LAKEVIEW MANAGEMENT INC.

CANADIAN CUSTOMER PRIVACY POLICY

AND INFORMATION PRACTICES STATEMENT

Introduction

We at Lakeview Management Inc. (“LMI”, “we” or “us”), which owns and manages hotels in Canada under the names (see schedule A), and which also sells vacation ownership under the name Lakeview Resort Vacation Club, recognize the importance of protecting the privacy of Personal Information collected online or offline by us about the guests, visitors and prospective guests of our hotels and purchasers of our vacation ownership (“Customers” or “you”).  This policy explains how we treat Personal Information provided to us by individual hotels and franchisees.

We have adopted this Canadian Customer Privacy Policy to guide how we utilize Personal Information about Customers.  “Personal Information” means information about an identifiable individual, and includes names, telephone numbers, addresses, e-mail address, credit card numbers, and related credit and transactional information and certain other personal information Customers may provide to us by any means, including through our websites, by e-mail, telephone, fax or mail. This Policy will evolve and change as we continue to study privacy issues and as the appropriate legislation develops over time.

Contents:

About This Policy

Consent/Opt-Out

Contacting Us

The Information We Collect

How We Use Your Personal Information

Limiting Collection, Use, Disclosure and Retention

Security

The Internet

Compliance with Law

Correction/Access

Downloading

Policy Changes

 

About This Policy

Our purpose in establishing this Policy is to advise you of the policies and information practices we follow in collecting, storing, using and disclosing Personal Information. This Policy is designed in a manner that recognizes both the right of privacy of individuals with respect to their Personal Information and our need to collect, use or disclose such Personal Information for purposes that a reasonable person would consider appropriate under the circumstances.

 

When Personal Information is sent by an individual hotel or franchisee to us as described in this policy, it will be treated in accordance with this policy as described below.

 

Consent/Opt-Out

Except as otherwise permitted or required by law, we will not collect, use, or disclose your Personal Information without your consent. Generally, by providing us with your Personal Information, you are communicating your consent to our collection, use and disclosure of such information for the purposes for which you provided the information to us, and as described in this Policy.  However, you will, at the point of collection of the Personal Information, and from time to time thereafter, be given the option of “opting in” to, our collection, use and disclosure of your Personal Information for certain other purposes by signing a form, checking a box on a form, clicking on an icon (or via a similar electronic method) on our websites, or by contacting us as described below. If you do not want us to collect your Personal Information or use it for purposes other than as necessary to fulfil your request, please use the “opt out” option so that your information is not collected or used. If you have submitted Personal Information to us and wish to later opt out or withdraw your consent to its retention, use or disclosure, please contact us using the methods described below. You may opt out or withdraw your consent, subject to legal or contractual restrictions, at any time and on reasonable notice.

 

Customers can elect to opt out from any or all of the following communications from us:  (1) Mail – e-mail and direct mail; (2) Phone -telephone and fax solicitation; or (3) Contact – all communications including e-mail, direct mail, fax and telephone.  In addition, Customers can opt out of further e-mail communications by following the directions included in our e-mail communications.

 

You should keep in mind that if you refuse to consent to, opt out of, or withdraw your consent to our collection, use and/or disclosure of your Personal Information that is necessary to fulfilling your request, we may not be able to offer you certain goods, services and benefits which you may want to take advantage of.  Also, refusing to provide us with certain information may prevent us from providing the hotel services you are requesting.

 

Contacting Us

A Customer may also contact us through the methods stated below for a number of other purposes, including: (1) to opt-out of communications as described in “Consent/Opt-Out” above; (2) to receive information or special offers; (3) to provide feedback and comments on this Policy; (4) to request access to or correction of the Customer’s Personal Information; and (5) to make inquiries or complaints regarding our Privacy Policy and/or privacy practices:

 

By e-mail:

privacyofficer@lakeviewhotels.com

 

 

By mail, phone or fax:

Privacy Officer

Lakeview Management Inc.

600-185 Carlton Street

Winnipeg, Manitoba

R3C 3J1

Phone:  204-947-1161

Fax:      204-957-1697

 

The Information We Collect

Individual hotels and franchisees send to us certain Personal Information collected in connection with your hotel stay, including the name, address, telephone number, e-mail address (if provided) and transaction detail (what goods and services were charged on the hotel bill and the method of payment).

