| PRIVACY STATEMENT |
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At the Canadian Snowbird Association (the CSA), the trust and confidence of our members stand at the core of our mission to advocate, protect and represent the interests of Canadian travellers. Recognizing the unique nature of our members’ lifestyle, we are committed to upholding the highest standards of privacy and data protection. |
| PURPOSE |
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The purpose of this privacy policy is to demonstrate the CSA’s unwavering commitment to protecting the privacy and personal information of our members and others (collectively “members”) who may access our services and/or those of our benefit partners. This policy outlines our practices regarding the collection, use, access and safeguarding of personal information, ensuring that our operations align with Personal Information Protection and Electronic Documents Act (PIPEDA) standards and reflect our dedication to transparency and accountability in all member interactions. |
| SCOPE |
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This policy applies to all personal information collected, maintained and processed by the CSA, encompassing, among other things, data obtained through membership enrolment, delivery of member benefits and member communications, digital or otherwise. |
| HOW WE COLLECT PERSONAL INFORMATION |
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At the CSA, we ensure that our methods of collecting personal information are clear and straightforward, fostering an environment in which members can easily grasp and agree to the data collection process and the data being collected. We gather personal information through various means to effectively serve our members in accordance with our privacy policy, those of approved third-party providers, and the respective terms and conditions of our member benefits. This includes personal interactions at our office or during special events in Canada and the U.S., enrolment in any member benefit (and the facilitation of same, whether by the CSA or an approved third-party provider), digital communications such as email exchanges and online submissions (Bird Talk, renewals, etc.), and hard-copy/paper transactions, which may include regular mail, couriers and or facsimiles. Personal information is collected from third parties only when applicable to the benefits or services in which the respective member is enrolled. |
| WHAT PERSONAL INFORMATION WE COLLECT |
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The CSA collects a range of personal information that is tailored to our members’ needs and the services being provided. This may include:
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| WHY WE COLLECT PERSONAL INFORMATION AND HOW IT MAY BE USED |
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In almost all instances, introductions to members are member driven. Consequently, any interactions initiated by the CSA, particularly via email, are deemed to be made with express permission, in accordance with Canada’s Anti-Spam Law (CASL), rather than being implied. Each aspect of information collection is guided by our commitment to respect your privacy and adhere to PIPEDA’s principles, ensuring that personal information is handled responsibly, securely, and only for the purposes for which it is collected. The primary purpose behind collecting personal information is to provide and improve the benefits and services which we offer. This includes:
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| HOW AND TO WHOM CSA DISCLOSES PERSONAL INFORMATION |
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The CSA is dedicated to ensuring the privacy and security of our members’ personal information, in strict adherence with our privacy policy and in compliance with CASL, PIPEDA and regulations set forth by FINTRAC under Anti-Money Laundering (AML) legislation. Our policy governs the careful disclosure of personal information to approved third parties, which is driven by necessity to facilitate benefits and services in which members are enrolled. This includes interactions with financial institutions, legal advisors and other service providers essential to the administration and delivery of member benefits such as SCE, CSANews, CSA Auto/Home Insurance Plan, Medipac Travel Insurance and this website – www.snowbirds.org – and any functions contained herein. Any disclosure of information is made with the obligation that such third parties are committed to protecting your information with a level of security that meets or exceeds our standards; is used for only the intended purposes; and is accessible only to those with a legitimate reason in the performance of their duties. It’s important to note that, in certain circumstances, we may be required to disclose information without express consent from our members. This includes, but is not limited to, compliance with court orders, legal obligations or situations in which disclosure is necessary to prevent fraud or to ensure compliance with AML or other regulations. In such instances, we commit to disclosing only the information that is strictly necessary under the circumstances. We obtain implied consent for these disclosures through your enrolment with our services, under the premise that such interactions necessitate the sharing of information to fulfil the service or benefit requested. However, we uphold the principle of transparency and give our members the right to withdraw consent at any time, provided such withdrawal is communicated to us in writing. In every aspect of our operations, the CSA remains steadfast in our commitment to safeguarding your privacy, ensuring that any disclosure of personal information is justified, secure and in alignment with the highest standards of privacy legislation. This section outlines a clear and respectful approach to information collection, aligning with the overarching commitment to privacy and transparency set forth in the initial statement. |
