Privacy Policy — Accurate Travels And Tours Inc.

This Privacy Policy ("Policy") sets out how Accurate Travels And Tours Inc. (collectively mentioned in this document as "Accurate Travels", "we", "our" or "us") safeguard the privacy of your personal data.

Accurate Travels is an established Canadian travel agency that has been serving travellers for over 20 years. To perform our business activities and functions, including managing and making travel bookings, arranging group travel packages, and organizing tours on behalf of our customers, we need to gather, use and disclose personal data. We are very devoted to safeguarding the privacy and secrecy of personal information and maintain several electronic, physical, and procedural shields to protect your 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 consent to us gathering, using and disclosing your personal information as mentioned in this Policy. If you do not agree with any part of this Policy, you must not give your personal data to us. If you do not consent to giving us your personal data, or if you withdraw a consent that you have already given under this Policy, this may affect our ability to provide further services to you. For example, in order to book your flight, hotel, or participate in a group tour package, you must provide the traveller's full name, contact details, and appropriate identification (e.g. passport details). Bookings cannot be completed without such data.

What type of personal information do we gather?

Personal information generally refers to 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 a 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, services, and group tours 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, group bookings, or required by the concerned travel service provider(s) (e.g. airlines, hotels, 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 a competition and you win, or sent us a query, we need your personal information so we can contact you to respond to your query or let you know about the competition results. We also gather information that is needed for use in the business activities of Accurate Travels and our related entities, including for example financial details essential to process transactions, footage of video surveillance cameras used for security purposes, and other personal data you may agree to provide to us.

In some instances, we also gather personal data from you which may be considered sensitive information. Sensitive data may include (without limitation) 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 13 years of age. We will only collect sensitive information in conformity with applicable laws, with your consent and/or where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to organize travel arrangements or manage group tours), unless we are otherwise required or permitted to do so by law. To the extent permitted or required under applicable laws, you consent to us using and disclosing your sensitive data for the purpose for which it was gathered, unless we subsequently receive your consent to use it for another purpose. For example, if you give us your health information in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health data in connection with arranging that travel insurance on your behalf. A further example is if you disclose your religious beliefs to us because you are interested in, for instance, certain group tour packages, in which case you consent to us using and disclosing that data in connection with fulfilling your request. We will not use your sensitive data for purposes other than those for which it was gathered, unless we subsequently receive your consent to use it for another purpose.

When do we act as agent for a travel service provider

Whenever we book or otherwise arrange travel related products and services, including group tours, we usually act as an agent on behalf of travel service providers. In this scenario, we generally 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, including the purpose of processing your booking request. As an agent, the bookings that are made on your behalf are subject to the terms and conditions, including the privacy policy, of these travel service providers. We will give you copies of the relevant terms, conditions, and privacy policies of travel service providers on request.

Accordingly, you are deemed to consent to the gathering, use, and disclosure of your personal data by us to the relevant travel service providers, and to the use and disclosure of your personal information by those 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 or joining a group tour through us, then as stated in this Policy you are giving us consent to gather your personal data and disclose that information to the airline or tour operator in order to book your travel or tour and for them to provide the service to you, and, to the extent allowed under applicable laws, for other reasons mentioned in their privacy policy.

We act as an agent for or on behalf of many thousands of travel service providers across the world, including hotels, airlines, and group tour operators, so it is not possible for us to list each one of the travel service providers for whom we act, or their locations, in this Policy. For more information about the disclosure of personal information to travel service providers situated overseas, please see the section below titled "Is personal information moved overseas?".

If you have any concerns regarding the transfer of your personal data to a travel service provider, or you want to contact us for further information, please see our "Feedback / Complaints / Contact" section below.

How do we gather your personal data?

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 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, or email. We may collect personal information about you when you purchase anything from us, make enquiries about your travel arrangements, book group tours, or use our other services and products; when you enter competitions or subscribe to promotions; when you register with us to receive marketing materials; when you provide information or use our services on a social media platform; or when you request brochures or other information from us. Unless you choose to do so anonymously, we may also gather your personal information (apart from sensitive information) whenever you complete surveys or give us feedback about our services.