 

In addition, we may collect, use or disclose Personal Information that you voluntarily provide to us for the purposes described under “How We Use Your Personal Information”, including Personal Information submitted by visitors to our websites.

 

How We Use Your Personal Information

With your consent, we may use your Personal Information for various purposes as described below.  Except as otherwise permitted or required by law, or as may otherwise be noted in this Policy, Customers will be given the opportunity to opt out of or opt in to use of their Personal Information for secondary purposes when Personal Information is collected, and at any time thereafter by contacting us as described in the Consent/Opt-Out section. We may use third party service providers to perform services on our behalf, and we provide Personal Information to such providers solely for the specific services that they are performing.  These service providers are prohibited from using or disclosing Personal Information for any other purpose.

Reservations/Hotel Stays.  When a Customer calls our hotels, reservation centre or contacts us via the Internet, fax or via other means about hotel reservations, we need Personal Information to respond to the inquiry and to make the reservation. This Personal Information is sent to the hotel where the reservation is also recorded.  Personal Information regarding your reservation or hotel stay may be used for the purpose of processing your reservation or other requests, administering, managing and auditing various aspects of our business, administering our customer loyalty programs, and to meet legal, regulatory, security and processing requirements.

Promotions.  With your consent, we may use and disclose Personal Information that is sent by a hotel to us in order to solicit additional hotel stays at the same hotel and other locations and participation in various affinity programs, and to offer you benefits such as offers, rewards and discounts, goods and services that we believe are relevant to your interests.  We believe that our Customers benefit from promotional activity offered by and through us.  In addition, Customers interested in enrolling in affinity card or loyalty club programs run by us or our affiliates may consent to have Personal Information provided to designated affinity credit card issuer(s) and loyalty club providers for use in the preselection process for these programs.  Customers will be given the opportunity to opt in or opt out of such promotions, disclosures and affinity/loyalty enrollments at the time your information is collected.

Contests.  Occasionally, we may run contests.  We use Personal Information provided for hotel reservations only if the Customer consents to use of such information for these contests.  Customers will be given the opportunity to opt out of use of their Personal Information for these contests when providing this information for hotel registration, and may opt out at any time by contacting us as described above in the Consent/Opt-Out section. Customers may also sign up for these contests at participating hotels, in which case the Customers who participate or enter will be asked to provide Personal Information, such as the Customer’s name, address, telephone number or e-mail address. If a Customer participates in a contest, his/her Personal Information may be used to reach him/her about the contest, and for other promotional, marketing and business purposes.  All contest entry forms will provide a way for participants to opt-out of any communications from the contest’s manager or administrator that are not related to awarding prizes for the contest.

 

E-mails.  We will ask each Customer to submit their e-mail address for the primary purposes of sending reservation confirmations to our guests when your request is made online or when you otherwise request e-mail confirmation. However, Customers can also consent to our disclosure of their e-mail addresses to our individual hotels, our affiliates and/or selected third party partners with whom we have a marketing relationship so that the Customers can receive e-mail offers from these parties regarding their own products and services.  At any time, a Customer may opt-out of receiving e-mail communications by following the directions posted in the e-mail communications or by following the contact instructions described above in the Consent/Opt Out section.

 

Direct Mail/Outbound Telemarketing.  Customers who supply us with Personal Information may receive periodic mailings or phone calls from us with information on new products and services or upcoming special offers/events.  Customers may also receive mailings/calls from third parties we select whom we believe offer potentially valuable goods or services. We will only disclose your Personal Information to these third parties with your consent.  Customers will be offered the option to decline or opt out from these communications at the time the information is collected.  Customers may also contact us to opt-out of such communications as described above in the Consent/Opt-Out section.

 

Research/Survey Solicitations.  From time to time we may perform research (online and offline) by conducting surveys of our Customers.  Participation in these surveys is voluntary, and the information collected will be used for research and reporting purposes and to help us to better serve Customers by learning more about their needs. We may contact a Customer to inquire or survey about the guest experience at the individual hotel visited and the prospect of future stays or the improvements needed to attract additional business from the Customer for the hotel visited or our other hotels/restaurants.  The survey responses may also be used by us to determine the effectiveness of our websites, various types of communications, advertising campaigns, and/or promotional activities.  We may also share and disclose aggregate data to other parties for anonymous research, statistical, and analysis purposes.  Participants who do not wish to receive e-mail or other communications, including communications relating to surveys, will be provided the opportunity to opt-out of the receipt of such communication at the time of collection of their Personal Information or by notifying us as described above in the Consent/Opt-Out section.

