Privacy Policy

Effective date: 9/16/2026

Last updated: 9/16/2026

1. Who we are and what this policy covers

BC Sportfishing Group ("BC Sportfishing Group", "we", "us" or "our") is a guided sportfishing and charter operator based in Harrison Hot Springs, British Columbia, Canada, offering sturgeon, salmon, steelhead and trout fishing trips on the Harrison and Fraser Rivers and elsewhere in British Columbia, together with adventure trips, accommodation packages, corporate and group trips, a fishing derby, and merchandise. BC Sportfishing Group is operated by BC Sport Fishing Group Ltd., a company incorporated in British Columbia 87040 2716 RC0001.

We respect your privacy and are committed to protecting the personal information you entrust to us. This Privacy Policy explains what personal information we collect, why we collect it, how we use and share it, how long we keep it, how we protect it, and the choices and rights you have.

This policy applies to:

• our website at bcsportfishinggroup.com and any subdomains or staging versions of it;
• our online booking pages and our online merchandise store, wherever they are hosted;
• bookings, enquiries and communications made by telephone, email, in person, or through a travel agent, hotel partner or online travel agency;
• our social media pages and accounts;
• entry into the Harrison Sturgeon Challenge derby; and
• participation in our fishing trips, charters, packages and activities.

We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and British Columbia's Personal Information Protection Act (PIPA). Where the EU or UK General Data Protection Regulation applies to our handling of your information, or where US state privacy laws such as the California Consumer Privacy Act apply, the additional sections at the end of this policy also apply to you. Because a substantial share of our guests travel from the United States and overseas, we have written this policy to cover those visitors as well.

Accountability

We have designated an individual who is accountable for our compliance with this policy and with applicable privacy law:

Privacy Officer: Frank Kozel

BC Sportfishing Group

100 Esplanade Avenue, Harrison Hot Springs, British Columbia V0M 1K0, Canada

Email: info@bcsportfishinggroup.com

Telephone: 1-877-796-3345 or 604-796-3345

2. Consent

In most cases we will collect, use and disclose your personal information only with your knowledge and consent.

Express consent. We ask for your express consent where the information is sensitive, where we want to send you marketing messages, or where the law otherwise requires it. You give express consent when, for example, you tick a box to subscribe to our mailing list or disclose a medical condition on a waiver.

Implied consent. Where the purpose is obvious and you voluntarily provide the information, we may rely on your implied consent — for example, giving us your email address so we can send your booking confirmation.

Without consent. We may collect, use or disclose personal information without consent only where permitted or required by law — for example, in an emergency that threatens someone's life, health or security; to investigate a breach of an agreement or a contravention of law; to collect a debt owed to us; or in response to a lawful order, subpoena or court process.

Withdrawing consent. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Contact our Privacy Officer using the details above. Please understand that withdrawing consent may mean we can no longer provide you with a booking or a service — we cannot take you on the water without an emergency contact, a signed waiver and a valid fishing licence.

Consent on behalf of others. If you make a booking for other people — as is common for group, corporate and multi-boat trips — you do so as their agent, and you confirm that you have their authority (or, for a child, the authority of their parent or guardian) to provide their personal information to us and to consent on their behalf to the uses described in this policy.

3. The personal information we collect

3.1 Information you give us directly

When you make a booking or enquiry:

• full name;
• email address;
• telephone number;
• billing address and country of residence;
• the trip, package or product selected, dates, duration, target species and number of anglers;
• the names and number of people in your party, and whether any participants are minors;
• accommodation details where you have booked a Fish, Play & Stay or other hotel package;
• flight or arrival details, where you give them to us so we can coordinate timing;
• dietary requirements and preferences, where catered lunches are ordered;
• accessibility requirements, where you are booking an accessible vessel or adaptive equipment;
• company name and billing contact, for corporate bookings;
• any special requests or notes you choose to give us;
• how you heard about us; and
• the content of your messages to us, including contact-form submissions, emails, text messages and voicemails.

When we obtain a fishing licence on your behalf: where you ask us to arrange a licence (we require at least 48 hours' notice), we collect the information the Province of British Columbia or Fisheries and Oceans Canada requires for the application. This typically includes your full legal name, date of birth, residential address, height, eye colour and a government-issued identification number, and the licence type and stamps required. This information is more sensitive than ordinary booking data. We collect it only for the purpose of obtaining your licence, transmit it only to the relevant licensing system, and delete it once the licence has been issued and the trip has taken place, except where we are required to keep a record.

