Lion World Travel Limited Privacy Policy

Last Updated: May 2023

US Privacy Policy

View Canada Privacy Policy instead.

1. About This Document

This is the privacy policy of Lion World Travel. (referred to as "we", "us" or "our"). We are incorporated under the laws of Ontario, Canada. Our incorporation address is 33 Kern Road, Toronto, ON M3B 1S9. This document sets out our privacy policy in respect of consumer personal information, which will govern the way in which we process any personal information that you provide us with. It serves as an expression of our commitment to protecting your private personal information.We adopt this policy to comply with the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act of 2020 (“CPRA”).  Any terms defined in the CCPA/CPRA have the same meaning when used in this notice. Please see Section 9 below for the rights which the law provides you with in relation to your personal information.

We will provide a link to this privacy notice when you are using our website, providing any personal information to us, or booking any travel services with us and we will ask you to read and confirm you have read this document where we collect your personal information.

2. Our Commitment

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information that you entrust to us.

3. Who Our Privacy Policy Covers

3.1 Our customers

Our privacy policy sets out how we process personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

3.2 Examples of who this policy covers

We include in this privacy policy personal information we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organizations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organization, employees or individuals who are acting as representatives of that business or other organization, and individuals connected to that business or other organization, such as owners, partners, shareholders, and directors; (4) individuals who visit our website or other online sites operated by us or our contractors or affiliates; (5) individuals who create an online account (if applicable); (6) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes); and (7) individuals or businesses from any other arrangement with us.

3.3 When we are an information processor only

This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

3.4 Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

When we refer to "process" or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

4. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA/CPRA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

5. How We Collect Or Generate Your Personal Information

This section sets out the ways in which we may collect or generate personal information concerning you. We obtain categories of personal information listed above from the following categories of sources:

5.1 Visiting our website

By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

5.2 Data you provide

Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

If you do not provide us with your personal information we will be unable to provide you with information or book travel services for or on your behalf.

5.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites if you have given consent to let Lion World Travel and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

Print materials - on our website - email activities - social posts - images on our trips - provide images to our trade partners to use on their websites, email marketing and other marketing initiatives - make available in our content feeds - We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods - Any other information provided to us by or in relation to you which concerns you as an individual.

5.4 Data obtained from third parties

We may obtain personal information concerning you from third parties, including from: people making enquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organizations; from any business or organization you are associated with; from telephone numbers identified by the telephone system when you telephone us.

Under the CCPA/CPRA, Lion World Travel Limited ensures it will take any reasonable and appropriate steps to ensure that the third-party service provider, or contractor provides the level of privacy protection required by the CCPA/CPRA. The service provider will only use the personal information transferred in a manner consistent with the CCPA/CPRA. If the service provider is unable to meet these requirements, Lion World Travel Limited will be notified by such service provider and take appropriate actions to protect your data in accordance with the CCPA/CPRA.

5.5 Cookies

A cookie is a small text file that is stored on a computer for record-keeping
purposes.Our third-party analytics providers use cookies to record information about your activities on the Site and to “remember” you when you return to the Site.Some cookies remain on your computer until you delete them.Others, like session ID cookies, expire when you close your browser.We do not control the use of cookies by third parties, We typically use the following types of cookies :

• Session cookies: temporary cookies that identify and track users within our website. These are automatically deleted by your browser when you close your browser or end the session; and
• Persistent cookies: cookies which enable our website to ‘remember’ who you are and your preferences within our website. These cookies are stored in your browser (the specific location depends on the browser and version) for a period of time.

