We Protect Your Data
At HighStreet Accommodations, we are committed to providing our clients and residents with exceptional service and accommodations. As providing this service involves the collection, use, and disclosure of certain personal information, protecting the personal information of our clients and residents is one of our highest priorities.
While we have always respected the privacy of our clients and residents, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (“PIPA”).
We will inform our clients and residents of why and how we collect, use, and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ and residents’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ and residents’ personal information and allowing our clients, customers, members to request access to, and correction of, their personal information.
Personal Information – means information about an identifiable individual. For example, at a move-in, HighStreet’s Resident Services Representative will use the Resident Registration Card to collect basic personal information including first and last names, home address, and home telephone number or personal mobile number. Under PIPA, Personal Information does not include Contact Information (described below).
Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that HighStreet Accommodations complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client or resident voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client or resident information that is necessary to fulfill the following purposes:
- To verify identity. To verify identity, we may ask to view a resident’s driver’s license, BC ID card, or passport to confirm identity against the information provided with the reservation;
- To identify client or resident preferences;
- To understand the accommodation needs of our clients and residents;
- To deliver requested accommodations and related services;
- To ensure a high standard of service to our clients and residents;
- To verify creditworthiness. To verify creditworthiness, we may ask for a valid credit card number against which we will process a temporary pre-authorization in the amount of $500.
Policy 2 – Consent
2.1 We will obtain client and/or resident consent to collect, use, or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Clients and/or residents can provide consent orally, in writing, electronically, through an authorized representative, or consent can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client and/or resident voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client or resident is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client or resident does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the accommodations and related services the client or resident has purchased from us, or the withdrawal of consent would frustrate the performance of a legal obligation), clients and residents can withhold or withdraw their consent for HighStreet Accommodations to use their personal information in certain ways. A client’s or resident’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client or resident in making the decision.
2.5 We may collect, use or disclose personal information without the client’s or resident’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud; and
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client or resident personal information where necessary to fulfill the purposes identified at the time of collection.
3.2 We will not use or disclose client or resident personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client or resident member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client or resident personal information to make a decision that directly affects the client or resident, we will retain that personal information for at least one year so that the client or resident has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client and resident personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client and resident personal information is accurate and complete where it may be used to make a decision about the client and resident or disclosed to another organization.
5.2 Clients and residents may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ or residents’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client and resident personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 At HighStreet Accommodations, the following security measures are followed to ensure that client and resident personal information is appropriately protected:
- Physically secured office premises where personal information is held, including the use of locked offices and locked filing cabinets;
- The use of user IDs, passwords, encryption, and firewalls;
- The use of a private, local server and network (i.e. no cloud storage or cloud-based services); and
- The restriction of employee access to personal information as appropriate, so that only those that need to know will have access.
6.3 We will use appropriate security measures when destroying clients’ and residents’ personal information such as shredding documents and permanently deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients and Residents Access to Personal Information
7.1 Clients and residents have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell and residents how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client or resident of the cost and request further direction from the client or resident on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client or resident in writing, providing the reasons for refusal and the recourse available to the client or resident.
Policy 8 – Service Providers
8.1 We use certain Google Analytics advertising features, including demographics and audience targeting tools, which are part of Google’s web analytics service that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
8.3 For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
8.4 For more information about how Google uses information from other websites or apps that use Google’s services, please see: https://policies.google.com/technologies/partner-sites
Policy 9 – Questions and Complaints: the Role of the Privacy Officer
9.1 The Privacy Officer is responsible for ensuring HighStreet Accommodations’ compliance with this policy and the Personal Information Protection Act.
9.2 Clients and residents should direct any complaints, concerns or questions regarding HighStreet Accommodations’ compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer, member may also write to the Information and Privacy Commissioner of British Columbia.
General Data Protection Regulation (GDPR) Compliance Statement
Under the GDPR, HighStreet Accommodations is both a data controller and also a data processor, meaning our clients provide us with the personal data we need to provide our accommodations and related services. We are responsible for the personal data that we collect and we take care that data is accurate, kept up to date, and removed when no longer necessary.
