Privacy Policy

1. Background

This Privacy Policy (“Policy“) sets out how Accurate Flights (Canada) Inc. (collectively mentioned in this document as “Accurate Flights“, “we” “our” or “us“) safeguard the privacy of your personal data.

Accurate Flights is known as one of the world’s biggest travel agency. To perform our business activities and functions, including managing and making travel bookings on behalf of our customers, we need to gather, use and disclose personal data. We are totally devoted to safeguarding the privacy and secrecy of personal information and maintain several electronic, physical, and procedural shields to protect personal data in our care.

By giving us your personal information (either directly or allowing someone to do this on your behalf), you acknowledge that this Policy will apply to how we manage your personal data and you comply to us gathering, using and revealing your personal information as mentioned in this Policy. If you do not comply with any of part mentioned in this Policy, you must not give your personal data to us. If you do not give us your personal data, or if you pull back a consent that you have already given under this Policy, this may influence our ability to provide services to you or negatively impact the services we can offer you. For example, in order to book your flight, you must provide the traveller’s full name and must include contact details followed by appropriate identification (e.g. passport details). Bookings cannot be done without providing that data.

2. What type of personal information do we gather?

Personal information generally referred to as the data which is related to a living person who can be recognized from that information, or from that data and other data in a person’s possession, that includes any expression of opinion, whether true or false, and whether documented in material form or not, about an recognized or reasonably recognizable person, and any indication of intention in respect of a person.

Generally, the type of personal information we gather about you is the data that is required to ease your travel bookings and arrangements and to arrange travel related products and/or services on your behalf. For instance, we may gather details such as your name, credit/debit card details (including card type, security number, card number, and expiry date), passport details, information about your dietary requirements and health issues, residential/mailing address, telephone number, email address, loyalty program / frequent flyer details, and other details relevant to your travel arrangements or required by the concerned travel service provider(s) (e.g. airlines and hotel or tour organizers). When you make contact with us for other purposes, we may also collect personal data about you in relation to those purposes. For instance, if you have entered in a competition and you win or sent us a query, we need your personal information, so we can contact you to respond your query or let you know about the competition results. We also gather information that is needed for utilizing in the business activities of Accurate Flights and our related entities, including for example, financial details essential to process several transactions, footage of video surveillance cameras used for security purposes, and other important personal data you may admit to provide to us.

In some instances, we also gather personal data from you which may be looked at as sensitive information. Sensitive data may include (without limitation) things like your racial or ethnic origin, criminal record and the alleged commission of an offence, philosophical or religious beliefs or affiliations, biometric and genetic information, sexual preferences or practices, membership of political, professional or trade associations, passwords and financial information and health information, and any personal data relating to a child under the 13 years of age. We will only collect sensitive information in conformity with the applicable laws, with your approval and/or where it is reasonably essential for, or directly associated to, one or more of our functions or activities (e.g. to organize travel arrangements), unless we are otherwise required or accredited to do so by law. To the extent permitted or needed under the applicable laws, you agree to us for utilizing and disclosing your sensitive data for which it was gathered, unless we subsequently receive your acceptance to utilize it for some other reasons. For example, if you give us your health information in relation with a travel insurance application you would like to make, you agree to us for utilizing and disclosing that health data in connection with managing that travel insurance on your behalf. A further instance is if you reveal your religious opinions to us because you are curious in, for instance, some tour packages, in which case you give acceptance to us for using and revealing that data in relation with easing your request. We will never utilize your sensitive data for reason apart from those for which it was gathered, unless we subsequently receive your acknowledgment to use it for other reason.

3. When do we step up as agent for a travel service provider

Whenever we book and otherwise arrange for the travel related products and services, at that time we usually act as an agent or we do on behalf of travel service providers. In this scenario, most of the time we gather personal information about you both for the travel service provider for whom we act as agent for their internal purposes (for instance to give you the booked services) and for our internal purposes as mentioned in this Policy, that includes the purpose of us processing your booking request. As an agent, the bookings that are made on your behalf are subjected to terms and conditions, including the privacy policy, charged by these travel service providers. We will give you the duplicate copies of all the important terms, conditions and privacy policies of travel service provider on request.

Accordingly, you are deemed to agree to the gathering, utilizing and disclosure of your personal data by us to the concerned travel service providers, and the use and revelation of your personal information by the concerned travel service providers, for the reasons described in this Policy and, to the extent allowed under applicable laws, for other purposes mentioned in their privacy policy. For instance, if you are booking a flight via us, then as stated in this Policy you are giving us consent to gather your personal data and reveal that information to the airline in order to book your flight and for the airline to give the flight service to you, and, to the extent allowed under applicable laws, for other reasons mentioned in their privacy policy.

