Privacy Policy

Background

The Canadian International Military Games Corporation also known as the Invictus Games Toronto 2017 (“IG2017”) is a not-for-profit organization, the mandate of which is to plan, organize, promote, finance and stage the third Invictus Games to be held in the city of Toronto September 2017.

The collection, handling and disclosure of any personal information collected by IG2017 is governed by the Personal Information Protection and Electronics Documents Act (“PIPEDA”) and the applicable provisions therein. In addition, service providers under contract to provide online services on behalf of IG2017 must follow the same practices required of IG2017. IG2017 will not collect your personal information unless you choose to use service, online or otherwise, provided by IG2017 that require it. For transactions with IG2017 involving credit cards, we use up to date security protocols to ensure the integrity and confidentiality of information and systems.

Objectives

This Privacy Policy has been developed by IG2017 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. Our prime objective is to respect the privacy of individuals whose information is collected, used and disclosed by IG2017. It reflects our commitment to protecting the privacy and confidentiality of the personal information entrusted to us by our stakeholders. This Policy may change with the introduction of new technologies, business practices and stakeholder needs.

The Policy applies to all current and prospective stakeholders of IG2017 as well as to users of our online properties. It is to be read in conjunction with our Terms of Use.

Collection of Personal Information

Under its authority to plan, organize, promote, finance and stage the Games, there may be times when IG2017 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, subscribe to our newsletters or consent to receive other IG2017 electronic messages, enter into contests, participate in surveys, join our social networking sites, apply for full-time, part-time and/or contract employment or volunteer positions, or communicate online with our customer service representatives. If you use our “email this style to a friend” or “refer 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. Only personal information required for the planning, organizing, promotion, financing and/or staging of the Games will be collected. Any commercial electronic messages sent by IG2017 to you and/or your friend will be compliant with Canada’s Anti-Spam Legislation. You may “Opt-out” of receiving such IG2017 communications at any time and your electronic address will be removed from our databases.

What we collect: We may collect personal information through surveys, questionnaires, applications, order forms and any other means necessary in order to plan, organize, promote, finance and stage the Games. 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: IG2017 collects personal information about its stakeholders through various applications and order forms, including credit applications, surveys, consultation and questionnaires, face-to-face interactions and our online properties, including, but not limited to, any email, comment, question or request submitted or subscription for information online and any e-commerce transactions conducted with IG2017. 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. Parents and guardians are strongly encouraged to monitor their children’s use of the internet.
Individuals have a right to access their personal information that is held by IG2017 by making an access request under PIPEDA. These requests may be subject to fees. Access is subject to limits and exceptions. For more information on the process for accessing your personal information, you may wish to access the Office of the Privacy Commissioner of Canada website: www.priv.gc.ca

Use and Disclosure of Personal Information

Use of Personal Information:

IG2017 will use the personal information we collect to:

◦ provide stakeholders with news about the Games;

◦ manage our business;

◦ sell merchandise and tickets;

◦ comply with regulatory and industry requirements;

◦ create and maintain our vendor accounts

◦ communicate with our stakeholders.

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. IG2017 makes all reasonable efforts to ensure that information is used responsibly and only for its intended purposes.

We may provide your personal information to any third-party service provider that administers any Games facility, service and/or promotion operated via our website invictusgames2017.com/
(“the Site”) on our behalf. Your personal information will be provided to such third-party service providers only to enable its proper administration that Games facility, service or promotion. 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.

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 (e.g. United States) for processing by IG2017 staff operating outside Canada and/or third-party service providers contracted by us. If you submit personal information, you specifically consent by doing so to such transfer, storing or processing. Although we will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy, data stored outside of Canada is subject to the laws of the jurisdiction where it is stored. Notwithstanding the foregoing, we will make every reasonable effort to ensure that access to personal information is restricted to those individuals or agents who require access to personal information in order to perform their duties and where access is necessary and proper for the administration of the program.

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 federal, provincial, municipal funding partners, national sport organizations, provincial sport organizations, sponsors, financial institutions, credit reporting agencies, and third party service providers such as data processing and marketing companies.

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.

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, we may do so. Where it is reasonable, we may also imply your ongoing consent to the continued use and disclosure of your personal information in accordance with this Policy where we make additional requests for information. We will obtain your express consent before using or disclosing your personal information for any purposes not identified in this Policy.

The use and disclosure of personal information of specific stakeholders is described below:

Employees and Contractors

IG2017 collects and uses its employees’ and contractors’ information with the main focus of supporting its workforce. IG2017 may from time to time operate online job application systems. We may also collect personal information for the purpose of a job application in hard copy. If you submit such an application, we may process the information provided by you for the purpose of considering the application. If your application is not accepted at that time, we may retain and store your personal information in a recruitment database for the purpose of future recruitment.

If you have applied for a paid position with IG2017, we may disclose your personal information to agencies conducting security, background and credit checks on our behalf.

In the event your application is accepted and you become an employee or contractor of IG2017, your personal information will be processed for payroll and benefits purposes and used to administer your employment with IG2017. Your personal information will be provided to third-party payroll and employee benefits providers in order to manage IG2017’s payroll and benefits programs. Your personal information will also be shared with the federal and provincial governments for the purpose of administering the income tax regime in compliance with the Income Tax Act.

