Privacy Policy

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Purpose of Policy.  The purpose of this Policy is to ensure the protection of personal information collected or under the control of Nieuport Aviation Infrastructure Partners GP (Nieuport) and to clarify guidelines with the respect to the collection, use and disclosure and retention of such personal. 

Nieuport respects and upholds an individual’s right to privacy and to protection of his or her personal information.

Nieuport is responsible and accountable for personal information under its control and will treat such information in accordance with legislation, regulations and best practices when appropriate.

Definitions

‘Personal information’ means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number, social insurance number, gender, income and family status. 

Personal information does not include does not include the name, title or business address or telephone number of an employee of an organization.

Aggregated or anonymized information which cannot be associated with a specific individual also is not personal information.

The Regulations to the Act specify information that is publicly available and which may be collected, used and disclosed without consent as being:

1. personal information consisting of the name, address and telephone number of a subscriber that appears in the telephone directory that is available to the public, where the subscriber can refuse to have the personal information appear in the directory;
2. personal information including the name, title, address and telephone number of an individual that appears in a professional or business directory that is available to the public, where the collection, use and disclosure of the personal information relates directly to the purpose for which the information appears in the directory;
3. personal information that appears in a registry collected under a statutory authority and to which a right of public access is authorized by law, where the collection, use and disclosure of the personal information relate directly to the purpose for which the information appears in the registry;
4. personal information that appears in a record of a judicial or quasi-judicial body to which public access is permitted, where the collection, use and disclosure of the personal information relate directly to the purpose for which the information appears in the record;
5. personal information that appears in a publication, including a magazine, book, or newspaper that is available to the public, where the individual has provided the information.

‘Customer’ for the purposes of this policy is any individual who uses or applies to use the Nieuport’s products, services, or facilities, including the website.

‘Third party’ for the purposes of this policy is an individual or an organization other than Nieuport and its customers.

Collection and Use. Nieuport collects and uses personal information that is voluntarily provided by you. This information is collected and used for the following purposes:

1. To develop, enhance, improve or provide products, facilities and services
2. To process payment for the use of products, services, and facilities
3. To enhance safety and security
4. In order to understand and respond to questions / requests for information
5. For identification purposes e.g. passes for restricted areas‍
6. For direct marketing purposes
7. For the online experience and online services
8. To comply with legal and regulatory requirements

Nieuport only collects personal information for the purposes identified above and only to the extent required for such purposes.

Disclosure. The only circumstances under which personal information may be disclosed to third parties is for the fulfillment of any purposes identified above, as required by law, or with customer consent. Where personal information is disclosed to a third party for the fulfillment of any purposes identified above, Nieuport will make all reasonable efforts to ensure that the third party has appropriate policies and measures in place to protect personal information.

Consent.  When you provide Nieuport with your personal information, you implicitly consent to the use of your personal information as identified in this policy, and as may be further identified at the time of collection. Sometimes you will be asked to give your express consent, such as by checking a box to indicate your consent to receive marketing communications.

Unless otherwise advised by you, your use of Nieuport’s products, facilities and services constitutes implicit consent for Nieuport to collect, use, and disclose personal information for the purposes stated in this policy.

Withdrawing or Refusing Consent. You may withdraw or refuse consent at any time, subject to legal and contractual restrictions and reasonable notice.  Withdrawal or Refusal of consent may prevent Nieuport from providing to you a product, service, or access to facilities.

To withdraw or refuse consent contact Nieuport through the contact us link of Nieuport.com. 

Limiting Use, Disclosure, and Retention.  Nieuport will not use or disclose personal information for any purpose other than those for which it was collected, except as required by law, or with consent.

Nieuport will only retain personal information for so long as it is necessary for the purpose it was collected in accordance with this Policy, or as required by law.

Storage and Safeguards.  Nieuport will make all reasonable efforts to ensure that personal information is protected against such risks as loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. 

Safeguards include employee training, physical, administrative, and technological security measures.

When an outside company engaged, contractual or other appropriate means will be used to ensure that your personal information is used in a manner that is consistent with this policy.

Nieuport may process and store personal information in Canada or other countries using third party service providers (for example, web hosting providers and/or payment processers). 

By consenting to the information practices set out in this policy, you specifically consent to your information being processed or stored in Canada or other countries.

Access and Correction.  Customers have the right to access and/or correct their personal information under the control of the Nieuport. 

Access or correction requests should be made to the Privacy Officer, in writing, through the contact us link of Nieuport.com. 

Subject to privacy legislation, Nieuport, in certain exceptional situations, may be unable to grat access to certain personal information under its control. Examples include, but are not limited to:

• where access may reveal personal information about another individual;
• where access would reveal confidential commercial information;
• where the information is subject to solicitor-client privilege; or
• where the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law.

If access cannot be provided, Nieuport will notify the individual making the request, in writing, of the reasons for the refusal.

Revisions to this Privacy Policy.  Nieuport’s policies are regularly reviewed and updated. For certainty, the most current version of this Policy is available at nieuport.com. 

Questions or Concerns Regarding Nieuport’s Compliance.  General questions regarding this policy should be directed through the contact us link of Nieuport.com.

Nieuport will investigate any complaints received in writing. If a complaint is found to be justified, appropriate measures will be taken to resolve the complaint including, if necessary, amending policies and procedures. A customer will be informed, in writing, of the outcome of the investigation regarding his or her complaint.

Why is there a Privacy Policy.  In April 2000, the Personal Information Protection and Electronic Documents Act, (the “Act” or “PIPEDA”) was passed. It sets out rules for the management of personal information by private sector organizations in respect of their commercial activities. 

The Act strives to achieve a balance between:

• the right of privacy of individuals with respect to their personal information; and
• the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.

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