Introduction
Monchu Inc., (hereinafter referred to as "Xcitelife", "we", "us" or "our") owns and operates a platform and community marketplace that offers members access to information including, but not limited to, listing, arranging and reservation services for adventure, travel and cultural exploration event packages of others over a global computer network; providing a website featuring listings and bookings for adventure, travel and cultural exploration event packages of others; providing a website featuring information regarding adventure, travel and cultural exploration event packages of others; providing a website featuring a public record of third parties's attendance at adventure, travel and cultural exploration events of others; and Operation and supervision of sales and promotional incentive schemes, which may be requested through the use of mobile or web application supplied by Xcitelife and/or downloaded and installed by you on your single mobile device (smart phone) (the "Application"). All services provided by Xcitelife to you by means of your use of the Application are hereafter referred to as the "Member Service".
We respect our Users ("You"/"Your") rights with respect to our collection of your Personal Information (as defined below). Personal Information collected by us will be kept strictly confidential and will only be collected, used and disclosed as provided for in this policy or as otherwise specifically consented to by You. The policy will apply to and protect Personal Information collected by Xcitelife, except information that is aggregated in such a manner that it cannot be connected to a person and/or information which is publicly listed in a written or online directory or typically made available through directory assistance.
For the purposes of this policy, “Personal Information” means information about an identifiable individual that is recorded in any form, but does not include aggregated information that can be associated with a specific User, which is aggregated in such a manner that it cannot be connected to him/her and/or information which is publicly listed in a written or online directory or typically made available through directory assistance.
Scope
Xcitelife’s policy applies to Personal Information about identifiable Xcitelife Users that is collected, provided, used or disclosed to Xcitelife in connection with Your use of the platform (the “Services”). It also applies to the management of Personal Information in any form whether oral, electronic or written.
Personal information which may fall under the policy may include but is not limited to:
1. User registration information, including your name, date of birth, gender, physical address, email address and phone number;
2. Information disclosed by You regarding your preferences, past experiences shared by You, bucket list, gift registry, photo gallery, feedback, reviews and comments
3. User names and passwords;
Collection of Personal Information
In using the Platform and providing You with the Services, you will have the option to, but not limited to, post and upload information pertaining to your profile, discover, search and book and/or reserve adventure, travel and cultural exploration event packages. However, aside from User Content, any other Personal Information, such as user name and contact information, will only be disclosed to a Vendor or Partner once you have granted permission by booking, reserving or purchasing an experience. Otherwise, we only collect Personal Information that You consciously provide us as we provide you with the Services, such as registration information. We may also collect Personal Information if you contact us, through e-mail, telephone conversations or the completion of forms, for support and other inquiries.
Principles
Xcitelife’s privacy policy is organized along the privacy principles of The Personal Information Protection and Electronic Documents Act (PIPEDA) https://www.priv.gc.ca/leg_c/leg_c_p_e.asp
Principle #1 – Accountability
Xcitelife is responsible for Personal Information under its control and has designated its Privacy Officer as accountable for the company’s compliance with the following principles.
1. Accountability for Xcitelife’s compliance with the provisions of Xcitelife’s privacy policy rests with the Privacy Office within Xcitelife, which shall designate one or more persons to be accountable for compliance with the privacy policy. Other individuals within Xcitelife may be delegated to act on behalf of designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information. The Privacy Office has been created to ensure Users and employees have a designated avenue to answer their privacy-related inquiries.
2. Xcitelife shall make known, upon request, the title of the person or persons designated to oversee Xcitelife’s compliance with this policy. 3. Xcitelife is responsible for Personal Information in its possession or custody, but not including information that has been transferred to vendor partner part of our network. Xcitelife shall use contractual or other means to provide a comparable level of protection while the information is being processed by our vendor partner. 4. Xcitelife shall implement policies and practices to give effect to these principles:
(a) Implementing procedures to protect Personal Information;
(b) Establishing procedures to receive and respond to complaints and inquiries;
(c) Training staff and communicating to staff information about the organization’s policies and practices; and
(d) Developing information to explain the organization’s policies and procedures.
Principle #2 – Identifying Purposes
Where appropriate, Xcitelife will identify the purposes for which Personal Information is collected at or before the time the information is collected.
1. Xcitelife collects Personal Information only for the following purposes:
(a) To provide Services to You;
(b) To establish and maintain responsible commercial relations with Users and to communicate with its Users (which will include, but not be limited to: advertising, promotion and account verification);
(c) To understand User needs and preferences;
(d) To meet legal and regulatory requirements; and
(e) To administer and manage its business operations.
2. Except where the collection of Personal Information is reasonably necessary in order to carry out the express wishes of the User (including User Content), Xcitelife shall specify orally, electronically or in writing the identified purposes to the User at or before the time Personal Information is collected.
3. Persons collecting Personal Information will be able to explain to individuals the purposes for which the information is being collected, or will refer the individual to a designated person at Xcitelife who will explain the purposes.
4. Unless required by law, Xcitelife shall not use or disclose Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining the consent from You, where such consent may not reasonably be implied.
Principle #3 - Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except in certain circumstances as described below:
1. In certain circumstances, Personal Information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information.
2. Where appropriate, Xcitelife will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Xcitelife wants to use information for a purpose other than those identified above).
3. In obtaining consent, Xcitelife will use reasonable efforts to ensure that You are advised of the identified purposes for which Personal Information collected will be used or disclosed.
4. The form of consent sought by Xcitelife may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, Xcitelife shall take into account the sensitivity of the Personal Information and the reasonable expectations of its Users and employees.
5. Xcitelife will seek consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive. Your use of the Services, including uploading User Content, will be considered implied consent to collect, use and disclose Personal Information for all identified purposes.
