This Privacy Policy was last revised January
19, 2004
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.
We maintain a firm commitment to the privacy of our customers’ 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 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 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. 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
- 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.
- Identifying Purposes: We
will identify the purposes for which Personal Information is
collected, either before or at the time of collection.
- Consent: We
will only collect, use and disclose Personal Information with
a customer’s knowledge and consent, except where otherwise
required or permitted by law.
- Limiting Collection: We
will limit the collection of your Personal Information to only
those details that are necessary for the purposes identified.
- 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.
- Accuracy: We
will keep Personal Information that we collect accurate, complete
and up-to-date to fulfill the purposes for which it was collected.
- Safeguards: We
will protect your Personal Information with security safeguards
appropriate to the sensitivity of the information.
- Openness: Specific
information about our policies and practices relating to the
management of Personal Information will be made available to
you upon request.
- 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 challenge
the accuracy and completeness of your Personal Information
and to have it amended as appropriate.
- Challenging Compliance: You
may contact us with any questions, complaints or suggestions
with respect to the above principles.
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 telephone
number of an employee of an organization. Personal Information with personal
identifiers removed (removes your identity from the information) 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:
Name
Mailing Address
Email Address
Telephone Number
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. HorsePlayer 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
Your Personal Information may also be used
to provide us with business statistics. These statistics do not
contain any information which identifies you personally.
You Can Choose Not To Receive
Direct Marketing
We may inform you about our events, promotions or services by mail, telephone,
e-mail or other means. If you do not wish to receive direct marketing, contact
us and tell us that you do not want to be contacted in a particular way. See
below for contact details.
Giving Consent
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 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.)
Withdrawing Consent
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 recognize your concerns about the security of the Personal Information which
you provide to us. Our processes and procedures keep your Personal Information
safe and secure. We have different safeguards in place (physical, technological
and organizational).
Your Personal Information will not be used or disclosed without your consent,
except where required or permitted by law. We will only use and disclose your
Personal Information to fulfill the purposes for which it was collected. Other
uses of your Personal Information will only be undertaken after we have obtained
your additional consent, or as may be required by law. We will only keep your
information for as long as needed for the stated purposes.
Your Personal Information will not
be sold to any organization for any purpose.
We will not disclose your Personal Information to any third party without your
approval, except that we reserve the right to disclose your Personal Information:
(a) to any of our affiliates, subsidiaries, third party service providers or
advisers that we deems appropriate; (b) if such disclosure is made pursuant
to a legal proceeding or as required by law; (c) to another business entity
should we plan to merge with, or be acquired by that business entity; or (d)
organizations involved in a merger, transfer or sale of our assets or business.
In the event that we disclose your Personal Information as set out of above,
we will require third party organizations who have access to your Personal
Information to protect and maintain your Personal Information in compliance
with the terms and conditions of this Privacy Policy.
Access and Update of Your Personal
Information
Accessing 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
or telephone number helps us in providing you with the best possible service.
You can contact us via our Web Site @ www.woodbineentertainment.com or
telephone our call centre at (416-675-8886).
We reserve the right to amend this Privacy Policy at any time. If we decides
to amend this Privacy Policy, we will provide you with notice of such amended
terms [by posting on our Web Site] so that you
will always know what information we gather, how we might use that information,
and whether we will disclose it to anyone. All amended terms shall be effective
immediately upon such notice.
Contact Us
If you have any questions, concerns or complaints regarding the privacy of
your Personal Information, you may contact us at the address listed below.
We will inform you of our complaint procedures and assist you in resolving
the situation. If a complaint is found to be justified, appropriate steps will
be taken including, if necessary, revisions to our practices and procedures.
Please write or e-mail:
Chief Privacy Officer
Woodbine Entertainment Group
P.O. Box 156, 555 Rexdale Blvd
Toronto, Ontario
M9W 5L2
privacy@woodbineentertainment.com
____________________________________________________________________
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
For copies of the Personal Information Protection and Electronic Documents
Act (PIPEDA) contact the Department of Justice or visit http://laws.justice.gc.ca