  Necessary

  Cookie Name	Provider	Type	Expiry
  CONSENT	youtube.com	HTTP	6098 days
  CookieConsent	lionworldtravel.com	HTTP	1 year
  guid	steelhousemedia.com	HTTP	3 years
  has_js	lionworldtravel.com	HTTP	Session
  rc::a	google.com	HTML	Persistent
  rc::c	google.com	HTML	Session
  tt	steelhousemedia.com	HTTP	3 years

   

  Statistics

  Cookie Name	Provider	Type	Expiry
  _at.hist.#	lionworldtravel.com	HTML	Persistent
  _ga	lionworldtravel.com	HTTP	2 years
  _gat	lionworldtravel.com	HTTP	1 day
  _gid	lionworldtravel.com	HTTP	1 day
  p.gif	typekit.net	Pixel	Session
  vuid	vimeo.com	HTTP	2 Years

   

  Marketing

  Cookie Name	Provider	Type	Expiry
  __atuvc	lionworldtravel.com	HTTP	1 year
  __atuvs	lionworldtravel.com	HTTP	1 day
  _at.cww	lionworldtravel.com	HTML	Persistent
  _fbp	lionworldtravel.com	HTTP	3 months
  _gcl_au	lionworldtravel.com	HTTP	3 months
  ads/ga-audiences	google.com	HPixel	Session
  at-rand	lionworldtravel.com	HTML	Persistent
  fr	facebook.com	HTTP	3 months
  IDE	doubleclick.net	HTTP	1 year
  loc	addthis.com	HTTP	1 year
  pagead/1p-user-list/#	google.com	Pixel	Session
  pagead/landing	doubleclick.net	Pixel	Session
  pagead/landing	google.com	Pixel	Session
  RUL	doubleclick.net	HTTP	1 year
  test_cookie	doubleclick.net	HTTP	1 year
  tr	facebook.com	Pixel	Session
  uvc	addthis.com	HTTP	1 year
  VISITOR_INFO1_LIVE	youtube.com	HTTP	179 days
  xtc	addthis.com	HTTP	1 year
  YSC	youtube.com	HTTP	Session
  yt.innertube::nextId	youtube.com	HTML	Persistent
  yt.innertube::requests	youtube.com	HTML	Persistent
  yt-remote-cast-installed	youtube.com	HTML	Session
  yt-remote-connected-devices	youtube.com	HTML	Persistent
  yt-remote-device-id	youtube.com	HTML	Persistent
  yt-remote-fast-check-period	youtube.com	HTML	Session
  yt-remote-session-app	youtube.com	HTML	Session
  yt-remote-session-name	youtube.com	HTML	Session

   

5.6 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.

6. What Do We Use Your Personal Information For?

We commit to use your personal information only for the purposes listed below and for as long as it is necessary to achieve these purposes.

6.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes customizing your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

6.2 Provide information and respond to enquiries

to provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

6.3 Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorized or made with us which relate to you.

6.4 Payments

To collect and make payments due and administer our accounts.

6.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

6.6 Record keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

6.7 Manage and improve our business

To analyze, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyze the results; to run promotions and competitions;

To undertake product or customer research/ development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes, including by sharing of photographs which you have voluntarily participated in during our Trips. Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;

To carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

6.8 Direct marketing

To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you.  We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 7 for the types of products we may market to you this way.

6.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

6.10 Advertising

For any purpose which we have obtained your consent to.

7. Use of Your Personal Information For Direct Marketing

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

7.1 Direct marketing by us

Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive or by clicking the ‘unsubscribe’ button at the bottom of any of our emails. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

7.2 Direct marketing by third parties

Where you have consented to this, we may disclose your personal information which is contact information (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

8. Information Retetion

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We dispose of the information we collect in accordance with retention policies and procedures. However, if we need to retain your data analytics purposes or trend analysis, we will anonymize and de-identify your personal information. If you would like to know more about our data retention policy, please ask us.

9. Disclosure Of Your Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

A.    Identifiers.

B.    Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

C.    Protected classification characteristics under California or federal law.

D.    Commercial information.

F.     Internet or other similar network activity.

I.     Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have sold personal information for direct marketing purposes, where you have given your prior consent.

