Privacy Policy

Last updated: [date]

Wheel & Anchor ("W&A," "we," "us") respects your privacy. This policy explains what personal information we collect, why, who we share it with, and the choices you have. In this policy, "Wheel & Anchor" means Wheel & Anchor Inc. and Vancouver Regency Travel Ltd. ("VRTL"). VRTL is the registered travel retailer (TICO Reg. 1817786), operating as Wheel & Anchor and New Sky Travel, through which all W&A trips are sold.

We follow Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL).

We ask for your consent when we collect your information, and we use it only for the purposes described here. You can say no to anything we don't need to deliver your trip, such as marketing, and still travel with us.

Privacy contact: Our Founder is accountable for this policy for both Wheel & Anchor Inc. and VRTL. Reach us at contact@wheelandanchor.ca.

1. What we collect, and why

We collect personal information only as needed to provide the services, products, or information that you (or someone booking for you) ask for. Depending on what you request, this can include:

Full name, age, home address, phone number, and email address
Passport details, where required for your travel
Health information you choose to share with us, such as medical conditions, mobility needs, allergies, and dietary requirements, so we can plan your trip safely
Insurance details, nationality, and residency
Travel and accommodation preferences
Trip destination information and comments you give us
Payment information (card details are handled by our payment processor; see section 7)
Recordings of phone calls with our team (see section 6)
Photos and video taken on our trips (see section 7)
How you use our website and our emails, through cookies and similar technologies (see section 10)

We also collect information if you enter a draw or contest, complete a survey, or request a brochure. We use it only for what you asked for, or for closely related services.

If we don't need a piece of information to deliver what you've requested, you can choose not to provide it. You can browse our website without telling us who you are, but our website does use cookies (see section 10).

Sensitive information. Health details and passport details are sensitive. We collect them only with your express consent, usually on your trip information form. We share them only with your trip host and the suppliers who need them to look after you.

2. How we use your information

We use your information to:

Book trips and services for you, and answer your questions about our trips
Provide ongoing service and support, including resolving issues
Understand your needs as a member and determine eligibility for our services
Tell you about our tours, merchandise, and services, and offers from partners that we think you'll like. We email you only if you've opted in or as CASL otherwise allows (see section 5), and we don't give your details to partners for their own marketing.
Suggest trips and information that match your interests, based on the trips you've taken or asked about and how you use our website and emails
Show you relevant Wheel & Anchor advertising on other websites and social media (see section 10)
Keep our members and services safe and secure
Handle our internal accounting and administration
Comply with laws, regulations, and immigration requirements
Receive and act on your feedback

To book your trip, we pass the information that suppliers need to those suppliers. For example, if you buy a flight through us, we give the airline the details it requires, such as your name, date of birth and passport details. Each supplier then handles your information under its own privacy policy and the laws where it operates.

3. What happens if you don't provide it

If you don't provide information we need to deliver a service, we may not be able to provide it, which could mean you can't take part in a trip. If you've paid a deposit and then decline to provide information that we or our suppliers require (for example, passport details for a flight), you may not be entitled to a refund for that service. The booking terms for your trip apply.

4. How we get your consent

We collect information when you book or inquire (through our website, our reservations team, trip information forms, member surveys, and prize draws), and from people you've authorized to book or inquire for you.

We obtain your consent through:

Written permission by mail, email, or online booking form
Verbal permission
Third-party consent, such as from your spouse or partner, or from the member booking on your behalf who has your permission to share your information

You can withdraw your consent at any time with reasonable notice, subject to legal restrictions. If you withdraw consent for something we need to deliver your trip, we won't be able to provide or continue that service, and any resulting costs are yours.

5. Marketing emails and your CASL rights

We send promotional emails, brochures, and other marketing materials if you've opted in, or for a limited time after you've booked a trip or asked us about one, as CASL allows. You can opt in on our website or through our reservations office.

You can unsubscribe at any time using the "Unsubscribe" link at the bottom of every email, or by contacting us. We'll act on your request within 10 business days. Unsubscribing from marketing doesn't stop the emails we need to send about a trip you've booked.

6. How we protect your information

We store your information with reputable service providers that protect it with access controls, encryption, and other safeguards. Card payments are handled by a payment processor that meets the Payment Card Industry Data Security Standard (PCI DSS). No system is 100% secure, and we can't guarantee the security of information you send us over the internet, but we take all reasonable steps to protect it.

Access is limited to:

Authorized W&A employees, trip hosts, and contractors who need it for their work
Third-party suppliers who need your information to provide the services you've requested (airlines, transportation companies, hotels, cruise lines, tour guides)

We require our employees and suppliers to follow this policy. Unauthorized access or disclosure of member information is strictly prohibited.

Phone calls. Calls with our team are recorded for quality assurance and to keep an accurate record of what was discussed. A recording may be transcribed if we need to clarify a booking-related matter. We'll tell you at the start of a call that it is being recorded.

If something goes wrong. If a privacy breach creates a real risk of significant harm to you, we'll tell you and report it to the Privacy Commissioner of Canada, as the law requires.

