Pacesetter Travel Privacy Code

This Privacy Code sets out the privacy policy of Pacesetter Travel and applies to its products, services and customers in Canada.

1. We collect only customer information that is needed and we tell customers how we use it.
   We limit the collection, use, retention, and disclosure of personal information about individuals who are customers or potential customers to what we need to know to provide customer services to offer new products and services to understand the current and future needs of our customers and to otherwise analyze and manage our business to assess and manage our risk to detect and protect us against error, fraud and other criminal activity to exchange information with customers who are jointly liable to us to comply with any legal and regulatory requirements or for any other purpose for which a customer consents. In this Code "personal information" means any information that relates to an individual and allows that individual to be identified.
   We tell our customers about the purposes for which we collect, disclose, use and process personal information we collect about them, and if requested by the customer, we will provide further explanation. Similarly, date of birth is required in certain circumstances to comply with "know your customer" requirements, and for security reasons.
2. We give customers choices about how their personal information will be used.
   At the beginning of a customer relationship, and on a regular basis, we give customers the choice of not receiving promotions and marketing offers. However, we will continue to provide information to our customers in keeping with the nature of their relationship with us.
   Subject to legal and contractual restrictions, you can withdraw your consent to our use of your personal information at any time with reasonable notice. For example, you may choose not to receive marketing offers or other promotional materials. If you refuse or withdraw your consent for any purpose that is required by us to fulfill our product or service contract with you, we will not be able to provide you, or continue to provide you, with the product or service.
3. We give customers rights to access and correct their personal information.
   Customers have access to personal information that is reasonably available and retrievable in the ordinary course of business. Upon written specific request, we will disclose to customers personal information about them that is entered in our records, and customers may correct any of such personal information that is inaccurate or incomplete. We will respond to a customer's request, and advise the customer in advance of any charges for copies of his/her file. There will be a minimum cost of $75.
   Some information may not be accessed if it refers to others, is subject to legal privilege, contains confidential information, cannot be retrieved using a customer's name or account number, cannot be disclosed for legal reasons, or as otherwise permitted by law. It should be noted that we do not record in customers' individual files when personal information was disclosed to third parties for routine purposes such as processing travel requests and storage. If we are informed and it is determined that a customer's personal information in our files is inaccurate, we will correct it. If we correct a customer's file, we will, where appropriate, notify persons who received the incorrect information in the preceding six months and, where applicable, to the person who provided the incorrect information. All customers may access their personal information by writing to: Protection of Personal Information at 3284 Yonge Street, Suite 500, Toronto, Ontario M4N 3M7.
4. We use prudent information security safeguards.
   We limit access to customer information to those who specifically need the information to conduct their business responsibilities, to meet our customer servicing commitments, for the purposes set out in this Code or as otherwise disclosed to customers. We employ safeguards designed to protect the confidentiality and security of our customer information.
5. We limit the disclosure of customer information/testimonials.
   We will not disclose customer information, including testimonials, to entities other than the Pacesetter Travel entity that collected the information and their agents and service providers, unless we have previously informed the customer, have been authorized by the customer, or are permitted or required to do so by law or other regulatory authority. In particular, when a court order or subpoena requires us to disclose information, we notify the customer promptly to provide the customer an opportunity to exercise his or her legal rights. The only exceptions to this policy are when we are prohibited by court order or law from notifying the customer, or in cases in which fraud and/or criminal activity is suspected.
6. We hold ourselves responsible for our Privacy Code.
   Each Pacesetter Travel employee is personally responsible for maintaining customer confidence in the company. We provide training and communications programs designed to educate employees about the meaning and requirements of this Code. We conduct a combination of compliance self-assessments, internal audits, and may commission outside-expert reviews of our compliance with the Code and the specific policies and practices that support the Code.
   Employees who violate the Code or other company policies and practices are subject to disciplinary action, up to and including dismissal. Employees are expected to report violations - and may do so confidentially - to their managers, or the Human Resources Department.
7. We extend this Privacy Code to our business relationships.
   We require companies we select as our business partners to agree to keep our customer information confidential and secure, to protect the information against unauthorized access, use, or disclosure by the recipient company, and limit its use to the purposes for which it was disclosed. We also encourage our business partners to respect their customers' information by adopting strong and effective privacy policies and practices. In addition, we participate actively in industry associations to advocate development of comprehensive privacy policies and implementation strategies.
8. Our customers' privacy concerns are important to us.
   Our Compliance Officer is responsible for ensuring that our day-to-day procedures comply with our Privacy Code.

Questions and Concerns:

If a customer has any questions or concerns, the customer can take the following actions:

A. Begin by talking to a Sales Agent at Pacesetter Travel

B. If the issue remains unresolved, write to the Protection of Personal Information at

3284 Yonge Street, Suite 500,
Toronto, Ontario M4N 3M7.