When you participate in a trip:

• the information on your signed waiver and release of liability, including your signature and date of birth or age;
• the name and signature of a parent or legal guardian for any participant under the age of majority;
• emergency contact name and telephone number;
• your fishing licence number and the stamps held, which we are required to verify;
• relevant medical conditions, allergies, food intolerances, mobility limitations, medications or other health information you choose to disclose so that we can plan for your safety and cater your meals. This is sensitive information. We collect it only with your express consent, use it only to keep you safe and to respond to an emergency, restrict access to guides and managers who need it, and delete it in accordance with our retention schedule;
• swimming ability and boating experience, where relevant;
• catch records, including species, length, girth, location and tag number — see section 3.5; and
• incident, accident and first-aid records where an incident occurs.

When you buy merchandise: your shipping address, delivery instructions, order contents and order history, in addition to the contact and payment details above.

When you pay us: we collect the amount, currency, date, and the last four digits and card type of the payment method, together with the transaction reference. We do not collect or store full payment card numbers, expiry dates or security codes. Card details are captured and processed directly by our payment processor within its own secure environment.

When you enter the Harrison Sturgeon Challenge: your entry details, team name and members, boat assignment, and your catch results for scoring purposes. Please note that entrant names, team names and results are published as part of running the derby — including on leaderboards, on our website and social media, and in any media coverage. Do not enter if you do not wish your name and results to be published.

When you contact us or engage with us: the content of enquiries, complaints, reviews, testimonials, survey responses and correspondence, and any photographs or videos you send us.

When you apply for a job or guiding position with us: your resume, work history, certifications (including MED A3, first aid and Pleasure Craft Operator Card details), references and any other information you provide.

When you subscribe to our mailing list: your name, email address and subscription preferences.

3.2 Information collected automatically when you use our website

Our website is built on the Duda website platform. When you visit, we and our service providers may automatically collect:

• your IP address and approximate location derived from it (typically city or region level);
• browser type and version, operating system, device type and screen resolution;
• the pages you view, the time and duration of your visit, and the links you click;
• the website or advertisement that referred you to us;
• search terms used to find us;
• items added to your cart in our merchandise store; and
• cookie identifiers and similar device identifiers (see section 6).

3.3 Photographs and video

Photographs are a big part of a fishing trip, and our guides regularly take pictures of guests with their catch, both for you to keep and for our marketing — including on our website, social media, in the derby leaderboard and in promotional material. Tell your guide before or during the trip if you do not wish your image to be used, and we will not photograph you or will not publish images in which you appear. If an image of you has already been published and you want it removed, contact us and we will remove it from the channels we control as soon as reasonably practicable.

3.4 Information we receive from others

• Online travel agencies, fishing booking platforms and resellers — such as [OTA / RESELLER PARTNERS], which pass us the booking details and your contact details.
• Accommodation partners — including Harrison Hot Springs Resort & Spa, Coast Hotel Chilliwack and Best Western Mission, where you book a Fish, Play & Stay package; they may share your reservation details with us and we may share yours with them so the package can be coordinated.
• Golf courses and other activity partners — for combined packages such as Fins 'n' Skins.
• Travel agents, tour operators, corporate travel bookers and group organisers — who book on behalf of participants.
• Our payment processor — confirmation of payment, chargeback and dispute information.
• Social media and review platforms — where you interact with us or leave a public review.

3.5 Catch data and conservation reporting

We participate in the Fraser River Sturgeon Conservation Society monitoring programme. When a sturgeon is caught, we measure it and record or read its PIT tag, and we submit that data to the Society so the population can be tracked. The data we submit is about the fish, not about you — species, measurements, tag number, date and location. [CONFIRM: whether the guide's or angler's name is included in the submission. If an angler's name is submitted, this sentence must be amended to say so, and the disclosure added to section 5.] We may also be required to report catch information to Fisheries and Oceans Canada or to the Province of British Columbia under fisheries regulations.

3.6 Children's information

Our website is not directed at children and we do not knowingly collect personal information directly from children online. Minors do take part in our trips, and where they do we collect only the information necessary for their safety and supervision, and only from a parent or guardian, who must sign the waiver on the minor's behalf. If you believe a child has provided us with personal information without parental consent, contact our Privacy Officer and we will delete it.

