Operating as Travelweek (hereinafter referred to as Travelweek) Website Privacy Policy (Last Updated on January 26, 2011) Travelweek respects the privacy of all of its users and is committed to protecting such privacy in accordance with this Privacy Policy. This Privacy Policy explains Travelweek and its subsidiaries’ (collectively, “Travelweek”) treatment of your personally identifiable information collected in connection with your activities on or related to all Travelweek websites referencing this Privacy Policy (the “Travelweek Sites”) and all services made available on the Travelweek Sites (collectively, unless noted otherwise, the “Travelweek Services”).

This Privacy Policy also explains how you can ask questions and make suggestions about our privacy practices and review and update your personal information.

We urge you to read this Privacy Policy carefully and to check back periodically as this Privacy Policy may change from time to time. Please note that this Privacy Policy does not apply to the practices of companies or websites which are not owned or controlled by Travelweek.

In the course of operating the Travelweek Services, we may collect two types of information about our users: Personal Information and Non-Personal Information. “Personal Information” is personally identifiable information, such as your name, address, email address, birth date and gender. Personal Information is collected by us when you choose to provide it to us when registering for a Travelweek Service, such as when you choose to subscribe to a Travelweek Service, enter a Travelweek promotion or choose to receive a Travelweek newsletter. In addition, if you choose to contact any of our customer service representatives, we may keep a record of that correspondence so that we may fully address the subject matter. We may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that you have permitted them to share such information.

Business contact information such as the name, title, business address, email address or telephone number of a business or professional person or an employee of an organization is not considered Personal Information. “Non-Personal Information” is information of an anonymous nature, such as your Internet Protocol Address (IP Address), the domain you may have used to access a Travelweek Service, the type and version of browser or operating system you may be using, and the website you may have come from and visit next. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors and average time spent on a Travelweek Service, is also considered Non-Personal Information.

Non-Personal Information is collected or derived by us in the course of operating the Travelweek Services. For example, our Web servers may automatically collect Non-Personal Information which is provided through your browser or stored on a Cookie (as defined herein) or through a Web Beacon (as defined herein) when you choose to visit a Travelweek Page 1 of 6 Service. Non-Personal Information is used by Travelweek as described in this Privacy Policy.

Personal Information may be used by us for the following purposes:

• Providing you with the Travelweek Services and information you have requested from us,including your use of the Travelweek Sites. We may from time to time use your Personal Information to contact you about changes, enhancements or similar notices related to the Travelweek Services;
• If you indicated that you were interested in receiving offers or information from Travelweek or certain of our selected sponsors or advertisers, Travelweek may send you email materials and other mailings about products and services that we feel may be of interest to you. If at any time you would like to end your subscription to any such email materials, follow the directions posted at the bottom of the email material;
• If you enter a contest or other promotion offered on a Travelweek Site, we may, under the rules of the promotion, use your name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion; or
• Travelweek may also use Personal Information if it has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law or in order to protect or defend a legal interest.

We will not sell or rent your Personal Information to anyone. We will only disclose your Personal Information to third parties:

• Where you have specifically given us your consent to disclose your Personal Information for a designated purpose;
• Who are acting on our behalf as our agents, suppliers or service providers, solely to enable us to more efficiently provide you with the Travelweek Services. Such entities act under strict contractual controls, requiring them to maintain the confidentiality of all such Personal Information and to use such information solely for purposes related to the provision of the Travelweek Services;
• As may be set out in the Terms and Conditions applicable to a Travelweek Service, to facilitate the provision of such Travelweek Service, such as fulfilling legal requirements;
• As required by law, including by an order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest; or
• In connection with a Travelweek corporate re-organization, merger or amalgamation with another entity, or a sale of all or a substantial portion of the assets of Travelweek provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

A Travelweek Service may contain links to other websites and services. While we try to link only to sites and services that share our high standards and respect for privacy, please understand that we are not responsible for the content of, or the privacy practices employed by, other companies or websites. This Privacy Policy applies only to the Travelweek Services referencing this Privacy Policy. The majority of the advertisements which are displayed in connection with the Travelweek Services are served through reputable third party advertisement serving partner(s), in accordance with their policies as described on their own website.

