Privacy Policy

1. Privacy Statement

SunwingJets and its affiliates (“SunwingJets”) are committed to protecting your privacy, and support a general policy of openness about how we collect, use and disclose your Personal Information (as defined below). For the purposes of this Privacy Policy “affiliates” has the same meaning as in the Ontario Business Corporations Act, R.S.O. 1990, c. B.16.

The purpose of this Privacy Policy is to inform you about SunwingJets’s and its affiliates’ (excluding U.S. affiliates’) practices relating to the collection, use and disclosure of Personal Information that may be provided through access to or use of our websites, services or products (if applicable), or that may otherwise be collected by us. By using the SunwingJets website (“Website”), you consent to the collection, use and disclosure of your Personal Information in accordance with the following terms and conditions.

This Privacy Policy also explains how you can contact us if you have a question about, want to make a change to or delete any Personal Information that SunwingJets may be holding about you. As one of our users or someone else with whom we do business, you understand and agree that we collect, use and disclose your Personal Information in accordance with this Privacy Policy. We strongly recommend that you take the time to read this Privacy Policy and retain it for future reference.

2. Personal Information

For the purpose of this Privacy Policy, “Personal Information” means information about an identifiable individual but does not include the name, title or business address or telephone number of an employee of an organization.

3. What Personal Information We Collect

We may collect Personal Information from individuals during their dealings with us or while visiting our web sites, for example when individuals request a quote, contact us by e-mail or phone, or subscribe to our updates or newsletters. The information we collect may include at least some of the following:

• Individual and business contact information (such as name, surname, company name, address, e-mail address and telephone number);
• Customer service comments, feedback or content you provide regarding your marketing preferences, in surveys, contests, or promotional offers, or to our Website and those of third parties that have a commercial relationship with SunwingJets;

The Personal Information we process is information that you or someone acting on your behalf knowingly provides to us or information that we receive from a third party.

This Privacy Policy also applies to the Personal Information about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.

4. How We Use Your Personal Information

We may use, collect and disclose your Personal Information to:

• Provide you with timely and reliable quotes through third parties;
• Process claims we receive in connection with our services;
• Provide customer support and respond to and communicate with you about quotes and your requests, questions and comments;
• Advise you about new products and services (if applicable) that may be of interest to you;
• Communicate about, and administer your participation in, special events, programs, surveys, contests and other offers or promotions;
• Develop and maintain our relationship with you and communicate with you; and,
• Perform data analyses and conduct other research (such as market and consumer research and trend analysis) to develop, manage, protect and improve our products and services, Website, and business (including analyzing the effectiveness of our marketing, sales and advertising).

5. When We Disclose Your Personal Information

Except with your consent, we will not sell, license, trade or rent your Personal Information to or with others.

SunwingJets may share Personal Information to or with third parties. From time to time, we may disclose your Personal Information as set out below:

1. Our affiliates and subisidiaries: SunwingJets may disclose and you authorize SunwingJets to disclose your Personal Information with its affiliates and subsidiaries.
2. Our agents, service providers and suppliers: SunwingJets may share Personal Information with third parties engaged to provide quotes to you, or to carry out one or more of the purposes described above. These service providers are prohibited from using your Personal Information for any purpose other than to provide this assistance and are required to protect Personal Information collected by them or disclosed to them by SunwingJets and to comply with the general privacy principles described in this Privacy Policy.
3. Legal requirements: SunwingJets reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so.
4. Business transfers: SunwingJets also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of SunwingJets or of any of the business or assets or shares of SunwingJets or a division thereof in order for you to continue to receive the same products and services from the third party.

7. Knowledge and Consent

SunwingJets collects Personal Information about you only when you voluntarily provide it. Yo may always choose what Personal Information (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot process a quote request without a name).

We will seek consent for the use or disclosure of your Personal Information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).

The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations of the individual in the circumstances.

