MY FREE HOLIDAY Online Privacy Statement
MY FREE HOLIDAY is committed to preserving and safeguarding your right to privacy. This Privacy Statement sets out the manner in which we will collect, use, disclose and otherwise manage your personal information.
Collection of Personal Information
We collect personal information that you provide us when you:
· Sign up for one of our products or services;
· Access our Web site;
· Contact our customer service department;
· Provide us with comments or suggestions; or
· Make payments online.
Information we may request includes your email address, name, home address, and telephone number, credit card and billing information. We may also ask for your Social Security Number or Social Insurance Number to process your credit or financing request.
We may collect information about your visits to our websites, including the pages you view, the links you click, and other actions you take in connection with Myfreeholiday.com websites and services. We may also collect certain information from the browser you used to come to our website, such as your Internet Protocol address, browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our website and to which URL you browse away from our site if you click on a link on our site.
Which personal data do we collect?
Types of data that we collect for specified purposes are:
- your name,
- last name,
- telephone number,
- country of residence, and
- email address.
Purpose and manner of personal data collection and use
MY FREE HOLIDAY collects and processes personal data in accordance with the provisions of the Personal Data Protection Act and other regulations in force in Canada and the European Union.
Your personal data are processed only on the basis of your approval – a free and express consent to process your personal data for the purposes related to the use of the Content available through myfreeholiday.com website. Your consent for the collection and processing of your personal data for a given purpose shall be requested when completing the appropriate form published on the web pages of myfreeholiday.com
Your personal data shall be used in order to provide Content, reply to queries concerning the content available on the website and inform you about the existing and new content, materials, functionalities, services and other offers that may interest you, and in order to improve the quality of the content on the website.
Data collected through quizzes and questionnaires are confidential and may be used only for our own purposes.
All collected data are electronically stored, and appropriate measures and procedures are applied in order to prevent unauthorized access, maintain the level of personal data protection and use the data collected online in a correct manner.
Even though we take all appropriate measures to ensure against unauthorized disclosure of your personal data, we cannot guarantee that some of the collected personal data shall never be disclosed in a manner that is not in accordance with these General Terms and Conditions. Accidental disclosure may be, for example, a consequence of false misrepresentation when accessing websites that contain such data, with the purpose of correcting possible errors in the data. We shall not be liable, to the fullest extent permitted by law, for any damage caused to users or third parties relating to accidental disclosure of personal data.
Collection and processing of personal data by other users or third parties
The myfreeholiday.com website contains Interactive Content and may contain Links to third party websites, through which other users or third parties may gain authorized or unauthorized access to your personal data. These General Terms and Conditions do not apply to the collection, processing or use of personal data that you communicate to other users and/or third parties. It is in your best interest to acquaint yourself with the rules of personal data protection, and the protection of privacy applied by other users and/or third parties. Since we cannot control the data you provide when accessing or using the Interactive Content, Links or third party websites, or in other circumstances in which you communicate your personal data to other users and/or third parties, we shall not be liable for any damage caused to you, other users and/or third parties, arising from the fact that you communicated your personal data, in relation to the use of the website myfreeholiday.com
Communication and disclosure of personal data to third parties
Please note that your personal data shall not be disclosed to third parties without your express consent, except under legal obligation. More specifically, your personal data shall not be transmitted or provided to third parties outside the European Union without your express consent, except under legal obligation.
The personal data you provided may be transmitted to our related companies and/or partners when this is deemed necessary for the purpose of maintaining and managing the MY FREE HOLIDAY website and for the purpose of provisioning our products and services. In such cases, we shall ensure that our partners and/or related companies take over the responsibility to protect personal data to an extent equal to that guaranteed in these General Terms and Conditions.
Your personal data (including your email) will never be shared with any third parties for marketing purposes.
How We Use Personal Information
MY FREE HOLIDAY uses your personal information to:
· Develop, enhance, market or provide products and services;
· Send communications to you such as information about products and services available from MFH or its distributors;
· Enforce our contract(s);
· Prevent fraud and other prohibited or illegal activities;
· Meet legal and regulatory requirements; or
· Otherwise, as disclosed to you at the point of collection.
Personal information collected may be stored and processed in Canada, the United States or any other country in which MY FREE HOLIDAY or its corporate affiliates, subsidiaries or agents maintain facilities, and by using MY FREE HOLIDAY products or services (including our website), you consent to any such transfer of information outside of your country.
