Last updated January 12, 2022

In this Privacy Policy, “we”, “us”, “our” and “ours” means Barrier Bay Resort, and “you” means (and “your” refers to) anyone who provides personal information to us, and their successors, heirs, administrators, executors and assigns (as the case may be).

We have adopted this Barrier Bay Resort Privacy Policy (the “Privacy Policy”) to explain how we will meet our responsibilities with respect to the information you provide to us. This Privacy Policy applies to both individuals and organizations, from whom we collect personal information.

The principles that form the basis of this Privacy Policy are interrelated and Barrier Bay Resort adheres to all of the principles as a whole. Each principle should be read in conjunction with the accompanying commentary. As permitted by Personal Information Protection and Electronic Documents Act (“PIPEDA”), the commentary in this Privacy Policy has been drafted to reflect privacy issues specific to Barrier Bay Resort. We will continue to review this Privacy Policy to make sure that it remains current with exceptions, changing technologies, industry standards and applicable laws.

1.    Scope and application

This Privacy Policy applies to personal information, in any form, collected, used or disclosed by Barrier Bay Resort in the course of commercial activities. It will not typically apply to information directly regarding Barrier Bay Resort’s corporate clients. However, such information may be protected by other Barrier Bay Resort policies and through contractual arrangements.

This Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Barrier Bay Resort:

• information about an individual that is publicly available and is specified by regulation pursuant to PIPEDA;
• personal information that is not collected, used or disclosed, for commercial purposes;
• non-personally identifiable information; and
• the name, title, business address or telephone number of an employee of an organization, where collection, use or disclosure of such information is solely for the purpose of communicating with the person about their employment, business or profession.

The application of this Privacy Policy is subject to the requirements and provisions of PIPEDA, and any other applicable legislation or regulation. If you reside in British Columbia, Alberta or Québec, then the substantially similar provincial privacy law of your province will apply to our handling of your personal information, rather than PIPEDA. In that case, reference in this Privacy Policy to PIPEDA shall be deemed to include your province’s substantially similar privacy law.

2.      Definitions

 collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. The form of consent we seek may vary, depending upon the circumstances and the type of personal information. In determining the form of consent, we take into account the sensitivity of the personal information and your reasonable expectations. Consent may be provided directly by you, or by your authorized representative, in accordance with applicable law.

disclosure: Making personal information available to a third party.

employee: An employee of, or an independent contractor to, Barrier Bay Resort. The inclusion of independent contractors within the definition of “employee” is for convenience of reference only, and should in no manner imply that such independent contractors are our employees within the meaning of employment legislation or are in an employee-employer relationship with us.

personal information: Information about an identifiable individual, but does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession, such as the individual’s name, position name or title, work address, work telephone number, work fax number or work electronic address. Where an individual provides their home address to Barrier Bay Resort as their business contact information, Barrier Bay Resort considers it to be business contact information, and is therefore not subject to protection as personal information. Information about corporations is not considered personal information.

third party: An individual or organization outside of Barrier Bay Resort.

use: The treatment, handling, and management of personal information by and within Barrier Bay Resort or by a third party with the knowledge and approval of Barrier Bay Resort.

3.      Accountability for our handing of personal information

Barrier Bay Resort is responsible for all personal information under its control and has designated the Barrier Bay Resort Privacy Officer to oversee privacy compliance. Other individuals within Barrier Bay Resort may be delegated to act on behalf of our Privacy Officer or to take responsibility for the day to day management of personal information. Barrier Bay Resort trains and communicates with employees about our privacy practices, including this Privacy Policy.

As appropriate, Barrier Bay Resort implements privacy policies and procedures to properly enforce this Privacy Policy, and we use contractual or other means to provide a comparable level of privacy protection while personal information is being processed or used by a third party.

4.      Reasons why we collect, use and disclose personal information

 Barrier Bay Resort collects personal information from you for the following purposes:

• to carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal or regulatory requirements;
• to notify you about changes to any products or services we offer or provide;
• to improve our products or services, marketing, or customer relationships and experiences;
• in any other way we may describe when you provide the information;
• for contests and giveaways; and
• for any other purpose with your consent, or as required or permitted by

Further reference to “identified purposes” mean the purposes identified in this section of this Privacy Policy.

