EDMONTON ESKIMO FOOTBALL CLUB (“EEFC”) WEBSITE
Last Amended Feb. 16, 2017
The EEFC’s website, located at http://esks.com/ , including any related software, apps, webpages, websites and associated products and services, including without limitation the EEFC Home, Team, Tickets, Schedule, Shop, News, Fan Zone, Community, History, and Log in webpages or websites, (collectively, the “Website”), is provided, owned and/or operated by EEFC. The Website shall include any new software, apps, webpages, websites, products, services, or client interface mechanisms which may be added from time to time.
· the information collected by EEFC;
· how EEFC collects, retains, uses, discloses, destroys and protects your personal information;
· certain of your options and obligations as a user of the Website;
· your requests to access or correct your personal information; and
· how to contact EEFC.
A. Compliance with Legislation
B. Our Commitment to Your Privacy
EEFC is committed to protecting your personal information and privacy and considers matters relating to the protection of your personal information and privacy to be of the utmost importance. EEFC adheres to the following principles to protect your privacy:
· all information which you provide to EEFC will be protected with industry-standard protocols and technology.
- “personal information” means information about an identifiable individual. Personal information does not include information that cannot be attributed to you as an identifiable individual, such as information of an aggregate or anonymous nature.
In the context of the Website, examples of personal information may include, without limitation, an individual’s name, e-mail address, mailing address, phone number, credit card or payment information, other account information, communication preferences, comments and other information posted in our interactive online forums, correspondence and other information that you send to us, unique identifiers (such as a user name or password), other unique identifiers (including mobile device identification numbers), Internet Protocol (IP) address, location information, information collected through cookies, web beacons, Local Shared Objects, and other technologies, Standard Server Log Information, or additional information as otherwise described to you at the point of collection or pursuant to your consent.
E. Personal Information Aggregated or Made Anonymous
To the extent that EEFC makes any of your personal information anonymous or aggregates it with the personal information of others such that it can no longer be attributed to you, your information will no longer be considered to be personal information and EEFC is entitled to use, retain, disclose and destroy such information in its absolute discretion.
F. Choosing to Provide Personal Information
When using the Website and dealing with EEFC, you may choose not to provide certain of your personal information. If you choose not to provide all information reasonably requested of you, it may limit the manner in which you can make use of the Website and otherwise interact with EEFC or you may not be able to use the Website or to interact with EEFC at all.
You provide implied consent to the collection, retention, use, and disclosure of your personal information for a particular purpose if you voluntarily provide the information to EEFC for that particular purpose and it is reasonable that a person would voluntarily provide that information.
In certain circumstances, including without limitation when dealing with certain legal, medical or security issues, EEFC may be authorised or required by law to disclose your personal information without seeking or obtaining your knowledge or consent.
H. Consent via Opt-In or Opt-Out in Certain Circumstances
EEFC may, from time to time, provide you with a reasonable opportunity to opt-out of certain collections, uses and disclosures of your personal information. You implicitly consent to a particular collection, use or disclosure your personal information if you fail to indicate within a reasonable time that you wish to opt-out of the particular collection, use or disclosure when you are given a reasonable opportunity to do so.
EEFC also may, from time to time, provide you with a reasonable opportunity to opt-in to certain collections, uses and disclosures of your personal information. If you do not opt-in to a particular collection, use or disclosure of your personal information when given a reasonable opportunity to do so, you do not consent to your personal information being collected, used or disclosed in that particular manner.
Where the EEFC provides an opt-in or opt-out opportunity, EEFC will use the opt-out method when the particular collection, use or disclosure does not pertain to sensitive information or would be reasonably expected by the user of the Website. EEFC will use the opt-in method in all other circumstances.
I. Changing or Withdrawing Consent
If you withdraw certain consents reasonably requested of you and necessary for you to make use of the Website or to otherwise interact with EEFC, it may limit the manner in which you can make use of the Website and otherwise interact with EEFC or you may not be able to use the Website or interact with EEFC at all.
Your ability to change or withdraw consent is not absolute. EEFC reserves the right to continue handling your personal information in those circumstances required or permitted by law despite a change or withdrawal of consent.
Any change to or withdrawal of consent will not apply retroactively.
J. Collection of Personal Information
In some instances, EEFC may collect your personal information directly from a third party, in which case EEFC will obtain your consent to such collection unless required or permitted by law not to obtain your consent or unless the third party provided confirmation to EEFC that it is entitled or required by law to disclose your personal information to EEFC.