IG2017 will disclose personal information related to your employment, should such disclosure be required by law.

Sponsors

Sponsorship is critical to the promotion, financing and staging of the Games. IG2017 sponsorship initiative requires the collection of personal information from all sponsors and potential sponsors. A sponsor’s personal information may be collected and compiled into a contact list containing IG2017 sponsors and partners (“Contact List”).

The Contact List will be shared with each sponsor and partner for the purpose of fostering current, and promoting future, business opportunities. The Contact List will also be shared with our federal and provincial government funding partners for the aforementioned purpose. IG2017 will contact you in order to obtain your consent if we receive a request to disclose your personal information to one of our municipal partners.

The personal information of IG2017 sponsors and partners will not be disclosed to any third parties aside from those named above, unless expressly consented to by the sponsor or partner.

Competitors

IG2017 will collect personal information of all competitors, coaches and competitor staff participating in the Games. Personal information collected from competitors, coaches and competitor staff may be processed for the purpose of, among other things, security and accreditation. Personal information of competitors may also be used and disclosed in various ways in order to host, promote and stage the Games. The purposes of such disclosure include, but are not limited to, broadcasting events, marketing and promotions. The activities of athletes may be photographed, recorded, distributed and used by IG2017 as part of its official, promotional or educational material and may be used in any medium or form or with any support and without any compensation.

Medical data relating to participating competitors may be collected in association with the Games; the use and disclosure of such information is addressed in a separate privacy policy.

Volunteers

IG2017 may from time to time operate online volunteer application systems. We may also collect personal information for the purpose of a volunteer application in hard copy. If you submit such an application, your personal information will be collected and processed by our third-party application and digital interview service providers for the limited purpose of considering your application.

If you have applied for a volunteer position with IG2017, we will collect and disclose your personal information for the purpose of administering the accreditation process for the Games. The personal information you provide may be shared by IG2017 with the Royal Canadian Mounted Police (RCMP) to make the required determination on the ability to access various secure zones and official venues of the Games. This information is collected under the authority of the Royal Canadian Mounted Police Act, R.S.C. 1985, c. R-10 and the Royal Canadian Mounted Police Regulations, 1988, SOR/88-361, as amended. The personal information requested is essential for making the above determination and, should it not be provided, accreditation will not be granted. The personal information gathered will be stored by the RCMP in a Personal Information Bank, may be shared with other Government of Canada institutions and may be disclosed pursuant to the Privacy Act, R.S.C. 1985, c. P-21, as amended. Under this Act, individuals have the right to protection of, access to and correction of their personal information. More specific information can be found at www.infosource.gc.ca. IG2017 will disclose your name, gender, address, telephone number, email address, date and place of birth, and nationality/citizenship to the Ministry of Community Safety and Correctional Services for the purposes of conducting security background checks to provide accreditation for individuals requiring access to official venues to the Games.

The IG2017 volunteer program seeks to create a lasting legacy of trained, competent and experienced volunteers that will benefit Toronto and Ontario. Some volunteers will have the opportunity to operate official IG2017 vehicles during the Games. IG2017 will disclose your name, address, date of birth, telephone number, email address, driver’s license number and gender to the Ontario Ministry of Transportation for the purposes of confirming you are licensed to operate a vehicle in Ontario and qualified in accordance with IG2017 Fleet program, if required in order to fulfil your Games volunteer duties.

The activities of IG2017 volunteers may be photographed, distributed and used by IG2017 as part of its official, promotional or educational material and may be used in any medium or form or with any support and without any compensation. Your image, likeness, voice or performance (or all of these) may be made available to IG2017 whether such images and recordings have been or will be: (a) made or taken by any IG2017 employee or agent; or b) made or taken by me or any other person and submitted by me or another person on my behalf to IG2017 or a IG2017 representative.

Vendors and Suppliers

IG2017 has and will continue to contract with corporations and/or individuals as vendors and suppliers of products and services critical to the success of the Games. Personal information of vendors and suppliers is collected through the public procurement process.

Upon a vendor or supplier’s consent, IG2017 may disclose vendor or supplier information to certain partners who have signed up through the IG2017 website. This contact information includes email, phone number, company name, company address, contact name and job title (“Contact Information”). This Contact Information may be used for the purpose of informing you of potential future business opportunities. Consent will have already been provided by the vendor or supplier upon submission of the RFP.

IG2017 is committed to the confidential and sensitive nature of procurement agreements, and for that reason, does not make any procurement agreements public, unless compelled to by law. Procurement agreements may be shared with our federal and provincial government partners in order to properly plan, finance and stage the Games. All procurement agreements are kept secure and private and are accessible only to the IG2017 Procurement and IG2017 Legal Departments. Similarly, IG2017 does not make any of the RFP proposal submissions public. Only the IG2017 Evaluation Committee and IG2017 Procurement Department can view these documents, including pricing. From time to time, third-party consultants participate on evaluation committees. In these circumstances, the third-party consultant is subject to a confidentiality agreement.

