Woodbine Entertainment Group ("we" or "our") offers a range of racing, gaming and entertainment products, which are available across North America and worldwide through our various Internet sites. Neither this web site nor any of our other Internet sites are intended for use by children.
We maintain a firm commitment to the privacy of our customers' and our employees' Personal Information (defined below under the heading "What is Personal Information?"). The following outlines our commitment to you:
• Purpose and Consent: At the time of collection we will explain to you the purpose of collecting your Personal Information and obtain your consent to collect, use and disclose your Personal Information.
• Limiting Collection: We limit the collection of Personal Information to what is reasonable under the circumstances and your Personal Information will only be used for the purposes for which it is collected.
• Security: Your Personal Information is kept strictly confidential and is not disclosed outside of our operations without your consent, unless required or permitted by law.
• Access: You have the right to access the Personal Information that we maintain about you and to correct any inaccuracies.
We have adopted the 10 privacy principles established by the Canadian Standards Association's Model Code for the Protection of Personal Information. These principles form a part of the Personal Information Protection and Electronic Documents Act ("PIPEDA" or the "Act") which establishes the rules governing the collection, use and disclosure of Personal Information in Canada. It should be noted that certain provinces (Alberta, British Columbia and Québec) have privacy legislation that governs the collection, use, retention, protection and disclosure of personal information in those provinces. We will periodically review our principles in order to ensure that they remain relevant and current with changing technologies and laws and the evolving needs of our customers and employees.
Our 10 Principles:
1. Accountability: We are responsible for maintaining and protecting Personal Information under our control. We have appointed a Chief Privacy Officer to oversee our compliance with the Act and our 10 principles.
2. Identifying Purposes: We will identify the purposes for which Personal Information is collected, either before or at the time of collection.
3. Consent: We will only collect, use and disclose your Personal Information with your knowledge and consent, except where otherwise required or permitted by law.
4. Limiting Collection: We will limit the collection of your Personal Information to only those items of information that are necessary for the purposes for which the information is collected.
5. Limiting Use, Disclosure and Retention: Your Personal Information will only be used or disclosed for the purposes for which it was collected, unless you have otherwise consented, or where it is required or permitted by law. We will retain your Personal Information only as long as necessary to fulfill the purposes identified.
6. Accuracy: We will keep Personal Information that we collect accurate, complete and up-to-date to fulfill the purposes for which it was collected.
7. Safeguards: We will protect your Personal Information with security safeguards appropriate to the sensitivity of the information.
8. Openness: Specific information about our policies and practices relating to the management of Personal Information will be made available to you upon request.
9. Access: At your request, we will inform you of the existence, use and disclosure of your Personal Information and give you access to your Personal Information. You have the right to verify the accuracy and completeness of your Personal Information and to have it amended as appropriate.
What is Personal Information?
Personal Information is broadly defined as information about an identifiable individual, but does not include the name, title, business address or business telephone number of an employee of an organization. Personal Information with personal identifiers removed (removing the identity of the individual from the information) so that it can no longer be identified with a particular individual is not considered Personal Information.
Personal Information We Collect
With your consent, we may collect Personal Information from you in person, either by telephone, by mail, by intercept survey or through the Internet. Typically, we collect and maintain the following:
Date of Birth
It is always your choice as to whether you provide us with your Personal Information. However:
• Several of our products and services (e.g. telephone account and Internet wagering) are governed by federal and provincial regulations that require specific Personal Information be collected and maintained by us.
• Some of our products and services can only be delivered to you if we can collect, use and disclose your Personal Information (e.g. HPIbet Rewards program).
How We Use Your Information
Relationships With Our Customers Are Important To Us
We want to provide you with our various services on an ongoing and efficient manner to establish a long lasting relationship which will meet your changing needs.
With your permission, we collect Personal Information about you to:
• Provide you with products, services or information that you request
• Assist in identifying your preferences
• Provide you with information about upcoming events, promotions and new and improved services
• Protect you and us, against error and fraud
• Comply with legal requirements
• Comply with our internal risk management and related policies
* Conduct and promote contests, including awarding prizes, etc.
* Conduct and inform indirect marketing activities
* Provide you with the opportunity to participate in additional product offerings (such as, without limitation, partial cash out opportunities)
Your Personal Information may also be used to provide us with business statistics. These statistics do not contain any information which identifies you personally.
In accordance with Canada's Anti-Spam Legislation, you must provide your consent in order to receive information from us about our events, promotions or services by email or other electronic means. We may otherwise inform you about our events, promotions or services by mail, telephone or other means. If you wish to receive email correspondence from us, or if you do not wish to receive direct marketing by mail, telephone or other means, you may contact us using the contact information provided below.
Key to protecting the privacy of your Personal Information is consent. We collect, use and disclose your Personal Information only with your consent except where otherwise permitted or required by law. You may decline to provide us with your Personal Information. However, this choice may make it impossible for us to provide you with certain products or services. For example, we cannot set up a telephone wagering account with Internet access without the Personal Information which is required by the Canadian Pari-Mutuel Agency, the agency which regulates pari-mutuel wagering, on behalf of the Ministry of Agriculture (Agriculture Canada).
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you wish to withdraw your consent we will inform you of the implications. To withdraw your consent, simply contact us and tell us of the Personal Information which you no longer wish us to collect, use and/or disclose. See below for contact details.
Security and Disclosure of Your Personal Information
We may transfer your Personal Information to a third-party service provider or agent who provides services to us or on our behalf such as hosting, data management and storage services, market analysis and retention services. We may, or any such third-party service provider may, use servers for such purposes which are located outside of Canada. Your Personal Information may be processed in a location outside of Canada, and the laws of any such foreign jurisdiction may apply such that the governments, courts, law enforcement or regulatory bodies of any such foreign jurisdiction may be able to obtain disclosure of your Personal Information.
Third Party Websites
Your Personal Information will not be sold to any organization for any purpose.
Access and Update of Your Personal Information
You may access and verify your Personal Information. At the time of your request we will need specific information to verify your identity before we can provide you with the Personal Information we hold. In some instances, we will not be able to provide you with the Personal Information you request, for instance where that information:
• Contains references to other persons
• Has already been destroyed due to legal requirements or because the information has served its purposes
• Cannot be disclosed for legal reasons (e.g. when subject to solicitor-client or litigation privilege)
If we are unable to provide you with access to your Personal Information, we will explain why and advise you as to any recourse available to you.
Updating your Personal Information We are committed to maintaining the accuracy of your Personal Information. To help us keep your Personal Information up-to-date we encourage you to notify us of inaccuracies or corrections. Timely notification of a change of address, telephone number and/or email address helps us in providing you with the best possible service. You can contact us via our Web Site at www.woodbineentertainment.com or telephone our call centre at (416) 675-8886.
Please write or e-mail:
Chief Privacy Officer
Woodbine Entertainment Group
P.O. Box 156, 555 Rexdale Blvd
Toronto, Ontario M9W 5L2
For more information on the Woodbine Entertainment Group's commitment to privacy, contact the Woodbine Entertainment Group through our website: www.woodbineentertainment.com
For copies of the CSA Model Code for the Protection of Personal Information contact the Canadian Standards Association or visit their Website at www.csa.ca/standards/privacy/Default.asp.
For copies of the Personal Information Protection and Electronic Documents Act (PIPEDA) contact the Department of Justice or visit laws.justice.gc.ca/en/P-8.6