The security of your Personal Information is important to us. Travelweek takes technical, contractual, administrative, and physical security steps to protect Personal Information that you provide to us. We instruct our employees with access to your Personal Information that it is to be used only in adherence with the principles set forth in this Privacy Policy and the laws applicable to each specific business. In certain areas, such as when you provide credit card information to us, we work to help protect the security of your credit card information during transmission by using industry standard Secure Sockets Layer (SSL) encryption technology.

You can help protect the security of your Personal Information as well. For instance, never give out your password, since this is what is used to access your account or registration information. Also remember to log out of your account and close your browser window when you finish using a Travelweek Service or surfing the Web, so that other people using the same computer won’t have access to your information.

Travelweek may from time to time change this Privacy Policy as new Travelweek Services are added or old ones changed. Changes will be effective when notice of such change is posted at a Travelweek Site. Please check this Privacy Policy regularly for updates by checking the date of “Last Update” at the top of this document.

Privacy procedures specific to a Travelweek Service can be found on a Travelweek Site at the location of the particular Travelweek Service, or in additional terms referenced at such Travelweek Site. Those procedures are an addendum to this Privacy Policy, and are provided to you at the place where they will be of most use to you.

Travelweek provides you with the means to access, update, edit or delete any account or registration information you may have provided to us at any time on your own by going to the appropriate page in the account or registration section of the relevant Travelweek Service, and changing or deleting such information as desired. If you are unsure whether we have a record containing any of your Personal Information and would like to confirm whether or not we do, please send an e-mail indicating all e-mail addresses that you may have given us.

If you decide at any time that you do not want to receive any e-mail materials to which you have subscribed, you may choose to unsubscribe to these e-mails by following the instructions at the end of the message.

If you have questions, comments or suggestions about this Privacy Policy or Travelweek’s privacy practices that were not answered here, send us an e-mail at travelweek@travelweek.ca

Non-Personal Information is collected or derived by us in the course of operating the Travelweek Services. For example, our Web servers may automatically collect Non-Personal Information which is provided through your browser or stored on a Cookie or through a Web Beacon when you choose to visit a Travelweek Service.

In addition to Travelweek’s practices related to IP Addresses, Cookies or Web Beacons, Non-Personal Information is used generally by Travelweek to monitor and improve the operation of the Travelweek Services, to perform statistical analyses of the collective characteristics and behavior of our users, to measure user demographics and interests regarding specific Travelweek Services, to describe our services to third parties such as prospective business partners and advertisers and to analyze how and where best to use our resources.

No Personal Information will be disclosed during these activities. Travelweek may also use Non-Personal Information to inform our sponsors and advertisers as to the performance of a particular sponsorship (such as a contest) or advertisement. In such case we may disclose to those third-party sponsors and advertisers the overall aggregate demographics available regarding, for example who participated in a contest or who saw and “clicked” on an advertisement. No Personal Information will be disclosed to these sponsors and advertisers as part of this process; only information in an anonymous, aggregate form will be disclosed.

An IP Address is the unique number which is assigned to every direct Internet access point. Many IP Addresses can generally be associated with certain Internet service providers or large organizations. IP Addresses do not contain any Personal Information. When you, through your browser, request a web page or similar Internet information from another computer on the Internet, your browser automatically provides that computer with an IP address to which it will send the requested information. Travelweek and IP Addresses: a. Whenever you request a Travelweek Service web page or certain other similar Travelweek content, your browser automatically provides our computers with your IP Address, to which our computers will send the requested information.

Each such request is logged by our computers with information including:

• the IP Address of the computer that requested the page and is stored by our computers as needed for the purposes described in this Privacy Policy;
• Travelweek may use your IP Address to display more appropriate and relevant content and advertising, such as content and advertising based on your geographic area. Aggregate information derived from IP Addresses may be reported by Travelweek to its advertisers and partners. For example, Travelweek may report to its advertisers the estimated total number of users accessing a particular Travelweek Site from a specific province;
• Travelweek may use your IP Address to facilitate the diagnoses and remedy of a technical problem reported by you or our technical team.