We transfer your personal information to third parties in the following circumstances:

9.1 Credit Checks

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

9.2 Bookings and performance of contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

9.3 Suppliers of travel and other services

We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third-party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

9.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

9.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

9.6 Public forums etc.

Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility), then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

9.7 Legal Requirements

We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

9.8 Direct Marketing by third parties

We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

9.9 Customer Representatives

If our customer is a business or organization, and we are holding your personal information in your capacity as an associate of that business or organization (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

9.10 Business acquirers

If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

10. Your Rights And Choices

The CCPA/CPRA provides California residents with specific rights regarding their personal information. This section describes your CCPA/CPRA rights and explains how to exercise those rights.

10.1 Request information about the processing of your personal data and access it 

This enables you to receive information on the processing of your personal data and a copy of personal information we hold about you in a commonly used format. This applies to information we have processed over the last 12 months. 

10.2 Request rectification of your personal information 

This enables you to correct and rectify inaccurate data that may be held about you. You can also request Lion World Travel Limited to complete any incomplete data, or to record a supplementary statement. 

10.3 Request deletion of your personal information 

This enables you to ask us to delete personal data where there is no good reason for us to keep it, unless the law allows us to. This applies to information we have processed over the last 12 months. 

10.4 Request information about the processing of your personal data in relation to our data selling and disclosure practices

This enables you to receive information on the personal data we have collected about you and shared with our service providers. You are also entitled to know which of your personal information has been sold and to whom. If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the " right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. You can manage your communication preferences at any time from your account. You (or your authorized representative) may also exercise the right to opt-out by submitting a request to us by visiting the following page: https://ttc.com/personal-data-request/ , or sending us an email to compliance@ttc.com

10.5  Request information on the disclosure of personal data for direct marketing purposes 

This enables you to receive information on the third parties to whom we have disclosed your information and the categories of disclosed personal data, which has been shared for direct marketing purposes. 

10.6 Request to opt-out of sharing your sharing personal information whether or not money or service is exchanged as a result of you sharing this information. 

Opt-out requests specifically to email direct marketing must be fulfilled within ten business days of receiving the request as, per the CAN-SPAM Act. No further direct marketing emails should be sent after this time.

10.7 Request to opt-out from the sale of personal data to other companies 

This enables you to cease any selling of your personal information. Please note that we are not engaged in selling any of your personal information to other companies. You can opt-out to any sale of your personal data through the following link: Do Not Sell or Share My Personal Information. You can also use the Cookie Preferences Center to opt-out of any sale of your personal data through cookies without detriment or preventing you from accessing Lion World Travel Limited website content.

10.8 Request not to be subject to decisions based solely on automated processing (including profiling)

This enables you to cease being subject to processing based on automated processing. If the decision produces legal effects concerning you or similarly significantly affects you. Lion World Travel Limited shall make all attempts not to conduct automated decision-making. However, if such automated decision making occurs, you will be allowed to opt out in accordance with the CCPA/CPRA.

10.9 Not to be discriminated as our consumer when you exercise any of the aforementioned rights. 

This means that, in an event of any of your request to us, we will not engage in or suggest any discrimination against you, in particular, we will not deny our services to you, we will not charge you differently, and we will not provide different level or quality of services to you, unless such difference is reasonably related to the value provided to you or you have agreed to enter into a financial incentives programme with us. 

10.10 Consumers’ Right to Limit Use and Disclosure of Sensitive Personal Information

This enables you to direct Lion World Travel Limited to limit its use of any Sensitive Personal Information that you may have provided. We will not discriminate against you for exercising your rights. We will not deny you services, charge different prices or rates, or provide a different level of service or some services require the usage of personal information to function, so compliance with your request may impact those experiences.

10.11 Exercising Your Rights

To exercise any of the privacy rights described above, please submit a verifiable request to us by either:

• E-mail to info@lionworldtravel.com
• Phone to 1-800-387-2706
• Mail to 33 Kern Road, Toronto, ON M3B 1S9

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

10.12 Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

10.13 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. Unless permitted by the CCPA/CPRA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

11. How Third Parties Will Handle Your Personal Information

Where we provide your personal information to a third party one of the following two circumstances will apply:

11.1 Processing on our behalf

In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

11.2 Processing on their own account

In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

12. Location of Your Personal Information

12.1 Transfer of personal information overseas

We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and information technology and business service providers.

