OKANAGAN HOCKEY GROUP INC.
Last Amended January 1, 2017
Academy Only: The athletes accepted into the Academy live with host families in a City in Canada where the hockey program is offered and receive products and services (collectively, the “Services”) relating to their Academy hockey training. In order to offer the Academy Services, OHG will collect, use and disclose personal information from and about the athlete and the athlete’s family. OHG will primarily manage the athlete’s personal profile through a third party platform, including any related software, apps, websites and associated services, (collectively, the “Platform”), which is customized and licensed to OHG.
The information collected by OHG;How OHG collects, retains, uses, discloses, destroys and protects your personal information;Certain of your options and obligations as a user of the Website, Services and the Platform;Your requests to access or correct your personal information; andHow to contact OHG.
Compliance with Legislation
Our Commitment to Your Privacy
OHG is committed to protecting your personal information and privacy and considers matters relating to the protection of your personal information and privacy to be of the utmost importance. OHG adheres to the following principles to protect your privacy:
“personal information” means information about an identifiable individual. Personal information does not include information that cannot be attributed to an identifiable individual, such as information of an aggregate or anonymous nature.
Personal Information Aggregated or Made Anonymous
To the extent that OHG makes any of your personal information anonymous or aggregates it with the personal information of others such that it can no longer be attributed to you, your information will no longer be considered to be personal information and OHG is entitled to use, retain, disclose and destroy such information in its absolute discretion.
Choosing to Provide Personal Information
When using the Website, Services or the Platform and dealing with OHG, you may choose not to provide certain of your personal information. If you choose not to provide all information reasonably requested of you, it may limit the manner in which you can make use of the Website, Services or the Platform and otherwise interact with OHG or you may not be able to access the hockey services through the Academy, Camps or Combines offered by OHG.
You agree that your child may be required to provide personal information about him/herself and his/her family directly to OHG and its employees, agents, contractors, host families and medical and para-medical professionals treating your child as part of his/her participation in the Academy, a Camp or a Combine. This information will be shared and stored by OHG.
You agree to abide by OHG’S policies and Code of Conduct, as amended from time to time, and to cooperate in any investigation or review regarding your child, whether the incident requiring an investigation or review occurred at school, with a host family, during camp, training, testing, practice or games or in the community. You agree to share all personal information reasonably necessary to permit OHG or any other entity authorized to carry out an investigation or review. Your refusal to cooperate in disclosing relevant information may result in the termination of your child’s participation in the Academy, Camp or Combine.
In certain circumstances, without limiting the foregoing provisions, including but not limited to when dealing with certain legal, urgent medical or security issues, OHG may be authorised or required by law to disclose your personal information without seeking or obtaining your knowledge or consent.
Consent via Opt-In or Opt-Out in Certain Circumstances
OHG also may, from time to time, provide you with a reasonable opportunity to opt-in to certain collections, uses and disclosures of your personal information. If you do not opt-in to a particular collection, use or disclosure of your personal information when given a reasonable opportunity to do so, you do not consent to your personal information being collected, used or disclosed in that particular manner.
Where OHG provides an opt-in or opt-out opportunity, OHG will use the opt-out method when the particular collection, use or disclosure does not pertain to sensitive information or would be reasonably expected by the user of the Services or the Platform. OHG will use the opt-in method in other circumstances.
Changing or Withdrawing Consent
If you are withdrawing consent with respect to health information, the above information applies. Further, a revocation of consent that is provided in writing must be signed by the person providing it. A revocation of consent that is provided electronically is valid only if the level of authentication is sufficient to identify the individual who is revoking the consent.
If you withdraw certain consents reasonably requested of you and necessary for you to make use of the Services or the Platform or to otherwise interact with OHG, it may limit the manner in which you and/or your child can make use of the Services or the Platform and otherwise interact with OHG or you and/or your child may not be able to use the Services or the Platform or interact with OHG at all.
Your ability to change or withdraw consent is not absolute. OHG reserves the right to continue handling your personal information in those circumstances required or permitted by law despite a change or withdrawal of consent.
Any change to or withdrawal of consent will not apply retroactively.
Collection of Personal Information
OHG may collect non-identifying health information about your child for any purpose. OHG will only collect personal information with respect to identifying health information if expressly authorized by law to do so.
