Fresh Tracks Canada Privacy Statement

  1. Who we are

    1. At Fresh Tracks (Canada) Inc., we are committed to protecting and respecting your privacy. We work hard to keep your information secure. We also recognize that it is important for you to understand how we use your personal information.
    2. This Privacy Statement (and any other documents referred to in it) describes the way we will process and use any personal information about our customers, potential customers, visitors to our website, and any other individuals whose data we process for the purposes of our business. Please read this Privacy Statement carefully to understand our practices regarding your personal information and how we will treat it.
    3. We have a legal obligation to protect personal information that we collect under the British Columbia Personal Information Protection Act (PIPA) and the Canadian Federal Personal Information Protection and Electronic Documents Act (PIPEDA) that came into effect on January 1st, 2004. This Act governs information collected as part of commercial activity by any private sector organization.
    4. We also have a legal duty to protect personal information that we collect under the Data Protection Act 1998 (the UK GDPR, (collectively, the “DPA”), and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”).
    5. For the purpose of the DPA and GDPR, we (Fresh Tracks (Canada) Inc.) are the data controller (in other words, the organization that determines how your personal information is used).
    6. We are located at 885 W Georgia St, Vancouver, British Columbia, V6C 3E8, Canada. Our contact details are set out in part 10 below.
  2. Personal information we collect, how we use it and our basis for processing

    1. We may collect and use diverse types of personal information. Details of this information, together with an overview of the way that we use it, and our lawful bases for the processing in each case are set out below:
    2. Travel service inquiries and bookings

      1. We will collect personal information voluntarily provided by you during inquiries, information requests, trip bookings, and travel with us. This information, including your name, contact details, requested materials or brochures, travel plans, preferred contact times, in-person appointment requests, reasons for contacting us, and any other comments or requests made, is used, and disclosed solely to fulfill the services you have requested.
      2. If you book trips with us, we will require additional information to fulfill the booked services. This may include details such as your passport information, emergency contacts, travel insurance arrangements, preferences, specific requirements, visa requirements, and flight details (if you arrange your own flights). This will also include details of any accompanying friends or family members as part of your booking.

        We will use this information to facilitate the organization of your trip, develop personalized itineraries, make bookings on your behalf, and, upon your request, arrange travel insurance coverage for you. Additionally, we will assist you with planning, provide support as needed during your trip, and ensure that both you and any accompanying friends or family receive the products and services outlined in your itinerary.
    3. We may also collect and use particularly sensitive personal information concerning you, including specific details of any relevant health conditions, disabilities, access requirements, and special dietary needs. We collect this information directly from you to enhance our ability to tailor services to your needs and ensure your health and safety during any planned trips through us. We may seek your explicit consent to process this information.
    4. Legal Basis: We rely on your consent for processing your personal information, and where applicable, we may also rely on our legitimate interests and the necessity to fulfill our contract with you. When we rely on our legitimate interests, we ensure that your rights are protected. If you provide us with information about third parties (such as other travelers or guests on your trips), we rely on you to obtain consent from the relevant third parties for this purpose. We rely on you to inform them about our privacy statement and provide them with our contact details if they have any queries. Please inform us if any of these third parties would like to communicate with us directly regarding the trip or our use of their data.
      1. We may retain personal information to be used when you next book with us as we have a legitimate interest in improving our customer journey and ensuring we look after our customers.
      2. If you have made an inquiry with us, or booked a trip with us, we might send you marketing e-mails. We send you these because of our legitimate interests, but you always have a right to object to our e-mails (see further below) and if you do not want to receive them, please let us know using the links provided in each e-mail messages or by contacting us using the details in section 10.
    5. Websites, marketing and advertising

      We will collect certain technical information about you when you visit our websites. This is likely to include: the internet domain you use, your IP address or other device identifier, your browser type and version (e.g. Chrome or Internet Explorer), the operating system and platform that you are using (e.g. Windows or Mac), the screen resolution of your device, the dates and times when you access our website, the full URLs of the pages you visit and the websites or links that you use to access our website, login information, details of products or services that are viewed and the length of visits to certain pages of the website.