There may be instances when it becomes necessary for us to collect your personal data from a third party. This happens where an individual makes a travel booking on your behalf that includes travel arrangements to be used by you (e.g. a travel booking made for you by your employer, a family member, a group booking, or a group tour). When this happens, we will rely on the authority of the person making the travel booking to act on behalf of any other traveller on the booking. By agreeing to provide your personal information to us, either directly or via a family member, employer, or travel agent or representative in connection with a travel booking or related service, you will be deemed to have consented to your personal information being gathered by us and used and disclosed in conformity with this Policy.

Where you are making a travel booking on behalf of another person (e.g. family, group booking, or booking for an employee), you confirm that you have obtained the consent of the other person for Accurate Travels to gather, use and disclose that person's personal information in conformity with this Policy, and that you have made the other person aware of this Policy. Please let us know immediately if you become aware that your personal data has been provided to us by another person without your consent, or if you did not obtain consent before giving another person's personal data to us.

How your personal information is used and disclosed by us

Where you contact us for a travel booking, group tour package, or an enquiry, the primary purpose for which we gather your personal information is generally to assist you with booking travel and/or travel related products and services and to provide you with travel advice. However, the reason for collecting your personal data may differ depending on the particular circumstances as described in this Policy.

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

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the categories described in this Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

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

• Providing you with services and tools you choose to use (for instance, saving your travel choices on our website(s) to a Wishlist, or saving your personal data to automatically fill your online forms);
• Detecting fraud or error;
• Regulatory reporting and compliance;
• Developing and improving our products, services, and group tour offerings;
• Maintaining our relationship with you by, among other things, creating and managing an individual profile so that we can serve you better or offer options on our web portal that we think may interest you based on your browsing and choices;
• Inviting your participation in market research, evaluating customer satisfaction, and seeking feedback based on our relationship with you and/or the service we have provided;
• Enabling you to participate in loyalty programs;
• Administering our referral program, including tracking referrals, calculating and issuing rewards, and detecting fraudulent or ineligible referrals;
• Internal accounting and administration;
• Complying with our legal obligations and any applicable customs and immigration requirements concerning your travel;
• Research and analysis in connection with our business and services, including but not limited to trends and preferences in sales, travel destinations, and use of our web portals; and
• Other purposes as permitted or required by law (e.g. to prevent a threat to life, health or safety, or to enforce our legal rights).

Promotional and marketing material

We may use your personal data to send you marketing communications concerning our products and services (and those of third parties) that we think may interest you, unless you have asked us not to. These may include, but are not limited to, electronic marketing (including online targeted marketing) and notifications (including telephone calls). Your personal information will only be used by us to send you electronic marketing materials (including e-newsletters, instant messages, email, and SMS) if you have subscribed to receive them. This may also include promotions for group travel packages and tour offers. You can opt in to receive e-newsletters and other electronic marketing materials by visiting the relevant links on our web portal or by asking one of our consultants to do that for you.

If you no longer want to receive marketing material from us, receive other types of communication from us, or participate in market research, please see the "Feedback / Complaints / Contact" section below. You can opt out at any time from receiving electronic marketing materials by clicking the unsubscribe option in your email, SMS, instant message, or other form of electronic marketing.

Is your personal data disclosed to third parties?

We may disclose your personal information to third parties, as described below, and in conformity with applicable laws. By using our services and/or by giving us your personal data (or permitting another person to do so on your behalf), you agree that personal data may be processed, transferred, and/or disclosed by us for the purpose for which it was gathered and, where authorized by applicable laws, for any related secondary purpose which we believe you would reasonably expect. Note that, in this Policy, where we say "disclose", 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 disclosed to the following types of third parties:

Our service providers, contractors, and suppliers, including without limitation:

• In each of the situations mentioned in the section above titled "How your personal information is used and disclosed by us";
• Suppliers of IT-based solutions that assist us in offering products and services to you (e.g. any external data hosting provider(s) we may use);
• Payment processors, for the purpose of issuing referral rewards to program members;
• Publishers, distributors, and printers of marketing material;
• Expo and event organisers;
• Mailing houses, courier services, and freight services; and
• External business advisers (e.g. lawyers, auditors, recruitment consultants, and accountants).

