Privacy Policy
Scope of this Policy
This Privacy Policy sets out the principles which the Silver Star Resort Association, operating as Destination Silver Star (“DSS”), will observe regarding the collection, use, disclosure, and retention of personal information about any identifiable person, including DSS’s members, guests, and stakeholders, but excluding DSS’s employees and volunteers.
This Privacy Policy is subject to all applicable laws, including the British Columbia Personal Information Protection Act (“PIPA”, SBC 2003, c. 63) and, where applicable, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).
Definitions
“Members” includes current, past and prospective residential and commercial members of the Silver Star Resort Association, including property owners, business operators, and any other persons or entities that engage with DSS in a membership capacity.
“Guests” includes visitors to the Silver Star Resort who interact with DSS’s digital platforms,
event programming, or destination services.
“Personal information” means any information about an identifiable individual, whether collected before or after this Policy was first published, including but not limited to the individual’s name, address, age, gender, identification numbers, employment, financial information, and contact details. Under PIPA, “contact information” (i.e., name, address, telephone number, and email address used for business purposes) is treated separately and is not considered “personal
information” for purposes of the Act. DSS may or may not hold personal information in all enumerated categories for any specific individual.
Principle 1 — DSS’s Accountability
DSS is responsible for all personal information under its control. The DSS Privacy Officer is accountable for compliance with the principles described in this Policy and may be contacted at:
Privacy Officer, Destination Silver Star
118 Shortt Street, Silver Star, British Columbia, V1B 0S4 Phone: 250-275-4942
Email: info@destinationsilverstar.com
Website: https://members.destinationsilverstar.com/
Principle 2 — Purposes for Collecting, Using, or Disclosing Personal Information
DSS will identify the purposes for which personal information is collected, used or disclosed before that information is collected, used or disclosed, as the case may be.
General Purposes
The general purposes for which DSS may collect, use or disclose information about members, guests and stakeholders include the following:
- to manage and promote DSS’s operations and services as a destination management organization under BC’s Resort Associations Act and BC Societies Act;
- to administer membership records, including assessment notices, the Members’ Register, online voting, and Members’ Portal access;
- to better understand the needs of DSS’s members and guests, to provide information about Silver Star Resort, and to respond to specific requests;
- to plan, deliver and communicate about destination events, programs, and community initiatives such as the Silver Star Community Showcase series, the monthly newsletter, and member engagement activities;
- to support regional marketing initiatives including the Explore North Okanagan (ENO) partnership and digital marketing programs;
- to fulfill requests for information, reservations, bookings or other arrangements with third-party service providers on behalf of members or guests;
- to conduct surveys, research and statistical analysis to support destination planning, including the DSS Destination Development Plan;
- to operate and fulfill contests, promotions or campaigns; and
- to comply with legal and regulatory requirements, including obligations under BC’s Resort Associations Act and Societies Act.
DSS generally collects personal information directly from its members, guests, and stakeholders. From time to time, DSS may also collect information from external sources such as regional tourism partners, member referrals, or publicly available business registries.
Consent for Marketing Communications
DSS distinguishes between two types of consent:
- Implied consent: By becoming a member of the Silver Star Resort Association, or by accessing DSS services, members provide implied consent to DSS collecting and using personal information necessary to administer membership and deliver member services (e.g., sending assessment notices, AGM communications, meeting notifications).
- Explicit (opt-in) consent: Where DSS wishes to use personal information to send promotional or marketing communications — including newsletters, event promotions, destination updates, or third-party offers — DSS will seek explicit, separate opt-in consent. Members may withdraw this consent at any time by contacting the Privacy Officer or using the unsubscribe feature in any DSS communication.
DSS will not require consent to marketing communications as a condition of membership or access to member services.
Out-of-Province Data Transfer
DSS uses cloud-based software platforms, email service providers, and third-party technology vendors that may store or process personal information outside of British Columbia or Canada. Where personal information is transferred to a service provider located outside BC, DSS will ensure through contractual or other means that the service provider provides a comparable level of privacy protection to that required under PIPA. By providing personal information to DSS, members and guests consent to it being stored and processed outside BC in these circumstances. DSS will identify the nature of foreign jurisdictions involved upon request.
