Privacy Policy

OVERVIEW

Last revised January 15, 2024

The collection, use and disclosure of personal information are a critical part of our business. Protection of all information collected is of the utmost importance to us.

In this policy ‘Luxus’ means The Luxus Group, Luxus Vacation Properties, and its affiliated companies. The words ‘we’ and ‘Luxus’ do not include third parties involved in the delivery of services; however, we have requested that all parties associated with The Luxus Group abide by the terms of our Privacy Policy.

This Privacy Policy describes the type of information we collect and receive, the policies and procedures we have established for its use and storage, and our policies for sharing certain types of personal information in specific limited circumstances. This Privacy Policy may be amended from time to time. Notice of change is given by posting our revised Privacy Policy on our website at www.luxusgroup.com and continued use of the Luxus services shall constitute consent to the changes to the Privacy Policy. An up-to-date version of this Privacy Policy may be obtained on our website, or by e-mailing us at [email protected].

WHAT IS PERSONAL INFORMATION

“Personal information” is information about an identifiable individual. This includes any information which can be linked to an individual’s identity, such as name, age, gender, occupation, contact information, financial information, and other information. It does not apply to the information of non-individuals, such as corporations and other business entities and, generally speaking, to business contact information of individuals.

THE TYPE OF INFORMATION WE COLLECT AND RECEIVE

Luxus collects personal information in order to establish and maintain responsible business relationships (administration) and to provide ongoing service. Personal information is used to manage and develop our business operations and marketing activities (optional). Information on Luxus Partners is collected to meet both legal and service delivery requirements.

There are several ways that you may provide us with your personal information:

By personally requesting information on our Company, contacting us via email, phone, or in-person or by providing your contact information through an organized networking event or activity.

By signing up for our newsletter on our websites or by contacting us via email, phone, or in-person.

HOW DO WE OBTAIN CONSENT

We ask for consent to collect, use, or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.

We assume your consent to continue to use and, where applicable, disclose personal information that we have already collected, for the purpose for which the information was collected.

We will ask for your express consent for most purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask customers to provide their consent in writing by signing a consent form.

WITHDRAWING YOUR CONSENT

You may also withdraw your consent with respect to the use of your personal information for the purposes described in our Privacy Policy at any time, subject to legal or contractual restrictions and reasonable notice, by e-mailing us at [email protected], and providing us sufficient personal identifiers so we can act effectively on your request.

You may unsubscribe from our marketing emails at any time by clicking on the “unsubscribe” link at the bottom of each newsletter or by emailing [email protected] with your request.

THE POLICIES AND PROCEDURES WE HAVE ESTABLISHED FOR ITS USE AND STORAGE

Personal information collected by Luxus is stored in Canada. Should any personal information collected by Luxus be transferred outside of Canada for storage purposes, Luxus will inform all affected persons within a reasonable amount of time.

Luxus will only keep personal information for as long as it is required to fulfill the purpose described in this Privacy Policy, or as is required or permitted by law. Information disclosed to third parties for the purpose of delivering service to a Luxus Partner, is requested to be destroyed after two weeks following its use. When information is no longer required it is thoroughly and properly destroyed. Any requests to be removed from our database are handled immediately. Whether electronic, or on paper, all files containing personal information are kept under strict security measures. We restrict access to personal information to those employees and contractors who need to access it to perform their job functions. We attempt to collect and use information that is accurate, up-to-date, and as complete as possible.

We have implemented technical, physical, and organizational security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.

OUR POLICIES FOR SHARING CERTAIN TYPES OF PERSONAL INFORMATION IN SPECIFIC LIMITED CIRCUMSTANCES

It is our policy never to disclose personal information to any third parties, except as it relates to the delivery of service to Limited Partners. Personal information will only be used by an authorized representative of Luxus for the purpose of contacting you, as long as you maintain an interest in receiving those communications. If at any point you do not wish to receive our communications, you will be removed from our database.

If Luxus wishes to use or disclose your personal information for any new business purpose, it will ask for your consent and it will not use or disclose your personal information for that new purpose until it has received your consent.

Unauthorized disclosure of company information by Luxus Team Members is not permitted. All Luxus Team Members are required to keep the business activities of Luxus strictly confidential, including protecting the privacy of our Partners and the security of our properties. All Luxus Team Members must be familiar with and abide by the Company’s Privacy Policy.

ACCESS TO RECORDS CONTAINING PERSONAL INFORMATION

Customers of Luxus have a right of access to their own personal information in a record that is in Luxus’ custody or under its control, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act (PIPA) (the “Act”) to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.

If Luxus refuses a request in whole or in part, it will provide the reasons for the refusal. In some cases where exceptions to access apply, Luxus may withhold that information and provide the customer with the remainder of the record.

A customer may make a request for access to his/her personal information in writing to Luxus’ Privacy Officer. A customer must provide sufficient information in his/her request to allow Luxus to identify the personal information sought by the customer.

A customer may also request information about Luxus’ use of their personal information and any disclosure of that information to persons outside Luxus.

A customer may also request a correction of an error or omission in his/her personal information. Luxus will respond to a customer’s request within 45 calendar days, unless an extension is granted.

Changes to this Privacy Policy

We will continue to evaluate this Privacy Policy as we update and expand our Services, and we may make changes to the Privacy Policy accordingly. We will post any changes here and revise the date last updated above. We encourage you to check this page periodically for updates to stay informed on how we collect, use, and share your information. If we make material changes to this Privacy Policy, we will provide you with notice as required by law.

HOW TO CONTACT US

If you have questions or concerns about our privacy practices or wish to make a request in respect of your personal information, please contact Luxus’ Privacy Officer. To protect your privacy and security, we take reasonable steps to verify your identity before granting access to information held by us or making corrections.

THE LUXUS GROUP PRIVACY OFFICER Our Privacy Officer may be contacted by email at [email protected] or if you prefer in writing at the following address:

Attention: Pam Bristow (Privacy Officer) The Luxus Group #330, 849 Premier Way Sherwood Park, AB T8H 0V2