We will indicate the identified purposes to you, orally, electronically or in writing, at or before the time your personal information is collected. Persons collecting personal information may explain the identified purposes or refer individuals to a designated person within Barrier Bay Resort who can explain these identified purposes.

5.      Collection of personal information

 If you request information, products or services from Barrier Bay Resort, we will collect your name, address, phone number, email.

You may also provide us your credit card information in order to pay for cabin rentals, equipment rentals. We collect this information only to process a deposit, and have on file for incidentals or damage that occurs.

Barrier Bay Resort collects and retains information about your transaction history when you use Barrier Bay Resort services and various programs.

Barrier Bay Resort may also provide individuals with an opportunity to specify certain preferences in respect of our products or services; if an individual chooses to provide such information, Barrier Bay Resort will collect and use your preferences. This     may include: allergies, scent free preferences, anniversary, birthday, honeymoon, engagement dates.

Barrier Bay Resort will only collect personal information that is necessary for the purposes identified in this Privacy Policy.

We collect no personal information about you unless you choose to provide that information to us. We do not use techniques that collect personal information about anyone without their knowledge. We only collect personal information about individuals when they specifically and knowingly provide it to us, for example when they “book a cabin or rent equipment”. As a limited exception to this principle, we may collect personal information without your consent, where permitted by PIPEDA and other applicable laws.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. You may contact us for more information regarding the implications of withdrawing consent.

6.      Consent for us to contact you about our products and services

The information you provide to Barrier Bay Resort – such as your name, address, etc. – allows us to inform you about openings, and cancellations and to notify you of issues, events or special offers which may be of interest to you. By sending in a request for booking, contact form, or entry in a contest (electronic or hardcopy), you are giving Barrier Bay Resort permission to contact you by way of the information you provide. Should you wish not to be contacted by Barrier Bay Resort – please email resort@barrierbay.com Subject: No longer Contact.

Disclosure of personal information

Barrier Bay Resort will not disclose personal information for purposes other than those purposes for which it was collected, except with your consent or as required or permitted by law. Barrier Bay Resort may disclose your personal information:

• when we have your consent, whether express or implied;
• to your authorized representatives;
• if and when we are involved in a corporate reorganization or if we sell or lease all or part of our business;
• to meet legal and regulatory requirements; and
• where required or permitted by

In such circumstances, we will not disclose more information than is required for the purpose for which the information is being disclosed. We will also, whenever it is reasonable and practicable to do so, enter into privacy agreements with third parties with whom we share personal information.

We will retain personal information only as long as it remains necessary or relevant for the identified purposes or as required or permitted by law. Where personal information has been used to make a decision about you, Barrier Bay Resort shall retain, for a period of time that is reasonably sufficient to allow for access by you, either the actual information or the rationale for making such decision.

Only our employees who require access for legitimate reasons or whose duties reasonably so require, are granted access to personal information.

We maintain reasonable controls, schedules and practices for personal information management retention and destruction. Personal information that is no longer necessary or relevant for the identified purposes, or is required by law to be retained, is destroyed, erased or made anonymous, as appropriate in the circumstances.

Barrier Bay Resort may share aggregate information – not personal information – about its clients, with other parties and related service providers, to help them better understand Barrier Bay Resort clients and their interests. Such aggregate information is used to give Barrier Bay Resort demographic data about its clients in order to improve the organization and the products and services we provide.

7.      Barrier Bay Resort Website

 Our website may use various technologies, from time to time, to:

• help us customize your experience on the site;
• track your use of our website for advertising, marketing, or promotional purposes;
• help us determine whether you opened an email message from us;
• gather information to deliver advertisements about products and services we think may be of interest to you;

This information enables us to: identify new areas of products/experiences, review current assets, identify areas of improvement.

 Your choices about how our website collects your information

We strive to provide you with choices regarding the personal information you provide to us.

You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using opt out tools created by Google Advertising, the Digital Advertising Alliance of Canada or by the Network Advertising Initiative. You may also opt out of our use of Google Analytics by visiting the Google Analytics opt out page. We may have reporting of your aggregate interactions with our ads across the Google Display Network or DoubleClick for Advertisers in conjunction with activity on our website.