Use of Personal Information
The following are particular circumstances in which OHG may use your personal information without obtaining your further consent. By providing your personal information to OHG, you consent to the following uses:
using identification information and contact information, such as your name, address and e-mail address, to provide you with information about OHG;using identification information and contact information, such as your name, address and e-mail address, so that OHG can identify you and deliver the Services that you request and to communicate with you regarding those Services;using payment method preferences and related financial information that you provide to OHG so that OHG can obtain payment for the Services that you request;using information relating to your physical, mental, health, accommodation, nutrition, transportation and educational needs and preferences so that OHG can deliver the Services and the Platform to you in accordance with those preferences;using customer relationship information such as your service requests, instructions, comments and feedback to assist OHG in delivering the Services and the Platform in accordance with your preferences;using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose;using your e-mail address to provide you with information about new features or enhancements to the Services or the Platform;analyzing your personal information to assist OHG in developing and enhancing the Services or the Platform; andanalyzing your personal information to assist OHG in conducting market analysis and strategic planning.
OHG uses a third party provider for processing payments. OHG complies with PIPEDA and requests the third party provider comply with PIPEDA. OHG cannot guarantee third party compliance with PIPEDA.
Disclosure of Personal Information
The following are particular circumstances in which OHG may disclose your personal information without obtaining your further consent. By providing your personal information to OHG, you consent to the following disclosures:
– where the disclosure is set out in the related documentation for the Services or the Platform or is reasonably expected through the provision of the Services or the operation of the Platform;
– where OHG is under a duty to disclose your 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 OHG believes in good faith 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;to enforce agreements to which OHG is a party;to investigate and defend OHG against any third party claims or allegations;to protect the security or integrity of the Services or the Platform; and/orto exercise or protect the rights, property or personal safety of OHG, its clients and users, employees, or others;
Accuracy and Completeness of Personal Information
When OHG 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 OHG’S purposes in collecting, using or disclosing the information. To do so, it may be necessary for OHG to request additional information from you or have you verify your personal information. Should your personal information change, please inform OHG of the change(s) so that your personal information in OHG’S possession remains accurate and complete.
Retention and Destruction of Personal Information
Within a reasonable time period after OHG no longer reasonably requires your personal information for the purposes for which it was collected or for legal or business purposes, OHG either will destroy the records under its custody or control containing your personal information or it will render your personal information anonymous so that it can no longer be used to identify you.
Security of Personal Information
OHG recognizes its obligation to protect personal information that is in its custody or under its control by implementing reasonable security safeguards to keep confidential and secure your personal information against risks such as loss, theft, and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. These reasonable safeguards may vary depending on the circumstances, including the level of sensitivity of the personal information, and may include restricting access to authorized individuals on a need-to-know basis, locked doors and/or filing cabinets, other organizational, physical or technological security measures, and contractual measures such as non-disclosure or confidentiality agreements.
Requests for Access to Personal Information
Requests for Personal Information
On your written request, and taking into consideration what is reasonable, OHG will provide you, not later than 30 days from OHG’S receipt of your request, or such additional time as permitted or required by law, with:
access to your personal information (if any) under our custody or control;information about the purposes for which your personal information (if any) under our custody or control has been and is being used by us; andthe names of persons to whom, and the circumstances in which, your personal information (if any) has been and is being disclosed by us.
If you request a copy of your personal information and the information can reasonably be reproduced, OHG will provide you with a copy of the record or the part of the record containing the requested information or, if applicable, it will give you reasons for any delay in providing a copy of the requested information or record.
All requests may be subject to reasonable fees and disbursements. Where appropriate, OHG may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.
REQUESTS TO ACCESS PERSONAL INFORMATION MUST BE IN WRITING
OHG requires that all requests for access to personal information be in writing, be signed by the requestor and include sufficient detail to enable OHG, with a reasonable effort, to identify any record in the custody or under the control of OHG containing the personal information in respect of which the request is made.
Limits on Right to Access Personal Information
Your ability to access your personal information under OHG’S custody and control is not absolute. OHG reserves all rights 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 any legal privilege;
the disclosure of the information would reveal confidential commercial information; orthe personal information was collected by us for an investigation or legal proceeding.
If access to your personal information is refused, in whole or in part, OHG will provide you with the reasons for the refusal, the provision of PIPEDA on which the refusal is based, and the name of the individual who can answer your questions on behalf of OHG about the refusal, and will inform you that you may ask for a review of the refusal in accordance with PIPEDA.
Requests for Correction of Personal Information
On written request by you, OHG will make every reasonable effort to correct errors or omissions in your personal information where that information is in OHG’S custody or control. OHG requires that all such requests be in writing, be signed by the requestor, and include sufficient detail to enable OHG, with a reasonable effort, to identify any record in the custody or under the control of OHG containing the personal information in respect of which the request is made.