In addition, your personal information may be disclosed to:

• Our related entities and brands;
• Travel service providers such as travel wholesalers, car rental companies, tour operators, transfer handlers, airlines, hotels, and other related service providers, including those providing group tours;
• A person making a booking on your behalf, where you are travelling on a booking made on your behalf by another person (e.g. a family member, work colleague, or friend);
• A person who can confirm to us that they have a connection with you where you are not reachable, where that person correctly answers our security questions and the request is, in our opinion, reasonable (e.g. where that person is concerned for your welfare or can take action on your behalf in case of unforeseen circumstances);
• Any party to whom disclosure is required or authorised by applicable law, and in order to comply with our legal obligations;
• Immigration and customs authorities, to comply with our legal obligations and any applicable customs and immigration requirements associated with your travel;
• Government agencies and public authorities, to comply with a lawful and authorized request;
• Regulatory bodies and law enforcement officials and agencies, in order to safeguard against fraud and for related security reasons; and
• Enforcement agencies where we suspect that illegal activity has been or may be engaged in and the personal data is relevant to our investigation or reporting of the matter.

For more information regarding the collection of data by travel service providers and their privacy policies and practices, see the section above titled "When do we act as agent for a travel service provider".

With respect to our contractors, service providers, and suppliers, we take reasonable steps to ensure that those third parties process personal data in conformity with our privacy obligations and to prevent and remedy any unauthorized processing. This includes entering into written contracts with each such third party restricting the third party's use of transferred data to specified purposes, requiring them to provide the same level of security required by our privacy obligations, and requiring them to inform us if they can no longer satisfy their obligations to provide such security. If we share personal data with third parties providing services to us, we require that they only use such data for its intended purpose. We may remain responsible for the acts of third parties who provide services on our behalf in respect of personal data that we transfer to them.

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

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the categories described in this Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Is personal information moved overseas?

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

Data may be transferred to an overseas recipient located in a jurisdiction that does not have the same level of data protection as in your jurisdiction, and where you may not have recourse under applicable laws. Personal information stored or processed in another country may be accessible to the courts, law enforcement, and national security authorities of that country under its laws. To the extent allowed by applicable laws, we are not responsible for how these overseas recipients handle, store, and process your personal data. By giving your personal data to us for the purpose of booking, group tour participation, and arranging travel-related products and services for you, you consent to our disclosure of your personal data to these overseas recipients for that purpose.

(a) Travel service providers located overseas

In providing our services to you, it may be necessary for us to share your personal data with relevant overseas travel service providers. We deal with many different travel service providers across the world, so the location of a travel service provider relevant to your personal data will depend on the travel services being provided.

Please see the section above titled "When do we act as agent for a travel service provider" for more information about when we act as agent for travel service providers and about their privacy practices and policies.

(b) Our third-party service providers located overseas

We may also share your personal data with third parties situated overseas for the purpose of providing services to us, such as storing and processing information. Generally, we will only share your personal information with these overseas recipients in order to facilitate your travel booking and/or to enable the performance of administrative and technical services on our behalf, including those related to group tour management.

We use key service providers located in India, the United Kingdom, Spain, Hong Kong, the United States, and Australia. This includes the third-party payment processor we use to issue referral rewards to members of our referral program, which is located in the United States. We also deal with service providers from around the world, so it is not possible for us to list all of them in this Policy. If you have a specific query about where or to whom your personal data will be transferred or shared, please see the "Feedback / Complaints / Contact" section below.

Security of information

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

We will destroy or de-identify personal data once we no longer need it for our business purposes, or as required by law.

Access to and correction of personal data

You are entitled to access the personal data we hold about you in conformity with applicable laws. If the personal information we hold about you is not correct, complete, or up to date, please let us know and we will respond to your request within a reasonable time. We reserve the right to verify the identity of the person seeking access or correction before complying with such a request. We may decline access where the legal rights of other persons would be infringed, where providing access would create risks to another person's privacy, or for any other reason permitted under applicable law. If we decline access or correction, we will give you written reasons and, where required by applicable laws, will record your request and our refusal in our records. If you want to access or correct any of your personal information, please see our "Feedback / Complaints / Contact" section below.

You must always give us correct information and you agree to update it whenever required. You also agree that, in the absence of an update, we may assume that the data given to us is accurate, unless we subsequently become aware that it is not.

