Privacy policy

This Privacy Policy (the “Policy“) explains how EDGARD collects, uses, discloses and otherwise makes use of your personal information when you visit and use this website www.edgard.ca (the “EDGARD Platform“), and make reservations on the EDGARD Platform or as a visitor to the EDGARD Platform (collectively, the “Services. This Policy also applies to EDGARD’s privacy practices in relation to personal information that it collects offline, such as by telephone.

For purposes hereof, the terms “EDGARD”, “we”, “us” and “our” shall mean the EDGARD Platform. The individual responsible for the protection of personal information collected by EDGARD is Étienne Lambert  who can be contacted at 819-277-6072 or info@edgard.ca. The term “you” refers to the natural person identifying themself as the representative of the employer, who is duly subscribed to the EDGARD membership community. The term “Carrier” refers to any airline company that offers charter or co-chartering of its flights through the EDGARD Platform and with which you choose to do business.

1.Commitment.

EDGARD is committed to respecting your privacy and protecting your personal information. EDGARD is responsible for and ensures compliance with the requirements of provincial and federal privacy laws (the “Laws“).

2.Personal information.

In order to provide you with subscription, registration, usage, purchase and transactional page services, process your transactions and enhance your experience with the EDGARD Services and the EDGARD Platform, we must collect certain personal information about you. This means any information about you as an individual that identifies you and may include, but is not limited to:

• your name, last name, gender, home and office contact information (such as your address, phone number, email address), work position, date and place of birth, age, marital status, nationality, photo, salary, passport and visa information;
• information about the transactions of the employer you represent with EDGARD, its affiliates, carriers, or other service providers or other third parties;
• information about your credit or debit card or the credit or debit card of the employer you represent, or any other payment method accepted by EDGARD;
• communications with us (such as recordings of calls with customer service representatives for quality control and training purposes);
• any information necessary to fulfill special requests (e.g. medical conditions requiring special rooms or services);
• information, feedback or content you provide about your marketing preferences, in surveys, contests or promotional offers, or on our websites or those of third parties who have a commercial relationship with EDGARD;
• other information collected when you access the EDGARD Platform.

The present Policy also applies to personal information collected about members of your organization travelling on behalf of the employer you represent.

3.Collection of personal information.

We collect personal information when you provide such information to us, when we collect it automatically or when we receive it from third parties. When you create an account for an employer you represent on the EDGARD Platform, sign up to receive offers or information, make a reservation, or communicate with us by email or telephone, you are providing us with your personal information. We also collect this information through automated technologies such as files placed on your browser, with your consent (if any), when you visit the EDGARD Platform. We also receive information from business partners and other third parties which helps us improve the EDGARD Platform and related tools and services, update and maintain accurate records, detect and investigate potential fraud, and commercialize our services more effectively.

4.Purpose of collecting personal information.

4.1 We use your personal information for the following purposes:

• With respect to your use of the EDGARD Platform, we use your personal information in order to:
  • charter the requested flight;
  • provide services related to the charter or account;
  • create, maintain and update user accounts on the EDGARD Platform and authenticate you as a user;
  • retain your search and travel history and similar information about your use of the EDGARD Platform and EDGARD services, and as otherwise described in this Policy;
  • enable and facilitate the acceptance and processing of payments, coupons and other transactions;
  • administer loyalty and rewards programs;
  • collect and enable the posting of reservation notices; and
  • help you use our services more quickly and easily through certain features.
• With respect to communications and marketing, we use your personal information to:
  • respond to your questions and inquiries and process choices related to information;
  • enable communication between you and the carriers;
  • contact you (for example, by text message, email, phone calls, mail, notifications or messages on other communication platforms) to provide you with information, such as flight chartering confirmations and updates, for marketing purposes or for other purposes described in this Policy;
  • to promote our products and services, to optimize such marketing to be more relevant to you, and to measure and analyze the effectiveness of our marketing and promotions; and
  • manage promotions such as contests and other giveaways.
• For other business and compliance purposes, we use your personal information to:
  • Conduct surveys, market research and data analysis;
  • maintain, improve, research and measure the effectiveness of our sites, applications, activities, tools and services;
  • monitor or record calls, chats and other communications with our customer service team and other representatives, as well as communications that take place on the EDGARD Platform or among partners and travelers for quality control, training, dispute resolution, and as described in this Policy;
  • create aggregated or anonymized or depersonalized data, which we may use and disclose without restriction where permitted;
  • Promote safety, verify the identity of our customers, prevent and investigate fraud and unauthorized activity, defend against claims and other liabilities, and manage other risks;
  • Comply with applicable laws, including, but not limited to, Laws, protect our rights and interests and those of our users, defend ourselves and respond to requests from law enforcement, other legal authorities and requests that are part of a legal process;
  • Comply with applicable security, anti-terrorism and anti-corruption laws and requirements, applicable customs and immigration laws and requirements, and other due diligence laws and requirements; and
  • operate our business for legitimate business purposes and within the limits of the Law.