In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

12.2 Counties to which your personal information is transferred

The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.

13. Keeping Your Data Secure

13.1 Our security measures

13.1.1 Our general commitment

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organizational measures against unauthorized or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

13.1.2 Transmissions between your web browser and our servers

We use Secured Socket Layer ("SSL") software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from "http" to "https".

13.1.3 Storage of your personal information

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

13.2 Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

14. How Long Do We Keep Your Personal Information For?

We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

15. "Do Not Track"

We are required to let you know how we respond to web browser Do Not Track (DNT) signals.

We do not respond to such signals at this time.

16. Changes to This Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time without notice to you, including by publishing a new version on our website. When we make changes to this privacy policy, we will notify you by email or through a notice on our website homepage to make sure that you are aware of any changes. You can check the top of the document to see the latest version in force. Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.

17. Contacting Us

If you have any questions about our privacy policy or about how we process your personal information, including any requests, queries of complaints, please contact us either by:

• E-mail to info@lionworldtravel.com
• Phone to 1-800-387-2706
• Mail to 33 Kern Road, Toronto, ON M3B 1S9

18. Copyright Notice

This document, and all content of our websites is Copyright© 2024 Lion World Travel. ALL RIGHTS RESERVED.

19. Enforcement

Our privacy policy is subject to the law of the state of California, County of Orange and disputes can be determined by the courts of state of California, County of Orange. The CCPA/CPRA is enforced by the California Privacy Protection Agency for enforcement and guidance. As the data subject you have a private right of action for breach of information.

Canada Privacy Policy

Last Updated: May 2023

Contents

1. ABOUT THIS POLICY
2. OUR COMMITMENT
3. OUR LEGAL BASES FOR PROCESSING
4. CHANGE OF PURPOSE
WE WILL ONLY USE YOUR PERSONAL INFORMATION FOR THE PURPOSE FOR WHICH WE OBTAINED IT. IF WE REASONABLY NEED TO RE-PURPOSE YOUR PERSONAL DATA, WE WILL ENSURE IT IS FOR A REASON THAT IS COMPATIBLE WITH THE ORIGINAL PURPOSE. IF YOU REQUIRE AN EXPLANATION AS TO HOW THE PROCESSING FOR THE NEW PURPOSE IS COMPATIBLE WITH THE ORIGINAL PURPOSE, PLEASE CONTACT US. WE MAY PROCESS YOUR PERSONAL DATA FOR UNRELATED PURPOSES, BASED ON OUR LEGITIMATE INTEREST.
5. WHO OUR PRIVACY POLICY COVERS
6. WHAT TYPES OF PERSONAL DATA WE MAY PROCESS
7. HOW WE COLLECT OR GENERATE YOUR PERSONAL DATA
8. WHAT DO WE USE YOUR PERSONAL DATA FOR?
9. PERIOD FOR RETAINING YOUR DATA
10. USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING
11. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
12. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA
13. LOCATION OF YOUR PERSONAL DATA
14. KEEPING YOUR DATA SECURE
15. YOUR RIGHTS
16. CONTACTING US
17. ABOUT US
18. COPYRIGHT NOTICE

1. About this policy

This is the Privacy Policy of The Travel Corporation are incorporated under the laws of Guernsey, Channel Islands. Our incorporation number is 50768 and our incorporation address or registered office is Travel House, Rue du Manoir, St Peter Port, Guernsey, GY1 2JH, Channel Islands. This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your information. This privacy notice supplements other notices and is not intended to override them. We collect, use, and disclose your personal information in accordance with applicable Canadian privacy requirements, including the Personal Information Protection and Electronic Documents Act (PIPEDA).

2. Our commitment

We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.

3. Our legal bases for processing

We will process your personal information in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal information unless at least one of the following requirements are met:

• You have given consent to the processing of your personal information for one or more specific purposes;
• The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
• Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
• Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);Processing is necessary for the reasonable purposes of the business activity pursued by us or by a third party (for instance, protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders). Please find below an indicative, non-exhaustive list of processing activities.