 

Vacation Ownership.  When an owner or prospective owner of our vacation club contacts us, we need Personal Information to respond to the inquiry, to process the request or to engage in the selling of the vacation ownership product.  Personal Information provided in these cases may be used for the purposes of processing the inquiry, selling vacation ownership, administering, managing and auditing various aspects of the vacation club business and to meet legal, regulatory, security and processing requirements.

 

Other Uses of Personal Information.  In addition to the uses described above, we will use or disclose your Personal Information for certain general business purposes including the following: (1) Using Personal Information to enforce a contract with us or a franchisee or any Terms of Use of our websites; (2) Providing information on corporate credit card usage to the corporate card holder Customer directly or through third party service providers; (3) Transferring and/or disclosing Customers’ Personal Information to parties connected with the contemplated or actual financing, insuring, sale, or assignment or other transfer of the beneficial interest in some, all or substantially all of the assets of LMI, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties.

 

Limiting Collection, Use, Disclosure and Retention

We collect, use and disclose Personal Information only to the extent necessary to fulfill the purposes for which it was collected and as required or permitted by law.

 

Your Personal and Credit Card Information is retained on file to expedite reservations for future hotel stays following all statutory or regulatory and legitimate business requirements.

 

All credit card information retained is done so ensuring Payment Card Industry Compliance.  PCI compliance requires that all but the last 4 digits of the credit card number, card holder name and card expiry date be masked and not readable.  A customer may request their personal credit card information be deleted by making a request either verbally or in writing to the address located in the Consent/Opt-Out section of this document.

 

Security

We endeavor to protect your Personal Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our control. These measures include safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use and modification.

Although “guaranteed security” does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Policy and all applicable laws and regulations.  We maintain safeguards as appropriate to protect your Personal Information.  Access to your Personal Information is restricted to those of our (and our affiliates’) employees and agents who need such access to do their jobs and to fulfill the purposes for which the Personal Information was collected.

We take all commercially reasonable efforts to ensure that, to the extent we control the Personal Information, the Personal Information is used, accessed and disclosed only as authorized by us consistent with this Policy, and to prevent unauthorized modification or destruction. Our information protection practices and processes help us to maintain accurate, timely, complete and relevant information for our business purposes.  We use commercially reasonable efforts to maintain data security when data is transmitted through third party communication service providers, which includes reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

The Internet

On our websites we do not collect Personal Information from Customers unless they provide it to us voluntarily and knowingly. When you reserve a room with us on the Internet, we will capture information such as name, address, telephone number, e-mail address, and credit card number and related transactional information to process your reservation.  The primary purpose of capturing the e-mail address is to send a reservation confirmation to the reserving guest.  However, the Personal Information may also be used to send Customers e-mail offers from us and select third party partners, when the Customer has consented to such communications as described in the “Email” section above. Information provided on the Internet is treated the same as that collected offline, and we will only use it for other purposes, such as contests, promotions or surveys, where the Customer has consented as described above.

 

Third Party Websites.  Third party websites (i.e. websites not affiliated with or controlled by us or our affiliates) that you may access through links, banners and/or other means of electronic connection on our websites may have their own separate terms of use, privacy and data collection practices, and security measures. We have no control over these third party websites and no responsibility or liability for the practices, policies, terms and security measures implemented by third parties on their websites. Your interaction with these sites will not be governed by this Policy or the terms of use of our websites. In addition, these third party websites may have content, advertising, banners, links, sponsors, partners and connections over which we have no control and no responsibility. We do not endorse or approve the content, terms of use, privacy policy, advertising or sponsors of any linked website.

 

Aggregated Non-Personal Information.  Like many other Internet sites, we may automatically collect certain non-Personal Information regarding our Customers, such as software client information (for example, IP addresses) and aggregate information (for example, number of pages accessed) in order to analyze Web traffic and usage trends, and to enable us to tailor content and services to provide a better fit to our Customers’ needs. We may use IP addresses to identify you when we feel it is necessary to enforce compliance with our website Terms of Use, to comply with applicable law, or to protect our service, website, users and others.