We play the role of an agent for or on behalf of many thousands of travel service providers across the world, so it is impossible for us to mention each one of the travel service providers for whom we act or about their locations in this policy. To get more information about the revelation of personal information to travel service providers situated overseas, please see to our section 7 (Is personal information transferred overseas).

If you have any doubts regarding the transfer of your personal data to a travel service provider, or you want to reach us for further information, please read our “Feedback / Complaints / Contact” section below.

4. How basically we gather your personal data?

Remember, we will gather personal information directly from you unless it is impracticable or unreasonable to do so. Mostly, this gathering of data will occur when you contact or deal anything with us either in person, by phone, when you visit any of our websites or when you connect with us via social media, letter, facsimile, email. Chances are that we may collect some personal information about you when you purchase anything from us or make enquiries about your travel arrangements or our other services and products. Or when you enter competitions or have subscribed for any type of promotions; when you registered with us to receive marketing materials from us; when you give information, or utilize our services, on social media platform; when you request brochures or other data from us. Unless you choose to do so anonymously, we may also gather your personal information (apart from the sensitive information) whenever you complete the entire surveys or give us your feedback about our services.

There may be instances when it becomes essential for us to collect your personal data from a third party. These things happen in a situation where an individual makes a travel booking on your behalf that includes travel arrangements to be utilized by you (e.g. a travel booking made for you by your employer, a family or group booking). When this thing happens, we will depend on the authority of the person doing the travel booking to act on behalf of any other traveller on the booking list. By agreeing to offering your personal information to us, either directly or via a family member, employer or some travel agent or representative in association with a travel booking or related service, you will be deemed to have agreed to your personal information being gathered by us and used and revealed in conformity with this Policy.

In cases, where you are making a travel booking on behalf of other person (e.g. it can be your family or group booking or booking for an employee), you agree, you have taken the acceptance of the other person for Accurate Flights to gather, utilize and disclose the other person’s personal information in conformity with this Policy. Plus, you have made the other person aware of this kind of policy. Immediately let us know if you become aware that your personal data that has been provided to us by some other person without your approval or if you did not taken approval before giving another person’s personal data to us.

5. How your personal information is used and disclosed by us?

In situation where you contact us for a travel booking or some kind of query, the primary purpose for which we gather your personal information is generally to assist you give you and/or give you travel advice with booking travel and/or travel related products and services. However, the reason for collecting your personal data may differ depending on the particular situations as mentioned in this Policy.

By regularly using our services and/or by giving us your personal data (or permitting another person to do so on your behalf), you agree to us for using and revealing your personal information for the reason for which it was gathered, and, where allowed by applicable laws, for any related secondary reason which we trust you would reasonably expect.

The reason for which we gather your personal information, and those secondary reasons which we consider to be directly related, includes the following:

• Offering you with services and tools you opt to utilize (for instance, preserving your travel choices on our website(s) to a Wishlist or saving your personal data to automatically fill your online forms);
• Recognize fraud or error;
• Regulatory reporting and conformity;
• Creating and improvising our products and services and those of our related entities;
• Maintaining our relationship with you by, among other things, creating and managing an individual profile to enable our brands so that they can service you better or offer various options on our web portal that we think may excite you depending on your browsing and choices;
• Involving your participation in the market research, evaluating customer satisfaction and seeking feedback based on our connection with you and/or the service we have provided;
• To make it easy for you to participate in loyalty programs;
• Internal accounting and administration;
• To be in accordance with our legal obligations and any applicable customs/immigration requirements concerning your travel;
• For research and analysis in connection to our business and services, including but not restricted to trends and choices in sales and travel destinations and utilization of our web portals;
• Other reasons as permitted or required by law (e.g. to hinder a threat to life, to enforce our legal rights, or health or safety).

Promotional/marketing material

We may use your personal data to send you targeted advertising activities concerning to our products and services (and of third parties too) that we think may excite you, unless you have asked us not to receive such data. These may include, but are not restricted to, electronic marketing (that also includes online targeted marketing) and notifications as mentioned below, and telephone calls). Your personal information will only use by us to send you electronic marketing materials (including e-newsletters, MSM and IM, email, SMS) if you have subscribed in to receive them. You can opt in to receive e-newsletters and lots of other electronic promotional/marketing materials by visiting the important links on our web portal or by asking one of our consultants to do that for you.