      1. We use cookies to collect this information; for more information about what cookies are and how we use them, please refer to our Cookie Policy.

        We collect this information so we can fulfil our legitimate interests as a business to ensure that our website is fit for purpose and promotes our services appropriately for our customers, including by displaying information that our customers are interested in. We also rely on our legitimate interest in measuring customer satisfaction and troubleshooting any website issues. Where required by law, we may also seek and rely on your consent.
      2. We may collect and use information from various sources in connection with the marketing and advertising of our services. This may include your contact details (and your marketing preferences) to contact you with certain marketing messages (e.g. marketing e-mails). We may also use data we collect from you (either directly or via our website or advertising) to help us measure the effectiveness of our advertising and to establish what interests you and what doesn't.

        We rely on your consent to contact you directly about our offering. In other scenarios in carrying out efficient and appropriate marketing and advertising for our services, we will rely on our legitimate interests, whilst always ensuring that your rights are protected. You can withdraw your consent or opt out of our direct marketing at any time through our marketing preference center or through the 'unsubscribe' option in any marketing email.
      3. We may collect your contact details when you enter competitions or promotions, or complete surveys. We will rely on your consent or on our legitimate interests, whilst always ensuring that your rights are protected.
      4. We may collect details about you, such as your username, when you engage with us on social media (by mentioning or tagging us in a post or contacting us directly) this is so that we can respond to any comments and queries you have. We rely on our legitimate interests to do this as we want to ensure our customers have the best possible experience, whilst always ensuring your rights are protected. Where required by law, we may also rely on your consent.
      5. Administrative or other business purposes

        We may collect and use certain other personal information when we correspond with you (whether by telephone, e-mail or otherwise). For example, we may record both in-bound and out-bound telephone calls or collect information when you use our Live Chat feature to speak with our team members, to ensure quality of service and for training purposes.

        We collect this information so we can respond to your questions, provide the services you request, and to fulfil our legitimate interests as a business to ensure that team members are trained to the highest level so that our customers receive the very best travel advice. We will tell you before we collect this information. 

      6. We may collect and use certain other personal information when we correspond with you (whether by We may collect certain other information that you give us, for example, when you contact us for a particular reason other than those set out above such as to report problems with our website.

        It is in our legitimate interests as a business to use your personal information in this way, for example, we have a clear interest in ensuring that our website works properly and in ensuring that we operate our business efficiently. We will always ensure that your rights are protected.
    6. As well as collecting personal information directly from you, we also collect some from third parties such as Google Analytics, Google AdWords, Bing Ads, and Social Media platforms such as Meta and Instagram. 
  3. How we share personal information

    1. In order to make sure that we run our business efficiently, and lawfully, and for the purpose of providing the services that you request or require, we will need to share your personal information, from time to time, as necessary, with the following third parties:

      • Third parties if necessary to comply with legal obligations or enforce agreements, for example, we are required to provide airlines with a passenger mobile phone number and email contact details under IATA Resolution 830d for the airline to inform the passenger of any operational difficulties.

      • Third parties such as travel providers, tour operators, airlines, hotels, and other businesses in the tourism industry, for the purposes of booking your trips and any associated activities and experiences. We may also share some of your personal information to provide you with travel insurance or for other reasonable purposes as necessary in order to carry out your instructions and provide you with the products and services that you have requested.

      • Subsidiaries and affiliates, and with service providers who perform services for us, these services include but are not limited to the provision of online advertising which may involve anonymous profiling in order to find similar prospects to you or showing you relevant ads based on your interest in our products and services.

      • For the purposes of processing your payments for the trips, experiences, and activities that we book on your behalf, we may require you to pay via our designated payment processor. Our payment processors may retain some of your personal information in de-identified form so that it cannot be used in an unauthorized manner. If you do not wish to make your payment through our payment processor, please speak to your travel advisor.

      More information about our payment processors’ retention practices is available at:

      • Any other third parties as necessary to comply with our legal obligations or protect our or your rights, property, or safety and/or the rights, property, or safety of others, or as required by law.