Social media integrations

Our web portals and mobile applications use social media features and widgets (for instance 'Like' and 'Share' buttons). These are offered and managed by third party companies (e.g. Facebook, Instagram) and are either hosted by a third party or directly on our web portal or mobile app. These features usually gather data such as the page you are visiting, your IP address, and may set cookies to enable the feature to function properly.

If you have opened a third-party website or app and are logged into your account, the third party may be able to associate data about your visit to and use of the website or mobile app with your social media account. The same applies when you interact with someone on social media; your interactions may be recorded by the third party. In addition, the third party company may send us data in accordance with their policies, such as your name, display picture, gender, number of friends, and any other data you have chosen to make visible, and we may share data with the third party company for the purposes of serving targeted advertising to you through that platform. You can control the sharing of data and opt out of targeted marketing through your privacy settings for the third-party social media platform.

IP addresses

When you visit our website, use any of our mobile apps, or receive other electronic communications from us, our servers may store information related to your device and the network provider you are using to connect to the internet and to us, including your IP address. An IP (Internet Protocol) address is a series of numbers which identifies a computer or device, and which is generally assigned by your network provider when you access their internet services. On its own, an IP address is not personal data, as multiple people may use one computer or device.

IP addresses are mainly used by us for system administration, investigation of security issues, and compiling anonymous information regarding use of our website and/or mobile apps. We may also link IP addresses to other personal data we hold about you and use it for the purposes explained above, including in connection with group travel bookings.

Tracking technologies and cookies

(a) What are cookies?

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

(b) How do we use cookies?

At Accurate Travels, cookies are used to recognize a visitor's browser, to anonymously track visits, and to improve the experience of the website. There are two main types of cookies: session ID cookies and persistent cookies. We use both. A session ID cookie expires when you close your browser. A persistent cookie stays on your hard drive for a longer period. When a visitor returns to the web portal, we may identify the visitor with the help of the cookie and customize the visitor's experience accordingly. You can delete persistent cookies by following the instructions in your internet browser's "help" file.

Even if you reject cookies, you may still access our web portal, but your ability to use certain areas of our website, such as contests, surveys, or group tour registrations, may be limited.

Web beacons and clear GIFs

We use a technology called clear GIFs (also called web beacons). These help us better manage the content on our website by letting us know which content is of interest. Clear GIFs are tiny graphics with a unique identifier, work similarly to cookies, and are used to track the online activities of web users. Unlike cookies, which are saved on a user's computer hard drive, clear GIFs are embedded invisibly on web pages. We do not link the data collected by clear GIFs to our customers' personal information.

Third-party tracking

The use of cookies by our partners, tracking utility companies, affiliates, or service providers is not covered by this Policy. We do not have access to or control over these cookies. Our third-party partners embed clear GIFs, images, and scripts that help them manage content on our website efficiently. We do not link the information collected to our customers' or users' personal data.

Behavioural targeting and 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 technologies to gather non-personally identifiable data about your activities on this and other web portals in order to give you targeted ads based on your interests, including promotions for group tours or travel packages.

If you do not want this information to be used for targeted advertising, you may opt out by emailing us. Doing so will not stop you from being served advertising entirely; you will still receive targeted or generic ads where third parties do not honour opt-out requests.

Third-party cookies

When you visit certain parts of our web portal or mobile app, third parties may store cookies on your browser and/or use web beacons to gather data. This information may include usage of the website or mobile app, device and browser data, and advertising information. This information is used to compile statistical reports measuring total visits, average time spent, and pages viewed, to serve targeted advertising, and to provide services that improve our website, mobile app, and the third party's products and services.

Current providers and details about their data practices and how to opt out:

• Google Analytics: www.google.com/analytics — privacy: http://www.google.com/intl/en_ALL/privacypolicy.html — opt-out: https://tools.google.com/dlpage/gaoptout/
• Criteo (targeted advertising): www.criteo.com — privacy: www.criteo.com/us/privacy-policy — opt-out: http://www.criteo.com/privacy/
• AdRoll (retargeting): www.adroll.com — privacy: https://www.adroll.com/en-AU/about/privacy — NAI opt-out: http://www.networkadvertising.org/choices/ — DAA opt-out: http://www.aboutads.info/

Managing cookies

You may block the installation of cookies using your browser settings; however, some website functions may then be limited. You can also prevent data collection via cookies by downloading and installing browser plug-ins.