Contests

In order to promote the Games, IG2017 may from time to time run promotional contests. Such contests may be operated through an online entry or registration system. If you submit a completed contest registration or entry form, we may process the information provided by you for the purpose of administering the contest.

With your prior consent, your personal information, including your name, address and email address may be used by IG2017 to send you our electronic newsletters or other such publications and information relating to other IG2017 promotions, contests, events or Games programs.

From time to time, IG2017 may run co-sponsored promotional contests. If you submit a completed contest registration form to one of IG2017 co-sponsored contest, we may disclose your name, address and email address to our co-sponsor.
The activities of IG2017 contest entrants may be photographed, distributed and used by IG2017 as part of its official, promotional or educational material and may be used in any medium or form or with any support and without any compensation. Your image, likeness, voice or performance (or all of these) may be made available to IG2017 whether such images and recordings have been or will be: (a) made or taken by any IG2017 employee or agent; or b) made or taken by me or any other person and submitted by me or another person on my behalf to IG2017 or a IG2017 representative.

Social Media

When you sign up to follow or communicate with social media accounts that we may operate from time to time, and/or to receive communications from IG2017 through these social media outlets, we may use the information that you provide to maintain, operate and facilitate such programs, networks and communications. Personal information that you provide to IG2017 via social media account(s) is collected to capture conversations (e.g. questions and answers, comments, “likes”, retweets) between you and IG2017. It may be used to respond to inquiries, contact you about giveaways or for statistical, evaluation and reporting purposes. This information will not be “mined” or stored by IG2017; however, your personal information may be collected, used and disclosed by the social media account administrator, independent of IG2017. Before engaging or communicating with IG2017, we strongly recommend that you review and understand the privacy policy, settings and information sharing functions of the social media website.

IG2017’s use of social media serves as an extension of its presence on the web. Social media account(s) are public and are not hosted on IG2017 servers. If you choose to interact with us via social media, you should read the privacy policies of these third-party service providers and those of any applications you use to access them. IG2017 uses Twitter, Facebook, Instagram, YouTube and LinkedIn.

Relay

The Invictus Games Relay will engage the public and showcase our partners, sponsors, participating municipalities and military bases. We may collect personal information of flag relay participants and may process such information for the purpose of planning, promoting and staging the Invictus Games Relay.

IG2017 may from time to time operate online relay application systems. If you submit such an application, your personal information will be collected and processed by our third-party application service providers for the limited purpose of considering your application.

If you have applied for a flag relay position with IG2017, we may disclose your personal information to agencies conducting security and background checks on our behalf.

The Invictus Games Relay is a sponsored event. IG2017 may disclose information provided by you to our sponsors.
Some Torch Relay volunteers will have the opportunity to operate official IG2017 vehicles during the Games. IG2017 will disclose your name, address, date of birth, telephone number, email address, driver’s license number and gender to the Ontario Ministry of Transportation for the purposes of confirming you are licensed to operate a vehicle in Ontario and qualified in accordance with IG2017 Fleet program, if required in order to fulfill your Games Relay duties.

The activities of the Invictus Games Relay volunteers may be photographed, distributed and used by IG2017 as part of its official, promotional or educational material and may be used in any medium or form or with any support and without any compensation. Your image, likeness, voice or performance (or all of these) may be made available to IG2017 whether such images and recordings have been or will be: (a) made or taken by any IG2017 employee or agent; or b) made or taken by me or any other person and submitted by me or another person on my behalf to IG2017 or a IG2017 representative.

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 us. 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. Any breach or apparent privacy breach of your personal information will be investigated in accordance to IG2017’s internal review process. 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 utilizes 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 email, we may retain the content of your email messages together with your email 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.

This website uses the Google AdWords, Facebook Conversion Pixel and Twitter remarketing services to advertise on third party websites to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example purchasing tickets. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network, Facebook, Twitter and YouTube. Third-party vendors use cookies to serve ads based on someone’s past visits to the IG2017 website. Of course, any data collected will be used in accordance with our own privacy policy and Google, Twitter and Facebook’s privacy policies.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can

◦ opt out of interest-based advertising entirely by cookie settings or

◦ permanently using a browser plugin

◦ opt out of Twitter ads simply uncheck the box next to “Promoted content” in your account settings, and Twitter will not match your account to information shared by their ad partners for tailoring ads.

◦ opt out of Facebook through the Digital Advertising Alliance.

Accuracy of Personal Information

IG2017 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. Please inform the appropriate IG2017 contact to request a change to your personal information. If you do not know, or are unsure of, the appropriate IG2017 contact, please send us your request at the address noted below.

Individual Access

If you have any questions about the collection, use, or disclosure of your personal information by IG2017, or if you simply want to know whether we have any of your personal information on file, you may contact us at the address set out below. IG2017 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) are 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 Canada. Any dispute arising under this Policy shall be resolved exclusively by the Office of the Privacy Commissioner of Canada. 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.

Canadian International Military Games Corporation
357 Bay Street, Suite 300
Toronto, Ontario Canada M5H 2T9
Attn: Personal Information Request