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Introduction

ALETHEA SPORT INC. (“Alethea Sport” or “we”) recognizes that your right to privacy is an important issue. We understand your interest in maintaining and protecting your private information. As a result, we manage your personal information as described in this Privacy Policy.

This Privacy Policy provides you with the safeguards set forth Alberta's Personal Information Protection Act (PIPA) (“Privacy Laws”).  Nothing in this Privacy Policy will limit Alethea Sport’s obligations and rights pursuant to such Privacy Laws. The Corporation is also obliged to comply with provincial and federal legislation, including without limitation the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and anti-spam legislation ("Applicable Legislation").

This Privacy Policy applies to personal information concerning the users of our website, business partners and suppliers (“you”) that is collected, used or disclosed by us.  It also applies to the management of personal information in any form whether oral, electronic or written. The Privacy Policy does not apply to other information that is protected by other policies and practices or through contractual arrangements.

 

What Personal Information Do We Collect?

Personal information is information about an identifiable individual, as defined in applicable Privacy Laws.  Generally speaking, personal information does not include:

  1. anonymous or aggregated information that does not allow an individual to be identified;
  2. information regarding companies and other “legal persons”; or
  3. business contact information such as your name, title or position, business address, telephone number or fax number.

The types of personal information that Alethea Sport may collect from you from time to time include: your name, home address, telephone number, personal email address, your mailing preferences and customer service preferences.  In addition, from time to time, we may ask you to provide us with more detailed information regarding your interests, occupation and background.  For example, we sometimes ask our customers to complete surveys in order to get a better sense of who they are and what issues, competitive events may be of interest to our website users.

Your Consent

CONSENT

 

BY SUBMITTING PERSONAL INFORMATION TO ALETHEA SPORT OR ITS SERVICE PROVIDERS AND AGENTS, YOU AGREE THAT ALETHEA SPORT AND ITS SERVICE PROVIDERS AND AGENTS MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY PRIVACY LAWS.  Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting ALETHEA SPORT’s Privacy Officer.  If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.  If you provide us  or our service providers and agents with personal information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to allow us to collect, use and disclose their personal information for the purposes set forth in this Privacy Policy.

 

 

The Privacy Principles Alethea Sport Follows

When we collect, use and disclose your personal information, we use “fair information practices” as described in the following ten privacy principles and embodied in the Privacy Laws:

  1. Accountability:  Alethea Sport is responsible for personal information under its control and has designated an individual who is accountable for Alethea Sport’s compliance with the ten principles (“Privacy Officer”).  As such:
  2. accountability for Alethea Sport’s compliance with these privacy principles lies with the Privacy Officer, although other individuals within Alethea Sport may be responsible for the day-to-day collection and processing of personal information.  In addition, other individuals within Alethea Sport may be delegated to act on behalf of the Privacy Officer;
  3. the identity of the Privacy Officer designated by Alethea Sport to oversee Alethea Sport’s compliance with the principles shall be made known upon request; and
  4. Alethea Sport is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing.  Alethea Sport shall use contractual or other obligations to provide a comparable level of protection while the information is being processed by a third party.
  5. Purpose of your Personal Information:  In general, Alethea Sport collects, uses and discloses personal information in an aggregate (anonymous) format or is otherwise consolidated based on age group(s) (also on an aggregate basis), in order to help us provide our services to you and build improvements to our website.  More specifically, Alethea Sport collects, uses and discloses your personal information for the following purposes:
  6. to establish and maintain commercial relationships with users, suppliers, event competition organizers/producers and other third parties, including to administer user accounts, process new accounts, and to fulfill contractual and legal obligations;
  7. to develop and manage our business and operations.  This may include the sharing of personal information by and between Alethea Sport personnel and with third party service providers and agents for this purpose;
  8. to detect and protect Alethea Sport and other third parties against error, fraud, theft and other illegal activity, and to audit compliance with Alethea Sport’s policies and contractual and legal obligations;
  9. to distribute our newsletters and other material to individuals on our mail and e-mail lists, including via third party mailing houses and e-mail service providers;
  10. to engage in a business transaction, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving Alethea Sport;
  11. to understand and respond to users, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
  12. to develop, enhance, market, sell or otherwise provide Alethea Sport’s products and services;
  13. to market, sell or otherwise provide products and services of third parties with whom Alethea Sport has a commercial relationship;
  14. as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
  15. for any purpose to which you consent.

