Compliance with Legislation
WFC endeavors to comply with the federal Personal Information and Electronic Documents Act, (“PIPEDA”), Canada’s Anti-Spam legislation, (“CASL”), and other legislation which may apply from time-to-time, designed to protect personal information and privacy.
Personal Information Definition
Personal information means any information about an identifiable individual. Personal information does not include information that cannot be attributed to an individual, such as information of any aggregate or anonymous nature.
WFC is committed to respecting and protecting personal information and privacy and considers matters relating to the protection of personal information and privacy to be highly important.
- WFC does not collect personal information except when such individuals specifically provide information on a voluntary basis, or as otherwise allowed by law.
- WFC does not knowingly collect any personal information from children under the age of 13, except for the purposes of registering in the Blue Bombers Kids Club, which is done with the permission of a parent or guardian. Children’s registration for the Blue Bombers Kids Club must also include contact information for the parent or guardian of the child.
- Personal information will not be disclosed to third parties unless: (a) the individual to whom it relates consents to the transfer; (b) it is allowed by law; or, (c) the third party is providing services, in respect of the personal information, to WFC and the third party agrees to meet applicable privacy standards.
- All personal information provided to WFC will be protected with industry-standard protocols and technology.
The following, without limitation, are particular circumstances in which WFC has implied consent:
- Using identification information and contact information, such as name, address and e-mail address, to provide a person with information about WFC when that information is requested;
- Using identification information and contact information, such as name, address and e-mail address, so that WFC can identify a person and deliver products, services, promotions, and newsletters requested and can communicate regarding those products, services, promotions and newsletters including in accordance with CASL when responding to customer service requests;
- Using payment method preferences and related financial information provided to WFC so that WFC can obtain payment for the products and services requested and can process transactions in an efficient manner;
- Using information relating to preferences so that WFC can deliver products and services and the Website in accordance with those preferences;
- Using customer relationship information such as products and services requests, instructions, comments and feedback to assist WFC in delivering products and services and the Website in accordance with stated preferences;
- Using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose;
- Using an e-mail address to administer a promotion or survey or to provide information about events that may interest a person or new features and/or enhancements to WFC’s products and services and to the Website, in accordance with CASL, where applicable;
- Analyzing personal information to assist WFC in developing and enhancing its products and services or the Website; and,
- Analyzing personal information to assist WFC in conducting market analysis and strategic planning.
WFC reserves the right to contact a subscriber regarding account status, changes to the subscriber agreement, and other matters relevant to the underlying service and/or the information collected.
The following, without limitation, are particular circumstances in which WFC may disclose personal information without obtaining further consent:
- Where WFC is under a duty to disclose 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 WFC in good faith believes 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;
• exercise or protect the rights, property or personal safety of WFC, its users, employees, or others;
• investigate and defend the WFC against any third party claims or allegations.
WFC reserves the right to continue handling personal information in those circumstances required or permitted by law despite a change or withdrawal of consent. Any change to or withdrawal of consent may not apply retroactively. Also, upon request, the WFC will allow any individual to “opt out” of further promotional contacts at any time.
Non personal information and data may be automatically collected through the standard operation of the WFC internet servers or through the use of “cookies”. Cookies are small text files a web site can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and allow a site to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site.
Most internet browsers permit a user to deny or accept the cookie feature. Users should note that cookies may be necessary to provide the user with certain features (e.g. customized delivery of information) available on the WFC website. If a user does not provide all information requested, use of the website and related interactions may be limited.
The WFC website may contain links to other websites or online services that are operated and maintained by third parties that are not under the control of WFC or maintained by WFC. These links are not an endorsement by WFC of the other websites, the content displayed therein, or the persons or entities associated therewith. These other sites may send their own cookies to users, to collect data or solicit personal information. WFC does not have any control over these third party services and therefore has no responsibility or liability for the manner in which the entities that operate the linked services may collect, use, or otherwise treat personal information.
Retention and Destruction of Personal Information
WFC may retain personal information for as long as it reasonably requires personal information for the purposes for which it was collected or for legal, tax, or business purposes.
When personal information is no longer needed it will be appropriate destroyed or anonymized.
Accuracy and Completion of Personal Information
When WFC 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 WFC’s purposes in collecting, using, or disclosing the information. To do so, it may be necessary for WFC to request additional information from an individual or to verify the information.
Also, upon request, the WFC will use reasonable efforts to allow individuals to update/correct personal information previously submitted which the individual states is erroneous or not current to the extent that such activities will not compromise privacy or security interests. Individuals can update their name, address, and contact information online for the My Bomber Account as well as their email subscription preferences, payment methods, and password.
WFC has an obligation to protect personal information that is in its custody or under its custody by implementing reasonable security and technology safeguards to keep personal information secure and protect it against risks such as loss, theft, and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. These reasonable safeguards will vary depending on the circumstances including the level of sensitivity of the personal information.
All WFC employees are required to abide by the privacy standards established. Full time employees are informed about the importance of privacy and they are required to sign comprehensive non-disclosure agreements which provide explicit legal confidentiality and privacy protections. Any employee who violates the privacy and/or security policies is subject to disciplinary action, including possible termination. To reinforce our understanding and commitment to upholding privacy and confidentiality, employees periodically receive up-to-date training about our privacy policies, principles and standards.
When we contract our suppliers to provide specialized services, they are given only the personal information necessary to perform those services. Additionally, they are prohibited from storing, analyzing, using or disclosing that personal information for purposes other than to carry out the service they have been contracted to provide.
Access to Personal Information
WFC acknowledges that individuals have a right to access the personal information that the WFC holds about them.
The VP of Operations is responsible for any requests received to access an individual’s personal information.
A written request should be submitted to the VP of Operations. The written request should be signed by the requestor and include sufficient detail to enable WFC, with a reasonable effort, to identify any record in the custody or under the control of the WFC containing the personal information in respect of which the request is made. WFC reserves the right to request sufficient information to ensure the identity of the requestor and that person’s right of access.
WFC will reasonably provide the following:
- Access to your personal information (if any) under WFC custody or control;
- Information about the purposes for which the personal information (if any) under WFC control has been and is being used by WFC;
- The names of the persons to whom, and the circumstances under which, personal information (if any) has been and is being disclosed by WFC.
If a copy of the personal information is requested and the information can be reasonably reproduced, WFC will provide a copy of the record or the part of the record containing the requested information. If applicable, WFC will provide reasons for any delay in providing a copy of the requested information or record.
WFC reserves the right to 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 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 the WFC has to refuse access to personal information, in whole or in part, WFC will provide the reasons for the refusal, the provision of the PIPEDA on which the refusal is based, and the name of the individual who can answer questions on behalf of the WFC about the refusal. WFC will also provide information on any recourse possible pursuant to the PIPEDA.
Accountability and Contacting WFC
Attention: Privacy Officer
Winnipeg Blue Bombers
Investors Group Field
315 Chancellor Matheson Road
Winnipeg, Manitoba R3T 1Z2