Privacy Policy
Last Updated: July 9, 2024
This Privacy Policy describes how VRGE Holdings LP o/a VRGE HOTELS (the “Company”, “we”, “us”) collects personal information of users (“you”) through our website www.vrge.ca (the “Website”), the VRGE mobile application (the “App”), our social media pages and the features, tools, materials or services made available on all of these platforms (collectively, the “Services”), as well as our other services offered at VRGE hotels (the “Hotel”). This Privacy Policy also describes how we use and disclose that personal information. This Privacy Policy forms part of our VRGE App Terms and Conditions [link], which are incorporated herein by reference.
IMPORTANT: If you are a customer of a merchant operating at the Hotel, please contact that merchant or review their privacy policy for information regarding how your information is collected, used and disclosed by them. The Company acts as a service provider to merchants at the Hotel by allowing them to process transactions through the App and processes information according their instructions. The Company does not access or use your financial or your purchase information related to merchant transactions for its own purposes.
By accessing the Services, using our other services at the Hotel, or otherwise providing your personal information (and/or that of an individual for whom you act as parent/legal guardian) to us, you are acknowledging and agreeing to the practices described in this Privacy Policy.
IF YOU DO NOT CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, DO NOT USE OUR SERVICES AND DO NOT PROVIDE US WITH ANY PERSONAL INFORMATION.
Information You Provide to Us Directly
We may collect certain personal information that you provide when you use our Website, the App, online social media pages, or purchase products or services from us, such as when you (1) book a stay at the Hotel and/or check-in at the Hotel; (2) create an account and verify your identity on the App; (3) send questions or comments by email or otherwise to the Company; (4) fill in your information when making a purchase from or booking with the Hotel (and not a merchant at the Hotel); (5) fill out surveys; or (6) otherwise communicate with us. The types of personal information that the Company might collect from you include, without limitation:
about you or an individual for whom you act as parent or legal guardian.
You are not required to provide us with such information, but certain features of the Services may not be accessible or available, absent the provision of the requested information.
Information Automatically Collected
We also may receive and store certain information about you and your device(s) automatically when you access or use our Website or App. This information may include:
The Company may use or disclose your personal information to: operate the Services, to verify your identity, to process requests for Hotel bookings or purchases; to issue invoices, receipts or other confirmations to you; to deliver satisfactory customer service; to contact you to respond to an inquiry; to send promotional communications regarding the Company, its affiliates and Merchants operating out of the Hotel; to contact you regarding policy changes; to enforce this Policy and our Terms and Conditions; to maintain security and regulatory requirements; to engage in related activities; and for any other reasonable purpose to which you consent. The Company may also use our personal information to maintain an internal customer database, which may only be accessed by our employees and affiliates as needed. The Company may also contact you through surveys to conduct research about your opinion on certain matters related to the Company, the Hotel, the Website, or the App.
Where applicable, you may opt out of having your personal information used or disclosed for a specific purpose at any time by emailing the Company’s Privacy Officer, using the contact details below.
The Company may send your personal information to merchants operating our of the Hotel, our service providers and suppliers, and our legal and financial representatives (collectively “Receivers”) to help us provide services to you and to help us complete the above-noted purposes/tasks. All such third parties are made aware of the confidential nature of your personal information. Your personal information will be shared with Receivers on a “need to know” basis only and we limit the information shared to what is needed for the specific task being performed or fulfilled. Your personal information may also be disclosed to government agencies as required by applicable law. The Company does not rent, sell or lease its customer lists to third parties.
We may also share your information with third parties where required to protect and defend our legal rights, protect the safety and security of other users of the Services, prevent fraud, and to comply with applicable laws.
In the event of sale, transfer, merger, reorganization, dissolution, or similar event, we may transfer your information to one or more third parties as part of that transaction, including during the negotiation of an actual or contemplated transaction, but we only provide as much information as is needed for the purposes of the transaction. If we sell our organization or merge with another party, you hereby consent to the transfer of your personal information and all information you provide to us, to our successor for the same purposes as set out in this Privacy Policy.
We may use cookies, web beacons, pixels, session replays, screen captures, and other similar technologies to collect information and personalize your experience with the Website or App. The Website uses Google Analytics, Microsoft Clarity and other onsite tracking tools.
Cookies are small web files that a website transfers to your device’s hard drive through your web browser that enables the Website and App’s systems to recognize your browser and remember certain information. We use certain first party-cookies to make the Website and App function properly, improve the services provided through the Website and App, recognize you when you return to the Website or App and remember the information your previously provided, and to provide a secure browsing experience.