7. Who we share it with

We share your information with the suppliers who deliver your trip, such as airlines, hotels, cruise lines, ground operators, guides, and insurance companies, and with service providers that work for us. All payments are made to VRTL and held in its trust account, as Ontario's Travel Industry Act, 2002 requires. Card payments are processed for VRTL by Hubspot.

Some of these organizations are outside Canada, or outside your country of residence if you book from abroad, and may be governed by different privacy laws. You can reasonably expect your information to be shared with organizations in the countries you're travelling to, and sometimes with the country where a supplier's head office is located. While your information is outside Canada, it is subject to the laws of that country and may be accessed by its courts, law enforcement, and national security authorities.

Our main service providers are HubSpot (our website, member records, and emails), Google Workspace (email and documents), and our accounting, project-management, team-messaging, and phone systems. HubSpot stores our account data in Canada, although some of its own service providers may process data elsewhere. Our service providers may use the information we give them only to perform services for us.

Trip groups. On many trips we use Telegram for day-to-day updates. Other travellers in the group can see your name and, depending on your Telegram settings, your phone number. You can change those settings in Telegram, or ask your host for another way to receive updates.

Photos and video. Our hosts, our filmmakers, and fellow travellers take photos and video on our trips, and we may use them in our newsletters, website, brochures, and social media. If you'd rather not appear, tell your host or contact us, and we'll respect that from then on.

We do not sell, lease, or trade your information or travel details to other parties in the ordinary course of business. If W&A were ever sold, your information would be among the assets transferred, and we commit that the new owner would be bound by this policy or one that is at least as protective.

8. Accessing your information, and how long we keep it

You can ask to see, update, or delete your personal information by contacting us by email, phone, or in person, subject to limits set by law. We'll respond within 30 days, at no cost to you. We keep your information only as long as we need it for the purpose we collected it for, and to meet our legal, regulatory, and tax obligations. Our standard retention periods are:

Booking, payment, and accounting records: 7 years after the end of the year in which your trip ends
Passport details: 6 months after your trip ends, unless you ask us to keep them on file for future trips
Health, mobility, and dietary details: 6 months after your trip ends, unless we need them for an incident, claim, or complaint
Complaint and conduct files: 2 years after the matter is closed, or longer while a claim is open. A decision that someone may not join future trips is kept for as long as it applies
Call recordings and transcripts: 12 months, unless needed to resolve a dispute
Marketing contacts: until you unsubscribe, or after 3 years with no booking, enquiry, or email engagement
Website analytics: no more than 26 months

After that, we delete, destroy, or anonymize it. Occasionally, you may need to provide your information again if it has been deleted.

9. Complaints

If you have a complaint or a question about how we handle your personal information or comply with privacy law, write to us at contact@wheelandanchor.ca or at the address below. We take every complaint seriously, and we'll respond in writing within 30 days. If you're not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada (priv.gc.ca).

If you opt out of a use of your information, we'll separate it and won't use or disclose it in the way you objected to. We may still keep information we're legally required to retain.

10. Cookies, analytics, and advertising

What is a cookie? A cookie is a small text file that a website sends to your browser. It can help the site remember what you did, so your experience is more consistent and efficient. Pixels and tags are similar tools that tell a website or an advertising platform when a page has been viewed or an action taken.

How we use them. We use three kinds. Strictly necessary cookies make the site and booking forms work. Analytics cookies (HubSpot and Google Analytics) show us how the site is used, such as pages visited, trips viewed, and how people find us. Advertising cookies and pixels (HubSpot, Google Ads, and Meta) measure our campaigns and show our ads to people who have visited our site or interacted with our content. Once you fill in a form or click a link in one of our emails, HubSpot can link your website activity to your contact record, which helps us understand which trips interest you.

Advertising audiences. We use advertising platforms, including Meta and Google, to promote our trips, membership, and events, and to measure how our ads perform. We may share limited contact details, such as your email address, with these platforms in a scrambled (hashed) form so they can match them to their users. We use this to build advertising audiences, to leave existing contacts out of some campaigns, and to reach people with similar interests. We never share health or other sensitive information for advertising. The platforms handle this information under their own privacy policies. To be left out of our advertising audiences, contact us.

Your choices. You can accept or decline non-essential cookies through our cookie banner and change your choice at any time through the cookie settings link at the bottom of every page. You can also manage cookies in your browser, and opt out of interest-based advertising through the Digital Advertising Alliance of Canada (youradchoices.ca) and the Network Advertising Initiative.

11. Where we operate

We're based in Ontario, Canada, and Canadian privacy law governs how we handle your information. We don't advertise in Quebec, and our website, policies, and booking documents are available in English only. We give every member and visitor the same privacy protections, wherever they live.

If you live outside Ontario, including in Quebec or outside Canada, you may have additional privacy rights under local law. Contact us using the details below, and we'll respond as that law requires.

12. Changes to this policy

We may update this policy from time to time. Changes may apply to information collected under earlier versions. If we make a significant change to how we use information we already hold, we'll tell you before it takes effect. The current version is always posted on our website with its "last updated" date.