Linked sites

Our web portal may contain links to third-party websites over which we have no control. We are not liable for the privacy practices or content of such sites. We encourage you to review the privacy policies of any linked third-party sites you visit, as their practices may differ from ours.

Facebook and Instagram messaging

When you contact Accurate Travels through Facebook Messenger or Instagram Direct Messages, we may securely collect and store your conversation, your name (if available), profile information provided by Meta, your phone number (if you choose to share it), and any files or images you send.

We use this information only to:

• Respond to your inquiries;
• Provide customer support;
• Manage travel bookings and quotations; and
• Improve our customer service.

We use the official Meta (Facebook and Instagram) Graph API and Messaging APIs to receive and respond to customer messages.

Data deletion

If you would like us to delete your Facebook Messenger or Instagram conversation and any associated personal information, please email us at support@accuratetravels.com with the subject "Delete My Data". We will process your request within a reasonable timeframe.

Accurate Rewards referral program

Accurate Travels operates a voluntary referral program ("Accurate Rewards") that allows past travellers to register, share a personal referral link, and receive a reward when someone they refer books and completes travel with us. Participation in the program is free and entirely optional. This section explains how we handle personal information in connection with the program. All other sections of this Policy continue to apply to members of the program.

(a) Information we collect from members

When you register for Accurate Rewards, we collect your name, email address, telephone number, and mailing address. We also create and maintain a record of your referral activity, including your unique referral link or code, the bookings attributed to it, the rewards you have earned, and the payouts issued to you.

In order to pay your rewards, we also collect payment and payout information, which may include your banking details and, where required by law, tax identification information. This information is collected and processed by a secure third-party payment processor on our behalf.

(b) How we use this information

We use the personal information of program members to:

• Register and verify your membership and maintain your member account;
• Generate your referral link and attribute bookings made through it;
• Calculate, track, and display your earnings in your member dashboard;
• Issue payouts to you and maintain records of those payouts;
• Detect and prevent fraudulent, duplicate, or ineligible referrals, including self-referrals;
• Meet our accounting, tax, audit, and other legal and regulatory obligations;
• Communicate with you about the program, including changes to the program terms; and
• Respond to your questions and provide support.

(c) Information shown to members about referred travellers

If you book with Accurate Travels using a referral link or code, the member who referred you will be able to see limited information relating to that booking in their dashboard, being your first name and last initial, the date of booking, the package booked, and the status of the referral reward. Members are not given access to your contact details, passport or identification details, payment details, health or dietary information, or any other personal information you provide to us in connection with your travel arrangements.

By making a booking using a referral link or code, you consent to this limited disclosure to the referring member. If you do not wish for this information to be disclosed, please do not book using a referral link or code, and contact us instead at support@accuratetravels.com.

Members are required to keep any information they receive through the program confidential and to use it solely in connection with the program.

(d) Disclosure to third parties

In addition to the disclosures described elsewhere in this Policy, we may disclose personal information collected under this program to our third-party payment processor for the purpose of issuing rewards, and to our accountants, auditors, and tax and regulatory authorities where required.

(e) Transfers outside Canada

Our payment processor and certain systems used to operate the program may store or process personal information outside of Canada, including in the United States. Personal information stored or processed in another country may be accessible to the courts, law enforcement, and national security authorities of that country under its laws. By registering for the program, you consent to this transfer. Please also see the section above titled "Is personal information moved overseas?".

(f) Retention

We retain member registration records, referral records, and payout records for as long as your membership remains active and thereafter for seven years, or for such longer period as is required to meet our accounting, tax, and other legal obligations.

(g) Withdrawing from the program

You may withdraw from Accurate Rewards at any time by contacting us at support@accuratetravels.com. Withdrawing from the program will not affect your existing bookings or your relationship with us as a traveller. We will continue to retain records of your past referrals and payouts as described above.

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 Travels And Tours Inc. 206-695 Markham Road Toronto, ON M1H 2A4

Email: support@accuratetravels.com

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

Changes to this Policy

We may change this Policy from time to time. If we make any changes to this Policy, the revised version will be posted on our web portal. We encourage you to review this page periodically to determine whether there have been any changes.