A _Cookie_ is a small text file containing a unique identification number that is transferred(through your browser) from a web site to the hard drive of your computer. The Cookie identifies your browser and will NOT let a web site know any personal information about you, such as your name and address. Since Cookies are only text files, they cannot run on your computer, search your computer for other information or transmit any information to anyone. Travelweek may use Cookies to: a. Monitor website usage and improve the operation and performance of the Travelweek Services and to make our Travelweek Services easier and more convenient to use. For example, Cookies help us remember who you are through your browser settings so that we can offer and provide more personalized services (e.g. language preference).

Cookies also allow us to save passwords and preferences for you so that you will not have to:

• re-enter them the next time you visit a Travelweek Service;
• Measure aggregate user traffic and demographic statistics related to the Travelweek Services and advertisements (e.g. number of users, average time spent, average age and similar statistics). This information helps us to better understand when to update, change or offer new services and provides us with details as to the performance of third party advertisements and content. This information may be reported, in aggregate form only, to our current and prospective sponsors, advertisers and business partners. No Personal Information will be disclosed in such reports;
• Displaying advertisements. Travelweek and third party advertising providers used by Travelweek may use Cookies when serving advertisements. Cookies are used on many major web sites. Most browsers are initially set up to accept Cookies.

If you prefer, you can reset your browser either to notify you when you have received a Cookie, or to refuse to accept Cookies. You should understand that while Travelweek does not require you to use Cookies, certain Travelweek Services will not function properly if you set your browser to not accept Cookies. Certain Travelweek Services may contain electronic images known as Web Beacons – sometimes called single-pixel gifs – that allow Travelweek to count users who have visited those pages and to deliver cobranded services. Web Beacons are not used to access your Personal Information; they are a technique used to compile aggregated statistics about Travelweek Service usage. Web Beacons collect only a limited set of information including a Cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. Certain Travelweek Service web pages may also contain Web Beacons placed there by our advertising partners to help Travelweek determine the effectiveness of our Internet advertising campaigns.

EFFECTIVE DATE: July 1, 2014

APPLICATION OF THESE POLICIES AND PROCEDURES

The policies and procedures outlined below will apply to all messages that may be Commercial Electronic Messages (CEMs) under Canada’s anti-spam law and communicated by TWK from time to time whether on its own behalf or on behalf of or relating to third parties. These communications shall include the following CEMs:

• Travelweek Online
• Newsletters
• Professions Voyages
• Learning Centre
• Travelweek E-blasts on behalf of 3rd parties or relating to 3rd parties;

PROCEDURES FOR COMMUNICATING CEM’s

CEM’s will be sent only to recipients who have subscribed for or consented to receive each of these messages. The consent must be given either in writing or in electronic form and must contain the following information at the very least;

• name of subscriber or recipient;
• e-mail address of the subscriber or recipient;
• such other information as may be required from time to time;
• the purposes for which the consent is being sought;
•  identifying information regarding the sender (corporate name, mailing address and one of the following – (the sender’s telephone number, the sender’s e-mail address or the sender’s web address);
• an effective statement that consent may be withdrawn.

All CEM’s whether originating from Travelweek or a third party will be reviewed to by designated TWK employees to ensure that the no misrepresentation provisions of Canada’s Anti-Spam Legislation are complied with. Clients advertising on specific CEM’s or on whose behalf a CEM is sent out to subscribers may be asked to certified that the content of their advertisement or message are in compliance with these provisions of Canada’s Anti-Spam Legislation.

All CDMs will include a simple process allowing subscribers and recipients to unsubscribe.

UNSUBSCRIBE PROCEDURES

All unsubscribe requests will be processed within 10 business as required by Canada’s Anti-Spam Legislation.

ONGOING COMPLIANCE

At TWK, we are committed to ongoing compliance with the provisions and requirements of Canada’s Anti-Spam Legislation. Ensuring continuous and open communications with our clients and subscribers is a priority.

For any inquiries or concerns regarding compliance, please contact our Designated Representative via email at travelweek@travelweek.ca.