At STS Travel Inc., respecting privacy is an important part of our commitment to our clients, our employees and the general public. When you participate in programmes conducted by our organization, you can be confident that any personal information that you share with us will stay with us. Any time you participate as a client, whether in person or by telephone, mail or Internet, you can be assured:

• That your individual responses will be kept confidential
• That your personal identifying information will never be sold to anyone

STS Travel reviews its Privacy Policy regularly to make sure that it is relevant and remains current with changing industry standards, technologies and laws. If you have any concerns about how your privacy is protected at STS Travel please contact maria@daCunhavoyages.com or by calling (905)-896-3636.

The STS Travel Privacy Policy has been drafted to reflect management of personal information specific to STS Travel. The application of the Privacy Policy is as follows:

• STS Travel Privacy Policy applies to personal information collected, used, or disclosed by STS Travel in the course of commercial activities
• STS Travel Privacy Policy applies to the management of personal information in any form whether oral, electronic or written
• STS Travel Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by STS Travel:
• Non-personally identifiable information;
  The name, title, business address and/or telephone number of an employee of an organization;
• Other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection Electronic Documents Act (Canada).

Personal information may be collected for the following purposes:

• STS Travel shall identify the purposes for which personal information is collected at or before the time the information is collected
• STS Travel collects personal information from the customer only for the purposes of executing the programme as requested by the customer
• When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use
• Unless the new purpose is permitted or required by law, the consent of the client will be acquired before the information will be used or disclosed for the new purpose
• STS Travel may provide clients or other third parties with information from any programme, in aggregate form. In aggregate form it is impossible to identify an

individual client‘s personal information.

Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of STS Travel. Implied consent is consent that can reasonably be inferred from an individual‘s action or inaction.

STS Travel is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party/supplier of services.

STS Travel collects personal information from the client only for the purposes of executing the programme as requested by the client. It may provide clients or other third parties with information from any programme, in aggregate form. In aggregate form it is impossible to identify an individual client‘s personal information.

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate. Participation by clients is always voluntary. When a client agrees to participate in a programme, he/she gives consent by participating in the registration or management of aforementioned programme.
STS Travel shall take into account the sensitivity of the personal information and the reasonable expectations of its clients.

STS Travel shall limit the collection of personal information to that which is necessary for the purpose identified by STS Travel. STS Travel shall collect personal information by fair and lawful means. We collect only the amount and type of information needed for the purpose identified to individuals.

STS Travel shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

STS Travel may disclose a client‘s personal information to a public authority or agent of a public authority if, in the reasonable judgment of STS Travel, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or to a third party or parties, where the client consents to such disclosure or disclosure is required or permitted by law.

Only STS Travel ‘s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about clients. STS Travel shall keep personal information only as long as it remains necessary or relevant for the identified purpose or as required by law.

STS Travel shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Personal information used by STS Travel shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a client.

STS Travel shall update personal information about clients and employees as necessary to fulfill the identified purpose or upon notification by the individual.

STS Travel shall protect personal information through security safeguards appropriate to the sensitivity of the information STS Travel shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

STS Travel shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purpose for which it is to be used.

All of STS Travel ‘s employees with access to personal information shall be required to respect the confidentiality of that information.

Upon written request, STS Travel shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

In certain situations, STS Travel may not be able to provide access to all the personal information that it holds about a client if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, it may not provide access to information if disclosure would reveal confidential commercial information.

For more information regarding STS Travel Privacy Policy, please contact maria.dacunha@ststravel.ca or by calling (905)-826-2872.

For additional information, please visit the Privacy Commissioner of Canada‘s website at https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/