Information is retained for the duration of any contract period, as well as for a period of up to 10 years after the termination of customer contracts and any renewals thereof.
Who has access to your information?
We do not sell or rent your information to third parties.
We do not share your information with third parties for marketing purposes.
However, we may disclose your information to third parties in order to achieve the other purposes set out in this policy. These third parties may include:
Third parties working on our behalf: We may pass your information to our third party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services and we have a contract in place that requires them to keep your information secure and prevents them from using it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.
Performance of a contract
Where we are entering into a contract with you or performing our obligations under it like when you buy MY FREE HOLIDAY products and services.
Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority like the Charity Commission or Fundraising Regulator.
Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).
You have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:
Right of access
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your information, please send a description of the information you want to see and proof of your identity by post to the address provided below.
Right to have your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so we’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email or post (see below).
Right to restrict use
You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy or we’re not lawfully allowed to use it.
Right of erasure
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to. In many cases, we will anonymise that information, rather than delete it.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format (csv file).
Right to object
You have the right to object to processing where we using your personal information (1) based on legitimate interests, (2) for direct marketing or (3) for statistical/research purposes.
If you want to exercise any of the above rights, please email us at firstname.lastname@example.org. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the Canada’s Information Commissioner’s Office.
Keeping your information safe
When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.
Any sensitive information (such as credit or debit card details) is encrypted and protected with the following software 128 Bit encryption on SSL. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Links to other websites
Our website may contain links to other websites run by other organisations. This policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links from our website.
16 or Under
We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ do not use our website. We cannot allow distributors aged 16 or under.
Transferring your information outside of Europe
As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. You should be aware that these countries may not have similar data protection laws to the EU countries. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.
If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services. We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained staff, volunteers and contractors.
How You can Access Your Information
MY FREE HOLIDAY wants to help you keep your personal information accurate. To review, verify or correct your personal information, please log in and update your Member Profile or contact our customer service department in writing.
MY FREE HOLIDAY may not be able to provide you with access to your personal information, where such refusal is permitted or required by applicable law or regulatory requirements. MFH will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
Selecting Your Communication Preferences
You may change or withdraw your consent to receive marketing communications from MY FREE HOLIDAY any time, subject to legal or contractual restrictions and reasonable notice, by contacting MFH customer service department. In some circumstances, a change in or withdrawal of consent may limit our ability to provide products or services to, or acquire products or services from, you. Because some marketing communications are developed in advance, you may sometimes receive solicitations after we receive a change in your consent to provide you with communications.
We assume, unless you advise us otherwise, that by receiving a copy of this privacy statement or by continuing to deal with MY FREE HOLIDAY or its affiliated entities, you have consented to the collection, use and disclosure of your personal information as explained in this privacy statement.
Safeguarding Personal Information
MY FREE HOLIDAY is committed to protecting the security of your personal information. We use a variety of technological, physical and organizational protections and procedures to help protect your personal information from unauthorized access, use, or disclosure, such as encryption, passwords, physical security, etc. While we strive to protect your personal information, MY FREE HOLIDAY cannot ensure or warrant that the personal information or private communications you transmit to us will always remain private, and you do so at your own risk.
If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving a site or service to protect access to your information from subsequent users.
When you interact with us on social media platforms such as Facebook and Twitter we may obtain information about you (for example, when you publicly tag us in an event photo). The information we receive will depend on the privacy preferences you have set on those types of platforms.
A cookie is a group of data serving as your anonymous individual identifier that is sent to your browser by websites. Cookies are sent when you access a website, they are stored in your computer and they serve to record information about your subsequent online visits. Therefore, after a cookie has been stored on your computer during your first access to a website, every time you return to the website it will look for its cookie in order to read the stored data.
Since a cookie is an anonymous individual identifier, it does not contain or send any personal information to the website that stored it on your computer, but only enables faster and more efficient activation of information, data and settings previously communicated during access and use of the website.
Your browser is set in such a way that each website can only access its own previously sent cookies, but not the cookies of other websites.
The Options or Settings menu of your browser allows you to select an appropriate option for receiving cookies, even to disable them completely. However, disabling cookies completely will reduce the efficiency of some contents available on some websites.
Changes to Our Privacy Statement
We will occasionally update this privacy statement. If we make changes to the privacy statement regarding how MY FREE HOLIDAY will use your personal information, we will revise the privacy statement to reflect such changes and revise the statement's effective date, included at the end of this section. We encourage you to periodically review this statement to be informed of how MY FREE HOLIDAY is protecting your personal information.