Toronto Organizing Committee for the 2015 Pan American and Parapan American Games
Privacy Policy
BACKGROUND
The Toronto Organizing Committee for the 2015 Pan American and Parapan American Games (“TO2015™”) is a not-for–profit organization the mandate of which is to plan, organize, promote, finance and stage the Pan/ParaPan American Games to be held in the Golden Horseshoe Region of southern Ontario in the summer of 2015 (the “Games”).
OBJECTIVES
This Privacy Policy has been developed by TO2015™ as an extension of our desire to combine our commitment to the delivery of excellent Games with the highest level of integrity and transparency in dealing with our stakeholders. The Policy is designed to assist you in understanding how we collect, use, and safeguard the personal information you provide to us and to assist you in making informed decisions when communicating with us and receiving news and related content through our online properties. It reflects our commitment to protecting the privacy and confidentiality of the personal information entrusted to us by our stakeholders. This Policy will be continuously assessed against new technologies, business practices, and stakeholder needs.
The Policy applies to all current and prospective stakeholders of TO2015™ as well as to users of our online properties. It is to be read in conjunction with our Terms of Use which can be found at www.toronto2015.org/lang/en/website-terms-of-use.html.
COLLECTION OF PERSONAL INFORMATION
In order to develop and execute the Games, there may be times when TO2015™ has to collect personal information which may include names, addresses, date of birth, phone numbers and email addresses. This may be collected from you in a variety of circumstances, such as when you purchase merchandise from us, enter into contests, participate in surveys, join our social networking sites, apply for paid or volunteer positions, or communicate online with our customer service representatives. If you use our "email this style to a friend" functionality, or if you choose to send an email from our site to a friend, we will also collect your friend's name and email address.
What we collect: We may collect personal information through surveys, questionnaires, and other means. In addition to name, address (postal and/or e-mail), telephone number, and transaction/credit card information, we may collect demographic information (i.e., age, gender, income, occupation, and education) and opinions of our stakeholders. If you contact us, we may keep a record of that correspondence and, if so, shall treat that as personal information.
Modes of Collection: TO2015™ collects personal information about its stakeholders through various applications and order forms, including credit applications, surveys and questionnaires, face-to-face interactions, and our online properties. For certain transactions, we may obtain personal information about a stakeholder from third parties, such as consumer reporting agencies.
Personal Information of Children: We are committed to protecting the online privacy of children under the age of 18. We encourage parents and guardians to monitor their children's use of the internet. Where a child is providing us with personal information, it is the responsibility of each parent or guardian to supervise them.
USE OF PERSONAL INFORMATION
TO2015™ uses the personal information we collect to provide stakeholders with news about the Games, manage our business, sell merchandise and tickets, and comply with regulatory and industry requirements. More specifically, we use personal information to create and maintain vendor accounts, communicate with our stakeholders, and supply stakeholders with information about the Games. We may also use information about stakeholder interests and preferences, as well as feedback we receive from surveys, to improve our delivery of the Games. TO2015™ makes all reasonable efforts to ensure that information is used responsibly, and only for its intended purposes.
We may provide your private information to a third party that administers any facility, service or promotion operated via our website, www.Toronto2015.org (the “the Site”) on our behalf to enable such third party to administer that facility, service or promotion properly.
We may use your personal information to operate the features of the Site and to allow you, when you choose to do so, to participate in features available only to registered users or interactive features of the Site.
We may from time to time operate online job or volunteer application systems. If you submit such an application, we may process the information provided by you for the purpose of considering the application.
When you sign up to take part in a program or initiative that we may operate from time to time, or to receive online and/or email communications (e.g. our supporters’ or partners’ newsletters or business e-alerts) or text communications (e.g. communications enabled via the Site between us and users of mobile telephones or other portable devices), we may use the information that you provide to maintain appropriate databases and otherwise to operate and facilitate such programs, networks and
communications.
The data that we collect from you may be transferred to, and stored at, a destination outside Canada for processing by staff operating outside Canada who work for us. If you submit personal information, you specifically consent by doing so to such transfer, storing or processing. We will endeavour to ensure that your data is treated securely and in accordance with this Privacy Policy.
DISCLOSURE OF PERSONAL INFORMATION
To whom we disclose your personal information: Depending on the nature of the information our stakeholders require, we may disclose personal information to our funding partners, financial institutions, credit reporting agencies, and third party service providers such as data processing and marketing companies. In addition, if you have applied for any position, whether paid or volunteer, with TO2015™, we will disclose your personal information to agencies conducting security and background checks on our behalf.
We will disclose your personal information if we reasonably believe that we are required to do so by law, regulation, court order or any competent governmental, statutory or public authority or to protect our rights and property or the rights and property of our stakeholders. We may also co-operate with law-enforcement agencies in any official investigation, and we may disclose your private information to such agencies in doing so.
We are bound by the provisions of the Freedom of Information and Privacy Protection Act (Ontario) and the disclosure obligations set out therein.
