Last Revision: April 30, 2016.
This Policy applies to all Vicinnity mobile applications, websites, emails, text messages and social media accounts (the “Platform“) and the booking and other services (“Services“) available through our Platform. By using our Platform or Services you agree to these terms and consent to the collection, retention and use of personal information about you on the terms set out below.
We reserve the right to change the provisions of this Policy at any time by making updates on our website indicating the last revision date. The onus is on you to review this Policy from time-to-time to make sure you its terms and agree with you how any personal information you provide to or is collected by Vicinnity will be used.
What Is Personal Information?
As used in this Policy, the term “personal information” means information that specifically identifies an individual (such as a name, user name or e-mail address), or information about that individual that is directly linked to information that specifically identifies an individual. Personal information does not include “aggregate” information, which is data we collect about the use of the Service or about a group or category of services or users, from which individual identities or other personal information has been removed. This Policy in no way restricts or limits our collection and use of aggregate information.
What Information Do We Collect?
We collect information from you in various ways when you use the Service. For example, when you use the Service, we collect information: (i) that is provided to us (such as your name, email address, telephone number, postal address, date of birth, credit card number, expiration date, authentication code, or similar information); (ii) to which you provide us access; (iii) about you that is publicly available; and (iv) received by us about you from third-party sources (such as credit agencies). You can choose not to provide certain personal information but, if you choose to do so, you might not be able to take advantage of the Service.
When you use the Service, some information is also automatically collected, such as your Internet Protocol (IP) address, your operating system, the browser type, the address of a referring website, and your activity on the Service. We may also automatically collect certain logistical information in server logs, including information about how you use various features of the Service and information about the number, frequency and length of each session.
We may also automatically collect certain information through the use of “cookies.” Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us to improve the Service and your experience. If we link cookies to any personal information, we will treat this information as personal information. If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this could affect certain features or services made available via the Service.
We may also employ the use of anonymous identifiers, which are random strings of characters that are used for the same purposes as cookies on platforms, including certain mobile devices, where cookie technology is not available.
We may use Web beacons or similar technology on the Service. Web beacons are small, invisible graphic images that may be used on the Service or in emails relating to the Service to collect certain information and monitor user activity on the Service, such as to count visits, understand usage effectiveness and to tell if an email has been opened and acted upon.
We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Vicinnity account.
Personal information will be stored on secured servers, and we may store and process personal information in Canada and other countries.
Why do collect Personal Information and How we us it?
We use personal information collected through the Service for the purposes described in this Policy or elsewhere on the Service. For example, we may use personal information we collect:
- to process and complete any transactions in connection the Service (e.g., to sell you a hotel room);
- to request feedback and to otherwise contact you about your use of the Service;
- to respond to your emails, questions, comments, requests and complaints, and to provide customer service;
- to monitor and analyze Service usage and trends;
- to personalize and improve the Service, and our users’ experiences with the Service (such as providing content or features that match interests), and to increase the Service’s functionality and user friendliness;
- to provide you with news and information about our or third-party events, offers, promotions and services we think will be of interest to you (you can unsubscribe from promotional content in the footer of promotional email communications);
- to send you confirmations, updates, security alerts and support and administrative messages, and otherwise facilitate your use of, and our administration and operation of, the Service;
- to notify you about important changes to the Service; and
- for any other purpose for which the information was collected.
What Personal Information Do We Share With Third-Parties?
We will not knowingly share the personal information we collect from you through the Service with third-parties, except as described in this Policy or on the Service. For example, we may share personal information as follows:
- with vendors, consultants, and other service providers (“Service Providers”) who are engaged by or working with us in connection with the operation of the Service and who need access to such information to carry out their work for us;
- with hotels where you have purchased a hotel room through the Service;
- when you give us your consent to do so, including if we notify you on the Service that the information you provide will be shared in a particular manner and you provide such information;
- in an aggregated or anonymized form that does not directly identify you;
- when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or to respond to lawful requests or legal authorities including, but not limited to, responding to lawful subpoenas, warrants, or court orders;
- when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to protect the rights, property, or safety of Vicinnity, our users, our employees, copyright owners, third-parties or the public including, but not limited to, protecting Vicinnity or our users from fraudulent, abusive, inappropriate, or unlawful use of the Service;
- to enforce or apply this Policy, the Terms, or our other policies or agreements; and
- in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where personal information may be disclosed or transferred as one of the business assets of Vicinnity.
You understand that when you use the Service, information you provide via the Service, information you grant access to by using the Service, as well as any information you share with individuals through the Service, will be available to other users and in some cases may be publicly available (with the exception of personal information, which shall not become publicly available, unless such personal information is shared by you as part of a review, photo submission or other similar method).
We are not responsible for the actions of Service Providers or other third-parties, nor are we responsible for any additional information you provide directly to any other users or third-parties, and we encourage you to become familiar with third-party privacy practices before disclosing information directly to any such third-parties. Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third-parties without your consent.
Links to Other Websites
What Steps Do We Take To Protect Your Personal Information?
We take reasonable measures to protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can guarantee against any interception or any other type of misuse. To assist with the protection of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Service by any person using your password. Please advise us immediately if you believe your password has been misused.
What Choices Do You Have Regarding the Use of Your Information?
You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to reasonable fees.
However your rights to access your personal information are not absolute. We may deny access, for example, when denial of access is required or authorized by law. If we deny your request for access to, or refuse a request to correct information, we shall explain why.
Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name or verifying your identity (for example, by accessing general information on our website). However the Proceeds of Crime (Money Laundering) and Terrorist Financing Act or other legislation may require us to confirm your identity.
You may ask us to correct errors in any personal information we have collected or retained.
You may ask us to delete any personal information we have collected or retained, and we will do so if required by law and we have no other legitimate legal or commercial reason to retain that information. We may, for example, have to retain personal information if you are continuing to use our Services, plan to use our Services in the future, or an applicable limitation period has not expired since you last used our Services.
Vicinnity Exchange Inc. is subject to and complies with the privacy laws applicable in Ontario, Canada.
Questions or Complaints?
If you have any questions, or wish to access your personal information, please contact our Privacy Contact at
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at
Phone: (819) 994-5444
Fax: (819) 994-5424
TTY: (819) 994-6591
Office of the Privacy Commissioner of Canada
30 Victoria Street