| HOW CSA ENSURES THE SECURITY OF YOUR PERSONAL INFORMATION |
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The CSA treats the security of your personal information with utmost seriousness. We ensure that all personal data, whether recorded in physical documents or stored electronically, are kept secure within our premises in Canada and, where applicable, at the locations of our trusted partner organizations. Our electronic data storage systems are monitored 24/7 with robust hardware and software firewalls to guard against unauthorized access and ensure data integrity. Access to personal information is stringently controlled; it is granted only to CSA staff, associates and authorized contractors who have a clear and defined need to engage with the data as part of their job responsibilities. To reinforce our commitment to privacy and security, all CSA personnel are provided with comprehensive training on best practices for handling personal information. This training emphasizes adherence to applicable privacy legislation, our own stringent privacy policy, and ethical codes of conduct, ensuring that every member of our team is equipped to protect your privacy rights diligently. |
| DATA RETENTION AND DELETION (WELLSPOKEN MOBILE APPLICATION) |
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Where your data is stored. All personal information you enter into the WellSpoken mobile application — including profiles, medications, allergies, conditions, doctors, immunizations, and any other health records — is stored locally on your own device. The CSA does not collect, transmit, host, or retain copies of this information on any server operated by CSA or its partners, nor does the App’s distributor. How long your data is retained. Because the data resides on your device, it is retained for as long as you keep WellSpoken installed and choose to keep the data within the app. CSA does not impose a retention period and has no ability to retain your records beyond your device. You remain in full control of how long your information is kept. Dictation (voice-to-text) data. When you use the optional dictation feature, the audio you record is transmitted to a third-party speech-to-text and AI transcription provider for the sole purpose of converting your speech into text and identifying form fields. Each dictation request is processed as an isolated, transient transaction. The audio is not used to train models, is not retained by CSA, and is discarded by the transcription provider after processing in accordance with their published policies. Only the resulting text is returned to your device, where it is saved locally if you choose to confirm it. How to delete your data. You can delete your data at any time, directly from the app, without contacting CSA:
• Delete a single entry — Open the relevant screen (Medications, Allergies, Doctors, etc.), select the entry, and use the delete option for that record. No server-side deletion request required. Because CSA does not store your WellSpoken records on its servers, there is no separate account or server-side deletion request process. Deletion is fully within your control on your device, and any deletion performed in the app is immediate and irreversible. Backups and shared copies. If you have enabled device-level backups (for example, Apple iCloud Backup or Google Drive backup) or if you have exported, emailed, printed, or otherwise shared your information outside the app, those copies are governed by the terms and retention policies of the relevant third-party service or recipient and are outside CSA’s control. You are responsible for managing or deleting those copies directly with the applicable service. Questions or requests. If you have questions about how your information is handled, or you need assistance with deletion, you may contact CSA at the address provided in the “Contact Us” section of this Privacy Policy. |
| ACCURACY AND ACCESS TO PERSONAL INFORMATION |
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At the CSA, we are dedicated to maintaining the accuracy of the personal information which we hold and utilize. We are committed to providing our members with access to their own personal information upon receipt of a written request, subject to necessary and reasonable conditions to safeguard the information and our processes. A nominal processing fee may apply to such requests, aimed at covering administrative costs. It is important to note, however, that there are specific circumstances under which access cannot be provided, including but not limited to situations where it might disclose:
This approach ensures that, while we uphold our members’ rights to access and verify their personal information, we also protect the confidentiality and integrity of all data managed by the CSA. |
| AMENDMENTS |
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The CSA may amend this policy from time to time and without notice. |
| FURTHER INFORMATION |
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Requests for further information, personal information access or complaints about CSA’s handling of personal information should be referred to CSA’s Privacy Officer as follows: Privacy and Compliance Officer |
| INQUIRIES, FEEDBACK AND ACCESSIBILITY |
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The CSA strives to comply with all accessibility regulations in jurisdictions in which it operates. Feedback on the delivery and accessibility of our products and services is encouraged from all of our members. All privacy and accessibility related inquiries and feedback should be directed to the Privacy and Compliance Officer of the CSA in written format using the above contact information. Submissions should include the following:
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