Privacy Policy

VIRAM Advisors is a private travel advisory run by two Founders from Vancouver, British Columbia. We arrange first and business class flights and luxury hotels for a small list of clients.

We are the organization responsible for the personal information described here. That means we decide what is collected and how it is used, and we are accountable for looking after it. British Columbia's Personal Information Protection Act (PIPA) governs how we handle personal information. Where our work crosses a provincial or national border, which most travel does, the federal Personal Information Protection and Electronic Documents Act (PIPEDA) also applies.

Correspondence about your information goes to one address, and only the two Founders read it. The address is on our contact page.

Identity and travel-document information. Your full name, date of birth, nationality, passport number and expiry date, and, where a booking requires it, a scanned copy of the passport. Depending on the trip this may also include visa details and the names and passport details of others travelling with you, where you provide them. If you hold a Known Traveller or redress number, we may collect that too — the number an airport or border agency uses to check you.

Contact information. Your address, email address and telephone number, and a preferred way and time to be reached.

Travel preferences. Seat and cabin preferences, airline and hotel loyalty program numbers, room and bedding preferences, and any dietary or accessibility requirements you ask us to arrange. All information remains confidential.

Booking and financial information. Itineraries, confirmations, invoices, and the payment details needed to settle a booking or our fee. Where card details pass through a payment provider, that provider handles them under its own security standards.

Correspondence. The emails, messages and notes that arise from arranging your travel and answering your enquiries.

Canadian privacy law runs on consent. We collect, use and disclose your personal information only for purposes a reasonable person would consider appropriate in the circumstances, and only with your consent.

In most cases that consent is express: you tell us where you are going and give us your passport details so that we can book the flight. Sometimes it is implied by the obvious purpose of what you have asked for — giving us your email address so that we can answer your enquiry is your consent for us to do so.

You may withdraw your consent at any time, subject to legal or contractual restrictions and to reasonable notice. Tell us, and we will explain what withdrawing means for any arrangement already in progress. Once an airline holds a ticket in your name, it has your details and its own obligations, and we cannot remove them from its systems.

The law allows a small number of narrow exceptions to consent — for example where disclosure is required by a court, a tax authority, or a border or aviation authority that lawfully demands passenger information for a booking. We rely on those only where they apply.

To arrange, confirm and service the flights and hotels you ask us to book, including providing the passenger and guest information that airlines, hotels and border authorities require.

To respond to your enquiries, give advice, and manage the working relationship between us.

To handle payment, keep accurate financial records, and meet our tax, accounting and other legal obligations.

To send you occasional communications about our service, where you have asked to receive them.

We collect only what a booking or the relationship reasonably needs. We do not gather information just in case, and we do not build profiles for advertising.

We do not sell your personal information. We have never done so, and we do not share it with advertisers, data brokers, or any third party for their own marketing.

We disclose it in two circumstances. The first is to the airline, hotel, ground transport provider or similar supplier needed to fulfil a booking you have specifically asked us to make. Only what that booking requires is passed on — the passenger name and passport details an airline needs to issue a ticket, for instance. Once your information reaches an airline or hotel, that company handles it under its own privacy policy and on its own account, and we would encourage you to read those where a booking matters to you.

The second is a small number of service providers who support us under contract, such as our payment provider and our secure IT and email systems. They may use your information only on our instructions and never for their own purposes.

We may also disclose information where the law requires it — to a tax authority, or in response to a valid legal demand. Beyond these narrow cases, it stays with us.

Travel is international by nature. Fulfilling a booking usually means sending your details to an airline, hotel or supplier outside Canada, and some of our service providers store information outside Canada.

While your information is in another country, it is subject to that country's laws. It may be accessed by that country's courts, law enforcement, and national security authorities under those laws. That is true of any travel arrangement, made through anyone.

We remain accountable for information we transfer to a service provider, and we use contractual means to require a comparable level of protection. We limit what is sent to what the booking requires.

We keep your information only as long as we have a reason to. The reason is either the working relationship, a legal obligation, or a right we may need to defend.

Booking and financial records are kept for six years, because Canadian tax and accounting rules require records to be retained for six years from the end of the last tax year they relate to. Correspondence and preference information are kept for the life of the relationship and a reasonable period afterward, so that we can pick up where we left off if you return to us.

We delete passport copies and other travel-document information once the trip they relate to is complete. If you ask us to keep them so you do not have to resubmit them for future travel, we hold them for that reason. We delete them whenever you tell us to. When a retention period ends we delete or securely destroy the information.

Where we have used information to make a decision that affects you, we keep it for at least one year afterward so that you have a real opportunity to ask for it.

You have the right to ask what personal information we hold about you, how we have used it, and who we have disclosed it to, and to be given a copy. You have the right to have information that is wrong or incomplete corrected. You have the right to withdraw your consent, as described above. You have the right to ask us any question about this policy and get an answer from one of the Founders.

To exercise any of this, write to the address on our contact page. There is no charge in ordinary cases. We respond within 30 business days, the period British Columbia's Personal Information Protection Act allows, and we will tell you if we need to extend that and why. We may ask you to confirm your identity first, so that we never hand your information to someone else.

We can refuse a request only on the narrow grounds the law sets out — for example where disclosing our information would reveal personal information about somebody else. If we refuse, we will tell you why and tell you how to complain.

We are a Canadian firm, but we arrange travel for people who live in the United Kingdom and the European Union, and European data protection law can follow its residents. Where the UK GDPR or the EU GDPR applies to what we are doing for you, we honour the rights it gives you — access, correction, erasure, restriction, objection, and portability — alongside the Canadian rights above.

In that case you may also complain to the Information Commissioner's Office in the United Kingdom, or to the supervisory authority in the EU country where you live or work.

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For any question about this policy, or to exercise a right over your information, write to the Founders of VIRAM Advisors at the address on our contact page. It reaches the two of us and nobody else.

If you are not satisfied with our answer, you may complain to the Office of the Information and Privacy Commissioner for British Columbia at oipc.bc.ca, or to the Office of the Privacy Commissioner of Canada at priv.gc.ca. We would rather you gave us the chance to put it right first, but the route is there and you are entitled to use it.

Where we make a material change to this policy we update the date on this page and, where it matters, tell you directly.