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GDPR Article 22

Automated individual decision-making, including profiling
  • The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
  • Paragraph 1 shall not apply if the decision:
    • is necessary for entering into, or performance of, a contract between the data subject and a data controller;
    • is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
    • is based on the data subject's explicit consent.
  • In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
  • Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place.

GDPR Article 21 (1)

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on points (e) or (f) of Article 6(1) of GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Points (e) and (f) of Article 6(1) of GDPR

  • Processing shall be lawful only if and to the extent that at least one of the following applies:

...

(e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

GDPR Article 21 (2)

Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

GDPR Article 8 (1)

Where point (a) of Article 6(1) applies, in relation to the offer of information society services* directly to a child, the processing of the personal data of a child shall be lawful where the child is at least 16 years old. Where the child is below the age of 16 years, such processing shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child.

* ‘information society service’ means a service as defined in point (b) of Article 1(1) of Directive (EU) 2015/1535 of the European Parliament and of the Council

Point (a) of Article 6(1) of GDPR

1. Processing shall be lawful only if and to the extent that at least one of the following applies:

(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

...

Information Society Services

means any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services.

For the purposes of this definition:

  • ‘at a distance’ means that the service is provided without the parties being simultaneously present;
  • ‘by electronic means’ means that the service is sent initially and received at its destination by means of electronic equipment for the processing (including digital compression) and storage of data, and entirely transmitted, conveyed and received by wire, by radio, by optical means or by other electromagnetic means;
  • ‘at the individual request of a recipient of services’ means that the service is provided through the transmission of data on individual request.

An indicative list of services not covered by this definition is set out in Annex I;

Indicative list of services not covered by the second subparagraph of point (b) of Article 1(1)

1. Services not provided ‘at a distance’

Services provided in the physical presence of the provider and the recipient, even if they involve the use of electronic devices:

  • medical examinations or treatment at a doctor's surgery using electronic equipment where the patient is physically present;
  • consultation of an electronic catalogue in a shop with the customer on site;
  • plane ticket reservation at a travel agency in the physical presence of the customer by means of a network of computers;
  • electronic games made available in a video arcade where the customer is physically present.

2. Services not provided ‘by electronic means’

  • services having material content even though provided via electronic devices:
    • automatic cash or ticket dispensing machines (banknotes, rail tickets);
    • access to road networks, car parks, etc., charging for use, even if there are electronic devices at the entrance/exit controlling access and/or ensuring correct payment is made,
  • offline services: distribution of CD-ROMs or software on diskettes,
  • services which are not provided via electronic processing/inventory systems:
    • voice telephony services;
    • elefax/telex services;
    • services provided via voice telephony or fax;
    • telephone/telefax consultation of a doctor;
    • telephone/telefax consultation of a lawyer;
    • telephone/telefax direct marketing.

3. Services not supplied ‘at the individual request of a recipient of services’

Services provided by transmitting data without individual demand for simultaneous reception by an unlimited number of individual receivers (point to multipoint transmission):

  • television broadcasting services (including near-video on-demand services), covered by point (e) of Article 1(1) of Directive 2010/13/EU;
  • radio broadcasting services;
  • (televised) teletext.

GDPR Article 9

Processing of special categories of personal data

1. Processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation shall be prohibited.

2. Paragraph 1 shall not apply if one of the following applies:

  • the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to in paragraph 1 may not be lifted by the data subject;
  • processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorized by Union or Member State law or a collective agreement pursuant to Member State law providing for appropriate safeguards for the fundamental rights and the interests of the data subject;
  • processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
  • processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects;
  • processing relates to personal data which are manifestly made public by the data subject;
  • processing is necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity;
  • processing is necessary for reasons of substantial public interest, on the basis of Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject;
  • processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards referred to in paragraph 3;
  • processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of Union or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject, in particular professional secrecy;
  • processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) based on Union or Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

3. Personal data referred to in paragraph 1 may be processed for the purposes referred to in point (h) of paragraph 2 when those data are processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies.

