Policy on Privacy of Personal Information

Horseshoe Valley Resort Ltd. will comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), a federally enacted act to protect personal information that is collected, used or disclosed. For the purposes of this Policy, personal information means information about an identifiable individual, exceeding what is normally on a business card or in a telephone book, i.e., name, title, business address or telephone number. Any reference to a guest within this Policy is in reference to personal information and not business information.

PIPEDA is based on ten (10) fundamental and internationally recognized principles, as follows:

1.      Accountability

2.      Identifying Purpose

3.      Consent

4.      Limiting Collection

5.      Limiting Use, Disclosure & Retention

6.      Accuracy

7.      Safeguards

8.      Openness

9.      Individual Access

10.    Challenging Compliance

Horseshoe Valley Resort Ltd. has implemented policies and procedures to give effect to these principles, including:

1. Implementing procedures to protect personal information.

2. Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information by Horseshoe Valley Resort Ltd.

3. Training staff and communicating information to staff about Horseshoe Resort’s policies and procedures.

4. Developing information to explain Horseshoe Resort’s policies and procedures to Guests.

These principles are explained in more detail below:          

1.ACCOUNTABILITY

Horseshoe Valley Resort Ltd. is responsible for the personal information under its control and has designated a Privacy Officer to be accountable for Horseshoe Resort’s compliance with PIPEDA.

2.IDENTIFYING PURPOSE

Horseshoe Valley Resort Ltd. will identify and document the purposes for which it collects personal information. Only personal information that is necessary for those identified purposes will be collected. If Horseshoe Valley Resort Ltd. intends to use the personal information that has been collected for a new purpose, this new purpose will be identified and consent for such new purpose will be obtained from the guest to which the personal information relates prior to using such personal information. Horseshoe Valley Resort Ltd. shall only collect, use and disclose personal information about Guests for the following purposes:

1. to facilitate return visits and, wherever possible, to meet Guests’ personal preferences;
2. to advise Guests of goods and services by or by arrangement with the company;
3. to improve the offering of goods and services to Guests;
4. to assist Horseshoe Valley Resort Ltd. in the collection of fees and other charges owing with respect to services rendered by Horseshoe Valley Resort Ltd.;
5. to assist Horseshoe Valley Resort Ltd. in revenue management with respect to the Resort;
6. to assist Horseshoe Valley Resort Ltd. in communication with users of the Resort for the purpose of promoting the use of the Resort;
7. to assist an entity with whom Horseshoe Valley Resort Ltd. has an agreement relating to the collection of fees and other charges in connection with the use of the Resort.

Horseshoe Valley Resort Ltd. does not sell or trade personal information about Guests to any third party agencies.

Guest inquiries regarding the purposes for the collection, use and disclosure of personal information will be addressed by Horseshoe Valley Resort Ltd. or referred to the Chief Privacy Officer.

3.CONSENT

The knowledge and consent of Guests is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law. Horseshoe Valley Resort Ltd. will seek consent for the collection of personal information at the time of collection, wherever possible. Horseshoe Valley Resort Ltd. will make a reasonable effort to ensure that Guests are advised of the purposes for which the personal information being collected will be used, and will state the purposes in a manner that will allow Guests to reasonably understand how their personal information will be used or disclosed by Horseshoe Valley Resort Ltd.          

Consent may be obtained in a variety of ways, for example, through contracts and registration forms, orally by telephone or by electronic media, depending on the circumstances and the type of personal information being collected, and in particular, on the sensitivity of the personal information. The reasonable expectations of Guests will be considered when obtaining consent. For example, where Guests provide their names and addresses for mailing and billing purposes, they should reasonably expect that this information would also be used for sending out Guest Satisfaction Surveys, where the choice to respond is the Guest’s.

In certain circumstances, personal information can be collected, used, or disclosed without the knowledge or consent of the Guest. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. Seeking consent my be impossible or inappropriate when there is an emergency threatening the Guest’s life, health or security, or where the Guest is a minor, seriously ill or mentally incapacitated.

Although information may be publicly available, Horseshoe Valley Resort Ltd. will treat this in accordance with PIPEDA principles. Moreover, Horseshoe Valley Resort Ltd. may provide personal information to its lawyers, advisors, agents and/or third parties to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.

The use of Horseshoe Valley Resort Ltd. will be considered consent to collect, use and disclose personal information for stated purposes.

Copies of the Horseshoe Valley Resort Ltd. Privacy Policy will be published on the Horseshoe Resort website at www.HorseshoeResort.com.