When we will get your consent: We will request your express consent to the use and disclosure of your personal information for specific types of transactions on the application or other forms used in connection with those transactions. Where it is reasonable to imply your consent to the use and disclosure of your personal information in accordance with this Policy (e.g., in connection with a background check following an application for accreditation), we may do so. Where it is reasonable, we may also imply your consent to the use and disclosure of your personal information in accordance with this Policy from continuing requests for information now that you are knowledgeable about our personal information practices. We will obtain your express consent before using or disclosing your personal information for any purposes not identified in this Policy.
LIMITING THE USE AND DISCLOSURE OF PERSONAL INFORMATION
Subject to contractual and other legal obligations, you are entitled to withdraw your consent to our use and disclosure of your personal information. Specifically, if you prefer that we do not use or disclose your personal information for marketing and promotional purposes, please notify our Privacy Officer. Please note that your request may take three to four weeks to implement. We are legally bound to inform you that withdrawing your consent may preclude us from providing you with certain information.
In the case of personal information obtained from third parties, we will work with stakeholders, list owners, and other media owners to fulfill the right of clients to know of the existence, use, and disclosure of their personal information and to provide access to that information.
Note that the Site may contain links to other websites which are outside our control and are not covered by the terms of this Privacy Policy. If you access other websites using the links provided, the operators of those websites may collect information from you which will be used by them in accordance with their privacy policies, which may differ from ours.
SECURITY OF PERSONAL INFORMATION
Once we have received your private information, we will use reasonable commercial efforts to protect it by using physical, managerial and technical procedures and security features to try to prevent unauthorized access to it. We cannot, however, guarantee the security of any personal information provided to us in an email or in online form while it is being transmitted to us, as the internet is a potentially non-secure method of information transfer. Any such transmission is at your own risk.
USE OF COOKIES
Similar to other commercial websites, our Site utilize a standard technology called "cookies" and web server logs to collect information about how our Site is used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our Site, and the websites visited just before and just after our Site. This information is collected on an aggregate basis. None of this information is associated with you as an individual. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages together with your e-mail address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of non-electronic information, such as that received by mail and telephone.
Information obtained through cookies on our Site is used for internal review, to improve the content of our web pages, and to customize the content and/or layout of our pages for each individual visitor; it is not shared with other organizations for commercial purposes.
Web beacons are small strings of code that are placed in a web page or in an email message. They are sometimes called "clear GIFs" (Graphics Interchange Format) or "pixel tags". Web beacons are most often used in conjunction with cookies to track activity on our websites. When you visit a particular web page, web beacons notify us of your visit. Since web beacons are used in combination with cookies, if you disable cookies the web beacons will only detect an anonymous website visit. When used in an email, Web beacons enable us to know whether you have received the email.
ACCURACY OF PERSONAL INFORMATION
TO2015™ will try to ensure that information about you is accurate, complete, and up-to-date. We may update the personal information in our records from time-to-time, where current information is required for the provision of a particular product or service. Please inform us of any change of name, address, or other information. Should you have questions about the accuracy of factual information we have collected about you, you will have access to that information to verify and update it. If we have disclosed inaccurate information about you to a third party, we will be pleased to contact the third party in order to correct the information.
INDIVIDUAL ACCESS
If you have any questions about the collection, use, or disclosure of your personal information by TO2015™, or if you simply want to know whether we have any of your personal information on file, you may contact our Privacy Officer. TO2015™ will respond to your requests for access in accordance with applicable privacy legislation. In the event that we refuse access to you, we will provide you with the reasons for our refusal upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
MISCELLANEOUS
Please note that this Privacy Policy and any privacy notices displayed on the Site ("Privacy Documents") have been drawn up in the English language and shall be interpreted in the English language. Where any of the Privacy Documents (or any part of a Privacy Document) is translated into any language in addition to English and there is any conflict in meaning between the English-language version and the translated version, the English-language version shall prevail in all respects.
We may, from time-to-time, change the terms of this Privacy Policy. Your use of our Site following any such change constitutes your agreement to follow and be bound by the terms, as changed.
This Privacy Policy shall be construed in accordance with the laws of the Province of Ontario, without regard to any conflict of law provisions. Any dispute arising under this Policy shall be resolved exclusively by the provincial and federal courts of the Province of Ontario. If any portion of these terms is held to be unenforceable, the unenforceable portion shall be construed in accordance with applicable laws to the greatest extent possible and the remainder of the provisions shall remain in full force and effect.
QUESTIONS OR CONCERNS
To access your personal information, inform us of changes you believe need to be made to that information, request that we investigate a concern you have about our personal information practices or obtain further information about this policy and its outlined practices, please send your questions or concerns to the contact below.To submit a request under FIPPA, please download the form and follow the instructions.
Freedom of Information and Privacy Coordinator
Toronto Organizing Committee for the 2015 Pan American and Parapan American Games
25 Dockside Drive, 7th floor
Toronto, Ontario Canada M5A 0B5
foiandprivacycoordinator@toronto2015.org