 

Cookies.  We may place a “cookie” on your web browser.  A cookie is a very small text file that is sent to a Customer’s browser from a web server and stored on the Customer’s computer hard drive. It assigns the computer a unique identifier.  The cookie stores information on your hard drive so we can communicate with you more efficiently, respond to you based on prior sessions at which you provided information about you or your preferences to us and understand what you prefer to view on our websites. Cookies do not tell us your individual identity or passwords unless you have chosen to provide these to us, for example where you are using the website to request a reservation. Your browser may be set to allow you to be notified when a cookie is to be placed on your browser, decline the cookie or delete cookies that have been placed on your browser. Some functions of our websites, such as online hotel reservations, may not work or may work slowly if a cookie is refused or deleted.

Our websites may use third party service providers to serve and host our advertisements. These third parties may place cookies on your computer if you click on the advertising. The third party cookies may be used to (among other things) track whether the site was accessed from the advertisement. We do not control these third party cookies, so they may not follow this Policy or the rules we have set for our own cookies. If you do not want to activate these third party cookies, do not click on the advertising.

Our websites may also use invisible pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate without the use of a Customer’s Personal Information.

 

Compliance with Laws

We may be permitted or required by law to collect, use or disclose Personal Information about you without your consent for certain purposes or under certain circumstances, including, but not limited to, disclosure to a law enforcement agency, response to a court order, under the discovery process in litigation and prosecution, or collecting a debt which you owe to us, an affiliate or to a franchisee.

 

Correction/Access

We make efforts to ensure the accuracy of Personal Information we use to fulfil your requests and for purposes for which you have consented, and to correct and update our database as necessary for the stated purpose. In the event a Customer notifies us that such Personal Information held by us is inaccurate or outdated, we will, where appropriate and upon notification and given sufficient time for verification, take all reasonable steps to correct any inaccuracy or update outdated information of which we are made aware. In addition, we will update Personal Information we store and provide it to the third parties described in this Policy when you indicate the information has changed, such as changes of address or e-mail address, (a) in response to your request and/or (b) in order to fulfill the purpose for which such Personal Information was collected, and/or as otherwise required by law.

You may request access to your Personal Information in our possession by writing to us at the address provided above. We establish and maintain a file of Personal Information for each Customer.  Only our authorized employees and agents who require access to your Personal Information to fulfil their job requirements will have access to your file.  If you wish to access your file or make corrections to it, please contact us as described above.   In some limited circumstances, we may not be able to grant you access to your Personal Information, for example if doing so would threaten the security of another individual.

 

Downloading

Please feel free to download or make a copy of this Policy. You may obtain a copy free of charge by writing to us at Privacy Officer, Lakeview Management Inc., 600-185 Carlton Street, Winnipeg, Manitoba, R3C 3J1, requesting a copy of our Canadian Customer Privacy Policy.

 

Policy Changes

We may change or terminate this Policy at any time without prior notice.  We will post any Policy changes to our websites to notify you of these changes and provide you with the ability to opt out of any new, unanticipated uses of Personal Information not previously disclosed in the Policy. Any such changes shall be effective immediately upon posting. Your continued use of our websites and/or provision of your Personal Information after such posting constitutes your acceptance of these changes.  Please check our Policy periodically, or contact us as described above, if you are concerned about how your Personal Information will be used.  This Policy was last updated on February 3, 2011.

 

 

 

Schedule “A”

 

The following hotels are owned or managed by Lakeview Management Inc.

British Columbia
Lakeview Inns & Suites – Fort St. John
Lakeview Inns & Suites – Chetwynd
Lakeview Inns & Suites – Fort Nelson
Four Points by Sheraton – Prince George

Alberta
Lakeview Inns & Suites – Drayton Valley
Lakeview Inns & Suites – Edson Airport
Lakeview Inns & Suites – Fort Saskatchewan
Lakeview Inns & Suites – Okotoks
Lakeview Inns & Suites – Whitecourt

Manitoba
Lakeview Gimli Resort
Lakeview Hecla Resort
Lakeview Inns & Suites – Brandon
Four Points by Sheraton Winnipeg Airport
The Grand Winnipeg Airport Hotel by Lakeview