If you no longer want to receive promotional/marketing material from us, receive other types of communication from us, or participate in any type market research, please go to the “Feedback / Complaints / Contact” section below. You can opt yourself out anytime from receiving electronic marketing materials by clicking on the unsubscribe option given in your email, SMS, MSM, IM or other form of electronic marketing.

6. Is your personal data disclosed to third parties?

We may reveal your personal information to third parties, as mentioned below, and in conformity with our applicable laws. By regularly using our services and/or by giving us with your personal data (or permitting another person to do so on your behalf), you agree to that personal data being processed, moved and/or revealed by us for the reason for which it was gathered and, where authorized by applicable laws, for any related secondary reason which we trust you would reasonably expect. Remember that, in this Policy, where we say “disclose or reveal”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.

Your personal information may be revealed to the following types of third parties:

• Our service providers, contractors, and suppliers including without restriction:

o    In each of the situations mentioned in section 5 (“How do we use and disclose your personal information?”);

o    Suppliers of IT based solutions that help us in offering products and services to you (for instance any external data hosting provider(s) we may use);

o    Publishers, distributors and printers of marketing material;

o    Expo and event organisers;

o    Mailing houses, courier services, freight services; and

o    External business advisers (for instance lawyers, auditors, recruitment consultants and accountants,);

• Our concerned entities and brands;
• Travel service providers such as travel wholesalers, car rental companies, tour operators, transfer handlers, airlines, hotels, and other related service providers;
• A person doing ticket booking on your behalf, where you are travelling on a booking made on your behalf by some other person (for example, a family member, work colleague or a friend);
• A person who can confirm to us that they have a connection with you where you are not reachable, the person reliably replies to our important security questions and the request is, in our opinion (for instance, where that person is concerned for your welfare or can take action on your behalf in case of unforeseen circumstances);
• As needed or authorised by applicable law, and to conform with our legal obligations;
• Immigration and customs to conform with our legal obligations and any applicable customs/immigration conditions associated with your travel;
• Government agencies and public authorities, to conform with a legal and authorized request;
• Several regulatory bodies followed by law enforcement officials and agencies, in order to safeguard against fraud and for related security reasons; and
• Enforcement agencies where we doubt that illegal activity has been or may be engaged in and the personal data is a important part of our investigation or reporting of the concerned matter.

For more information regarding the collection of data by travel service providers and their privacy policies and practices, refer to the section above named, “When we act as agent”.

With respect to our contractors, service providers and suppliers, we take important and reasonable steps to make sure that those third-parties process personal data in conformity with our privacy policy and other obligations and to stop and restore any unauthorized processing. This includes getting into written contracts with each such third party restricting the third parties’ use of moved data to specified reasons, requiring them to give the same level of security needed by our privacy policy and other obligations and to inform us if they can no longer satisfy their obligations to provide such safety. If we share personal data with third parties offering services to us, we want that they only utilize such data received from us for their intended reason. We may remain responsible for the acts of third parties who provide services on our behalf for the management of personal data that we move to them.

Apart from that, we will not share your personal information without your acceptance unless we reasonably believe that revealing is required to lessen or prevent a threat to life, or for certain action to be taken by an enforcement body, or health or safety of a person or to public health or safety or where such disclosure is permitted or needed by law.

7. Is personal information moved to overseas?

We may share your personal data to some overseas recipients, as mentioned below, which we will do in conformity with applicable laws.

It is possible that data will be transferred to an overseas recipient located in a jurisdiction where you will not be able to find help under applicable laws and that does not have a same level of data security as in your jurisdiction. To the extent allowed by applicable laws, we will not be responsible for how these overseas people will handle, save and process your personal data. By giving your personal data to us for the booking purpose and managing travel associated products and services for you, you agree to our disclosure of your personal data to these overseas recipients for that reason.

(a)   Travel service providers located overseas

In offering our services to you, it may be important for us to share your personal data to concerned overseas travel service providers. We deal with plethora of different travel service providers across the world, so the location of a travel service provider important to your personal data will rely on the travel services being offered.

Please go through our section 5 (“when we act as agent”) for more information about when we play the role of agent for travel service providers and their privacy practices and policies.

(b)    Our third party service providers located overseas

We may also share your personal data to third parties situated overseas for the purpose of providing services for us, such as storing and processing information. Mostly, we will only share your personal information to these overseas recipients in order to ease your travel booking and/or to facilitate the performance of administrative and technical services by them on our behalf.

We use key service providers located in India, United Kingdom, Spain, Hong Kong, USA, and Australia. We also deal with plenty of service providers from all over the world, so it is impossible for us to mention all of them in this Policy to which we may send your personal data. However, if you have any particular query about where or to whom your personal data will be moved or shared, please refer to the “Feedback / Complaints / Contact” section below.