If you make such a request, OHG will, as soon as reasonably possible and not later than 30 days from OHG’S receipt of your request, or within such additional time as permitted or required by law, either:
correct the personal information and, if reasonable to do so, send correction notifications to any third party to whom OHG disclosed the incorrect information; ordecide not to correct the personal information, but OHG will annotate the personal information under its control to indicate that a correction was requested but not made.
OHG will inform you of the action that it has taken in response to your request for correction, the name of the individual who can answer your questions on behalf of OHG about your request for correction, and that you may ask for a review of the action taken in accordance with PIPEDA.
Notwithstanding any requests for corrections of personal information, OHG will not correct or otherwise alter an opinion, including a professional or expert opinion.
Academy Athletes Only:
1. Use of the Services and the Platform
The Platform is licensed to OHG by a third party technology and software developer (“Developer”). The personal information is stored by the Developer on servers in Austria and in the cloud governed by Austrian law. The Developer will create future modules for the Platform, which will be rolled out and customized for the Academy as future needs arise. The main purpose of the Platform is to provide a complete athlete management application directly to the youth’s mobile device (“App”) and to OHG’S coaches, trainers, educators, employees, contractors and agents with the objective of delivering ongoing training, developmental and management of the athlete’s daily and long term goals. The app also provides chat rooms and other means for the youth to communicate directly with teammates and other users of the app, and to share personal information, videos and photos.
The Platform and the App is intended to be used only by your child. The guardian(s) of the child will not be provided with direct access to the app, unless specifically requested.
In order to use the Services, OHG may require that you/your child provide personal information to OHG and consent to OHG collecting personal information about you from third parties such as your school, your host family, and your medical caregivers. The personal information collected by OHG will be used to create a player profile about you (the “Player Profile”). The Player Profile may include data and reports with respect to your physical condition, training history, athletic performance, educational performance, medical history, and disciplinary and conduct history.
As part of the Services, OHG may disclose, in its sole discretion, any portion of the athlete’s Player Profile to Interested Third Parties for the purpose of creating future developmental opportunities relating to your child’s hockey career. It may be necessary to disclose performance statistics, academic, medical and disciplinary records.
You may revoke your consent to the use and disclosure of your Player Profile, or any portion of the Player Profile by OHG in writing. Please note that OHG will not inform you in advance of any disclosure to Interested Third Parties. If you would like to be notified in advance of any disclosure to Interested Third Parties, you will need to advise OHG in writing at the beginning of the Academy year. By revoking your consent to any other disclosure required for the Services or the Platform, you may no longer be able to use the Services or the Platform.
OHG web servers collect the domain names, IP addresses and the activity of visitors. This information is aggregated for the purposes of measuring the number of visits, average time spent on the Platform, pages viewed, and other similar purposes. OHG uses this information to measure the use of the Platform and to improve the content of the Platform.
2. Use of the Okanagan Hockey Group Inc. Player Profile
You may also use the App to communicate directly with other users of the App (the “In-App Communications”). OHG does not monitor or otherwise have access to the In-App Communications, unless an employee or agent of OHG is a participant in the In-App Communications. In-App Communications will not be collected by OHG or included in the Player Profile. If the In-App Communications are used inappropriately, e.g., in contravention of OHG’S policies on conduct and behaviour, or are used to harass, bully, disparage or otherwise harm any other individual, OHG reserves the right to collect, use and disclose that information in order to take any necessary disciplinary action.
You may revoke your consent to the disclosure of your Player Profile to the Developer by requesting that OHG delete your App User Profile. At such time that your App User Profile is deleted, you will no longer be able to use the App or access any data saved on the App and this data will be destroyed by the Developer.
If your browser permits, you may adjust the settings of your Internet browser to notify you when you receive a cookie or to reject cookies altogether, but in some cases doing so may impact your ability to use the Platform. Because each Internet browser is different, users of the Platform should check the “help” menu of their browsers to learn how to change their cookie preferences.
4. Other Collection, Use and Disclosure of Personal Information
OHG also reserves the right to collect, use and disclose your personal information without your knowledge or consent where permitted or required by law.
Accountability and Contacting Okanagan Hockey Group Inc.
Should you have any questions or comments regarding OHG’S privacy policies, practices, or handling of your personal information or if you wish to request access to or correction of your personal information under OHG’S care and control, you may contact Okanagan Hockey Group Inc.’s Privacy Officer at:
Attention: Privacy Officer
Daryl Meyers firstname.lastname@example.org