4. Member States may maintain or introduce further conditions, including limitations, with regard to the processing of genetic data, biometric data or data concerning health.

GDPR Article 89 (1)

Processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, shall be subject to appropriate safeguards, in accordance with this Regulation, for the rights and freedoms of the data subject. Those safeguards shall ensure that technical and organizational measures are in place in particular in order to ensure respect for the principle of data minimization. Those measures may include pseudonymization provided that those purposes can be fulfilled in that manner. Where those purposes can be fulfilled by further processing which does not permit or no longer permits the identification of data subjects, those purposes shall be fulfilled in that manner.

GDPR Article 46

Transfers subject to appropriate safeguards

  • In the absence of a decision pursuant to Article 45(3), a controller or processor may transfer personal data to a third country or an international organization only if the controller or processor has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available.
  • The appropriate safeguards referred to in paragraph 1 may be provided for, without requiring any specific authorization from a supervisory authority, by:
    • a legally binding and enforceable instrument between public authorities or bodies;
    • binding corporate rules in accordance with Article 47;
    • standard data protection clauses adopted by the Commission in accordance with the examination procedure referred to in Article 93(2);
    • standard data protection clauses adopted by a supervisory authority and approved by the Commission pursuant to the examination procedure referred to in Article 93(2);
    • an approved code of conduct pursuant to Article 40 together with binding and enforceable commitments of the controller or processor in the third country to apply the appropriate safeguards, including as regards data subjects' rights; or
    • an approved certification mechanism pursuant to Article 42 together with binding and enforceable commitments of the controller or processor in the third country to apply the appropriate safeguards, including as regards data subjects' rights.
  • Subject to the authorization from the competent supervisory authority, the appropriate safeguards referred to in paragraph 1 may also be provided for, in particular, by:
    • contractual clauses between the controller or processor and the controller, processor or the recipient of the personal data in the third country or international organization; or
    • provisions to be inserted into administrative arrangements between public authorities or bodies which include enforceable and effective data subject rights.
  • The supervisory authority shall apply the consistency mechanism referred to in Article 63 in the cases referred to in paragraph 3 of this Article.
  • Authorizations by a Member State or supervisory authority on the basis of Article 26(2) of Directive 95/46/EC shall remain valid until amended, replaced or repealed, if necessary, by that supervisory authority. Decisions adopted by the Commission on the basis of Article 26(4) of Directive 95/46/EC shall remain in force until amended, replaced or repealed, if necessary, by a Commission Decision adopted in accordance with paragraph 2 of this Article.

Objection rights

For example, if you have subscribed to receive commercial emails from us, participated in promotional activities or transacted with us (requested a quote, bought our servicesproductstickets and other related services). You can easily unsubscribe from ASAPTICKETS.CO.UK marketing communications at any time by clicking on the “Unsubscribe” link included in the newsletter email/ sms or just change your subscription preferences.
Another example is a “soft opt-in” option. We will send a direct marketing if you requested a price quote or purchased our services and did not object the processing of your personal data for the direct marketing purposes.

Welcome to Asaptickets.CA Privacy Policy

Effective February 1st, 2020

Asaptickets.CA (“Asaptickets.CA”, “we”, “our”, “us”) respects your privacy and is committed to protecting your personal information. This policy describes our practices regarding personally identifiable information or personal data (“personal information/ PI”). This policy applies to our websites, applications, email, voice calls and text messages, and social media accounts(the “Platforms”). When you use the Platforms, you agree to the terms in this policy.

