Privacy Policy

Tour Operator/Travel Agent Privacy Policy for Canada

Unique Travel Corp. (“Unique,” “we,” “us”, “our” or the “Company”), the worldwide representative for Sandals, Beaches and Grand Pineapple Beach Resorts, operates this website (the “Site”), and maintains this information privacy policy (this “Privacy Policy”).

This Privacy Policy describes our practices with respect to “personal data”. As the term suggests, “personal data” is information about an identified or identifiable individual, including, for example, an individual’s name, address, or telephone number, e-mail address, information about an individual’s holiday arrangements or booking history, and information about online activities that are directly linked to them. Personal data does not include data where you can no longer be identified from it such as anonymised aggregate data.

It is common practice and often a necessity for companies or other organizations to collect personal data in order to conduct business and offer services. Unique is committed to protecting your privacy and this Privacy Policy sets out what personal data we collect, how we collect it, what we use it for and who we share it with.

This Privacy Policy applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as a travel partner, including when you attend familiarization trips with us, use our Site, portal or call centres, or engage with us at a trade fair or event we are attending.

We may provide other supplemental privacy policies on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. Those supplemental policies should be read together with this Privacy Policy.

Where you also provide us with personal data of others, for instance, guests accompanying you on your vacation, please provide those persons with a copy of this Privacy Policy. Their personal data is also subject to the terms hereof.

What information do we collect about you and what do we use it for?

The types of personal data about you we may collect, store and use are set out in the table below and in each case we have specified what we use it for and our basis for processing it. Most commonly, we will rely on one or more of the following bases for processing your personal data:

  1. Where we need to perform the contract we have entered into with you (i.e. we need to provide the services you have booked);
  2. Where we need to comply with a legal obligation;
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  4. Where you have consented to us doing so.
Category of personal data What we use this data for Basis

Personal contact details including full name, contact number, e-mail address, postal address

Contacting you in relation to the familiarisation trip you have booked, the services you provide to us Confirming your familiarisation trip arrangements (e.g. booking your flights)

Fulfilling brochure requests

Contacting you with promotions and marketing information (if you are a natural person we will only do this if you have consented to us doing so)

Handling complaints

Managing our relationship with you

Our legitimate interests in providing you with a familiarisation trip to develop your knowledge of our services

Our legitimate interests in customer care, handling your complaint and performing our contract with you

Our legitimate interests in providing you with specifically targeted marketing information, developing and growing our business

Our legitimate interests in customer care, handling your complaint and performing our contract with you

To comply with our legal obligations

Our legitimate interests in maintaining our accounts and records

Date of birth

Booking the trip that you have requested

Our legitimate interests in providing you with a familiarisation trip to develop your knowledge of our services

Name(s) and date(s) of birth of any accompanying guests, including children.

Booking the trip that you have requested

Our legitimate interests in providing you with a familiarisation trip to develop your knowledge of our services

Flight details

Coordinating reservations and your pick-up and drop-off to and from the airport at your trip destination

Our legitimate interests in providing you with a familiarisation trip to develop your knowledge of our services

Dates of stay

Identifying the dates on which you have reserved the trip

Our legitimate interests in providing you with a familiarisation trip to develop your knowledge of our services

Name of your host resort

Identifying the resort at which you have booked your trip

Our legitimate interests in providing you with a familiarisation trip to develop your knowledge of our services

Job title

To confirm your eligibility for an agent concession

Our legitimate interests in providing you with appropriate concessions

Passport details

Confirming your full name for your flight and checking eligibility for entry into the destination country (i.e. your passport has the required validity time and no visas are required)

Our legitimate interests in providing you with a familiarisation trip to develop your knowledge of our services

Our legitimate interests in providing you with a comprehensive service

Emergency contact name and number

For use in case of an emergency

Our legitimate interests in contacting your emergency contact in the event of an emergency

Manager’s Name & Contact Details

For use in case of an emergency both before and after the trip and for feedback

Our legitimate interests in contacting your manager in the event of an emergency and in order to discuss feedback

Where required by law, in addition to the lawful basis for processing identified above, we will obtain your consent, which may be explicit or implied depending on the circumstances.

Special categories of personal data

Certain categories of personal data, such as race, religion or health, are considered to be “special categories” of personal data as they are more sensitive types of data. We try to limit the circumstances where we process special categories of personal data as much as possible, however, we may also occasionally collect, store and use the special categories of personal data set out in the table below.

Category of special category personal data What we use this data for Basis

Dietary requirements revealing or suggesting a religious or philosophical belief or a health condition.

Minimising health risks (e.g. allergic reactions) and accommodating guest preferences

Your consent

Relevant medical information such as current medications taken

In case of an emergency

Minimising health risks or discomforts

For your safety

Your consent

Special categories may also encompass other requests in relation to your travel arrangements that may contain or suggest some details about you that could be categories as more sensitive personal data. For instance, you may request that special meals are available to you in resort which could imply or suggest that you hold particular religious beliefs or have a particular medical condition.

