Protecting privacy and maintaining the confidentiality of personal information is an essential priority for Les Investissements Nolinor Inc., doing business as OWG (hereinafter “OWG”). When you travel with OWG, we must collect your personal information in order to process your reservation, offer you a safe trip and provide you with an optimal experience on board.
The Policy has been drafted to comply with the requirements set out in the privacy laws and regulations. It completes the OWG Terms of Service, which you can find at the following address: 11600, rue Louis–Bisson. Mirabel (Québec) J7N 1G9.
- COLLECTION OF PERSONNAL INFORMATION
The Policy applies to all personal information collected by OWG and any information that can allow to identify you shall be considered personal information.
Information may be collected during any interaction with OWG, for example, when you visit the Site, communicate with OWG by email or participate in a contest organized by OWG. Information may also come from third party partners who provide services to you.
OWG may collect the following categories of personal information:
– Identification (name, date of birth, sex, nationality and passport number);
– Contact details (phone number, physical address and email address);
– Reservation details (date of travel, flight reservations, payment details; services booked with a third party);
– Trip details (travel itinerary, medical needs, check-in information, special dietary requirements, additional help required);
– Interactions (communications with OWG on social networks, by email or by phone);
– Usage of the Site and the mobile application (IP address, browser type, operating system, preferred correspondence language, surfing behavior, universal unique identifier and use of the application);
– Personal information deemed sensitive (origin, health, beliefs, previous convictions);
- METHODS OF COLLECTION AND USE OF THE INFORMATION
Your personal information is collected when you create an account on the Site or otherwise communicate with OWG. The personal information processed is limited to that necessary to achieve the following purposes:
– Management and improvement of the Site;
– Analytical purposes;
– Provision of services;
– Communication of promotional offers related to OWG services;
– Customer contact;
– Compliance with legal obligations;
– Detection or prevention of any attempted fraud, security issues or technical problems;
– Other purposes to which you consent.
OWG only uses personal information for the purposes for which it was collected.
You can object to the recording of these cookies by configuring your browser software. To do so, you must refer to the instructions of your browser. In the event that you choose to deactivate cookies, you can continue browsing the Site, but its operation may be affected. Any malfunction of the Site is not the responsibility of OWG.
By accessing the Site and continuing to browse, you acknowledge having read the information provided to you concerning these cookies as well as the means available to you to object to the registration of such files.
- SECURITY OF PERSONNAL INFORMATION
The personal information collected by OWG is kept in a secure environment and is inaccessible to the public. OWG employs technological, material and organizational processes to maintain the confidentiality of the personal information it holds and to protect it against loss, theft, transmission, access or unauthorized use. OWG is committed to maintaining a high degree of confidentiality by integrating the latest technological innovations to ensure the confidentiality of your transactions, to the extent possible.
To ensure the security of your personal information, OWG has namely put into place the following measures:
– Access to personal information is only granted to employees who reasonably need to access them in the performance of their duties;
– Training sessions about the importance of protecting personal information are offered to OWG’s employees;
– Issuance of directives outlining the roles and obligations of employees regarding the protection of personal information;
– Login information including a password;
Notwithstanding the foregoing and despite the goodwill of OWG, no mechanism for transmitting data over the Internet offers absolute security. Therefore, OWG cannot guarantee such security and cannot accept any responsibility for the use of your personal information by third parties who have intercepted it or gained access to it by hacking or fraud.
- PERIOD OF RETENTION OF PERSONNAL INFORMATION
OWG will retain personal information only to the extent that it remains useful or relevant for the purposes mentioned in the Policy or as required by law. Information that is no longer needed will be destroyed or anonymized.
- HOSTING OF PERSONAL INFORMATION
The Site is hosted by: P3F, whose head office is located at the following address: 11845 rue Irénée-Vachon Mirabel, Québec J7N 3L2.
Personal information collected by OWG may be stored or processed in Canada or abroad. It will be protected by appropriate measures but may be subject to the laws of the country where they are kept.