A Guest may withdraw consent by providing reasonable notice to Horseshoe Valley Resort Ltd.’s Privacy Officer. Horseshoe Valley Resort Ltd. will inform the Guest of any implications of such withdrawal. Any withdrawal of consent will still allow Horseshoe Valley Resort Ltd. to use and disclose a Guest’s personal information in order to collect or enforce payment of amounts owing as a result of a Guest’s previous or continuing use of the Resort.  Subsequent use of the Resort will automatically provide consent for the collection, use, disclosure and retention of personal information.

4.  LIMITING COLLECTION

The collection of personal information will be limited to that which is appropriate in the circumstances.

Horseshoe Valley Resort Ltd. collects some information about prospective Guests using technology, so it may not be readily apparent to prospective Guests that it is being collected. For instance, when a prospective Guest visits our website, their IP address is collected so that we know how many visits we have had by separate individuals. An IP address is often associated with the place from which a prospective Guest enters the Internet like their Internet Service Provider (ISP), their firm or company or their university. This information is not personally identifiable.

Horseshoe Valley Resort Ltd. may use “cookie” technology to obtain non-personal information from its online visitors for certain purposes. The cookie is stored on their computer to allow them to get back into certain areas of the website with as minimal delay as possible. We do not extract personal information in this process nor do we disclose this information.  Cookies are tools that allow us to update and improve our sites.

5.LIMITED USE, DISCLOSURE & RETENTION

Horseshoe Valley Resort Ltd. will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the guest or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.

Horseshoe Valley Resort Ltd. may disclose a Guest’s personal information to third parties retained by Horseshoe Valley Resort Ltd. for the purposes of billing such a Guest for the use of Horseshoe Valley Resort Ltd. Properties and/or facilities, and to collect and enforce payment of amounts owing by such Guests.

Certain Horseshoe Valley Resort Ltd. employees and third party agents may be given access to a Guest’s personal information collected by Horseshoe Valley Resort Ltd. in so far as their duties require access for the purposes outlined above. Horseshoe Valley Resort Ltd. employees and such third party agents are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated purposes.

Personal information that has been used to make a decision about a Guest will be retained in accordance with the Horseshoe Valley Resort Ltd. document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. Horseshoe Valley Resort Ltd. retains personal information of a Guest only for as long as it is required for Horseshoe Valley Resort Ltd.’s business purposes or as required by federal and provincial laws.

6.ACCURACY

Horseshoe Valley Resort Ltd. will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Horseshoe Valley Resort Ltd. will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. Horseshoe Valley Resort Ltd. will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is accurate and up-to-date.     

Access to a Guest’s personal information on record with Horseshoe Valley Resort Ltd. may be requested by that Guest in order to review and amend their personal information, as appropriate. In circumstances where personal information has been provided by a third party, Horseshoe Valley Resort Ltd. will refer the Guest to that party. It is the responsibility of the third party to maintain accuracy of the personal information that is provide by them. To access your personal information, refer to “How to contact us”.

7.SAFEGUARDS

8.OPENESS

Horseshoe Valley Resort Ltd. will make readily available to Guests specific information about its policy and guidelines relating to the management of personal information.  Horseshoe Valley Resort Ltd. will be open about its policy and procedure with respect to the management of personal information, and Guests will be able to acquire information about these policies easily and in a form that is generally understandable. This policy and any related information is available at all times on the Horseshoe Resort Website, www.HorseshoeResort.com, under Privacy. To contact Horseshoe Valley Resort Ltd., refer to “How to contact us”.

9.INDIVIDUAL ACCESS

Horseshoe Valley Resort Ltd. will inform a Guest of the existence, use and disclosure of their personal information (including to third parties) and will provide access to that personal information, upon written request. Horseshoe Valley Resort Ltd. will assist a Guest in the preparation of a request for access when such a Guest requests assistance. Horseshoe Valley Resort Ltd. will inform the Guest whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible. There may, however, be situations in which Horseshoe Valley Resort Ltd. will not be able to provide access to all the personal information that it holds about a Guest, although these situations will be limited and specific, and permitted or required by law. For example, Horseshoe Valley Resort Ltd. will not be able to provide access to a Guest’s  personal information where giving such access would likely reveal personal information

about a third party, unless that third party’s personal information can be severed from the Guest’s personal information. If Horseshoe Valley Resort Ltd. refuses a request for access, the Guest will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Guest of their recourse.

Horseshoe Valley Resort Ltd. will require that Guests requesting access to their personal information provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit Horseshoe Valley Resort Ltd. to provide an account of the existence, use and disclosure of the Guests’ personal information.