Digital and Platform-Specific Considerations
The DSS website and Members’ Portal automatically collect certain non-personal technical information when accessed, such as the date and time of access, browser and operating system type, and pages viewed. This information is used for system administration, security, and to improve our digital platforms. DSS does not share or disclose website visitors’ email addresses or other submitted information with third parties, except as described in this Policy.
DSS uses cookies and similar technologies to enhance the functionality of its website and Members’ Portal and to measure the effectiveness of destination marketing. Members and guests may decline cookies through their browser settings, though certain features may be affected as a result.
Members’ Register
Under BC’s Societies Act, DSS is required to maintain a Members’ Register containing each member’s name and the contact information provided by that member. This register is an official Society record that may be inspected by members and directors, subject to applicable
restrictions. The Members’ Register is not a contact list or member directory and is not disclosed to the general public. Personal information held by DSS beyond the Members’ Register (such as billing records, correspondence history, or portal engagement data) is maintained in separate confidential records and is not subject to member registry inspection rights.
Members’ Portal
The DSS Members’ Portal collects personal and business contact information, membership status data, and engagement history for the purposes of administering membership services and facilitating communication between DSS and its member community. Access to the Members’ Portal is secured by individual credentials and is accessible only to authorized DSS staff and the relevant member.
Operational Transfers
DSS may be involved in the reorganization, amalgamation, or transfer of some or all of its operations at some time in the future. As part of that process, DSS may disclose personal information to a successor organization but will require that organization to protect personal information in a manner consistent with this Privacy Policy.
Disclosure to Service Providers
DSS may transfer personal information to third parties for processing or to provide services, including regional tourism partners, marketing agencies, event service providers, and technology platform providers. DSS will use contractual or other means to ensure a comparable level of privacy protection while information is in the custody of any such third party. Service providers are not permitted to use personal information for their own purposes.
Principle 3 — Consent
Subject to applicable legal exceptions, DSS will make a reasonable effort to advise individuals in advance of the purposes for which their personal information will be collected, used or disclosed, and to obtain consent for those activities. The form of consent (express or implied) will be appropriate to the sensitivity of the information and the circumstances of collection, as required by PIPA.
Members may withdraw consent to marketing or promotional communications at any time by contacting the Privacy Officer or using the unsubscribe option in any DSS communication. Please note that members cannot opt out of receiving communications that DSS is legally or by-law required to send, such as assessment notices and AGM materials.
Principle 4 — Limiting Collection
DSS will collect only the personal information necessary to fulfill the identified purposes described in this Policy. DSS will not, as a condition of membership or the supply of services, require an individual to consent to the collection, use or disclosure of personal information beyond what is required to fulfill those purposes.
Principle 5 — Limiting Use, Disclosure and Retention
DSS will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law.
Retention Schedule
DSS will retain personal information only as long as necessary for the fulfillment of identified purposes, or as required by applicable legislation. DSS’s general retention principles are as follows:
- Active member records are retained for the duration of membership and for a reasonable period thereafter to support potential reinstatement, accurate statistical records, and compliance with the Resort Associations Act.
- Financial and billing records are retained in accordance with applicable tax and corporate recordkeeping requirements (generally a minimum of seven years).
- Marketing and communications data (e.g., email list subscriptions) are retained until consent is withdrawn or the individual requests deletion.
- Website and portal usage data is retained for the period necessary to support system administration and security reviews.
When personal information is no longer required for any identified purpose or legal obligation, DSS will securely destroy, erase, or anonymize it. Members may contact the Privacy Officer to inquire about the retention of their specific personal information.
Principle 6 — Accuracy
DSS will keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is used. DSS will generally rely on members and individuals to provide updated information, such as changes to contact details or business information. If an individual demonstrates that personal information is inaccurate, incomplete, out of date, or irrelevant, DSS will revise it accordingly and, where necessary, notify relevant third parties who were provided with the incorrect information.