We are committed to:
-Transparency with regard to the use of data;
-Lawful, fair, transparent, and necessary processing of the data provided to us for a specific purpose; and
-Safe, secure storage of data while it is being used.
GDPR compliance and Google Analytics
When we collect personal information through cookies, website forms, and other features on hscr.com, we will not identify users or facilitate the merging of personally identifiable information with non-personally identifiable information collected through any Google Analytics tool unless we have provided robust notice of, and obtained the user’s prior affirmative (i.e., opt-in) consent to, that identification or merger, and are using a Google Analytics feature that expressly supports such identification or merger. Irrespective of users’ consent, we will never attempt to disaggregate data that Google reports in aggregate.
Terms & Conditions of www.hscr.com
By accessing or using the website operated at www.hscr.com and such other locations as made available from time to time (collectively, the “website”) and the accommodations and related services offered through the website, you (“you” and, together with all persons accessing or using the website, collectively, the “users”) signify that you have read, understand and agree to be bound by these terms and conditions (the “terms and conditions”) with HighStreet Accommodations Ltd. (“us”, “we” or “our”), in all respects with respect to the website.
PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY AS THEY CONTAIN IMPORTANT INFORMATION REGARDING YOUR LEGAL RIGHTS, REMEDIES AND OBLIGATIONS. THESE INCLUDE, BUT ARE NOT LIMITED TO, VARIOUS LIMITATIONS AND EXCLUSIONS, AND INDEMNITIES.
Your use of the website is subject to these terms and conditions. If you are not willing to be bound by each and every term or condition, or if any representation made herein by you is not true, you may not use, and must cease using, the website.
2. Amendments. We reserve the right to amend these terms and conditions at any time without notice to you. We will use reasonable efforts to publish each amendment before such amendment becomes effective. We will ensure that the latest, fully amended version of these terms and conditions is published on this website. You are responsible for regularly reviewing the website to obtain timely notice of such amendments. If any amendment is unacceptable to you, you may terminate the agreement between you and us regarding the use of the website as set out in these terms and conditions. If you continue to use the website after the effective date of each amendment, you will be conclusively deemed to have accepted such amended version of these terms and conditions.
3. Legal Capacity. You represent and warrant that you possess the legal right, capacity and ability to agree to these terms and conditions and use the website in accordance with them. If you are using the website on behalf of a corporation or other organization, you represent and warrant that you have the ability to agree to these terms and conditions on behalf of such organization and all references to “you” throughout these terms and conditions will include such organization, jointly and severally with you personally.
4. License. We grant to you a non-exclusive, non-transferable, limited license only to use the website in accordance with the provisions set out in these terms and conditions. All rights not expressly granted to you in these terms and conditions are reserved by us.
5. Website Limitations. The website depends on the Internet, including networks, cabling, facilities and equipment that is not in our control; accordingly (i) any representation made by us regarding access performance, speeds, reliability, availability, use or consistency of the website is on a “commercially reasonable efforts” basis, (ii) we cannot guarantee any minimum level regarding such performance, speed, reliability, availability, use or consistency, and (iii) data, messages, information or materials sent over the Internet may not be completely private, and your anonymity is not guaranteed.
6. Acceptable Use and Prohibitions.
a. Lawful Use. You will ensure that
i. you only use the website for lawful purposes, and
ii. if at any time you become aware of any violation by any person or entity of any part of these terms and conditions, you will immediately notify us and provide us with assistance, as requested, to stop or remedy such violation.