4. Why we collect and use your personal information

We identify the purposes for which we collect personal information at or before the time of collection. We use personal information to:

1. Provide the service you booked — take and confirm your booking, allocate guides, boats and equipment, schedule your trip, coordinate accommodation and meals, and deliver the trip or package.
2. Communicate with you about your booking — send confirmations, licence requirements, reminders, meeting-point instructions, what-to-bring information, weather and river-condition updates, and changes or cancellations.
3. Obtain fishing licences on your behalf, where you ask us to.
4. Take payment — process deposits, balances, merchandise orders and refunds, issue receipts and invoices, and manage chargebacks and disputes.
5. Fulfil merchandise orders — pick, pack, ship and track your order, and handle returns.
6. Keep you and others safe — plan for medical, dietary, mobility and accessibility needs, allocate appropriate vessels and adaptive equipment, brief guides, and respond to emergencies.
7. Meet our legal and regulatory obligations — including Transport Canada and workplace safety record-keeping, fisheries reporting, tax and accounting law, and responding to lawful requests.
8. Support fisheries conservation — submit catch and tagging data as described in section 3.5.
9. Manage risk and protect our legal interests — maintain waivers and incident records, respond to claims, report to and cooperate with our insurers, and establish, exercise or defend legal claims.
10. Run the Harrison Sturgeon Challenge — administer entries, score the competition, publish results and award prizes.
11. Answer your enquiries and handle complaints.
12. Improve our business — analyse how our website, booking system and store are used, understand which trips are popular, monitor service quality, and train our team.
13. Market our trips and products to you — send newsletters, seasonal offers, derby announcements and news, where you have consented or where the law otherwise allows. Every commercial electronic message we send includes an unsubscribe link, as required by Canada's Anti-Spam Legislation (CASL).
14. Display testimonials, reviews and catch photographs — with your consent, or where you have posted them publicly.
15. Recruit and manage staff, guides and contractors.
16. Protect the security of our website, systems and property — including detecting and preventing fraud and misuse.

If we want to use your personal information for a purpose that is materially different from those listed here, we will tell you and, where required, obtain your consent first.

Legal bases (for visitors covered by the EU or UK GDPR)

Where the GDPR applies, our legal bases are:

• Performance of a contract — taking your booking and delivering the trip, package or merchandise you purchased (purposes 1, 2, 3, 4, 5).
• Legal obligation — fisheries, safety, tax and regulatory compliance (purposes 7, 8 in part).
• Vital interests — responding to a medical emergency on the water (purpose 6).
• Legitimate interests — running, securing and improving our business, handling complaints, running the derby, and defending legal claims, where these are not overridden by your rights (purposes 9, 10, 11, 12, 15, 16).
• Consent — health and dietary information, marketing, non-essential cookies, and publishing testimonials or photographs (purposes 6 in part, 13, 14). You may withdraw consent at any time.

Where we process health information, we rely on your explicit consent, or on the necessity of the processing to protect your vital interests or those of another person.

5. How we share your personal information

We do not sell your personal information, and we do not rent or trade it. We share it only as described below.

5.1 Our service providers

They may access personal information only to perform services on our behalf, under contract, and are not permitted to use it for their own purposes. They include:

• Website platform — Duda, which hosts and serves our website and online store.
• Booking and reservation system — Checkfront, which manages bookings, availability, customer records and booking communications.
• Payment processing — Square, and any other payment processor we use, which processes card payments, store transactions and refunds. Card data is handled within the processor's PCI DSS compliant environment; we never see your full card number.
• Shipping and fulfilment carriers — for merchandise orders.
• Email and communications — our email provider, and [EMAIL MARKETING PLATFORM] for newsletters.
• Analytics and advertising — Google Analytics
• Accounting, bookkeeping and tax advisers.
• IT support, backup and security providers.

5.2 Our trip partners

• Guides, skippers and contractors — who receive the participant list, licence status, emergency contacts, dietary requirements and any safety-relevant information.
• Accommodation partners — Harrison Hot Springs Resort & Spa, Coast Hotel Chilliwack, Best Western Mission and others, for package bookings.
• Golf courses, caterers and other activity partners — for combined packages and catered lunches.
• Online travel agencies, travel agents and resellers — where your booking came through them.
• Other charter operators — where a large group requires additional boats operated by another company, we share the participant information necessary for them to run their portion safely.

5.3 Regulators and conservation bodies

• The Province of British Columbia and Fisheries and Oceans Canada — for licence applications we make on your behalf, and for catch reporting required by law.
• The Fraser River Sturgeon Conservation Society — catch and tag data, as described in section 3.5.
• Transport Canada, WorkSafeBC, the Canadian Coast Guard and law enforcement — where required by law, in an emergency, or in response to a lawful request.