The following, without limitation, are particular circumstances in which EEFC may collect your personal information:
· EEFC collects personal information from you when you register an account, register for the EE Kids Club, purchase tickets or merchandise, subscribe to the EE Insider E-Newsletter, submit a donation request, respond to an electronic survey or communication from EEFC (such as e-mail), submit comments or participate in another feature of the Website. In particular, when registering an account, registering for the EE Kids Club, purchasing tickets or merchandise, subscribing to the EE Insider E-Newsletter, submitting a donation request, responding to an electronic survey or communication from EEFC, submitting comments or participating in another feature of the Website, EEFC may ask you for your name, e-mail address, mailing address, phone number, credit card or payment information or other information;
· EEFC also may collect information, including without limitation their name, address, e-mail address about recipients of ticket transfers. Such information about the recipient would be provided by the transferor; and
K. Use of Personal Information
The following, without limitation, are particular circumstances in which EEFC may use your personal information without obtaining your further consent. By providing your personal information to EEFC, you consent to the following uses:
· using identification information and contact information, such as your name, address and e-mail address, to provide you with information about EEFC when you request that information;
· using identification information and contact information, such as your name, address and e-mail address, so that EEFC can identify you and deliver the products, services, promotions, newsletters, that you request and can communicate with you regarding those products, services, promotions and newsletters including without limitation when responding to your customer service requests;
· using payment method preferences and related financial information that you provide to EEFC so that EEFC can obtain payment for the products and services that you request and can process transactions in an efficient manner;
· using information relating to your preferences so that EEFC can deliver products and services and the Website to you in accordance with those preferences;
· using customer relationship information such as your products and services requests, instructions, comments and feedback to assist EEFC in delivering products and services and the Website in accordance with your preferences;
· using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose;
· using your e-mail address to administer a promotion or survey or to provide you with information about events that may interest you or new features and/or enhancements to EEFC’s products and services and to the Website, unless you choose to unsubscribe to such messages in accordance with CASL, where applicable;
· using identification information and contact information, such as your name, address and e-mail address to send you promotional material or special offers on our behalf of our marketing partners and/or their respective affiliates and subsidiaries and other thrid parties;
· analyzing your personal information to assist EEFC in developing and enhancing its products and services or the Website;
· analyzing your personal information to assist EEFC in conducting market analysis and strategic planning; and
· as otherwise described to you at the point of collection or pursuant to your consent.
L. Disclosure of Personal Information
The following, without limitation, are particular circumstances in which EEFC may disclose your personal information without obtaining your further consent. By providing your personal information to EEFC, you consent to the following disclosures:
- where the disclosure is set out in any related documentation for the Website or is reasonably expected through the use and operation of the Website;
- where EEFC is under a duty to disclose your personal information in order to comply with any applicable legal obligation, legal or regulatory process or an order or request of a government institution, investigative body, regulatory body or judicial authority of competent jurisdiction;
- where EEFC believes in good faith that disclosure is necessary:
- to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies or investigative bodies in that regard;
- to enforce the Terms and Conditions of Use or any other policies of the Website or any agreements to which EEFC is a party;
- to investigate and defend EEFC against any third party claims or allegations;
- to protect the security or integrity of the Website; and/or
- to exercise or protect the rights, property or personal safety of EEFC, its users, employees, or others;
· some of the content, advertising and functionality on our Website may be provided by third parties that are not affiliated with us. For Example:
o content providers, which may operate contests, sweepstakes, fantasy or interactive games, or public forums on our Website;
o retail and other companies (such as those that operate our Shop and those that operate other services on our Website), which may process transactions, provide customer service, and perform other related functions;
o advertising providers, which help us and our advertisers provide ads (on our Website or elsewhere online) that are tailored to users’ interests and understand users’ response to those ads;
o audience-measurement companies, which help us measure the overall usage of our Services and compare that usage to other online services;
o social networking services (such as Facebook, Twitter, and Google+), which enable you to log in to certain of our Website, to comment on content available on our Website, and to share things you find on our Website with your social network; and
o mobile location analytics providers, which use location-specific data to facilitate the transmission of informational, marketing, and public service communications to you.
· if we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your information as part of such transaction;
· we may share information with third parties when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool. If you post to these interactive features, it will be publicly available and you may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features; and
· we may share information with third parties when you consent to such sharing. For example, if you win a contest or sweepstakes, we may ask your permission to publicly post certain information on the Services identifying you as the winner.
M. Cookies and Similar Technologies
Cookies do not enable EEFC to identify a particular visitor unless that visitor has previously provided personal information during a visit.
If your Internet browser permits, you may adjust the settings of your Internet browser to notify you when you receive a cookie or to reject cookies altogether, but in some cases doing so may impact your ability to use the Website. Because each Internet browser is different, users of the Website should check the “Help” menu of their Internet browsers to learn how to change their cookie preferences.
If you adjust your Internet browser settings to reject cookies, you may no longer have access to certain features of and services on the Website. However, you may nevertheless place an order from the EEFC Shop by telephone by contacting EEFC’s customer service.
N. Links to Other Websites
O. Other Collection, Use and Disclosure of Personal Information
EEFC also reserves the right to collect, use and disclose your personal information without your knowledge or consent where permitted or required by law.
P. Accuracy and Completeness of Personal Information
When EEFC collects, uses or discloses personal information, it will make a reasonable effort to ensure that the personal information is accurate, up-to-date, and complete to the extent that is reasonable for EEFC’s purposes in collecting, using or disclosing the information. To do so, it may be necessary for EEFC to request additional information from you or have you verify your personal information. Should your personal information change, please inform EEFC of the change(s) so that your personal information in EEFC’s possession remains accurate and complete.