Alethea Sport will collect, use and disclose only that personal information necessary for the purposes that have been identified.

  1. Consent:  your knowledge and consent are required for the collection, use, or disclosure of personal information, except as permitted by Privacy Laws.  Pursuant to this Privacy Policy, you acknowledge your consent to Alethea Sport’s collection, use and disclosure of your personal information, or the personal information of another individual which you provide to Alethea Sport, as stated above.  Generally, should a different purpose to the collection, use or disclosure of your personal information be proposed by Alethea Sport, Alethea Sport shall seek your consent at the same time it collects the information. However, Alethea Sport may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed, for a new purpose.  You may withdraw consent at any time to some or all of the purposes indicated below, subject to legal or contractual restrictions and reasonable notice.  Please note, however, that in some circumstances, we may not be able to provide you with our services if you withdraw your consent to our use of your personal information.

NOTE: In certain circumstances under Privacy Laws, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information.

  1. Limiting Collection:  The collection of personal information is limited to what is necessary for the purposes identified by Alethea Sport.  Information shall be collected by fair and lawful means and may be collected from other sources who represent that they have the right to disclose the information.  In most cases, collection shall be pursuant to appropriate contractual arrangements.
  2. Limiting Use, Disclosure, and Retention:  Personal information shall not be used or disclosed for purposes other than those for which is was collected, except with the consent of the individual or as required or permitted by Privacy Laws or other Applicable Laws.  Personal information shall be retained only as long as necessary for the fulfillment of those purposes or as required by law.

Alethea Sport may collect from and/or disclose your personal information to:

  1. a person who, in the reasonable judgment of Alethea Sport, is providing or seeking the information as your agent;
  2. any of the companies and business entities that form part of Alethea Sport;
  3. an organization or individual retained by Alethea Sport to perform functions on its behalf, such as contractors, consultants, auditors, software developers (including web-site developers and hosts), data processing, document management and office services;
  4. an organization or individual retained by Alethea Sport to evaluate your creditworthiness or to collect debts outstanding on an account;
  5. financial institutions and credit card providers, on a confidential basis and solely in connection with user account administration (including deposits and payments), fraud investigations and security, and processing of payments and deposits through the Alethea Sport services;
  6. a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;
  7. our auditors and professional advisors;
  8. another person or corporation as part of conducting business together or pursuant to the sale of all or substantially all of Alethea Sport’s assets related to one or more specific lines of business, subject to the other person or corporation agreeing to manage personal information in accordance with Privacy Laws;
  9. another company or person for the development, enhancement, marketing or provision of any of Alethea Sport’s products or services;
  10. an agent or third party retained by Alethea Sport in connection with Alethea Sport’s administration or the provision of Alethea Sport 's products or services;
  11. credit grantors and reporting agencies;
  12. applicable public authorities where such disclosure is required pursuant to Applicable Laws; and
  13. a public authority or agent of a public authority, if in the reasonable judgment of Alethea Sport, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of this information.

Except as permitted in this principle, Alethea Sport does not provide or sell its customer lists to any outside company for use in marketing or solicitation.