b. Prohibited Conduct. Without limiting the generality of any other restriction in these terms and conditions, you agree that you will not, in connection with the website, directly or directly do or permit any of the following:
i. post, upload, reproduce, distribute or otherwise transmit any Content (defined below) that
1. is unauthorized or unsolicited commercial communications, junk or bulk communications or other “spam” (whether or not using e-mail services, including instant messaging, blog or comment spam) or is otherwise duplicative or unsolicited,
2. contains a virus, cancelbot, Trojan horse, worm or other harmful, disruptive or surreptitious component,
3. is defamatory, infringing, or unlawful,
4. is inappropriate, profane, obscene, indecent, or contains information without suitable or lawfully-required access controls (which controls will in no event be our responsibility),
5. gives rise to civil liability, or otherwise violates the rights or assists others to violate the rights of us or any third party, such violations including engaging in copyright infringement, invasion of privacy, trademark infringement or defamation, or
6. constitutes a criminal offence, or otherwise engages in or assists others to engage in any criminal offence, including communicating hatred, pyramid selling, unauthorized use of a computer, mischief in relation to data, fraud, obscenity and child pornography;
7. engage in threats, harassment, intimidation, stalking or abuse or any conduct that violates the legal rights of others, including the rights of minors and rights relating to privacy and publicity;
8. scan or probe another computer system, obstruct or bypass computer identification procedures or engage in unauthorized computer or network trespass without the express permission of the owners of such computer systems;
9. forge headers or otherwise manipulate any protocols or identifiers used in any system or protocol in such a manner to disguise the origin of any data transmitted using the website;
10. impersonate or falsely represent your association with any person, including a representative of us;
ii. disrupt or threaten the integrity, operation or security of any Website, any computer or any Internet system;
iii. disable or circumvent any access control or related process or procedure established with respect to the website;
iv. sublicense, share, resell, reproduce, copy, distribute, redistribute, or exploit for any commercial purposes (except for your internal business purposes), any portion of, use of or access to, any website, except where expressly authorized by us; or
v. extract, gather, collect, or store personal information about others without their express consent.
c. Our Remedies. Without limiting any of our rights, we may suspend, restrict or terminate your use of the website without notice if, in our sole and absolute discretion, we determine or believe that you have violated any of the acceptable use rules set out above.
7. Proprietary Rights.
a. Content — “Content” means all materials and content, including designs, editorial, text, graphics, audiovisual materials, multimedia elements, photographs, videos, music, sound recordings, reports, documents, software, information, formulae, patterns, data and any other work.
b. Third-Party Content — Content accessed or available through the website or the Internet may be owned by parties other than you or us (collectively, “Third Party Content”) and may be protected by applicable copyrights, trade-marks, patents, trade secrets or other proprietary rights and laws. Nothing in your use of the website or these terms and conditions grants you any right, title or interest in or to this Third Party Content except for the limited right to use the Website as set out in these terms and conditions. The website may contain links to Third Party Content on websites operated by parties other than you or us (“Third Party Websites”). We are under no obligation to verify the accuracy of the contents on Third Party Websites, and we do not endorse, warrant, promote or recommend any services or products that may be offered by or accessed through such Third Party Websites or the operators of them.
Our Content — Except where expressly stated otherwise, all right, title and interest in and to the website and all Content, source code, processes, designs, technologies, URLs, domain names, marks and logos forming any part of the website (collectively, “our content”) is fully vested in us and are protected by applicable copyrights, trade-marks, trade secrets or other proprietary rights and laws. You agree that our content is licensed subject to the terms of these terms and conditions, including the disclaimers and limitations of liability herein. Nothing in your use of the website or these terms and conditions grants you any right, title or interest in or to our content except the limited right to use the website as set out in these terms and conditions. Unless otherwise expressly authorized by us in writing, you agree not to
i. copy, modify, deep link, rent, lease, loan, sell, assign, sublicense, grant a security interest in or otherwise transfer any right or interest in our content
ii. distribute, create a derivative work of, reverse engineer, reverse assemble or otherwise attempt to discover the source code, of our content, to the maximum extent that such prohibition is permitted by applicable law
iii. remove any proprietary notices or labels on or in our content, or
iv. allow any other person or entity to engage in any of the foregoing.