Please note that we may use your personal data without your knowledge or consent, in compliance with the above rules, if we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

What if you do not provide the personal data we request?

If you do not provide us with certain information when requested, we will not be able to provide all or some of the trip elements (such as booking your flights or hotel).

Change of purpose

We will only use your personal data for the purposes for which we collected it (as identified above in the What we use this data for column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.

How do we collect this information?

We typically collect personal data about you when you book a familiarization trip with us or otherwise contact us in relation to your role as a tour operator agent or travel agent or when you visit our website, you may directly give us some personal data and we may also automatically collect certain data such as technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see the below Cookies section for further details.

In addition, we may receive personal information about you from third parties, such as:

  • Companies contracted by us to provide services to you
  • Companies involved in your travel plans

If you access the Site through a mobile device, we may also be able to identify the location of your mobile device. You may choose not to share your location details with us by adjusting your mobile device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

Our internet service providers may also use other standard web-based technologies to analyze your movements while accessing our Site. The technologies include analytic solutions, web “beacons,” “pixel tags,” and “clear gifs.” These technologies help us ascertain the effectiveness of our product and service campaigns and marketing programs; allow us to customize the services offered on or through the Site; and help determine the best use for Site content, and product and service offerings. Some of this information, including the IP address, may be stored on our internet service provider’s server logs, and may be available for extended periods of time.

Cookies

A cookie is an element of data that is stored on a user's computer. It may be used to identify the device you use to access the website to help us improve and deliver a more personalized service based on browsing style. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file instructions.

Types of Cookies:

Category 1- Strictly Necessary Cookies: These cookies are essential for the operation of our web site. These cookies enable services you have specifically asked for such as a shopping basket. These cookies remain on your device only until you close your browser after visiting our web site. This cookie is destroyed at the end of the user’s visit.

Category 2 - Performance Cookies: These cookies collect anonymous information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a web site works. This cookie is destroyed at the end of the user’s visit.

Category 3 - Functionality Cookies: These cookies remember choices you make to improve your experience. These cookies remain on your device for an extended period of time. When you revisit our web site, we recognize these cookies and remember your preferences and choices such as your user name to log on to the website. Personal information on our system may be associated with these cookies but the cookies themselves do not contain any of your personal information. This type of cookie may also gather information about your computer, IP address and your operating system and browser type in order to enhance your experience.

Category 4 - Targeting Cookies or Marketing Cookies: These cookies gather information about your browsing habits in order to make advertising relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign.

By using our websites, you agree that we can place these types of cookies on your device. These cookies can be removed or blocked by following Internet browser help file instructions. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites.

Analytics Tracking Tools Disclaimer

The Site may also use third-party analytic tools such as Google Analytics, a web analytics tool that helps website owners understand how their visitors engage with their website. Google Analytics collects information anonymously, and reports web site trends without personally identifying individual visitors. Google Analytics uses its own cookie to track visitor interactions. The Google Analytics cookie is used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. A different Google Analytics cookie is used for each website that use the Google Analytics tool, and visitors are not tracked across multiple websites. To disable this type of cookie, some browsers will indicate when a cookie is being sent and allow you to decline cookies on a case-by-case basis. In addition to declining cookies, you can also install the Google Analytics Opt-out Add-on in your browser, which prevents Google Analytics from collecting information about your website visits. Visit Google Analytics website to receive more information about the Google Analytics Opt-out process.

Who will personal data be shared with?

We share your personal data with third parties, including third-party service providers, and other entities within our group where this is required by law, where it is necessary to perform our contract with you, or where we have another legitimate interest in doing so.

We will need to share your personal data with others including:

  • The resort at which you are staying;
  • The airline providing your flights;
  • Other entities within our group who participate in the booking process for the services provided to you;
  • Our booking system providers;
  • Our tour provider if you choose to book a tour;
  • The Sandals Foundation if you choose to make a donation;
  • Third parties we have engaged to run customer surveys on our behalf;
  • Professional advisers including our legal teams (both internal and also external law firms), bankers, auditors and insurers to the extent such information is relevant to the performance of their services;

We will share your personal data with other entities in our group who participate in the booking process for the services provided to you, as part of our regular reporting activities in company performance, in the context of a business reorganization or group restructuring exercise, for system maintenance support and hosting of data.

We may share your personal data with third parties, in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law or a judicial process. We may disclose your personal data if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may transfer the personal data we collect about you to Canada where our servers are located, and where personal data files are maintained, for our legitimate interests in hosting all data on our central servers there.

We may transfer the personal data we collect about you to countries where the third parties listed above are located including the United States, Panama, Jamaica, Bahamas, St. Lucia, Antigua, Grenada, Barbados and Turks & Caicos in order to perform our contract with you by booking your requested holiday. Your personal data may also be transferred to Honduras and India where our database maintenance teams are located for our legitimate interests in maintaining such database.

Unique may also use personal data to investigate and help prevent potentially unlawful activity or activity that threatens the network or otherwise violates the Site’s terms and conditions for usage.