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Asaptickets.CA collects and processes your PI, including any PI you may provide through the Platforms, when you purchase a product or service or sign up to our newsletter.
It is important that you read this privacy policy together with any other privacy policy, notice or fair processing policy we may provide on specific occasions, when we are collecting or processing PI about you, so that you are fully aware of how and why we are using your PI.This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTACT DETAILS

Asaptickets.CA is the organization responsible for your PI. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the DPO using the details set out below.
Full name of the organisation: International Travel Network, LLC
Email address: privacy@asaptickets.ca

POLICY AMENDMENTS

We keep our privacy policy under regular review.
Asaptickets.CA might make minor amendments to this Privacy policy which shall not adversely affect your privacy, except if laws set otherwise.
In case of material changes Asaptickets.CA will definitely publish such amendments and amended policy on our website and, as far as possible, notify you either by email or by pop-up windows when you are using our Platforms next time.
Amendments shall enter into force on the Effective Date.
Actual version of the Privacy policy is published on our website.

DATA ACCURACY

When you give us PI, you are telling us, that the information is true, accurate, complete and current.
You are also telling us, that you have the authorization to provide it to us.
It is important that the PI we hold about you is accurate and current. Please keep us informed, if your PI changes during your relationship with us.

THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We may collect, use, store and transfer different kinds of PI about you which we have grouped together as follows:

  • Identifiers or Identity Data such as a first/ middle/ last name, alias, postal address, unique personal identifier (cookie), date of birth, online identifier Internet Protocol address, or other similar identifiers.
  • Contact Data includes (billing address, delivery address, email address and telephone numbers).
  • Commercial Information, including requested price quotes, products or services purchased or other purchasing or consuming histories or tendencies, as well as Financial Data (bank account and payment card details) and Transaction Data (details about payments to and from you and other details of products and services you have purchased from us).
  • Network Activity Information, including, but not limited to Technical Data (your login data, browser type and version, browsing history, search history, time zone setting and location, browser plug-in types and versions, operating system and Platform, and other technology on the devices you use to access our Platforms), and information regarding your interaction with our Platforms (Usage Data).
  • Geolocation data (country, state or city).
  • Audio (e.g. call records) and Electronic (e.g. email threads) information .
  • Inferences (conclusions) drawn from any of the PI collected by Asaptickets.CA, including, but not limited to Profile Data (your preferences, characteristics, psychological trends, behavior, attitudes, intelligence, feedback and survey responses) and Marketing Data (your preferences in receiving marketing from us and our partners and your communication preferences).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your PI, but is not considered PI in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Network Activity Information to calculate the percentage of users accessing a specific Platform feature. However, if we combine or connect Aggregated Data with your PI, so that it can directly or indirectly identify you, we treat the combined data as PI which will be used in accordance with this privacy policy.
Customer support If you choose to contact our customer support services we will collect any inquires, complaint or other information that you may submit to our support team.
We do not collect any Special Categories of PI about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

CHILDREN

Asaptickets.CA does not knowingly collect PI from minors, except if the minor is one of travelers. If we become aware that a minor is attempting to submit PI, we will remove this information from our records. If you are the parent/legal guardian of a minor who has given us PI, please contact us so we can delete it.

IF YOU FAIL TO PROVIDE PERSONAL INFORMATION

Where we collect PI required by law or under the terms of a contract, and you fail to provide that PI when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We use different methods to collect PI from and about you including through:
PI you give to us
We collect your PI directly from you (using life chat, online forms or via voice call/ messenger). Any contact data (emails, phones etc.) provided by you throughout any interaction will be treated as your personal contacts and saved in your profile for future communications, unless specifically requested not to be stored (one-time communication only). For example, when you provide us with your PI by requesting a quote, registering or booking travels, contacting our customer support. This includes PI you provide when you:
  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • give us feedback or contact us.
One of the main collection methods are VOICE CALLS

We have vested interest to ensure you have chosen the best possible option. Voice calls are an exclusive opportunity to provide you with an immediate customer support and disclose additional product features, you might not notice on website. Usually, we call back on your request. Sometimes there might be unfinished conversations regarding current flights (misunderstanding in live chat, email system error, poor internet connection etc.), which require immediate response. We don’t make unwanted telemarketing robocalls or any annoying advertising campaigns. You can opt-out this communication any time by contacting us via phone or email.

