PRIVACY POLICY

Revisions to the Privacy Legislation - Personal Information and Electronic Documents Act (PIPEDA), which went into effect on January 1, 2004, require LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   to provide the following information to all our customers.
Terms of Reference:
Personal information includes any factual or subjective information, recorded or not,
about an identifiable individual. This includes information in any form, such as:

• Age, name, ID numbers, income, ethnic origin, or blood type
• Opinions, evaluations, comments, social status, or disciplinary actions
• Employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs)

Personal information does not include the name, title, business address or telephone number of an employee of an organization.
The Provisions of the Privacy Act require compliance in 10 areas: We have listed those areas below, as well as information on how LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   complies with each requirement.
1) Be accountable:

• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   will comply will all 10 principles of the Privacy Act
  Brian Robertson, President and Chief Operating Officer, is responsible for LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  's compliance with the act.
• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   will protect all personal information held by LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   
• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   does not transfer information to third parties, nor have we ever made our customer lists available to third parties, either voluntarily or for sale
• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   makes every reasonable attempt to correct customer information and keep them up to date.
• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   has had occasion to destroy obsolete files over the years. In these cases, the services of a shredding company have been used, to ensure that personal customer information is destroyed, and not simply discarded.

What personal information do we collect?
Each customer file lists:

• Name
• Business Title/ Position
• Dates on which pertinent information was sent
• Customer Number
• Canada location code
• Birthday (to send out Birthday cards)
• Preferred Language of correspondence
• Preferred place of correspondence
• Method of Payment (we do not keep credit card records in our database--we only note whether payment was made by cash, cheque or credit card)
• Home Contact information
• Business Contact information

2. Identify the Purpose
Why do we collect it?
We collect information to maintain correspondence with LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   customers, past and present. We collect mailing information from consumers who have requested to be placed on mailing lists. The information allows us to contact individuals at the place of their choosing.
How do we collect it?
Generally, information is conveyed to LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   Customers:

• Verbally--over the telephone, in person at LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   functions, and during office visits
• Electronically-via email
• Faxes

3. Obtain Consent
What is consent?
LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   considers consent to be an expression of permission to collect and use information for the purpose of providing customer services and benefits, or for the provision of consumer information.
We obtain consent by:

• Written permission via mail, email or fax
• Verbal permission with a dated notation in the customer's file, along with the initials of
  the staff who recorded the information
• Third party consent, as long as the third party is well known to LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   and/ or is in a reasonable position to give such consent (e.g. The Office manager correcting the information on an associate's file)

What do we your personal information for?
To maintain the accuracy of customer records; to better communicate with our
customers; to establish customer eligibility for services and benefits, to mail
information to consumers who have specifically requested LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   information.
Where do we keep your personal information?
Information at LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   is kept:

• In the database, on the computer.
• Paper records are kept in file cabinets

How is your personal information secured?
LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   computers are backed up regularly, with back up tapes kept in the on-site safe. The office is secured in off-hours, and the building in which the office is located has strict off-hours security.
Who has access to your personal information, or uses it?
Only employees of LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   have access to customer records. When part time help is used for filing, all activities take place under the direct supervision of a LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   full time employee.
To whom is your personal information disclosed?
Information is used in the office and by LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   employees to service the customer. LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   does not disclose information without the express permission of LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  'S customers.
In cases that request immediate contact with a customer, LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   will telephone or email the customer before giving out any contact information.
When does LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   dispose of your personal information?
LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   disposes of obsolete customer files, usually those with whom we have had no correspondence for a period of 5 years. We use the services of a shredding company to dispose of all records that include personal information.
4. Limit Collection
In order to make our database as efficient as possible with regard to responding to
customer inquiries, LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   maintains one "screen" for all customer information. Neither do we collect information that is extraneous to the efficient operation of the organization, nor do we collect information on behalf of third parties. The only instance where "other" information is collected is through regular industry surveys for the purpose of obtaining general industry trends. Surveys returned anonymously, as well as those that contain personal information (for instance if an incentive prize is involved for survey completion) are destroyed after the information is recorded.
5. Limit use, disclosure and retention

• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   only collects information for the purpose of maintaining customer files.
• Obsolete customer records are shredded every five years. Financial records are maintained for a period of 7 years.

6. Be Accurate

• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   endeavors to keep customer records as up-to-date as possible, through regular communication with customers via the LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   newsletter or electronic mail.
• Personal information on individual customers can be retrieved from the database by a
  LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   employee in order to verify the accuracy of the information, in consultation with a customer.

7. Use Appropriate Safeguards

• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   employees are made aware, verbally and in writing (The LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   Corporate Culture Document) of LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  'S Privacy Policy with regard to compliance of the Privacy Act

LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  'S security policy regarding customer records includes:

• Physical measures: The LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   office is situated in a secure building where after-hours access is restricted to employees with a pass-card or secure alarm code.
• Technological Tools: LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   computers are password protected. All computer forms that relate to financial transactions are "secure". The LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   computer system is firewall protected.
• Organizational Controls: LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   employees are vigilant with regard to the access of customer files. Staff training includes awareness of the provisions of the Privacy Act, as well as this policy document.

8. Be Open

• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   has always made it known, and will continue to inform customers, industry associates, sponsors and the public, of LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  's policies and practices for the management of personal information.
• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  's Privacy Policy is available on the LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   website (www.Vision2000.ca), as a main link, and also on the site index.
• Brian Robertson, the Chief Operating Officer is responsible for LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  's privacy policies and practices.
• While any full time employee is able to update customer information files,
  correspondence should be sent to the Customer Services Coordinator at
  110-2680 Skymark Avenue, Mississauga, Ontario, L4W 5L6; by telephone at
  (905) 602-9992, or travel@Vision2000.ca.
• Customers may contact the sources listed above for a copy of the personal
  information in their files.
• Individuals can complain to LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   using the contact information listed above.

9. Give individuals access

• Individuals may visit the LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   office during regular office hours to review their customer records. They may also request a copy of the information LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   has in their file, as long as they satisfy verification of their identity.
• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   will correct information in customer files on a timely basis, usually within 24 hours of notice.
• There are no costs or charges associated with the correcting of information in
  customer files
• LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   attempts to translate all abbreviations, short-forms and codes used in customer files. This information is readily available should a customer be unable to decipher any aspect of their customer record.

10. Provide Recourse

• The easiest method of complaint about LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP  'S enforcement of Privacy policy and procedures is to communicate directly with the organization, via letter, fax, email or telephone. In most cases, complaints can be satisfied within 24 hours. Understandably, complaints that involve more than a simple correction or updating of information should be submitted in writing so that both the complainant and LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   have a paper trail to follow in accounting for the resolution of the complaint.
• Should an individual not be satisfied with the handling of a Privacy Policy complaint
  by a LUXURY-CRUISE.COM, PART OF LUXURY-CRUISE.COM, PART OF VISION 2000 TRAVEL GROUP   employee, they should
• Bring the complaint directly to the attention of the Chief Operating Officer.
• If still not satisfied they should bring the complaint to the attention of the Chair
  of the Board of Directors
• If still not satisfied they should bring the complaint to the attention of the
  Privacy Commissioner of Canada.