Privacy Policy
Privacy Policy
Hospitality Newfoundland and Labrador (HNL) is committed to protecting the privacy of all individuals who visit its website found at www.hnl.ca (“the Site”) and who use the services found on the Site. This policy covers the treatment of personally identifiable information (“Personal Information”) gathered by HNL when users are accessing the site. Hospitality Newfoundland and Labrador is committed to collecting, using and disclosing Personal Information provided to us in compliance with all applicable federal and provincial privacy laws in Canada (“Privacy Legislation”).
What is Personal Information?
Federal privacy legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA), applies to “personal information” about an “identifiable individual” but does not include name, title, business address, and business phone number used for business purposes.
Accordingly, the term “Personal Information” within this Privacy Policy means information about an identifiable individual, but does not include publicly available information such as a public directory listing of an individual’s name, position name or title, business telephone number, business address, business e-mail, business fax number and other similar business information (as long as such information is used for contacting the individual in relation to the individual’s business responsibilities and for no other purpose); or aggregated information that cannot be associated with a specific individual.
Personal Information Collected Through Website
A visitor to the Site does not automatically provide HNL with Personal Information. However, the HNL web server may collect and retain certain information related to a computer’s visit to the Site such as the IP address and domain used to access the Site, the type and version of the browser used to access the Site, the date and time of the visit, the page that the Site was entered and exited by; and the address of any referrer website if the visiting computer was referred to the Site by a search engine or other website. HNL automatically collects and receives information from your computer or mobile device, including type of hardware, information obtained by cookies and traffic data to better understand user needs, diagnose problems, analyze trends, provide services, better understand and market to our residents and visitors, and improve the features we offer.
Hospitality Newfoundland and Labrador also makes use of non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Site pages with a view to introduce improvements and improve usability of our services and products.
The Site uses Google Analytics to record the IP addresses of computers that connect to the Site. Google Analytics uses these IP addresses to generate geographically related statistics which assist HNL with the administration of the Site. HNL does not attempt to link the IP addresses of the computers that have visited the Site with the identities of individuals.
More information regarding Google Analytics can be found at https://www.google.com/intl/en/analytics/privacyoverview.html.
The Site also uses “cookies” which are small data files transferred to a user’s hard drive by the web browser when a user visits the Site. A transferred cookie can only be read by the Site when a user returns to the Site. Cookies are used to identify users and track their preferences so that a user’s experience with the Site may be customized accordingly. If a user does not want to have a cookie placed upon their hard drive by the Site, most web browsers allow users to change this preference to disallow cookies; however, note that this could change the functionality of the Site.
Your IP address and other relevant non-identifiable information may be used in order to trace any fraudulent or criminal activity.
Linking to Third-Party Websites
The Site may contain links to third-party websites. These links are provided solely as a convenience to visitors to the Site and not as an endorsement by HNL of the contents of such third-party sites. Hospitality Newfoundland and Labrador disclaims all responsibility for the privacy practices, policies, or other privacy related matters associated with the third-party websites to which the Site is linked.
Hospitality Newfoundland and Labrador recommends that visitors who link to third-party websites through the Site thoroughly review the privacy policies of those third-party websites prior to providing personal information.
When Does Hospitality Newfoundland and Labrador Collect, Use and Disclose Personal Information?
Contact
Hospitality Newfoundland and Labrador collects Personal Information submitted by visitors to the Site through the “contact” portion of the Site.
This Personal Information is used by HNL to establish or manage its relationship with users of the Site, to respond to queries of users of the Site and to provide requested information and services. Hospitality Newfoundland and Labrador restricts the collection of personal information to that which is necessary for the identified purposes.
Newsletter
Hospitality Newfoundland and Labrador collects Personal Information submitted by visitors to the Site through the Newsletter portion of the Site.
This Personal Information is used by HNL to provide visitors to the site who opt in with information on activities, events and news from HNL through a regularly emailed newsletter. Visitors may opt out of receiving theses communications at any time.
Other
Other parts of the website may be used to provide services to members from time to time, such as membership fee payment, registration for events, and other purposes.
This Personal Information is used HNL for the purposes outlined in the specific pages or areas of the Site where such information is requested.
Providing Consent
By providing Personal Information to HNL through the Contact link on the website, through the Newsletter or by voluntarily providing Personal Information elsewhere on the Site, your consent to HNL using that Personal Information for the identified purposes is implied by Privacy Legislation.
When We May Share Personal Information
Except as provided in the next paragraphs and elsewhere in this Privacy Policy, HNL does not divulge any Personal Information gathered to third parties.
Notwithstanding anything in the Privacy Policy to the contrary, we may share any information we have collected about you or that you have submitted:
- when you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;
- where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands; or
- if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
Subject to obligations consistent with this Privacy Policy, we may also disclose information to our affiliates, agents, contractors, and service providers in order to provide you services, such as processing transactions, fulfilling requests for information, or providing support services or other tasks.
In order to ensure full compliance with Canada’s Anti-Spam Legislation, and to respect the privacy and level of consent provided by our members, Hospitality Newfoundland and Labrador will not disclose member contact information, outside of the Membership Directory format available on this website, to any third party.