You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent at any time, please contact our Privacy Officer as described below under “Contacting Us”. We will inform you of the implications of withdrawing consent.

We will not, as a condition of the supply of a product or service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.

7. Use or Disclosure for Marketing Purposes

Your Personal Information will be used for the purposes described in this Privacy Policy. If you have subscribed to receive SunwingJets’s updates or newsletters, we may also use (but will not disclose) your Personal Information to send you relevant information based on your subscription preferences, including by means of direct marketing. We may also disclose your Personal Information to our affiliates so that they can send you promotional materials directly.

You may unsubscribe at any time by clicking the unsubscribe link embedded at the SunwingJets email communications. Note, however, that clients of SunwingJets will continue to receive periodic emails that relate to their business relationship with us. You can also choose not to allow us to use your Personal Information for marketing purposes by contacting us as outlined below (see “Contacting Us”).

8. Cookies

When you visit our Website, we or one of our third party service providers places a text file called a “cookie” in the browser directory of your computer’s hard drive. A cookie is a small piece of information that a website can store on your web browser and later retrieve information. The cookie cannot be read by any website other than the one that placed the cookie. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this website may not function properly.

These third party service providers use cookies on our behalf to collect and store Internet log information, such as what time the visits occurred, whether the visitor has been to this site before, and what site referred the visitor to the web page. Geographic data is also determined by the IP Address of the visitor’s computer. This information collected by the cookie is transmitted to our third party service providers and is then used to evaluate visitors’ behaviour and to generate statistical reports for the website activity on SunwingJets’s website and may be used for marketing purposes.

You can choose to disable cookies in your browser at any time by following the procedure described in the Tools or Preferences menu in your browser. If you choose to modify your browser in this manner, some pages of the Website may not function properly. Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.

9. How We Protect Your Personal Information

SunwingJets makes commercially reasonable efforts to ensure that Personal Information collected from you is protected against loss, theft and unauthorized access, disclosure, copying, use, or modification. This protection applies in relation to information stored in both electronic and hard copy form. Access to your Personal Information is restricted to selected employees or representatives. In addition, SunwingJets employs generally accepted information security techniques, such as firewalls, access control procedures and cryptography, to protect Personal Information against loss and unauthorized access.

10. Links to Third Party Sites

This Website may offer links to other third party websites. You should be aware that operators of linked websites may also collect your Personal Information (including information generated through the use of cookies) when you link to their websites. SunwingJets is not responsible for how such third parties collect, use or disclose your Personal Information, so it is important to familiarize yourself with their privacy policies before providing them with your Personal Information.

11. Retention and Storage of Your Personal Information

SunwingJets retains your Personal Information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains valid after termination of our relationship with you.

For the purposes set out in this Privacy Policy, we or one of our affiliates or an unaffiliated service provider may process and store your Personal Information outside of the province in which you reside and/or outside of Canada, and under the laws of those other jurisdictions, in certain circumstances courts, law enforcement agencies, regulatory agencies or security authorities in those other provinces or foreign jurisdictions may be entitled to access your Personal Information.

12. Changes to this Privacy Policy

SunwingJets reserves the right to modify this Privacy Policy at anytime without notice to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with Personal Information. The Privacy Policy posted at any time or from time to time via this Website shall be deemed to be the Privacy Policy then in effect.

This Privacy Policy is effective as of October 18, 2017

13. Correcting or Updating Your Information

You can help us maintain the accuracy of your Personal Information by notifying us of any changes to this information. You may contact SunwingJets in any one of the ways described below to request access to or correction or update of your Personal Information.

14. Contacting Us

If you have any questions about SunwingJets’s Privacy Policy or if you have reason to believe that SunwingJets may have failed to adhere to this Privacy Policy, you may contact our Privacy Officer via mail at 27 Fasken Drive, Toronto Ontario Canada M9W 1K6.

We may require you to confirm your identity (such as by providing government-issued identification) before processing any request in relation with your Personal Information.