PI we collect passively We also collect your PI passively. For example, we collect information about you over time and across different Websites when you visit the Platform. We also use tracking tools like cookies and beacons. As you interact with our Platforms, we will automatically collect Network Activity Information about your equipment, browsing actions and patterns. We collect this PI by using cookies and other similar technologies. For additional information, please, refer to our Cookie policy.

Platform features may make use of your device attributes and settings that will allow us to determine your physical location (country, state). Such technologies may include IP address mapping or other technologies. We use this information to enhance and personalize your experience and provide you with offers and services that may be of interest to you. Asaptickets.CA does not have control over your device settings, but we do recommend enabling location services on your device so you can take advantage of the location based features and functionality offered.
PI we receive from service providers: We collect your PI using service providers. This can include when you log in using a service provider platform, such as Facebook. In addition, we also integrate service providers' software that collects information about users for security reasons.

FOR WHAT PURPOSE WE USE YOUR PERSONAL INFORMATION

We will use your PI for the following purposes:
Improving our services To provide you and improve our Platforms and services, to better understand the users of our Platforms and services, and to protect our property and to prevent damage to them.
Regular customers
If you have ever requested a price quote or purchased our services, we treat you as the Regular (loyal) Customer. Regular Customers have plenty of benefits:

  • become experts of using our services;
  • receive the most relevant price quotes.

According to our policy, we may contact you as a Regular Customer via email/phone saved within previous requests and transactions. Such cases may be, for example, when you have accidentally provided the wrong email/phone or when you cannot be reached via email/ phone left in the last request/ purchase. If you want to opt-out, please contact us.


Bookings We and our travel partners use your PI to process your bookings and store your itinerary information where applicable.


Marketing activities
We use your information for marketing purposes. These activities may include:
  • To send you marketing emails and/or text messages from Asaptickets.CA address regarding our services or those of our partners, if you have opted-in to receive emails and/or text messages from us or have transacted with us, and as permitted by law. You can easily unsubscribe from these marketing communications at any time by clicking on the “Unsubscribe” link included in the newsletter or by texting STOP via sms.
    To display more relevant advertising and recommendations, or suppress advertising and content that you might find irrelevant. This advertising might be shown to you on our Platforms as well as third party platforms (including Google and social media sites like Facebook) and include information or offers that we, or our business partners’, believe you will find interesting. Individualized advertising may be based on information collected through cookies or other tracking technologies. You can opt out from from Google (press here) and Facebook (press here) ad personalisation any time.
  • If you choose to participate in promotional activities, relevant information may be used to administer these promotions.

To communicate with you, including as follows:

  • To send booking confirmations;
  • To send alerts and notifications you have subscribed to, including to your mobile device;
  • To solicit reviews;
  • To update you regarding itineraries processed by our service;
  • To communicate with you if you have contacted Asaptickets.CA customer support;
  • To send you information servicing and administrative emails;
  • To send you information about services, offered by Asaptickets.CA or our business partners, that we believe you would be interested in;

Legal purposes In certain cases we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance or to enforce the terms of use of the service.
Performance of a contract The use of your PI may be necessary to perform the services and provide you products that you have requested from us. For example, if you make a booking on our Platform, we need to collect PI from you in order to complete the booking.
Consent We may rely on your consent to use your PI for certain direct marketing purposes. You can withdraw your consent anytime by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your PI.