PROCESSING ACTIVITY REASONABLE PURPOSE

4. Change of Purpose

We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal information, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal information for other reasonable purposes.

• There are some circumstances in which personal information may be processed for purposes that go beyond the original purpose for which the personal information was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
• For circumstances where we may have other secondary purposes, for processing already existing information which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
• We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal data by law, as you will not be directly or indirectly identified. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
• However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal information which will be processed as required under applicable Canadian law.

5. Who our privacy policy covers

5.1 Our customers

Our privacy policy sets out how we process personal information relating to individuals who are:

• booking or enquiring about booking travel services with or through us; or
• the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you); or
• customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal information as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

5.2 Examples of who this policy covers

We include in this privacy policy personal information we process relating to:
(1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers and employees of businesses and organisations booking with or through us);
(2) individuals in respect of whom any enquiry or booking is made with us by an agent;
(3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;
(4) individuals whose personal information is obtained from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes). 

5.3 When we are information processor only

Please however note that this privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal information on their instructions.

5.4 Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, and any such individual whose personal information we process from time to time.
When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.
When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both:
(1) all such products and services which we supply or operate ourselves (including where we sub-contract); and
(2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

6. What types of personal information we may process

This section summarises the types of personal information about you that we process:

6.1 Information concerning you as an individual

We may collect the following:
- name,
- age,
- gender,
- address,
- telephone,
- mobile,
- fax,
- e-mail,
- Social networking contact details, your social posts about any of our trips and travel experiences.
- photographs,
- proofs of identity and address, copies of passports, driving licences, and utility bills,
- card and other payment details, and financial information,
- health information relevant to your planned travel and travel insurances held,
- results of searches carried out against you (such as to verify your identity, address, and credit status),
- your preferences,
- Frequent flyer or travel partner programme affiliation and member number.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

6.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you:
- business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.),
- your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and
-  your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

6.3 Enquiry and Booking information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:
- records of enquiries and searches for holiday and travel products made by or on your behalf,
- details of your personal interests,
- needs and other information relevant to your enquiry;
- details of results, quotes, proposals, estimates and other information given in response to enquiries;
- details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about;
- details of the passengers / holidaymakers travelling;
- details of the provider of the travel services (e.g. tour operator);
- dates and times of travel;
- price;
- payment details (including card details);
- passport information and visa information;
- foreign exchange requirements and arrangements; and
- Sensitive information such as health, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us.

6.4 Survey Information

Information collected or generated out of any surveys we conduct.

6.5 Competition Information

Information collected or generated out of any competitions or promotions we run.

6.6 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

6.7 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.

6.8 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website.
This information may include: 
- your IP address (a unique identifier allocated to your computer for your connection to the internet);
- your computer device details (PC, tablet, smartphone, watch etc.);
- the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using;
- your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc);
- your time-zone;
- your browser plug-ins;
- any web-page you came from, identified as the referrer web page address by your web browser;
- cookies (as per our cookie policy); 
- identifiers assigned to you by third-party advertising providers and web beacons you interact with;
- page response times;
- download error;
- pages and parts of pages you visit;
- usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.;
- services and products you viewed;
- length of visit to website and pages;
- page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).
This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally.
This information may also include:
- information inputted into forms and fields;
- registrations for any accounts,
- forum,
- feedback mechanism,
- social functionality,
- newsletters or other features of our site;
- usernames and passwords,
- log-in / out history, and settings;
- actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review, or other social functionality on our website.
Such information will be treated as personal information and processed according to this privacy policy.

7. How we collect or generate your personal information

This section sets out the ways in which we may collect or generate personal information concerning you.

7.1 Visiting our website

By visiting and using our website you or your computer may provide personal information. This includes:  information which is automatically provided by your browser to our servers; information recorded on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. This is more detailed in our cookie policy.