4.2 EDGARD limits the collection of personal information to that information which is necessary for the purposes identified. We will retain your personal information only for as long as it is reasonably necessary for the purposes for which it was collected or processed, in accordance with this Policy, or to comply with the requirements of applicable privacy laws. The criteria we use to determine the length of our retention periods are as follows:

• the length of our relationship with you, including any open accounts you may have with us;
• if we have a legal obligation related to your personal information, such as laws requiring us to keep records of your transactions with us; and
• whether there are any current and relevant legal obligations affecting the period of retention of your personal information, including contractual obligations, litigation holds, statutes of limitations and regulatory investigations.

4.3 For the purposes set out in this Policy, EDGARD, one of its affiliates or one of its unaffiliated service providers may process or store your personal information outside the province in which you reside or outside of Canada. Under certain circumstances and in accordance with the laws of those other jurisdictions, law enforcement, regulatory and security authorities in those other provinces or foreign countries may be granted access to your personal information.

5.Consent to the use.

By subscribing as an authorized representative of an employer to the EDGARD Platform member community or on any occasion by chartering on the EDGARD Platform, you consent to EDGARD’s use of your personal information to respond to your request. We will only use your information to process your request. You may withdraw your consent at any time. If you refuse, object, wish to limit the processing of, or request the deletion of, any information necessary for the delivery of the Services, or, if you wish to withdraw consent to collect and use information about your physical or mental health, religious beliefs or criminal convictions or offenses, and ethnic origin, which is considered sensitive personal information, we may not be able to provide you with all or part of our Services. In such cases, cancellation fees may apply. If a third party, including a member of your organization, a friend or colleague, attempts to make a reservation on your behalf, they must provide the same personal information that you would normally provide in order to complete your transaction. Unless otherwise specified, we consider that third party to have your consent and authorization to provide us with your personal information, to receive promotional and service emails from EDGARD, and to make reservations (and changes thereto) on your behalf in accordance with this Policy. Please note that the collection, use and disclosure of your personal information by a third party is dependent on your relationship with that third party and is subject to these applicable privacy policies and practices.

6.Sharing personal information

We share your personal information as described below and in this Policy, and as permitted by applicable law.

• Third Party Service Providers. We share your personal information with third parties in the course of providing services to you and operating our business (for example, to provide credit card processing, customer service, business analysis, fraud prevention and compliance services, and to provide you with advertising tailored to your interests). These third-party service providers are required to protect the personal information we share with them and may not use any personally identifiable information about an individual except to provide the services we have hired them to provide. They are not permitted to use the personal information we share for direct marketing purposes (unless you have separately consented to this with the third party under the terms provided by the third party).
• Service providers. We share your personal information with service providers, such as carriers and insurance companies. Please note that carriers may contact you for additional information if and when necessary to facilitate your reservation or to provide the charter or related services.
• Business partners and offers. If we promote a program or offer a service or product in conjunction with a third party business partner, we will share your information with that partner to help market or provide the associated product or service. In most of these cases, the program or offering will include the name of the third party business partner, either alone or with our name, or you will be directed to that company’s website with notice. An example of such a business-partner relationship would be a third-party loyalty program for which you could earn points by making a reservation on our platform.
• Legal rights and obligations. We may disclose your personal information to enforce our policies, or if we are permitted to do so by applicable law, for example in response to a request by governmental or law enforcement authorities, or in connection with actual or proposed litigation, or to protect our property, persons and other rights or interests. We may also share your personal information pursuant to a subpoena or other legal request, or as necessary to remit certain taxes in connection with payment processing, as required by law or legal process.
• Commercial transactions. We may share your personal information as part of commercial transactions, such as a disinvestment, merger, consolidation, assignment or sale of assets, or in the unlikely event of bankruptcy. In the case of any acquisition, we will inform the purchaser that they must use your personal information only for the purposes disclosed in this Policy.