8. Security of information

Accurate Flights has incorporated several physical, managerial and electronic security measures to safeguard the personal data it holds from loss and misuse, and from illegal access, interference, modification and disclosure. Accurate Flights constantly reviews security measures and will strive to safeguard your personal information as fully as we safeguard our own important information. Accurate Flights is not liable for any third party’s actions or their security measures with respect to data that third parties may gather or process through their web portals, or services.

We will destroy personal data once we no longer need it for our business reasons, or as needed by law.

9. Access to and correction of personal data

You are authorized to access any personal data we may hold about you in conformity with applicable laws. If the personal information we have about you is not correct, complete or up-to-date or it is unimportant or inaccurate, you need to let us know and keep it updated and we will reply to your request within a reasonable amount of time. We reserve the right to validate the identity of the person looking for access or correction to personal data before obeying such a request. We have the full the right to decline you access where the legal rights of other persons would be violated, where the expense of giving you authorization would increase the risks to another person’s privacy, or for any other reason allowed under applicable law. If we decline authorization or correction, we will give you written reasons for such decline and, where required by applicable laws, will note down your request and the rejection of same in our records. If you want to access or rectify any of your personal information, we saved about you, please visit our “Feedback / Complaints / Contact” section below.

You must always give correct data and you give consent to update it whenever required. You also concur that, if there is no update, we can assume that the data given to us is accurate, unless we subsequently come to know about it that it is not right.

10. Social Media Integrations (SM)

Our web portals and mobile applications nowadays use social media features and widgets (for instance ‘Like’ & ‘Share’ buttons/widgets). These are offered and managed by third party companies (e.g. Facebook, Instagram) and either hosted by a third party or directly on our web portal or mobile app. SM Features usually gather data such as the page you are visiting on some website or app, your IP address, and may set cookies to enable the Social Media Feature in order to function properly.

If you have opened a third-party website or app and are logged into your account, then the third party may be able to store data about your visit to and use of the website or mobile app to your social media account with them. Same is the case when you interact with someone on the social media, your interactions with them may be recorded by the third party. In addition, the third party company may send us data in association with their policies, such as your full name, display picture, gender, number of friends in your list and any other data you have chosen to make visible, and we may disclose data with the third party company for the purposes of serving targeted advertising to you through the third party social media platform. You can control the sharing of data and unsubscribe yourself from targeted marketing through your privacy settings for the third-party social media platform.

11. IP addresses

When you visit our website, using any of our mobile apps or other electronic medium or communications from us, our servers may store information related to your device and the network provider you are using to connect with internet and us, followed by your IP address.  An IP (Internet Protocol) address is a series of numbers which recognize your PC, and which are generally assigned by your network provider when you access their services of internet.  Alone, IP addresses are not personal data, as multiple people may use one computer or device. This means it is not possible to determine the identity of a user just from the PC or the electronic device he/she may be using).

IP addresses are mainly used by us for system administration, inspection of security issues and compiling anonymous information regarding who used our website and/or mobile apps.  We may also connect IP addresses to other personal data we stored about you and utilize it for the purposes explained above.

12. Tracking Technologies / Cookies

(a) What do you mean by Cookies?

A cookie is described as the small text file that is stored on a user’s computer and can be used for record-keeping purposes. We may connect the data we save in cookies to any personal information you submit while on our website by filling the online registration form or feedback form. Cookies save data about individual visitors to the website, such as the visitor’s name, screen preferences, password, the pages of a website viewed by the visitor, username, and the advertisements viewed or clicked by the user.

(b) For what these cookies are used by us?

At Accurate Flights, cookies are used to recognize a visitor’s browser, to anonymously track his/her visits or to improvise the experience of the website. Cookies are basically of two types: Session ID and Persistent cookies. We use both session ID cookies and persistent cookies. A cookie named session ID, expires when you close your browser. A persistent cookie stays on your hard drive for a long period of time. When a visitor revisits the web portal, we may identify the visitor with the help of the cookie and customise the visitor’s experience accordingly. You can delete the persistent cookies by following instructions given in your Internet browser’s “help” file.

Even if you reject cookies, you may still have access to our web portal, but your accessibility to use some particular areas of our website, such as contests or surveys, may be restricted.

Web Beacons / Gifs

A software technology has been employed by us which is called clear gifs (also called Web Beacons). It helps us to better manage the content written on our website by letting us know that which part of content is attractive. Clear gifs are actually tiny graphics that comes with a unique identifier, works similarly as cookies, and are used to track the online activities of Web users. In contrast to cookies, that are saved on a user’s computer hard drive, clear gifs are fixed invisibly on Web pages and are as tiny as the size of the period at the completion of this sentence. We do not link the data collected by clear gifs to our customers’ personal information.