8. Termination of Use. We may, in our sole discretion, suspend, restrict or terminate your use of the website, effective at any time, without notice to you, for any reason, including because the operation or efficiency of the website or our or any third party’s equipment or network is impaired by your use of the website, any amount is past due from you to us, we have received a third party complaint which relates to your use or misuse of the website, or you have been or are in breach of any term or condition of these terms and conditions. We will have no responsibility to notify any third party, including any third party providers of services, merchandise or information, of any suspension, restriction or termination of your access to the website.
9. DISCLAIMERS, LIMITS OF LIABILITY AND INDEMNITIES.
a. CUSTOMER ACKNOWLEDGEMENT—YOU ACKNOWLEDGE AND AGREE THAT:
i. ALL USE OF THE WEBSITE PROVIDED BY US IS AT YOUR OWN RISK;
ii. THE WEBSITE MAY CONTAIN LINKS TO OTHER WEBSITES, WHICH ARE PROVIDED SOLELY AS A CONVENIENCE TO YOU AND THE INCLUSION OF ANY SUCH LINK DOES NOT IMPLY ENDORSEMENT, INVESTIGATION OR VERIFICATION BY US OF SUCH WEBSITES OR THE INFORMATION CONTAINED THEREIN; AND
iii. THE WEBSITE PROVIDED UNDER THESE TERMS AND CONDITIONS IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.
b. DISCLAIMER OF WARRANTIES—WE MAKE NO CONDITIONS, WARRANTIES OR REPRESENTATIONS ABOUT THE SUITABILITY, RELIABILITY, USABILITY, SECURITY, QUALITY, CAPACITY, PERFORMANCE, AVAILABILITY, TIMELINESS OR ACCURACY OF THE WEBSITE OR ANY OTHER PRODUCTS SUPPLIED UNDER THESE TERMS AND CONDITIONS. WE EXPRESSLY DISCLAIM ALL CONDITIONS, WARRANTIES AND REPRESENTATIONS, EXPRESS, IMPLIED OR STATUTORY, INCLUDING IMPLIED CONDITIONS OR WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, DURABILITY, TITLE AND NON-INFRINGEMENT, WHETHER ARISING BY USAGE OF TRADE, BY COURSE OF DEALING, BY COURSE OF PERFORMANCE, AT LAW, IN EQUITY, BY STATUTE OR OTHERWISE HOWSOEVER.
c. NO LIABILITY—NOTWITHSTANDING ANY OTHER PROVISION OF THESE TERMS AND CONDITIONS, IN NO EVENT WILL WE, OUR AFFILIATES, AGENTS, EMPLOYEES, SUPPLIERS, RESELLERS AND DISTRIBUTORS (COLLECTIVELY, IN THESE CAPITALIZED SECTIONS, “WE” OR “US”) BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, OR ANY OTHER DAMAGES OR LOSSES WHATSOEVER, INCLUDING DAMAGES FOR LOSS OF PROFITS, GOODWILL, OPPORTUNITY, EARNINGS, USE OR DATA, ARISING DIRECTLY OR INDIRECTLY FROM OR RELATED TO THESE TERMS AND CONDITIONS OR THE USE, OR NON-USE OF THE WEBSITE REGARDLESS OF THE CAUSE OF ACTION AND EVEN IF ONE OR MORE OF US HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES, INCLUDING DAMAGES OR LOSSES ARISING FROM OR IN ANY WAY RELATED TO THE FOLLOWING: (i) ANY LOSS OR DAMAGE TO DATA ARISING DIRECTLY OR INDIRECTLY OUT OF USE OR NON-USE OF THE WEBSITE OR RELATED COMPONENT; (ii) DELAYS, ERRORS, INTERRUPTIONS, MISTAKES, OMISSIONS, NON-DELIVERY, INCORRECT DELIVERY, OR DEFECTS ON OR RELATED TO THE WEBSITE. WITHOUT RESTRICTING THE FOREGOING, IF CIRCUMSTANCES ARISE IN WHICH YOU OR ANOTHER PARTY IS ENTITLED TO RECOVER DAMAGES FROM ONE OR MORE OF US, THE AGGREGATE LIABILITY OF US FOR DAMAGES IS LIMITED TO THE AMOUNT PAID TO US BY YOU THROUGH THE WEBSITE DURING THE SIX-MONTH PERIOD PRECEDING THE CIRCUMSTANCES IN WHICH SUCH LIABILITY ARISES.