We may also use third party analytics providers to compile aggregate data about site traffic and site interaction and to collect information about your computer and internet connection, including your IP address, operating system, and browser type. The information collected through these cookies is used to better understand your interactions with the Website or App and to improve our services and content.
You may disable the use of cookies by modifying your browser settings. If you choose to disable cookies you may not be able to fully experience the interactive features of the Website or App. For more information on cookies and how to disable cookies visit https://youradchoices.ca/en/tools.
Web beacons, also known as web bugs, pixel tags or clear GIFs, are small graphics with a unique identifier that may be included on the webpages to deliver or communicate with cookies, in order to track and measure the performance of the Website or App and related services, monitor how many web visitors use the Website or App, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on webpages (or in an email). We may also use (or our third-party suppliers may use) automated technologies together with personal information that we have collected about you to tailor and deliver ads and content to you when you are on the Website or App.
The Company takes reasonable physical, technological and organizational precautions to prevent the loss, misuse, or modification of personal information under our control. For example:
The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or App, you are responsible for keeping this password confidential. Passwords registered with our Website or App are encrypted to ensure protection against unauthorized access to your personal information.
Unfortunately, the transmission of personal information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or App or over any public network. Any transmission of personal information is at your own risk. Without prejudice to any mandatory legal obligations to which we may be subject, we are not responsible for circumvention of any privacy settings or security measures on our Website or App.
Transfers, Retention and Storage
Please note that your personal information may be accessed, transferred, disclosed, stored and processed in Canada and any other country where the Company, its affiliates, its Receivers, and its agents are located or where their cloud computing infrastructures may be hosted. While your information is located outside Canada, it will be subject to local law, which may be less protective of your data than Canadian laws, and under the jurisdiction of local law enforcement.
The Company retains your personal information for only as long as needed to fulfill the purposes for which it was collected, or for as long as necessary to comply with applicable laws, whichever is longer. Personal information that is no longer required is destroyed, erased or anonymized. Your consent to the Company’ collection, use and disclosure of your personal information for such purposes remains valid after the termination of the Company’s relationship with you.
Third Party Links
The Services may contain links to other websites operated by third parties, including merchants operating out of the Hotel. Please note that this Privacy Policy applies only to the personal information that we collect or receive from third parties with your consent and we cannot be responsible for personal information that third parties may collect, disclose, store and use, including through their websites. You should always read the privacy policy of each website you visit carefully.
In addition, when you provide information to us through a third-party website or platform, the information may also be collected by the third-party website and may be subject to their privacy policy.
Children under the Age of 13
Individuals under the age of 13 must not submit any personal information to the Company without parental consent. We do not knowingly collect personal information from any person who is under the age of 13. If it comes to our attention that we have collected personal information from a person under the age of 13 without parental consent, we will delete this information as soon as reasonably possible. If you have reason to believe that this has occurred, please contact our Privacy Officer (see contact details below).
The Company makes commercially reasonable efforts to keep your personal information complete, up-to-date and accurate. Should you wish to access, update, correct or delete your personal information, or express any concerns regarding our use of your personal information, please contact our Privacy Officer at the contact information set forth below. We ask that you provide us with the name, address and email address that you previously provided to us, a brief description of under what circumstances you provided your personal information to the Company, and the purpose of your request. If you are unsure as to whether the Company is holding any personal information that belongs to you, you may also contact our Privacy Officer for confirmation.
The Company will make reasonable efforts to respond to your request as soon as practicable, or in any event, in compliance with applicable laws. In order to protect your privacy and security, the Company will take steps to verify your identity before granting access or making any changes to the personal information that we maintain.
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact our Privacy Officer using the information below. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
The Company may update this Privacy Policy from time to time for any reason whatsoever. We encourage you to periodically review this Privacy Policy in order to stay informed of how the Company is protecting your personal information. Each time this Privacy Policy is amended, the “Last Updated” date at the beginning of the Privacy Policy will be revised. If we make any material or substantive changes in this Privacy Policy, we will notify you by posting a clear and conspicuous notice of these changes on the Website and App and in this Privacy Policy and sending you an email to the last email we have on file.
Should you have any questions or comments regarding your personal information or this Privacy Policy, please contact our Privacy Officer:
Attention: Privacy Officer
Email: mcrowley@icmgroup.ca
Mail: 700, 404 6th Avenue SW, Calgary AB, T2P 0R9
You may also contact or make a complaint to the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or info@privcom.gc.ca, or the applicable provincial privacy commissioner, as appropriate.