3rd Party Tracking

The use of cookies by our partners, tracking utility company, affiliates, or service providers is not at all included by this Policy. We do not have authorization or control over these types of cookies. Our third-party partners embed clear gifs, images, and scripts that help them manage the content on our website efficiently. We do not link the information collected to our customers’ or users’ personal data.

Behavioural Targeting / Re-Targeting

We partner with third party advertising networks to either display ads on our web portals or to manage our ads on other web portals. Our advertising network partners use cookies, Web beacons and other things to gather non-personally recognizable data about your activities on this and other web portals to give you targeted ads based on your interests.

If you do not want to have this information used for the purpose of serving you targeted advertising, you may opt-out by emailing us. Please remember that doing this will not unsubscribe you out of being served advertising. You will still receive targeted ads or generic ads where third parties do not honour unsubscribe capabilities.

(c) Third Party Cookies

When you visit certain parts of either our web portal or mobile app, third parties may store cookies on your computer’s browser and/or use of web beacons (gifs) to gather data.  This information hold things like the usage of the website or mobile app, device and browser data and ad information. The information that is generated by the gifs and cookies about your usage of the website is transferred to third parties.  With the help of this information statistical reports are compiled which allow us to measure and analyse the total number of visits to our website and its pages, the average time spent by the people on our website and the pages they viewed; serving targeted advertising to you; giving us services that helps in improving our website, mobile app and the third party’s products and services.

Our current providers plus the information about their data practices and how to unsubscribe from it, include any one of the given below as may be upgraded from time to time:

1. Google Analytics: Google Analytics is a website analytics service that is provided by Google, Inc. When you visit certain parts of the web portal, Google analytics will store cookies on your computer’s browser. The information generated by the stored cookies about the usage of the website is transferred to Google. With the help of this information statistical reports are compiled which allow us to measure and analyse the total number of visits to our website and its pages, the average time spent by the people on our website and the pages they viewed. We will not (and not allow either any third party to) use Google Analytics in order to track or gather any personal information of visitors to our web portal. We will not correlate any information collected via use of cookies with any personal information from any source as part of our usage of Google Analytics. If you want to know more about Google Analytics, you can visit www.google.com/analytics and to know details about Google Analytics’ Privacy Policy, you can visit http://www.google.com/intl/en)ALL/privacypolicy.html. You may select to unsubscribe from Google Analytics by using the Add-on of Google Analytics Opt-out Browser. You can also access it from here  https://tools.google.com/dlpage/gaoptout/.
2. For targeted advertising, Criteo is a company that is specialised in this advertising. For get more information about company Criteo, you can go to www.criteo.comand for details about its Privacy Policy, go to www.criteo.com/us/privacy-policy. To know about how to disable its services and/or to unsubscribe of Criteo, go to http://www.criteo.com/privacy/ and use the opt-out feature.
3. AdRoll is a company that is used for retargeting. To get more information about AdRoll, go to www.adroll.comand to know about its Privacy Policy, go to https://www.adroll.com/en-AU/about/privacy. You can also choose to unsubscribe from receiving targeted ads from AdRoll by going to the NAI website unsubscribe page here: http://www.networkadvertising.org/choices/ or the DAA unsubscribe page here: http://www.aboutads.info/.

(d) Managing Cookies Usage

You may block the installation of cookies by doing some settings given by your browser; we would like to let you know that however in this case you may not be able to have full access to all functions of Accurate Flights site. Furthermore, you can avoid the compilation of data (including your IP address) via cookies and website by just downloading and installing the browser plug in available.

13. Linked Sites

Our web portal may incorporate links to third party websites and we have no control over it. We are not liable for the privacy practices or the content of such portals. We encourage you to go through the privacy policies of any linked third-party portals you visit because chances are that their privacy policy and practices may differ from ours.

14. Feedback / Complaints / Contact

If you have any questions, complaints or comments about this Policy or our handling of your personal data, please contact us at:

Accurate Flights

Address: 206A-3464 Kingston Road,

Toronto, ON M1M 1R5

Email: iqbal@accuratetravels.com

We will respond to any questions or complaints received as soon as possible.

15. Alterations to our Policy

We may alter this Policy from time to time. If we make any modifications to this Policy, the revised version will be posted on our web portal. It is your duty, and we encourage you, to go through the website from time to time to determine whether there have been any modifications.

Last updated November 2019