7.Cookies

We use “cookies” to personalize the EDGARD Platform for returning visitors. These cookies remain on your computer and are retrieved automatically on subsequent visits to the EDGARD Platform. These cookies only contain information about the type of customer and the pages frequently visited. No other information is stored in the cookies. Most browsers are initially programmed to accept cookies; however, you can disable cookies on your computer by using the “help” feature at the top of the taskbar of most browsers, which will indicate how to stop accepting cookies and how to disable existing cookies, or by selecting one of the options below :

• Digital Advertising Alliance of Canada unsubscribe page (DAAC): https://youradchoices.ca/fr/comprendre-la-publicite-en-ligne/;
• NAI unsubscribe page: http://www.networkadvertising.org/managing/opt_out.asp; and
• Ad Choices unsubscribe page: http://www.aboutads.info/choices/.

The above programs provide tools that identify the member companies that have placed cookies on your browser and provide ways to unsubscribe from these cookies.

Disabling cookies may affect the functionality of the EDGARD Platform for the user.

8.Safety measures

EDGARD makes reasonable commercial efforts to ensure that your personal information collected is protected against loss, disclosure, copying, use, modification, or unauthorized access and theft. This protection applies to information stored in both electronic and paper form. In addition, EDGARD employs generally accepted information security techniques such as firewalls, access control procedures and encryption to protect such information from loss and unauthorized access. In addition, we take reasonable steps to ensure that agents, representatives and other outside organizations comply with the requirements of the Laws. Finally, access to your personal information is limited to certain employees or representatives and we make our employees aware of the importance of protecting personal information by providing training sessions on this subject and by issuing directives from time to time outlining their role and obligations in this regard.

9.Transparency

EDGARD’s privacy practices are set out in this Policy. If you have any questions or comments, you may contact EDGARD as indicated at the beginning of this Policy.

10.Advertisement.

This section informs you about EDGARD’s online advertising practices.

As stated above, we use “cookies” and other similar monitoring technologies (including scripts, pixel tags, graphic images and web beacons) on the Edgard Platform. Cookies are small text files that your browser installs on your computer or other device that allow the EDGARD Platform to recognize you on your visit. Some cookies are necessary for the EDGARD Platform to operate or to help us recognize you, such as when you log in to your account. We collect this information to help us analyze the performance of the EDGARD Platform, remember your preferences, track your usage, and tailor ads to you. We also have third party service providers, such as Google Analytics, that use third party cookies or other digital markers to maintain and improve the EDGARD Platform and our Services, and to provide interest-based advertising on the EDGARD Platform and other websites.

We use several tools to help us and our marketing partners tailor advertising to what we believe is most useful and relevant to you. We tailor and personalize these advertisements to your interests based on information from your activities, such as the actions you take when you visit the EDGARD Platform, or when you visit websites that display EDGARD advertisements.

We work with third-party social media platforms, such as Facebook and LinkedIn Ads, to display tailored advertisements to you. To deliver such advertisements, we may convert your email address, phone number or other contact information provided by you into a unique value to be linked to your social media profile by our partners, such as Facebook or other social media platforms. While EDGARD does not provide personal information to these platforms, they may gain information about individuals who respond to advertisements we display. Please visit Facebook and LinkedIn for information on advertising and privacy policies. Access to Personal Information. You may access the personal information contained in your profile at www.edgard.ca. Upon request, EDGARD will inform you if it is storing or processing your personal information on behalf of a third party. To access personal information contained in a reservation through a call center, you must provide your reservation or ticket number so that we can verify that you have the right to access this information. To obtain this information, please contact EDGARD whose contact information is listed at the beginning of this Policy. We will respond to your request within a reasonable time.

11.International transfer of information.

The personal information we process may be transmitted or transferred to countries other than Canada. These countries may have data protection laws that differ from the Laws. The EDGARD Platform servers are located in Canada, and third party service providers operate in many countries around the world. When we collect your personal information, we may process it in any of these countries. We have taken appropriate steps and implemented safeguards to ensure that your personal information remains protected in accordance with this Policy and in compliance with the Laws.

12.Filing a complaint.

Complaints about EDGARD’s compliance with the Laws are always taken seriously and investigated in all cases. Concerns regarding EDGARD’s compliance with the Laws may be communicated to EDGARD, whose contact information is provided at the beginning of this Policy.

13.Applicable law

This Policy is governed by the applicable laws of the Province of Quebec and the applicable laws of Canada, without regard to conflict of laws. You hereby agree that any dispute arising out of or relating to the use of the EDGARD Platform shall be subject to the jurisdiction of the Quebec courts in the district of Montreal.

14.Update and Amendment of the Policy.

EDGARD reserves the right to update this Policy at any time and without notice of changes to legal or regulatory obligations or changes in procedures for handling personal information. You can see when the Policy was last updated by checking the “last updated” date posted at the top of the Policy.