Last modified: July 2017
Under the PIPA, personal information includes information about an identifiable individual, such as name, address, telephone number, e-mail address, and credit card information. (“Personal Information”). Business contact information is not included in the definition of personal information under this legislation.
By submitting Personal Information to the VFTS, you
(ii) acknowledge and consent that the VFTS may retain service providers to perform certain services and that in the event that a service provider is located in the United States, Personal Information may be processed and stored in the United States and that United States governments, courts or law enforcement or regulatory agencies may be able to obtain disclosure of personal information through the laws of the United States.
Ultimately, it is up to you whether you want to provide any personal information to the VFTS. An individual may withdraw her or his consent at any time (subject to legal or contractual restrictions and reasonable notice) by notifying the VFTS in writing. However, if enough personal information is withheld, the VFTS may be unable to provide services.
c/o Vancouver Fringe Festival
1398 Cartwright Street
Vancouver, British Columbia, V6H 3R8
Information we collect and how we use it
General purposes – The VFTS collects, uses, and discloses Personal Information as follows:
- to administer and service our business relationship with you and to provide you with requested services;
- to enforce your obligations under your agreements with the VFTS;
- to offer you additional products and service that may be of interest to you;
- to solicit fundraising requests
- to solicit volunteer requests
- to confirm your eligibility for contests and special offerings;
- if required, to provide the various associations (e.g., Visa, MasterCard, Interac) with certain reporting with respect to our business;
- to investigate suspicious activities in relation to your account;
- in the event of a contemplated or actual fundamental restructuring of our business such as a reorganization, merger, acquisition, or amalgamation;
- when required or permitted by law; and
- otherwise with your consent.
• Information you provide – When you sign up to purchase tickets, to be an active member of the VFTS, sign up to volunteer, or sign up for our email newsletter, we ask you for Personal Information. We may combine the information you submit under your account with information from other VFTS services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
• Log information – When you access the Website, our servers automatically record information that your browser sends whenever you visit a website. These “server logs” may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser or your account.
• User communications – When you send email or other communications to the VFTS, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services. If you send and receive SMS messages to or from one of our services that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction. We may use your email address to communicate with you about our services including promoting upcoming events, special offers, volunteer opportunities, and fundraising requests.
How Long Personal Information is Retained
The length of retention of Personal Information varies in relation to the nature of the service provided. We keep Personal Information for the length of time necessary to fulfill the purpose(s) for which it was collected, as long as the retention and/or use is required by law, or until the user withdraws their consent, in writing, to the continued retention and/or use of their Personal Information.
The VFTS only shares personal information with other companies or individuals outside of the VFTS in the following limited circumstances:
- We have your consent. We require opt-in consent for the sharing of any sensitive personal information, which includes information we know to be related to confidential medical information, racial or ethnic origins, political beliefs, religious beliefs, or sexual orientation, and tied to Personal Information.
- We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to:
• satisfy any applicable law, regulation, legal process or enforceable governmental request;
• detect, prevent, or otherwise address fraud, security or technical issues; or
• protect against harm to the rights, property or safety of the VFTS, its users or the public as required or permitted by law.
The VFTS may provide some information received from you to outside organizations as necessary to provide requested services. Such organizations may include the various credit or debit card associations (including without limitation Visa, MasterCard, and Interac) or credit or debit card processors.
Our contracts with such third parties and affiliates require that any information:
- that we provide to them is held strictly confidential; and
- provided to them may be used solely for the purposes of providing the services that they have been contracted with to provide.
The VFTS may transfer Personal Information to outside agents or service providers that perform services on our behalf (for example, emailing houses) in which case we use similar contractual or other means to ensure that your Personal Information is protected and not used or disclosed for any purposes other than as directed by the VFTS.
The VFTS takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage and processing practices, and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.
The VFTS restricts access to Personal Information to VFTS employees, select volunteers, contractors, and agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
The VFTS may store the Personal Information in an electronic file or a physical file. The VFTS has implemented reasonable technological, organizational, and physical security measures to protect your Personal Information from unauthorized access, improper use, and accidental destruction or loss. The physical file containing your personal information will be stored at the VFTS’s premises, or if required, at an offsite storage facility. The electronic file containing your Personal Information will be stored on a secure network. Authorized employees and agents of the VFTS who have a legitimate purpose for accessing the Personal Information and require it in the course of their duties will have access to your Personal Information. There is restricted access to the VFTS’s offices and the VFTS’s computer server.
The VFTS uses encryption technologies to increase security levels when you visit certain secured areas of the Vancouver Fringe website. Encryption causes any data you provide to be altered into an unreadable format to prevent unauthorized access. In addition, patrons are also required to use a user ID and password to enter certain secured areas of the Website.
Accessing and updating personal information
When you use VFTS services, we make good faith efforts to provide you with access to your Personal Information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. After you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
The VFTS adheres to PIPA and the applicable privacy laws of the Province of British Columbia and Canada.