7.2 Information you provide

Your personal information will include data you provide (or later amend), whether:
- from correspondence with you;
- verbally to us over the phone or in person;
- by filing in any field or form on a website;
- by filling in any printed form we provide you with;
- by e-mail;
- from documents you provide us with; and
- from updates to any information you provide to us from time to time. 
This includes when you:
- register or subscribe for any service, account, members, or loyalty program,
- make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise;
- send us your comments or suggestions;
- subscribe to any newsletter or other publication;
- and request sales and advertising information, including brochures.

7.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let [Brand Name] and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:
- Print materials
- on our website
- email activities
- social posts
- images on our trips
- provide images to our trade partners to use on their websites, email marketing and other marketing initiatives
- make available in our content feeds
- We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods
- Any other information provided to us by or in relation to you which concerns you as an individual.

7.4 Information obtained from third parties

We may obtain personal information concerning you from third parties, including from:
- providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries;
- credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations;
- Any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

7.5 Information generated by us

We and any suppliers or sub-contractors working for us may generate personal information relating to you, including:
- in connection with responding to and dealing with any enquiry, booking or complaint; or
- in performing any booking or other contract with you; or
- through the analysis of your personal information; or
- information gained from your use of our website according to our cookie policy.
We may record telephone calls with you for training and quality purposes.

7.6 Cookies

COOKIES. A cookie is a small text file that is stored on a computer for record-keeping
purposes.  Our third-party analytics providers use cookies to record information about your activities on the Site and to “remember” you when you return to the Site.  Some cookies remain on your computer until you delete them.  Others, like session ID cookies, expire when you close your browser.  We do not control the use of cookies by third parties. We typically use the following types of cookies: 

• Session cookies: temporary cookies that identify and track users within our website. These are automatically deleted by your browser when you close your browser or end the session; and
• Persistent cookies: cookies which enable our website to ‘remember’ who you are and your preferences within our website. These cookies are stored in your browser (the specific location depends on the browser and version) for a period of time.

  Necessary

  Cookie Name	Provider	Type	Expiry
  CONSENT	youtube.com	HTTP	6098 days
  CookieConsent	lionworldtravel.com	HTTP	1 year
  guid	steelhousemedia.com	HTTP	3 years
  has_js	lionworldtravel.com	HTTP	Session
  rc::a	google.com	HTML	Persistent
  rc::c	google.com	HTML	Session
  tt	steelhousemedia.com	HTTP	3 years

   

  Statistics

  Cookie Name	Provider	Type	Expiry
  _at.hist.#	lionworldtravel.com	HTML	Persistent
  _ga	lionworldtravel.com	HTTP	2 years
  _gat	lionworldtravel.com	HTTP	1 day
  _gid	lionworldtravel.com	HTTP	1 day
  p.gif	typekit.net	Pixel	Session
  vuid	vimeo.com	HTTP	2 Years

   

  Marketing

  Cookie Name	Provider	Type	Expiry
  __atuvc	lionworldtravel.com	HTTP	1 year
  __atuvs	lionworldtravel.com	HTTP	1 day
  _at.cww	lionworldtravel.com	HTML	Persistent
  _fbp	lionworldtravel.com	HTTP	3 months
  _gcl_au	lionworldtravel.com	HTTP	3 months
  ads/ga-audiences	google.com	HPixel	Session
  at-rand	lionworldtravel.com	HTML	Persistent
  fr	facebook.com	HTTP	3 months
  IDE	doubleclick.net	HTTP	1 year
  loc	addthis.com	HTTP	1 year
  pagead/1p-user-list/#	google.com	Pixel	Session
  pagead/landing	doubleclick.net	Pixel	Session
  pagead/landing	google.com	Pixel	Session
  RUL	doubleclick.net	HTTP	1 year
  test_cookie	doubleclick.net	HTTP	1 year
  tr	facebook.com	Pixel	Session
  uvc	addthis.com	HTTP	1 year
  VISITOR_INFO1_LIVE	youtube.com	HTTP	179 days
  xtc	addthis.com	HTTP	1 year
  YSC	youtube.com	HTTP	Session
  yt.innertube::nextId	youtube.com	HTML	Persistent
  yt.innertube::requests	youtube.com	HTML	Persistent
  yt-remote-cast-installed	youtube.com	HTML	Session
  yt-remote-connected-devices	youtube.com	HTML	Persistent
  yt-remote-device-id	youtube.com	HTML	Persistent
  yt-remote-fast-check-period	youtube.com	HTML	Session
  yt-remote-session-app	youtube.com	HTML	Session
  yt-remote-session-name	youtube.com	HTML	Session

   

   

8. What do we use your personal information for?

This section sets out the uses which we make of your personal information and the legal basis on which we rely to do this.