Principle 7 — Safeguards
DSS employs appropriate security safeguards to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification. The nature of safeguards will vary depending on the sensitivity, volume, format, and storage method of the information.
Safeguards employed by DSS include:
- physical measures, including restricted access to offices and secure storage of physical records;
- organizational measures, including limiting access to personal information on a need-to-know basis and staff training on privacy obligations; and
- technological measures, including password protection, encryption, secure login
- protocols for the Members’ Portal, and periodic security reviews of digital platforms.
Privacy Breach Notification
In the event of a privacy breach involving personal information under DSS’s control, DSS will:
- assess the risk of harm to affected individuals;
- notify affected individuals where it is reasonable to conclude they are at risk of significant harm; and
- document the breach internally, including the nature of the incident, information involved, and corrective actions taken.
While breach reporting under BC PIPA is currently voluntary, DSS is committed to transparency and accountability in its handling of privacy incidents. DSS will take prompt corrective action to prevent recurrence.
Principle 8 — Openness
DSS will be open about its policies and procedures with respect to the management of personal information and will make this Privacy Policy available in a form that is generally understandable.
Copies of this Privacy Policy will be made available to members, guests, and other members of the public through the DSS website at destinationsilverstar.com and through the Members’ Portal at members.destinationsilverstar.com.
Principle 9 — Individual Access and Correction Rights
Under PIPA, individuals have the right to request access to their personal information held by DSS and to request corrections to information that is inaccurate or incomplete.
How to Submit an Access Request
Members and individuals may submit a written access request to the DSS Privacy Officer at the contact details provided in Principle 1. The request should include sufficient identifying information to allow DSS to locate the relevant records.
DSS will respond to written access requests within 30 business days of receipt, unless that period is extended in accordance with PIPA. Reasonable charges may apply to certain requests as permitted by law. If DSS is unable to provide access to certain information, DSS will explain why and identify any lawful basis for the refusal.
How to Request a Correction
If a member believes that personal information held by DSS is inaccurate or incomplete, they may submit a written correction request to the Privacy Officer. DSS will correct the information if it determines the correction is warranted. If DSS declines to make the requested correction, the individual’s request will be attached to their file so that it is disclosed alongside the disputed information in any subsequent use or disclosure.
Principle 10 — Complaint Process
Any member or individual may direct a privacy-related complaint or inquiry to the DSS Privacy Officer. DSS will maintain accessible and straightforward procedures to receive and respond to complaints about the application of this Policy or of PIPA.
DSS Complaint Handling Process
Upon receiving a complaint, DSS will:
- acknowledge receipt of the complaint in writing within five business days;
- investigate the complaint and gather relevant information;
- provide a written response to the complainant within 30 business days of receipt, setting out DSS’s findings and any corrective actions taken or planned; and
- amend its policies and practices if the investigation finds the complaint to be justified.
Escalation to the OIPC
If a member or individual is not satisfied with DSS’s response to a privacy complaint, they may
escalate the matter to the Office of the Information and Privacy Commissioner for BC (OIPC):
Office of the Information and Privacy Commissioner for BC (OIPC)
Website: www.oipc.bc.ca Phone: 250-387-5629
Toll-free (via Enquiry BC): 1-800-663-7867
Amendments to this Policy
DSS may review and update this Privacy Policy from time to time to reflect changes in our practices, legislation, or operational context. For material changes — those that affect how personal information is collected, used or disclosed — DSS will notify members through the DSS website, the Members’ Portal, or direct communication before the change takes effect. For minor administrative updates, the revised policy will be posted on DSS’s website and the effective date updated accordingly.
Contact Us
For questions, concerns or requests related to this Privacy Policy or the handling of your personal information, please contact:
Privacy Officer, Destination Silver Star 118 Shortt Street, Silver Star, BC, V1B 0S4 Phone: 250-275-4942