You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

In addition, we have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this website may not be accessible or may not function
• Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by emailing Barrier Bay Resort (resort@barrierbay.com) with the Subject: don’t share.
• Promotional Offers. If you have opted in to receive certain emails from us but no longer wish to have your email address/contact information used by Barrier Bay Resort to promote our own or third parties’ products or services, you can opt out by contacting emailing Barrier Bay Resort (resort@barrierbay.com) with the Subject: stop advertisements. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
• If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by using the opt out tools created by the Digital Advertising Alliance of Canada, the Network Advertising Initiative or Google

8.      Accuracy of personal information

We make reasonable efforts to ensure that personal information we collect, use, or disclose is as accurate, complete and up to date as necessary for the purposes for which it is to be used. If you find any errors in our personal information holdings, we should be informed so that we can make the appropriate corrections. We will convey these corrections to any third party that may have been provided inaccurate information. For personal information that remains in dispute, we will make note in our records of your opinion as to accuracy of the relevant personal information.

9.    Security of personal information

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to prevent any unauthorized access, disclosure, copying, use, or modification of personal information. Safeguards include securing physical documents and technological measures by way of secure access and encryption. Barrier Bay Resort employees are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed.

We protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the personal information and the purposes for which it is to be used.

We may engage service providers to assist us with fulfilling the purposes for which personal information has been collected, used and disclosed, and, in some instances, these service providers may be located outside Canada. We only select service providers that protect personal information in a manner that is comparable to the protection we provide under our own privacy policies. However, personal information may be subject to, and accessed under, the laws of the countries in which our service providers operate. If you have any questions about our transfer of personal information to our service providers outside Canada, or if you would like to learn more about our privacy policies in that regard, please contact the Barrier Bay Resort Privacy Officer at the contact information provided below.

10.  Openness concerning our policies and procedures

We are open about the policies, procedures, and practices we use to protect your personal information. Information about these policies, procedures and practices will be made available to you either electronically or in writing.

11.  Access to your personal information

You may access any personal information that we have concerning you, and which has been collected, used or disclosed for a commercial purpose, by sending a written request to the Barrier Bay Resort Privacy Officer. Barrier Bay Resort may advise you in advance if there is a minimal charge to conduct a search of our records and will respond within 30 days, or advise that the request for access is subject to an extension as authorized by PIPEDA.

To protect your privacy, you may be required to provide sufficient identification, in order to permit us to account for the existence, use and disclosure of certain personal information and to authorize access to such information. Any such information will only be used for this purpose.

We may not be able to provide personal information to you if doing so would violate the privacy of a third party or if certain personal information is subject to legal privilege, contains information proprietary to us or a third party, is too costly to retrieve, or cannot be disclosed for other legal reasons. If we are unable to provide access to all or part of your personal information, we will explain our reasons for such a decision.

Where you have been provided with access to your personal information, you shall be able to challenge the accuracy and completeness of your personal information and have it amended as appropriate.

Personal information that is disclosed to third parties by us will be subject to the general laws applicable in the jurisdiction in which the third party conducts business. As a result, and in certain limited situations, we may not be legally permitted to account for certain collections, uses or disclosures of personal information. In most circumstances, however, we shall provide an account of the collection, use and disclosure of personal information and, where reasonably possible, we shall state the source of the personal information. In providing an account of disclosure, we shall provide a list of organizations to which we may have disclosed your personal information when it is not possible to provide an actual list.

12.  Challenging compliance with privacy laws

All questions or concerns regarding our privacy practices should be directed to the Barrier Bay Resort Privacy Officer.

We will investigate all complaints concerning compliance with this Privacy Policy and if a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending our privacy policies and procedures. We will inform you of the outcome of the investigation regarding your complaint.

13.  Contact Us

If you have any questions or concerns about this Privacy Policy or about Barrier Bay Resort’s information handling practices, please contact us at:

Attn: Privacy Officer

resort@barrierbay.com

204-348-7755

Please also visit the Office of the Privacy Commissioner of Canada’s website at https://www.priv.gc.ca/en/