8.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities, and functions of our websites.  This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

8.2 Provide information and respond to enquiries

To provide information to you about our website, systems, and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your information because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.3 Bookings and other contracts

To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your information because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.4 Payments

To collect and make payments due and administer our accounts.  This is necessary for the preparation of any contract between us.

8.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your information because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.6 Record Keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.  This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.

8.7 Manage and improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;
- to carry out surveys and analyse the results;
- to run promotions and competitions;
- undertake product or customer research/development;
- to assist us in and help us to improve our sales;
- to carry out other business development and improvement activities;
- to provide training to our staff, sub-contractors and suppliers;
- editorial, advertising, and marketing processes, including sharing of photographs which you have voluntarily participated in during our Trips.  Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;
For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.  This is done on the basis of our legitimate interests in ensuring our business runs efficiently.

8.8 Direct marketing

To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you.  We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 10.1 for the types of products we may market to you this way.

8.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

8.10 Anything you have specifically consented to

For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that information and you have had to take an affirmative step to give consent on an informed basis. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.

8.11 Consequences of Not Providing your Information

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your information to authorities when you travel is a legal obligation for us.

9. Information Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We dispose of the information we collect in accordance with retention policies and procedures. However, if we need to retain your data analytics purposes or trend analysis, we will anonymize and de-identify your personal information. If you would like to know more about our data retention policy, please ask us.

10. Use of your personal information for direct marketing

We do not use or disclose your personal information for direct marketing purposes unless:

- we have obtained your consent to do so, such as through an opt-in box on any form or website of ours; and/or
- you have made a booking with us, and it is reasonable to inform you of similar products or services.

If you do not want to receive direct marketing activities anymore, you can manage your communications preferences by clicking “unsubscribe” at the end of every of our electronic communications.

In addition to data protection law if we use your personal information for direct marketing purposes, we may also be subject to additional rules that regulate direct marketing. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.

10.1 Direct marketing by us

We will use your personal information to send you marketing information (including adverts and details of promotions) about travel services:
(1) offered by us;
(2) which can be booked with third parties through us;
(3) which can be booked with other companies within our group (i.e. the Travel Corporation Group); and
(4) offered by third parties selected by us. However, we will not pass any of your details to third parties without your prior and specific consent.

Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email or SMS). 

10.2 Direct Marketing by Third Parties

From time to time, we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number, fax number and preferences) to:
(1) other companies within our The Travel Corporation, which are bound by the same requirements set in this privacy policy; and
(2)  other companies which offer services that may enhance your travel experience or be able to help you to finalise your travel arrangements (“third parties”). Such third parties may then contact you directly with marketing information about services and products offered by them. Such third parties are not part of The Travel Corporation and are not bound by this privacy policy. However, we ensure that our partners will only contact you in the manner you agreed to (e.g. email, text) when providing your consent. 

10.3 Withdrawing from Direct Marketing

You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”
When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.
You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

11. Disclosure of your personal information to third parties

We transfer your personal information to third parties in the following circumstances:

11.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

11.2 Bookings and performance of contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;
- to apply for visas on your behalf,
- to collect payments to be made by you,
- to investigate and respond to complaints, and
- to enforce any booking or other contract with you.
Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal information that you will expect from us.

11.3 Suppliers of travel and other services

We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you.
We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator.  Details of any third-party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

11.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer.  Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

11.5 Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then we may provide your personal information to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal information with the same level of care and duty as us.