d. APPLICABILITY—SOME JURISDICTIONS PROHIBIT THE DISCLAIMER OF CERTAIN WARRANTIES OR CONDITIONS OR THE LIMITATION OF CERTAIN TYPES OF LIABILITY. IN SUCH CIRCUMSTANCES, TO THE EXTENT THAT SUCH PROHIBITIONS PROHIBIT ANY EXCLUSIONS AND LIMITATIONS IN THESE TERMS AND CONDITIONS, SUCH EXCLUSIONS AND LIMITATIONS WILL NOT APPLY TO YOU STRICTLY TO THE EXTENT NECESSARY TO MAKE THESE TERMS AND CONDITIONS CONSISTENT WITH SUCH PROHIBITIONS.
10. Enforceability. Your use of the website and the content and features accessed through the website constitute your electronic signature to the agreement set out in these terms and conditions and your consent to enter into agreements with us electronically. This Agreement will be deemed to satisfy any writings requirements of any applicable law, notwithstanding that the agreement set out in these terms and conditions is written and accepted electronically. All contracts between you and us completed electronically will be deemed for all legal purposes to be in writing and legally enforceable as a signed written agreement.
11. Interpretation. In these terms and conditions, (i) the captions and headings are for convenience only and do not constitute substantive matter and are not to be construed as interpreting the contents of these terms and conditions, (ii) the word “including”, the word “includes” and the phrase “such as”, when following a general statement or term (whether or not non-limiting language such as “without limitation” or “but not limited to” or other words of similar import are used with reference thereto), is not to be construed as limiting, and the word “or” between two or more listed matters does not imply an exclusive relationship between the matters being connected, and (iii) all references to website addresses or URLs will also include any successor or replacement websites containing substantially similar information as the referenced website(s).
12. Waiver of Rights and Remedies. Our failure to insist upon or enforce strict performance of any provision of these terms and conditions will not be construed as a waiver of any provision or right. Neither the course of conduct between you and us nor trade practice will act to modify any provision of these terms and conditions. Our rights, powers and remedies in these terms and conditions, including without limitation the right to suspend, restrict or terminate any use of the website, are cumulative and in addition to and not in substitution for any right, power or remedy that may be available to us at law or in equity.
13. Severability. If any provision of these terms and conditions is determined to be invalid or unenforceable in whole or in part, such invalidity or unenforceability will attach only to such provision or part thereof and the remaining part of such provision and all other provisions hereof will continue in full force and effect.
14. Limitation Period. Any cause of action you may have with respect to these terms and conditions or the Website must be commenced within two years after the claim or cause of action arose, or it will be barred.
15. Notices. Any notice, consent, waiver, approval, authorization or other communication to be delivered in connection with these terms and conditions
a. by us to you will be deemed to have been effectively and validly given if delivered or sent to any of the contact particulars then listed in your Account;
b. by you to us will only be deemed to have been effectively and validly given if in writing and delivered or submitted to the Privacy Officer.
16. Assignment and Inurement. We may at any time assign our rights and obligations under these terms and conditions, in whole or in part, without notice to you. You may not assign these terms and conditions without our prior, written consent. These terms and conditions will inure to the benefit of and bind you and us and our respective personal and legal representatives, successors and permitted assigns.
17. Relationship. You agree that no joint venture, partnership, fiduciary, employment or agency relationship exists between us and you as a result of these Terms and Conditions or use of the website.
18. Force Majeure. Neither party will be responsible for a failure to fulfil its obligations under these terms and conditions or for delay in doing so if such failure or delay is due to circumstances beyond its reasonable control, such as acts of nature, acts of government, war, riots, strikes and accidents in transportation, but excluding a lack of financing, cash or credit.
20. English Language. The parties have requested and agree that these terms and conditions and all documents relating there to be drawn up in English.