Security

Unique has implemented physical, organizational and technological security features in an effort to safeguard the privacy of your personal data from unauthorized access or improper use, and Unique will seek to continue to enhance its security procedures as new technology becomes available. However, you acknowledge and agree that perfect security is not possible and your personal data could still be accessed and used by others without authorization. Your access and use of the Site constitutes your agreement that Unique is not and shall not be responsible for any such unauthorized access and use of your personal data.

You acknowledge and agree that Unique can use your personal data for the purposes described herein, and that authorized employees, representatives and agents will have access to your personal data for these purposes. If Unique discloses your personal data to third party contractors, Unique will require that the person or entity receiving your personal data agrees to only use and disclose your personal data to carry out its specific business obligations to Unique or for the permitted purpose of the disclosure (as described above). Unique cannot, however, guarantee that any such person or entity to which Unique discloses your personal data or other information will not re-disclose it in ways that you or we did not intend or permit.

Additionally, notwithstanding any other provision contained herein, to the extent permitted or required by law, regulation or other legal requirement, we will disclose your information to government authorities or third parties if: (i) required to do so by law, or in response to a subpoena or court order; (ii) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (iii) we believe that you have abused the Site by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws or in violation of our Site Terms and Conditions. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.

How long will we retain your information?

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.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Generally, we will keep information relevant to our dealings with you for seven years once you have ceased being a customer.

Generally, we will keep information relevant to our dealings with you for up to seven years once you have ceased being a customer. Exceptional circumstances will or may apply to customer service data where we will keep information for up to 10 years.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you as it is no longer personal data.

Once we no longer require your personal data for the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We will securely destroy your personal data in accordance with applicable laws and regulations.

Your rights in relation to your information

It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us, for example, if you change your address or contact information.

You may have the right to:

  • Request access to your personal data and request certain information in relation to its processing;
  • Request rectification of your personal data;
  • Request the erasure of your personal data;
  • Request the restriction of processing of your personal data;
  • Object to the processing of your personal data;
  • Request the transfer of your personal data to another party.

If you want to exercise one of these rights please contact us at privacy@uniqueglobalinc.com.

Fees

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee where permitted by law or, where permitted, if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

Where personal data is processed based on your consent, you have the right to withdraw your consent for that processing at any time. To withdraw your consent, please contact privacy@uniqueglobalinc.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we have an alternative legal basis for doing so. A revocation of consent does not have any effect on Unique’s prior actions taken in reliance on the consent before revoked, and does not affect Unique’s use of information that does not constitute personal data. Following receipt of a request from you, we will take reasonable steps to delete your information as requested.

User Opt-Out

You may choose not to receive direct marketing communications from Unique by notifying Unique by email. If Unique receives such a request from you, Unique thereafter (a) will discontinue contacting you directly with marketing messages about Unique’s products or services, and (b) will not use personal data obtained from your use of the Site to contact you with marketing messages about any Unique events, products or services. Please note, however, that any such opt out only applies to Unique and will not apply to any other third parties to which Unique has supplied your personal data. Additionally, you acknowledge and agree that such opt-out notification processing may not be immediate, and you agree that should you receive additional communications your rights and remedies are limited to contacting us to reiterate your request to opt-out.

Other Web Sites

Unique’s privacy policy only applies to the Site. The Site may link from several points throughout the Site to third party websites and information or service providers that may collect personal information from you in order to provide you with information or services. Advertisements that may appear on pages on the Site may also request personal data or provide you with access to other sites that request personal data. Unique has no control over the privacy policy of any third party or other website. Their privacy policies may differ or they may have no privacy policies. Please examine the privacy policies of such third parties prior to submitting any personal information, as they may differ from ours.

Surveys

Unique may from time to time conduct surveys on the Site. Surveys are conducted at random and are completely voluntary to users of the Site. The survey may require a user to provide personal data. Unique may use this information and share it with its contractors as described above to better tailor its products, services and marketing efforts, including advertising or other content provided on the Site and/or to you in particular.

Additional Privacy Protections for Children Using the Internet

Our Site is not intended for use by minors. Unique is concerned about the privacy and safety of children when they use the Internet. We will never knowingly request personal data online from anyone under the age of 13 without prior verifiable parental consent.

Business Transfers

In the event that Unique or any of its affiliates is acquired (whether by sale of assets or ownership interests) by merger with a third party entity or otherwise, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from our website visitors as part of such merger, acquisition, sale, or other change of control, and your use of the Site and/or submission of any information to the Site constitutes your consent to such transfer or assignment. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal data is treated, transferred, or used.

Policy Changes

We reserve the right to update this privacy policy at any time, and we will make an updated copy of such privacy policy available on our Site and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data. Your access and use the Site thereafter constitutes your acknowledgment and acceptance of same. This privacy policy does not create any legal right for you or any third parties.

Questions?

Please direct any questions or comments regarding our privacy policy to our Compliance Officer at privacy@uniqueglobalinc.com.