5.4 Others

• Emergency services and medical personnel — where necessary to respond to a medical emergency, accident or search-and-rescue situation.
• Insurers, brokers, lawyers and claims adjusters — where an incident occurs or a claim is made.
• Purchasers of our business — if we sell or reorganise all or part of our business, personal information may be transferred as part of that transaction, subject to the purchaser agreeing to protect it on terms consistent with this policy.

6. Cookies and similar technologies

Cookies are small text files placed on your device when you visit a website. We use them to make our site and store work, to remember your preferences and cart, to understand how the site is used, and — where you allow it — to measure and target advertising.

The categories we use:

• Strictly necessary cookies — required for the website, booking system and shopping cart to function, and for security. These cannot be switched off.
• Preference cookies — remember choices such as language or region.
• Analytics and performance cookies — tell us, in aggregate, which pages are visited and how visitors move through the site.
• Marketing and advertising cookies — set by advertising platforms to measure campaign performance and show you relevant advertising elsewhere. We use these only with your consent.

Your choices. Where required by law, we display a cookie banner on your first visit that lets you accept or reject non-essential cookies, and you can change your choice at any time through the cookie settings link on our website. You can also block or delete cookies through your browser settings — though blocking strictly necessary cookies may stop the booking system and store from working.

Do Not Track. There is currently no consistent industry standard for responding to browser "Do Not Track" signals, and our website does not respond to them. Where we are legally required to honour an opt-out preference signal such as Global Privacy Control, we do so.

7. Storage, and transfers outside Canada

Please read this section carefully. Several of our service providers — including our website platform, booking system and payment processor — are located in, or store and process data in, the United States and other countries outside Canada. This means your personal information may be stored on, or accessible from, servers outside Canada and outside British Columbia.

While your personal information is in another country, it is subject to the laws of that country, and may be accessible to the courts, law enforcement and national security authorities of that country under those laws — including, in the United States, under lawful access legislation. We cannot prevent lawful access of this kind.

We take reasonable steps to ensure that any service provider we use provides a comparable level of protection to that required in Canada, including through contractual commitments. Where we transfer personal information from the European Economic Area or the United Kingdom, we rely on the European Commission's adequacy decision for Canada (for commercial organisations subject to PIPEDA) or on Standard Contractual Clauses, as appropriate.

If you have questions about how your information is handled outside Canada, contact our Privacy Officer.

8. How long we keep your personal information

• Booking and customer records — up to seven (7) years from the date of the booking, to meet tax and accounting requirements.
• Financial and transaction records — seven (7) years, as required by the Income Tax Act and the Excise Tax Act.
• Merchandise order records — seven (7) years, for tax and warranty purposes.
• Signed waivers and releases — for at least the applicable limitation period under BC law, and longer where a participant was a minor at the time (limitation periods do not begin to run against a minor until they reach the age of majority). We typically retain adult waivers for [SUGGESTED: 7 years], and waivers signed for minors until [SUGGESTED: the participant's 21st birthday, or longer on our insurer's advice].
• Incident, accident and first-aid records — for the period required by our insurer and by applicable safety legislation, and in any event until any related claim is fully resolved.
• Licence application data — deleted once the licence is issued and the trip has taken place, unless a record is required.
• Health and dietary information — deleted shortly after the trip, unless it relates to an incident.
• Derby entry records and published results — results are part of the public record of the competition and are retained indefinitely; entrant contact details are retained for [SUGGESTED: 3 years].
• Marketing list data — until you unsubscribe, and then only the minimum record needed to honour your opt-out.
• Enquiries that do not result in a booking — normally no more than two (2) years.
• Job applications — normally one (1) year for unsuccessful applicants.
• Website analytics data — as set by the retention settings of the analytics tool, typically 14 to 26 months.

When personal information is no longer needed, we securely destroy, erase or anonymise it.

9. How we protect your personal information

We protect personal information using safeguards appropriate to its sensitivity, including: encryption of our website, booking pages and store in transit (HTTPS/TLS); storing booking and payment data in reputable systems that maintain their own recognised security certifications, including PCI DSS for card data; access controls, so that staff, guides and contractors can access only what they need; unique accounts, passwords and multi-factor authentication where available; confidentiality obligations in our contracts; secure storage of paper records such as waivers and licence paperwork, and secure destruction when no longer needed; and training our team on their privacy and confidentiality obligations.