    2. We do not share your personal information with third parties for them to use for the purposes of sending you marketing information about other businesses, or for those third parties to use your information for their own purposes.
  4. Automated decisions and profiling

    1. We may on occasion use automated decision making or profiling on customer data that has been provided through consented channels to ensure delivery of relevant marketing content. If you would like to know more about our automated decision making and profiling, please contact
  5. Where we transfer and store personal information

    1. From time to time, we may process (or ask, or permit a third party to process) your personal information outside of the European Economic Area (EEA) where local laws may not provide legal protection for your information in the same way as is applicable in the EEA.

      For example, when you book a trip, we will need to provide your information to local accommodation or service providers. In other cases, we may need to share your information with an overseas service provider such as our local partners who host you during your safari experience, the provider of a cruise or experience train journey.
    2. Whenever we send (or permit a third party to send) your personal data outside of the EEA, we will make sure that we take the steps necessary to protect your data as required by applicable laws. For example, we may require the overseas recipient to enter into particular contract terms, or we will make sure that the information that we give to them will be limited to what is needed to fulfill our contract with you.
    3. If you wish to learn more about the safeguards in place to protect your personal information when we transfer it outside of the EEA, please contact us using the details in section 10 below.
    4. The personal data that we collect from you will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff involved in, among other things, providing support services.
  6. Security of your personal information

    1. We take the security of your information very seriously and have put physical, technical, operational, and administrative strategies, controls, and measures in place to help protect your personal information from unauthorized access, use or disclosure as required by law and in accordance with accepted good industry practice. We review these regularly to make sure that the measures we have implemented remain appropriate.
  7. Retention of personal information

    1. We will keep your personal information for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal information. This means that the retention periods will vary according to the type of personal information. For example, some transaction information will be kept for a number of years in order to comply with various finance and tax related obligations. If you need more information on this, please contact:
  8. Your rights in your personal information

    1. Depending on what country you live in; you will have certain rights in respect of the personal information that we hold about you. Details of these rights are set out below. To exercise any of these rights, please contact us (see the "Contact and Complaints" section of this Privacy Statement below).
    2. The rights that may apply, subject to applicable law:

      1. Access: We will confirm to you whether or not we are processing and using personal information about you, at your request and, if so, provide you with access to and a copy of such personal information and the other details to which you are entitled.
      2. Rectification: We will correct any inaccurate personal information and complete any incomplete personal information (including by providing a supplementary statement) that we hold about you.
      3. Prevention of processing likely to cause damage or distress: We will respect your rights to require us to cease or not to begin processing your personal information for a specific purpose, or in a specific way, which is likely to cause you or any third parties unwarranted damage or distress.
      4. Erasure: We will erase your personal information at your request without undue delay where there is no good reason for us to continue to use it.
      5. Restriction: We will restrict the processing of your personal information in certain circumstances if you ask us to do so.
      6. Data portability: We will provide you or third parties on your behalf with a copy of any personal information that we hold about you which you have provided to us in a structured, commonly used, and machine-readable format.
      7. Objection (including objection to direct or e-mail marketing): We will respect your general rights to object to the processing of your personal information in certain circumstances, including for direct and e-mail marketing purposes.
  9. Changes to our Privacy Statement

    1. We reserve the right to modify this Privacy Statement from time to time. For example, if we need to reflect changes to the way that we use your personal information. Any changes we make in the future will be posted on the following website: and, where appropriate, notified to you by e-mail. You should check back frequently to see any updates or changes to our Privacy Statement.
  10. Contacts and complaints

    1. We are very keen to hear from you, including if you have any questions, concerns, comments, requests, or complaints regarding this Privacy Statement, our website, and/or our use of your personal information. Please contact:

      Privacy Officer
      Fresh Tracks Canada Inc.
      P.O. Box 1024 885 W Georgia St
      Vancouver, BC, V6C 3E8
    2. If you have any complaints regarding this Privacy Statement or the way that we use your personal information, you may also contact the Office of the Privacy Commissioner of Canada or the European National Data Protection Authorities.