11.6 Public forums etc.

Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility), then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.

11.7 Legal requirements

We may supply personal information to a government authority or regulator where required to:
- comply with a legal requirement,
- for the administration of justice or when required by a public enforcement body, or
- for the purposes of customs, visas and immigration.
We may disclose your personal information where otherwise required by or permitted by law.  

11.8 Direct Marketing by third parties

We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent.  Please refer to the direct marketing section above for more information.

11.9 Business Customers who are businesses (not individuals)

If you are a business or organisation (“Business Customer”), and we are holding personal information of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal information.  
If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

11.10 Business acquirers

If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal information.

11.11 Cross border transfers

We may transfer your to third parties outside of Canada. In the case of your data being transferred to such third parties, we will ensure that processing requirements set by PIPEDA are met. While your information is in third party jurisdictions, it may be accessed by courts, law enforcements and national security authorities. We ensure that the correct safeguards to keep your data secure are implemented, as set out in Section 14 ‘How we keep your data secure’.

12. How third parties will handle your personal information

Where we provide your personal information to a third party one of the following two circumstances will apply:

12.1 Collecting, using and disclosing on our behalf

In some cases, your personal information may be held and otherwise processed by others on our behalf.  We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal information, and your personal information will only be held and processed by them in accordance with our instructions and this privacy policy.  The sharing of your information is necessary for the performance of any contract with you and for the efficient provision of our services.

12.2 Collecting, using and disclosing on their own account

In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account.  In such case, they will have their own responsibility for your personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party and they will provide their privacy policy to you.

13. Location of your personal information

We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world. Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use and disclose that information anywhere in the world. Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from those in Canada or the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the information processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

14. Keeping your information secure

14.1 Our security measures

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this. We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide. The measures we implement to protect your personal information include:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
- using secured servers to store your information;
- verifying the identity of any individual who requests access to information prior to granting them access to the information;
- using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions.
Unfortunately, transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal information and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal information to. We never contact you to ask you for your payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made.  Please let us know if you someone purports to contact you in our name.

15. Your Rights

You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this, or your identity is not established by you. This is to ensure that your information is protected and kept secure.  More information about your rights and our obligations can be found on the website of the Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca/en/
To exercise any of your rights below, please use a dedicated online form https://ttc.com/privacy-policy/personal-data-request-world/, or send your request via email to compliance@ttc.com.

15.1 Right to know 

You have a right to know about Lion World Travel Limited’s policies and procedures with respect to the management of your personal information. 

15.2 Access to your personal information

You may request us to tell you whether we are collecting, using, and disclosing personal information about you, to tell you what personal information we are collecting, using and disclosing and for what purposes, and to provide you with a copy of your personal information that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case. If we refuse to provide you with access to information, we hold about you, we will provide reasons for such refusal.

15.3 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

15.4 Use for direct marketing and electronic communications

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

15.5 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

16. Enforcement

Lion World Travel Limited process your personal data in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). The Office of the Privacy Commissioner of Canada (OPC) oversees compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), which sets out the privacy obligations many private sector organizations must adhere to when they handle personal information in the course of their commercial activities. For federally regulated organizations, PIPEDA also applies to the personal information of employees as well as applicants for employment.

17. Contacting us

If you have any questions about our privacy policy or about how we process your personal information, including any requests or complaints, please contact us either by e-mail to [compliance@ttc.com], telephone on 416-322-8468, or by post to Privacy Officer, 33 Kern Road, Toronto, ON M3B 1S9.

18. About us

This is the privacy policy of Lion World Travel (referred to as "we", "us" or "our").  We are incorporated under the laws of Ontario, Canada. Our incorporation number is 449471 and our incorporation address or registered office is 33 Kern Road, Toronto, Ontario, Canada M3B 1S9. We are a member of TICO (Wholesale Registration #: 1004818, Retail Registration #: 1031815) and USTOA.

19. Copyright notice

This document, and all content of our websites is Copyright © 2024 Lion World Travel.  ALL RIGHTS RESERVED.

End of Document