6. You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Xcitelife will inform the individual of the implications of such withdrawal. In order to withdraw consent, You must provide notice to Xcitelife in writing.
Principle #4 - Limiting Collection
The collection of Personal Information will be limited to that which is necessary for the purposes identified by Xcitelife. Information will be collected by fair and lawful means.
-- Xcitelife collects Personal Information from its Users for the purposes described under Principle #2.
Principle #5 - Use and Retention of Personal Information
Any Personal Information collected by us will be used solely for the purposes of carrying on our internal business affairs and providing Xcitelife Services to You, and other services as You may request and authorize from time to time. Personal Information will be retained as long as you are a member of the Xcitelife community.
1. Xcitelife may collect, use or disclose Personal Information without Your knowledge or consent in certain circumstances as described in Principle #3.1.
2. Xcitelife may disclose Your Personal Information to:
(a) a Vendor partner who you wish to hear more about a Vendor or Unique experience, after you have requested so via the website or smartphone application;
(b) an Xcitelife affiliated company; and
(c) any other third party, upon receiving Your consent or as required by law.
3. Only Xcitelife’s employees with a business need to know, or whose duties reasonably so require are granted access to Your Personal Information.
4. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Xcitelife, if the You no longer wish to be a member of the Xcitelife community.
5. We do not currently convey Your or Your Users’ Personal Information to third parties for the purposes of outsourcing, Xcitelife services or other storage or processing. To the extent that may occur in the future, Xcitelife commits to contractually bind such entities to abide by the fundamental terms of this policy and applicable laws, including with respect to their capability to use, disclose and retain such Personal Information.
6. Except as provided for in this policy, we will not sell, rent, lease, commercially exploit or otherwise disclose Your Personal Information or data to third parties unless: (i) required by law or to cooperate with any bona fide legal investigation; (ii) required to protect the legal interests of Xcitelife, including for credit checking and collection purposes, as applicable; or (iii) You provide consent to such disclosure.
Principle #6 - Accuracy
Xcitelife shall ensure that Personal Information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Xcitelife will update Personal Information as and when necessary to fulfill the identified purposes or upon notification by the individual.
Principle #7 - Security
Personal Information will be protected by security safeguards appropriate to the sensitivity of the information.
1. Any Personal Information in our possession is stored electronically, either on our server or on other electronic storage media that may be retained as part of Your files or otherwise.
2. We have security measures in place to protect against the loss, misuse, access to or alteration of Your Personal Information and data under our control.
3. We operate computer networks that are protected by industry standard firewalls and password protection. Appropriate physical and managerial security is also in place. including but not limited to the execution by our employees of a confidentiality/non-disclosure agreement as a standard practice of our hiring and employment.
4. Xcitelife will protect Personal Information it discloses to third parties through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
5. While we cannot guarantee that loss, misuse or alteration to Your data will not occur, we will use our resources and expertise to attempt to prevent such occurrences.
6. We commit to providing a minimum of an annual review and training with respect to this policy among our staff with potential access to Your Personal Information.
Principle #8 – Openness
Xcitelife will make readily available to You information about its policies and practices relating to the management of Personal Information.
1. Xcitelife will make information about its policies and practices easy to understand, including:
(a) the title and address of the person(s) accountable for Xcitelife’s compliance with the policy and to whom inquiries or complaints can be forwarded;
(b) the means of gaining access to Personal Information held by Xcitelife; and
(c) a description of the type of Personal Information held by Xcitelife.
2. Xcitelife will make this privacy policy available online at http://www.xcitelife.com/privacypolicy
Principle #9 - Access
Upon request, Xcitelife will inform you of the existence, use and disclosure of Your Personal Information. You may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain situations, Xcitelife may not be able to provide access to all of the Personal Information it holds about You. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. Xcitelife will provide the reasons for denying access upon request.
1. You may access or inquire about Your Personal Information in our possession at any time during our business hours. The Personal Information requested will be provided within a reasonable time, and at a minimal or no cost to You.
2. You always have the right to request that we delete, destroy, return, amend or update Your Personal Information in our possession as You may direct, subject to reasonable notice.
3. Xcitelife will be specific as possible in providing an account of third parties to which it has disclosed Your Personal Information. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, Xcitelife will provide a list of organizations to which it may have disclosed
Principle #10 – Challenging Compliance
In the event of any dispute, complaint or problem with respect to this policy and related Xcitelife practices, a definitive procedure for resolution has been established as outlined below. Xcitelife is committed to resolving any such issues promptly, justly, objectively and, where possible, confidentially.
A written outline of the issue should be forwarded directly to the Privacy Officer of Xcitelife, who in turn will investigate, examine and evaluate all the facts. On the information gathered and other related details, a formal written decision will be completed and will be forwarded to You within 30 days of the Privacy Officer’s receipt of Your complaint. During investigation of the issue, it may be necessary for further Personal Information to be shared with the Privacy Officer or other appropriate parties internal or external to Xcitelife. In all cases, Xcitelife will remain responsible for the protection of all such Personal Information.
You may also contact the office of the Privacy Commissioner of the federal government if You are dissatisfied with the implementation of the policy by Xcitelife.
Notification of changes
We may update this privacy policy from time to time, so please review it periodically on our website at http://www.xcitelife.com/privacypolicy . However, regardless of our right to update this policy as indicated, we will never use Personal Information that You have provided to us in a new way without providing You an opportunity to give us Your consent.
Contact Us
For further information concerning this privacy policy or its application or for access to Your’ Personal Information, please write to us, via e-mail at info@xcitelife.com. The Privacy Officer at Xcitelife is Kye Husbands (Monchu Inc).