  1. Accuracy:      Alethea Sport will update your personal information as and when you request.  Alethea Sport will not routinely update personal information, unless such process is necessary to fulfill the identified purposes.  If ever your contact and/or other personal information changes, please feel free to contact us so that we can update our records.
  2. Safeguards:  Your Personal information will be protected by security safeguards appropriate to the sensitivity of the information.  This is to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.  The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage.  The methods of protection include:
  3. physical measures, such as locked filing cabinets and restricted access to offices;
  4. organizational measures, such as security clearances and limiting access on a “need-to-know” basis; and
  5. technological measures, such as the use of passwords, firewalls and encryption.
  6. Openness:     Alethea Sport shall make readily available to you information about our Privacy Policy and practices relating to the management of personal information.  For example:
  7. the name or title, and the address, of the Privacy Officer to whom complaints or inquiries can be forwarded;
  8. the means of gaining access to personal information held by Alethea Sport;
  9. a description of the type of personal information held by Alethea Sport, including a general account of its use;
  10. a copy of any brochures or other information that explain Alethea Sport’s policies, standards, or codes;
  11. what personal information is made available to related organizations, i.e.: affiliated companies; and
  12. Individual Access:  Upon your request, subject to certain exceptions under Privacy Laws, you shall be informed of the existence, use, and disclosure of your personal information and shall be given access to that information. You may wish to challenge the accuracy and completeness of the personal information and have it amended as appropriate.

NOTE:  In certain situations, under Privacy Laws, Alethea Sport may not be able to provide access to all of your personal information it holds.  The reasons for denying access will be provided to you.  Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-users or litigation privilege.

  1. Challenging Compliance:  You may wish to address a concern regarding Alethea Sport’s compliance with the above principles to Alethea Sport’s Privacy Officer.  Alethea Sport shall investigate all complaints.  If a complaint is found to be justified, Alethea Sport shall take appropriate measures to resolve the complaint, including, if necessary, amending this Privacy Policy and practices.

Privacy and our Website

Cookies – When you access the Alethea Sport website, we may use a browser feature called a “cookie” to collect information, such as the type of Internet browser and operating system you use, the domain name of the website from which you came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated.  A cookie is a small text file containing a unique identification number that identifies your browser, but not necessarily you, to our computers each time our website is visited.  Unless you specifically inform us (e.g. by registering for an event or sending us correspondence from the website), we will not know who you are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with whom we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by you.  You can reset your browser either to notify you when you have received a cookie or refuse to accept cookies.  However, if you refuse to accept cookies, you may not be able to use some of the features available on our website.

Online Communications – In order to provide you with services or information, you may voluntarily submit personal information to us through our website for purposes such as conducting business online, asking a question, obtaining information, reviewing or downloading a publication, participating in an event, and participating in contests and surveys.  If you are known to Alethea Sport as a registered user of an online service, we may combine and store personal information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.  All collection, use and disclosure of personal information obtained through our website shall be subject to this Privacy Policy and Privacy Laws.

E-mail Communications – Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about the services of Alethea Sport and other third parties with whom we have a relationship.  We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from Alethea Sport.

Links – Our website may contain links to other websites which are provided as a convenience only.  Visitors are advised that other third party websites may have different privacy policies and practices than Alethea Sport, and Alethea Sport has no responsibility for such third party websites regarding its privacy policies on its content generally.

Changes to the Privacy Policy

Alethea Sport reserves the right to modify or supplement this Privacy Policy at any time.  If we make a change to this Privacy Policy, we will post the revised Privacy Policy on our websites.  We will provide to you such revised Privacy Policy upon request to the Privacy Officer.  However, Alethea Sport will obtain the necessary consents required under applicable Privacy Laws if it seeks to collect, use or disclose an individual’s personal information for purposes other than those to which your consent has previously been obtained unless otherwise required or permitted by Privacy Laws.

Further Information

Alethea Sport has appointed a Privacy Officer to oversee compliance with this Privacy Policy and applicable Privacy Laws.  For information on Alethea Sport’s privacy practices, please contact our Privacy Officer at:

Address:        Alethea Sport Inc.

PO Box 94095 Elbow River Postal Outlet

Calgary AB, T2S 0S4

 

Email:             privacy@aletheasport.com