PurposeActivity Category of PI
To assist in purchasing air tickets and related travel products (car rentals, hotel booking etc.) - Main Activity, to provide an assistance requested by you or otherwise perform contractual obligations To register you as a new or a Regular customer/ to start a business relationshipA. Identifiers
B. Contact Data
C. Audio/Electronic information
To process and deliver your order related to the Main Activity, including:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
(c) Providing to you post-sale customer support
A. Identifiers
B. Contact Data
C. Commercial Information
D. Inferences
E. Audio/Electronic information
For solely internal uses that are based on your relationship with us or compatible with the context in which PI was collected To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(c) sending holiday greetings
A. Identifiers
B. Contact Data
C. Inferences
D. Audio/Electronic information
To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youA. Identifiers
B. Contact Data
C. Commercial Information
D. Network Activity Information
E. Inferences
To use data analytics to improve our Platforms, products/services, marketing, customer relationships and experiencesA. Network Activity Information
To make suggestions and recommendations to you about goods or services that may be of interest to youA. Identifiers
B. Contact Data
C. Commercial Information
D. Network Activity Information
E. Inferences
To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity To administer and protect our business and Platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) A. Identifiers
B. Contact Data
C. Network Activity Information
D. Audio/Electronic information
To identify and repair errors that impair existing intended functionality To administer and protect our business and Platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)A. Identifiers
B. Contact Data
C. Network Activity Information
D. Audio/Electronic information
To comply with a legal obligation (a) To manage tax matters;
(b) Bookkeeping and accountancy of transactions;
(c) To manage consolidated reports and annual financial reports
(b) To comply with the requirements of licenses, registrations and permissions obtained by Asaptickets.CA, including industry standards (airline safety rules, PCI DSS etc.)
A. Identifiers
B. Contact Data
C. Commercial Information
D. Audio/Electronic information
To exercise or defend legal claims (a) To manage complaints
(b) To comply with requests, subpoenas and other enforcement notices issued by regulators, courts and law enforcement agencies
(c) To protect and exercise legal claims of Asaptickets.CA before court, authority or law enforcement agency
A. Identifiers
B. Contact Data
C. Commercial Information
D. Network Activity Information
E. Inferences
F. Audio/Electronic information
G. Geolocation data

CHANGE OF PURPOSE

We will only use your PI for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

YOUR CHOICES

As a customer-oriented business we respect and value your expectations.
As a result, you are able to make announcements and queries at any time regarding your concerns in privacy matters.
Each of our marketing email has an opt-out button and you can change preferences or unsubscribe at all from such communication at any time. Each affiliated ASAPTICKETS website, including ASAPTICKETS.CA, is targeted to the current audience and region, therefore subscribe/ unsubscribe options are also different.
You cannot unsubscribe from servicing emails and administrative messages.

HOW WE SHARE YOUR PERSONAL INFORMATION

Corporate affiliates and change of control We may share your PI with our corporate affiliates and if Asaptickets.CA itself (or part of its business) is sold or otherwise changes control, owners would have access to your PI for the uses set out herein.
Service providers We may share your PI with suppliers who perform services on our behalf and have agreed in writing to protect and not further disclose your information.
Payment service providers and travel vendors If you book through the Platforms, we may share your PI with the payment service providers, acquirer banks and the travel vendors you have booked with. This can include online travel agencies, hotels, airlines, car rental companies, and travel insurance providers. These third parties will process your PI as data controllers in accordance with their own privacy policies. If you contact our customer support, they may need to share information about your request with the relevant travel vendor in order to assist you.
Business partners We may share your PI with various business partners. Some of these business partners may use your PI for fraud detection, including, but not limited Identifiers, Contact Data and Network Activity Information , also to detect, prevent, or otherwise address fraud, security or technical issues. We may also share your PI to ask our partner to create a survey, form, application, or questionnaire, so we know the degree of your satisfaction with our services. Some of these business partners may use your PI for online behavioral advertising purposes, or to offer you services or products that we believe you may be interested in. We may also share your information as otherwise described to you at the time of collection. We may also share anonymous aggregated usage information with partners.
We enter into confidentiality and PI processing terms with partners to ensure they comply with high levels of confidentiality and best practice in privacy and security standards and we regularly review these standards and practices.
Trips shared by you If you use or have itineraries as part of our Service, you can send or grant access to your itinerary to anyone you choose. Your itinerary may contain enough details (for example, booking reference codes) to allow the recipient to cancel or modify your booking, perform a check-in, etc. You should only share your itinerary with people you trust. If you choose to display your itinerary on publicly-viewable web pages (Facebook, for instance), that information may be collected and used by others.
Information shared in public If you provide us a review of your trip, you authorize us to publish it on all our Platforms under the screen name you provided. You also authorize us to aggregate it with other reviews.
Authorities We may disclose PI if required by law, for example to law enforcement or other authorities. This includes court orders, subpoenas and orders arising from legal processes, and administrative or criminal investigations. We may also disclose your PI if the disclosure is necessary for the prevention, detection or prosecution of criminal acts or to prevent other damage, or in response to a legal action or to enforce our rights and claims.
We may also share anonymous aggregated usage information with others.

