PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR PERSONAL INFORMATION HANDLING PRACTICES. BY ACCESSING AND/OR USING THE SERVICES, YOU ARE ACCEPTING THE TERMS AND CONDITIONS IN THIS POLICY AND TO ANY CHANGES IN EFFECT AT THE TIME OF USE. IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT CONTINUE TO USE ANY OF THE SERVICES OR PROVIDE ANY PERSONAL INFORMATION TO US. The applicability of this Policy and our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.
This Policy applies to the collection and handling of your Personal Information by Flex if you:
2.1 Definition. “Personal Information” means factual or subjective information about an identifiable individual. Examples of Personal Information include your name, personal e-mail addresses, phone number and age.
2.2 Personal Information.
2.3 Non-Personal Information.
When you visit our Site, we automatically track and collect certain non-personal information, including : (i) IP address, (ii) domain server, (iii) type of computer, (iv) type of web browser; and (v) number of views (collectively “Non-Personal Information“). For further details on what Non-Personal Information is collected or generated, the purposes for the collection and how to disable the cookie function, please consult the section on Non-Personal Information.
3.1 Data Protection Officer. Flex has established the office of the Data Protection Officer to oversee the implementation of our Policy and address complaints about the handling of your Personal Information.
3.2 Employees. The Data Protection Officer has developed and conducted training programs to foster employees’ awareness and understanding of our privacy practices. Safeguards are in place so that the Personal Information is not accessed or disclosed more widely than is necessary to achieve the purpose(s) for which it was gathered. The categories of employees who would have access to your Personal Information would depend upon the purpose for providing the information. For example, if you apply for a position with us, your information would be shared with human resources but not with marketing.
3.3 Third Parties. We may share your Personal Information with third parties, who are bound by law and by contract to protect your Personal Information and are only authorized to use your Personal Information in accordance with our instructions.
4.1 Consent. The type of consent we obtain will depend on the circumstances and on the applicable laws where you live. In some cases, an implied consent may be sufficient. In others, the law may require us to obtain your express consent. Express consent includes a verbal consent, a signature, or an online checkmark.
4.2 No Consent. Sometimes it may not be possible or may be inappropriate to obtain your consent. In those cases, we may collect, use or disclose your Personal Information without your consent. For example: (a) if it is clearly in your interests (such as a medical emergency or a threat to your safety); (b) to comply with applicable laws or regulations (e.g. a warrant or other court order) or with a request by a governmental authority; (c) to collect a debt; (d) to investigate fraud or breach of an agreement or applicable law; (e) to protect the safety of our personnel and third parties on our premises; (f) in the event of a reorganization, restructuring or similar corporate change; or (g) as otherwise legally required or permitted.
5.1 Personal Information. Flex identifies the purposes for which Personal Information is collected at or before the time of collection. The general purposes for collecting your Personal Information will depend upon the circumstances, but can be any or all of the following:
5.2 Examples. Below are some examples of how we use your Personal Information:
5.3 Non-Personal Information. Below is a description of the types of non-personal information collected or generated by us and our service providers and the purposes for such collection or generation.
6.1 Personal Information.
Flex transfers Personal Information only to those third parties who need to have access to it to fulfill the purposes for which the information was collected. Access by such third parties is further restricted by only allowing access to the minimum amount of Personal Information necessary to fulfill the identified purposes. We may share your information:
Except as stated above, or unless otherwise stated in this Policy or at the time of collection, our policy is that we will not sell, rent, share, or authorize any third party to use your Personal Information without your consent.
6.2 Non-Personal Information.
Non-personal information is provided to our business partners and our suppliers for processing to fulfill the purposes set out above or as otherwise consented by you. We may also share information about our user audience in aggregate or de-identified form with analytics and search engine providers that assist us in the improvement and optimisation of our Site.
Flex is headquartered in Montreal, Quebec but has customers around the world. Please be aware that we maintain and process your Personal Information in Canada. Your data, including Personal Information is hosted and stored in Canada at our offices as well as by our supplier, Amazon Web Services. All of your Personal Information will be afforded a level of protection in accordance with applicable laws and contractual obligations wherever it is processed and no matter whether it is held by us or by Amazon Web Services.
You may restrict the amount and type of Personal Information that Flex receives about you simply by choosing not to provide your Personal Information to us. However, some of our Services can only be provided to you if you provide us with a minimum amount of Personal Information. Other parts of our Services may ask whether you wish to opt into our contact lists for surveys and additional services that may be of interest to you. Depending on your country of residence, you may have the right or choice to:
To exercise any of your rights above, please contact us. Note that the rights set out above are not absolute and depend upon where you reside. There are instances where applicable law or regulatory requirements allow or require us to refuse your request to exercise a particular right or choice. In the event that we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Flex uses technical, physical and administrative controls to protect your Personal Information including the following: your Personal Information is encrypted at rest and in transit; offices are locked when not in use; authorized employees, agents and service providers will have access to your Personal Information only to the extent necessary in connection with their role; and data protection agreements are entered into with each of our customers setting out data sharing restrictions. Unfortunately, no control or procedure can be 100% effective, and so we cannot guarantee that your Personal Information will not be accessed, disclosed, altered, or destroyed by breach of any of our safeguards and we make no representations as to the reasonableness, efficacy, or appropriateness of the control or procedure we use to safeguard such data. Mitigating risks requires your cooperation as well – including submitting only the minimum Personal Information necessary for Flex to fulfill the purpose for its collection and implementing the proper safeguards on your end (e.g. strong passwords, installing anti-virus ware, ignoring phishing attempts, etc.) Where Flex believes that there can be a residual risk of significant harm despite the measures we implement, we will inform you of such risks at the time of collection.
Our Services do not intentionally collect any Personal Information from children. Should a child whom we know to be under the legal age of majority provides his or her Personal Information, we will use that information only to respond directly to that child to inform him or her that we must have parental consent before receiving his or her Personal Information.
Your Personal Information will be retained as long as necessary to achieve the purpose for which it was collected. The retention period may vary based on the amount, nature and sensitivity of your Personal Information, the potential risk of harm from unauthorized use or disclosure or applicable legal requirements. Once Personal Information is no longer reasonably necessary or relevant for the identified purposes, or required by law to be retained, your Personal Information will be destroyed, erased or de-identified.
We will obtain your consent prior to sending commercial electronic messages (including emails) (“CEM“) to you, unless applicable laws, such as Canada’s Anti-Spam Legislation (“CASL“) provides for an exemption. Exemptions include where:
12.2 CEM Practices. Below is a description of how Flex generally uses CEMs to communicate with you.
12.3 If you do not wish to receive information and promotional material from us you may update your subscription preferences, by contacting [email protected]
Flex reserves the right to change this Policy at any time. Any such changes will be posted on this page so that you are kept current of our privacy practices and the effective date of the revised Policy will be set out in the revised Policy. Please check back frequently to see any updates or changes to our Policy.
Flex has established the office of the Data Protection Officer to oversee its implementation of the Policy and address any concerns about the handling of your Personal Information. You can contact:
Data Protection Officer
Flex Travel Solutions, Inc.
3 Place Ville Marie, Suite 400,
Montreal (Quebec) H3B 2E3
Email: [email protected]
Last Updated: 10-April-2020
© Flex Travel Solutions Inc. 2020