ROYAL AGRICULTURAL WINTER FAIR ("RAWF") PRIVACY POLICY
Effective January 1, 2004
At The Royal Agricultural Winter Fair ("RAWF"), we are committed to protecting the privacy and confidentiality of the personal information of our clients (individually, the "Client" and collectively, the "Clients".)
The purpose of this Privacy Policy is to advise you as to why we ask for personal information, how we use it, what safeguards we employ, and how to contact us with privacy-related questions.
What Is Personal Information?
In this Privacy Policy, "Personal Information" means information that specifically identifies a Client as an individual and is provided to, or collected by, RAWF and its staff or by RAWF's agents, associates, and affiliates on RAWF's behalf (collectively, the "RAWF Group"). Personal Information however, does not include business related information and certain publicly available information such as business address, name, title and fax. Where an individual uses his or her home contact information as business contact information as well, we consider that the contact information provided is business contact information.
Why RAWF Collects Personal Information?
RAWF collects and uses Personal Information for the following purposes:
Providing services to the Client;
Advising Clients of the promotional events available through RAWF; Administration, billing, accounting and collection issues related to a Client's account with RAWF; Compliance with all municipal, provincial, federal and other applicable laws; and such other specific purposes which are communicated to the Client by a member of the RAWF Group before collection of such Personal Information.
Except when otherwise permitted by law, we will only use a Client's Personal Information for the purposes identified to the Client. When Personal Information is to be used for a purpose not identified, we will take all reasonable steps to ensure that new purpose is identified prior to use.
How Do We Collect Personal Information?
Wherever possible we collect your personal information directly from you, at the time of application.
Consent
Your provision of Personal Information to RAWF means that you agree and consent that RAWF can collect, use and disclose your Personal Information in compliance with this Privacy Policy. RAWF will not collect, use or disclose a Client's Personal Information without the Client's requisite consent, except in certain extraordinary circumstances. Such extraordinary circumstances shall include without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent or where it is otherwise in the best interests of the Client.
You may also consent by implied means such as when you have previously provided Personal Information to us and continue to use our services on other matters or where you provide us with your personal telephone number so that we can contact you at home or place of work.
Our Clients may withdraw their consent by written notice to us at any time, subject to any legal or contractual restrictions and reasonable notice. A Client's refusal to provide, or subsequent withdrawal of, his or her consent may affect RAWF's ability to provide the Client with services. A member of RAWF will inform the Client of the implications of such withdrawal. To withdraw consent, a Client should contact the Chief Privacy Officer in writing at:
RAWF
Direct Energy Centre, Exhibition Place
Toronto, Ontario, M6K 3C3
Attn: Privacy Officer
Email: privacyofficer@royalfair.org
Use and Disclosure of Personal Information
We will use a Client's Personal Information to provide services to the Client, to administer our database, to include Clients in direct marketing activities and for the other uses described above under the heading "Why RAWF Collects Personal Information". Under certain circumstances, RAWF will disclose a Client's personal information to third parties. Specifically, Personal Information may be used, shared and disclosed to, from, or with, are necessary to facilitate the matter for which the Client has retained our office and provided its consent.
Under certain circumstances RAWF may disclose Personal Information where: required or authorized by law to do so, for example if a court issues a subpoena; a Client has consented to the disclosure; where it is necessary to establish or collect fees; if RAWF engages a third party to provide administrative or support services to us (such as computer back-up services, shredding or archival file storage) and the third party is bound by our Privacy Policy; or if the information is already publicly known.
Limiting collection and retention of Personal Information
RAWF limits the collection of a Client's Personal Information to that which is necessary for the purposes identified in this Privacy Policy as same may be amended from time to time, or for any additional purpose identified to the Client before the collection of the Personal Information. As well, Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Client or as otherwise permitted by law.
RAWF will retain Personal Information only for so long as it is needed to fulfill the purposes for which it was obtained.
Accuracy
RAWF strives to ensure that a Client's Personal Information is as accurate, complete, and up-to-date as is necessary for the purposes for which it is used.
Safeguards
RAWF endeavours to maintain adequate safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Clients' Personal Information in the care of the RAWF.
Accountability, Openness and Client Access
RAWF is responsible for the Personal Information under its control and has appointed a Chief Privacy Officer to oversee our efforts to comply in all material respects with applicable privacy legislation and the terms of this Privacy Policy. The Chief Privacy Officer and those designated by the Chief Privacy Officer (the "Privacy Team") address and investigate questions or concerns regarding a Client's Personal Information.
To reach the Chief Privacy Officer or a member the Privacy Team, please 416-263-3400 or e-mail: privacyofficer@royalfair.org. A copy of this Privacy Policy and any future updates or amendments is available at www.royalfair.org.
RAWF will provide a Client access to their Personal Information. The Client may correct or amend any inaccuracies in the Client's Personal Information. RAWF has the right to refuse a request for access to Personal Information if:
Granting access would reveal confidential commercial information;
Doing so would reasonably be expected to threaten the life or security of another individual;
The information was collected for purposes related to the detection and prevention of fraud;
The information would likely reveal personal information about another individual;
The request is vexation or frivolous; or
To protect our rights and property.
Challenging Compliance
Clients are encouraged to discuss any privacy issues with the Chief Privacy Officer or a member of the Privacy Team.
Changes To This Privacy Policy
RAWF will from time to time review and revisit privacy practices and this Privacy Policy. In the event of any material amendment, an appropriate notice will be posted on RAWF's Web site. All Clients are encouraged to contact RAWF to establish if any updates have been made to this Privacy Policy, which can be ascertained by the date listed at the top of this Privacy Policy. All updates and amendments to this Privacy Policy can be found at www.royalfair.org.
RAWF Web site
Our Web site may contain links to other sites, which are not governed by this Privacy Policy. On our Web site, like most other commercial Web sites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.