HOW WE STORE AND PROTECT YOUR PERSONAL INFORMATION

Our servers and data centers are located in the U.S and our service providers may be located there and in other countries. By providing us PI, you agree that your PI may be transferred to and stored in these countries. These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your PI may be subject to access requests from governments, courts, or law enforcement in those countries according to laws in those countries. Subject to the applicable laws of such countries, we will provide the necessary safeguards to maintain protections of your PI, e.g. by obtaining from the PI recipients contractual commitments based on the EU model clauses.
Asaptickets.CA has a security program intended to keep the PI stored in our systems protected from unauthorized access and misuse. Our systems are configured with data encryption, or scrambling technologies and firewalls constructed to industry standards. We also use Secure Socket Layer (SSL) technology that protects the PI you send over the Internet. PI may only be accessed by persons within our organizations, or our service providers to carry out the uses indicated in this Privacy Policy.
We have put in place appropriate security measures to prevent your PI from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your PI to those employees, agents, contractors and other service providers who have a business need to know. They will only process your PI on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected PI breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

RETENTION PERIODS

We will only retain your PI for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your PI for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for PI, we consider the amount, nature and sensitivity of the PI, the potential risk of harm from unauthorised use or disclosure of your PI, the purposes for which we process your PI and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

OTHER WEBSITES

If you click through to third party websites or other platforms, Asaptickets.CA privacy policy does not apply.

REQUESTS AND COMPLAINTS

Under certain circumstances set by applicable law, including the Personal Information Protection and Electronic Documents Act, you are entitled to:

  • Request access to your PI (commonly known as a “data subject access request”). This enables you to be informed of the existence, use, and disclosure of your PI and access to that information.
  • Request correction of the PI that we hold about you. This enables you to request any incomplete or inaccurate PI to be corrected, though we may need to verify the accuracy of the new PI you provide to us.

Due to the remote nature of our services, it is important for us to keep communicating through the same email (Verified Email), which was used by you to request a price quote or purchase air tickets and other related services.
The Verified Email is the key communication channel for us, so we can give quick answers and not divulge your data to any malicious person.
You might also submit a request through the voice call, but still we must use the Verified Email to reply, due to law requirements and in order to protect our legal claims.
If you submit your request through the authorised agent or by using third party service we will ask for additional verification by contacting you via Verified Email.
NONDISCRIMINATION: We shall not discriminate (deny services, charge different prices, provide different levels of quality) against you because you exercised any of the rights set herein.
This right might be limited in case, if the difference in prices or levels or quality is reasonably related to the value provided to you by your PI.
We might obtain your opt-in consent and provide you financial incentives, so you agree to provide additional PI or not to request the deletion of your PI.
FEES and DENIALS: You will not have to pay a fee to access your PI (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive (more than twice in a 12-month period) or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We might also refuse to act on your request, when we are not in a position to identify you and verify your request or the requested fee was not paid.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your PI (or to exercise any of your other rights). This is a security measure to ensure that PI is not disclosed to any person who has no right to receive it. We may also contact you (via email, phone or messenger) to ask you for further information in relation to your request to speed up our response.
In certain situations, we may not be able to provide access to all your PI we hold about you. The reasons for denying may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
TERMS: We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. The maximum response time shall not exceed 60 days.

CONTACTS: you can submit your complaint/ request to DPO email (see above).

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