- DATA PROTECTION OFFICER
OWG’s Data Protection Officer is responsible for orchestrating the secure handling of your information and for ensuring the integrity and confidentiality of such information. He/she is committed to protecting the personal information collected, not transmitting it to third parties without advising you first and respecting the purposes for which the information was collected.
In addition, the Data Protection Officer undertakes to notify you in the event of rectification or deletion of your personal information, unless this entails disproportionate formalities, procedures or costs for him/her.
If the integrity, confidentiality or security of your personal information is compromised, the Data Protection Officer will inform you by any means necessary and as soon as possible.
For any questions, the Data Protection Officer can be contacted at firstname.lastname@example.org.
- TRANSMISSION OF PERSONAL INFORMATION
To ensure that it can provide you with the services you have requested, OWG may need to transmit your personal information to trusted third parties, namely:
– Government authorities and law enforcement agencies, such as airport authorities, customs and border services, to ensure the safety of passengers and to comply with legal requirements;
– Service providers whose services have been retained by OWG to perform certain functions, such as refueling agents, freight providers, reservation agents or airport assistance services;
– Any entity in the event of a sale, merger or change of control of OWG in whole or in part, only if the parties enter into an agreement whereby the collection, use and disclosure of the information is limited to the objectives of the business transaction;
– Other passengers listed on your reservation as part of the online check-in process;
– Providers of investigative services in the event of a personal information breach;
– Providers of technology services whose systems are used by OWG, including for conducting surveys, sending marketing communications or processing your reservations and travel;
OWG takes the appropriate measures, by contract or otherwise, to ensure that the third parties process personal information only for the purposes they determine and comply with the rules set out in the Policy. In addition, OWG requires the third parties to comply with the requirements of applicable privacy laws.
- YOUR RIGHTS
You have the right to object to the processing of your personal information by the Site. You also have the right to request that your personal information no longer appear, for example, in a mailing list.
In order to object to the processing of your personal information or to request its removal, you must send a request by email to the following address: email@example.com.
You can access your personal information or request its correction or deletion by submitting a written request to the above-mentioned email address. You can also access the information and modify it by directly logging into your personal account on the Site. OWG encourages you to keep your personal information complete and up to date.
Given the obligation of confidentiality in the processing of personal information, your requests relating to the exercise of one of your rights treated above will be processed only if you provide proof of your identity by producing copies of two valid identity documents.
- RIGHTS TO DATA PORTABILITY, RESTRICTION ON PROCESSING, OBJECTION AND DELETION FOR EEA RESIDENTS
If you reside in a member state of the European Economic Area (“EEA”), in addition to the rights detailed in Article 9, you can exercise your rights of deletion, limitation and opposition to processing and portability of your personal information in accordance with the General Data Protection Regulation. Fees may be charged by OWG to cover the administrative costs incurred in processing such requests.
As part of the services offered by OWG, you may receive emails and other communications on its behalf. Said emails are in addition to those you have requested to receive through your personal account settings. Communications relating to your account will be limited to the purposes related to the services offered, such as retrieving your password and notifications of important updates to OWG policies. You cannot refuse this type of communication unless you delete your personal OWG account.
- OTHER WEBSITES
The Site may provide links to other websites for your convenience and information. The other websites may have their own privacy policies, which OWG strongly recommends that you read. OWG is not responsible for the policies, content and practices of other companies.
OWG reserves the right to make changes to this Policy. Updated versions of the Policy will be posted on the Site and may be notified to users by email. Consequently, OWG invites you to regularly consult the Policy in order to stay informed of the latest changes that have been made. The use of personal information will be subject to the Policy in effect at the time of its collection.
OWG undertakes to comply with the legislative provisions set out in:
– Act respecting the protection of personal information in the private sector, CQLR c P-39.1;
– Personal Information Protection and Electronic Documents Act, (S.C. 2000, c. 5);
– General Data Protection Regulation, (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016.
OWG is committed to treating you with respect and providing you with an outstanding level of service. If you have any complaints, questions or concerns about the Policy, please contact the Data Protection Officer at the following email address: firstname.lastname@example.org.
Last update: August 21, 2020.