No method of transmitting or storing information is completely secure, and we cannot guarantee absolute security. If a breach of security safeguards occurs that creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as required by law, and will keep a record of the breach.

10. Accuracy

We make reasonable efforts to keep personal information accurate, complete and up to date where it is used to make a decision about you. Please tell us promptly if your contact details, party composition, dietary needs or medical information change before a scheduled trip — this matters more here than in most businesses, because we plan boats, guides and catering around it.

11. Your privacy rights in Canada

Under PIPEDA and BC PIPA you have the right to:

• Access — ask whether we hold personal information about you, what we hold, how we have used it, and to whom we have disclosed it.
• Correction — ask us to correct information that is inaccurate or incomplete. If we do not make the correction, we will annotate the record to show that a correction was requested and refused.
• Withdraw consent — subject to legal or contractual restrictions and reasonable notice.
• Unsubscribe — opt out of marketing communications at any time.
• Complain — see section 14.

How to make a request. Write to our Privacy Officer at info@bcsportfishinggroup.com or the postal address above. We may ask you for information to verify your identity. We will respond within 30 days, and will tell you if we need an extension as permitted by law. Access is normally free; if a fee would be payable for a request that requires substantial effort, we will give you a written estimate first and you may withdraw or narrow the request.

Limits on access. We may be unable to provide access where doing so would reveal personal information about another person, where the information is subject to solicitor-client privilege, where it was generated in the course of a formal dispute resolution process, or where disclosure would breach law. If we refuse, we will tell you why and how to complain.

12. Additional rights under the EU and UK GDPR

If you are in the European Economic Area or the United Kingdom, you also have the right to: request erasure of your personal information; request restriction of processing; object to processing carried out on the basis of legitimate interests, and to object to direct marketing at any time; receive the personal information you provided to us in a structured, commonly used, machine-readable format and have it transmitted to another controller (data portability); and not be subject to a decision based solely on automated processing that produces legal or similarly significant effects — we do not carry out such automated decision-making.

These rights are subject to the exceptions in the GDPR — for example, we may need to retain waivers, incident records and fisheries records to comply with law or to establish or defend legal claims even after an erasure request. Exercising any of these rights is free of charge unless your request is manifestly unfounded or excessive. You may complain to your local supervisory authority; in the UK, this is the Information Commissioner's Office (ico.org.uk).

13. Additional rights for United States residents

If you are a resident of California, or of another US state with a comprehensive consumer privacy law (including Colorado, Connecticut, Virginia, Utah, Texas and others), you may have the right to know what personal information we have collected about you and how we have used and disclosed it; to request deletion of your personal information; to request correction of inaccurate personal information; to opt out of the "sale" or "sharing" of personal information and of targeted advertising; and to be free from discrimination for exercising these rights.

We do not sell personal information, and we do not knowingly sell or share the personal information of anyone under 16. Some analytics and advertising cookies may constitute "sharing" for cross-context behavioural advertising under California law; you can opt out through our cookie settings or by using a Global Privacy Control signal.

To exercise these rights, contact us using the details in section 14. We will verify your request and respond within the time allowed by the applicable law. You may use an authorised agent, in which case we will require proof of their authority.

14. Questions and complaints

Please raise any question or concern with us first:

Frank Kozel, Privacy Officer, BC Sportfishing Group

100 Esplanade Avenue, Harrison Hot Springs, British Columbia V0M 1K0, Canada

Email: info@bcsportfishinggroup.com

Telephone: 1-877-796-3345

We will acknowledge your complaint, investigate it, and tell you the outcome in writing. If you are not satisfied with our response, you may complain to:

• Office of the Privacy Commissioner of Canada — priv.gc.ca, 1-800-282-1376.
• Office of the Information and Privacy Commissioner for British Columbia — oipc.bc.ca, 250-387-5629.
• Your local data protection supervisory authority, if you are in the EEA or UK.

15. Third-party websites

Our website and communications contain links to third-party sites, including our booking system, payment pages, government licensing portals, social media profiles, review platforms and accommodation partners. We are not responsible for the privacy practices or content of those sites. We encourage you to read their privacy policies before providing them with personal information.

16. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our practices or to the law. The current version is always posted on our website with the "Last updated" date shown at the top. Where a change is significant, we will take reasonable steps to notify you. Your continued use of our website or services after a change takes effect means you accept the updated policy.