information, so it is important to familiarize yourself with their privacy policies before providing them with your Personal Information.

Personal information collected by SellOffVacations is retained for as long as it is reasonably required for the purposes for which it was collected, or as permitted or required by law, following which it is securely destroyed or made anonymous.

We operate and provide products and services to guests located in many different countries around the world. The global nature of our business means that your Personal Information may be transferred across national boundaries, including, potentially, to countries that do not require companies to look after your Personal Information in the way you have come to expect in your own country (or province of residence). Your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of such foreign jurisdiction. Where we transfer your Personal Information across national boundaries, we will protect your Personal Information by ensuring that those transfers are made in compliance with all relevant data protection laws.

The safety and security of your Personal Information also depends on you. While many of our services are publicly accessible, your account information, where applicable, and some of our services are accessible only through the use of an individual user ID and password. To protect the confidentiality of your Personal Information, you must keep any password associated with your use of our services confidential and not disclose it to any other person. Please advise us immediately if you believe that the confidentiality of any such password has been compromised or that it has been misused. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

We are obliged to keep your Personal Information accurate and up to date. You can help us maintain the accuracy of your Personal Information by notifying us of any changes to this information. You may contact SellOffVacations’ Privacy Officer as set out below to request access to (subject to exceptions), correct, update or delete your Personal Information, as well as to withdraw your consent to our use and/or disclosure of your personal information at any time subject to limited exceptions under applicable laws, or contractual requirements, and reasonable notice.

A request to access, correct, update or delete your Personal Information must be made in writing providing details of the Personal Information being sought. Depending on your jurisdiction, a minimal fee may be charged and, if so, we will inform you about the total cost.

In certain circumstances, we may need to restrict your rights to safeguard the rights of others, the public interest (for example, the prevention or detection of crime) and our interests (for example, the maintenance of legal privilege).

If you have an account on our Website, you can view, manage and modify your Personal Information and preferences on your own, and you can opt in or out of features like electronic communications about our promotional offers and special offers from our partners.

SellOffVacations reserves the right update or modify this Privacy Policy at any time without notice to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with Personal Information, as required or permitted by applicable law, including by posting an updated version on this Website, at which time we will update the effective date of this Privacy Policy to alert you of a change. Each time you use products or services that link or otherwise refer to this Privacy Policy, the version of this Privacy Policy then posted will apply to that use, so you should check this Privacy Policy each time you use such products or services. This Privacy Policy posted at any time or from time to time via this Website shall be deemed to be the Privacy Policy then in effect.

This Privacy Policy is effective as of September 1, 2023.

If you have any questions about SellOffVacations’ Privacy Policy or if you have any concerns or queries regarding the processing of your Personal Information or the administration of this Privacy Policy, you may contact our Privacy Officer via mail at 27 Fasken Drive, Toronto, Ontario, Canada, M9W 1K6

We may require you to confirm your identity (such as by providing government-issued identification) before processing any request in relation with your Personal Information.