Q. Retention and Destruction of Personal Information
EEFC may retain your personal information for as long as it reasonably requires your personal information for the purposes for which it was collected or for legal or business purposes. For example, EEFC may retain information about an individual sales transaction in order to service that transaction or to keep records for legal or business purposes.
Within a reasonable time period after EEFC no longer reasonably requires your personal information for the purposes for which it was collected or for legal or business purposes, EEFC either will destroy the records under its custody or control containing your personal information or it will render your personal information anonymous so that it can no longer be used to identify you.
R. Security of Personal Information
EEFC recognizes its obligation to protect personal information that is in its custody or under its control by implementing reasonable security safeguards to keep confidential and secure your personal information against risks such as loss, theft, and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. These reasonable safeguards may vary depending on the circumstances, including the level of sensitivity of the personal information, and may include secured networks, restricting access to authorized individuals on a need-to-know basis, locked doors and/or filing cabinets, other organizational, physical or technological security measures, and contractual measures such as non-disclosure or confidentiality agreements.
S. Requests for Access to Personal Information
Requests for Personal Information
On your written request, and taking into consideration what is reasonable, EEFC will provide you, not later than 30 days from EEFC’s receipt of your request, or such additional time as permitted or required by law, with:
- access to your personal information (if any) under our custody or control;
- information about the purposes for which your personal information (if any) under our custody or control has been and is being used by us; and
- the names of persons to whom, and the circumstances in which, your personal information (if any) has been and is being disclosed by us.
If you request a copy of your personal information and the information can reasonably be reproduced, EEFC will provide you with a copy of the record or the part of the record containing the requested information or, if applicable, it will give you reasons for any delay in providing a copy of the requested information or record.
All requests may be subject to reasonable fees and disbursements. Where appropriate, EEFC may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.
Requests to Access Personal Information must be in Writing
EEFC requires that all requests for access to personal information be in writing, be signed by the requestor and include sufficient detail to enable EEFC, with a reasonable effort, to identify any record in the custody or under the control of EEFC containing the personal information in respect of which the request is made
Limits on Right to Access Personal Information
Your ability to access your personal information under EEFC’s custody and control is not absolute. EEFC reserves all rights not to disclose personal information, in whole or in part, in certain circumstances permitted or required by law, including but not limited to where:
- the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual;
- the disclosure would reveal personal information about another individual;
- the information is protected by any legal privilege;
- the disclosure of the information would reveal confidential commercial information; or
- the personal information was collected for an investigation or legal proceeding.
If access to your personal information is refused, in whole or in part, EEFC will provide you with the reasons for the refusal, the provision of PIPEDA on which the refusal is based, and the name of the individual who can answer your questions on behalf of EEFC about the refusal, and will inform you of any recourse which you may have pursuant to PIPEDA.
T. Requests for Correction of Personal Information
On written request by you, EEFC will make every reasonable effort to correct errors or omissions in your personal information where that information is in EEFC’s custody or control. EEFC requires that all such requests be in writing, be signed by the requestor, and include sufficient detail to enable EEFC, with a reasonable effort, to identify any record in the custody or under the control of EEFC containing the personal information in respect of which the request is made.
If you make such a request, EEFC will, as soon as reasonably possible and not later than 30 days from EEFC’s receipt of your request, or within such additional time as permitted or required by law, either:
- correct the personal information and, if reasonable to do so, send correction notifications to any third party to whom EEFC disclosed the incorrect information; or
- decide not to correct the personal information, but EEFC will annotate the personal information under its control to indicate that a correction was requested but not made.
EEFC will inform you of the action that it has taken in response to your request for correction, the name of the individual who can answer your questions on behalf of EEFC about your request for correction, and will inform you of any recourse which you may have pursuant to PIPEDA.
Notwithstanding any requests for corrections of personal information, EEFC will not correct or otherwise alter an opinion, including a professional or expert opinion.
In addition to EEFC’s reasonable security safeguards to protecting the privacy and integrity of Personal Information provided by adults, the following practices are also adhered to in regards to protecting the privacy and integrity of Children’s Personal Information:
· in general, EEFC does not knowingly collect Personal Information from Children, except for the purposes of registering in the EE Kids Club (“EKC”);
· Children’s registration for the EKC must also include contact information of the parent of the child;
· upon submitting a child’s registration for the EKC, an EE customer service representative would subsequently contact the parent to confirm the registration and request payment for the membership;
· Children are not permitted to submit Personal Information via the Website for the purposes of, but not limited to, any current or future promotions or contests; and
· The EEFC’s Privacy Officer may be contacted at firstname.lastname@example.org for any comments or questions about EEFC’s commitment in regards to safeguarding the privacy and integrity of Children’s Personal Information.
W. Accountability and Contacting EEFC
Should you have any questions, comments or concerns regarding EEFC’s privacy policies, practices, or handling of your personal information or if you wish to request access to or correction of your personal information under EEFC’s care and control, you may contact EEFC’s Privacy Officer at:
Attention: Privacy Officer
EE Football Team
11000 Stadium Road
Edmonton, AB T5H 432