Great Canadian Gaming Corporation – Privacy Statement
Great Canadian Gaming Corporation and its subsidiaries (collectively “GCGC”) are committed to ensuring you have the very best experience at our properties. You have a right to know how your personal information is collected and what we do with it, so that you can make informed choices. We have created this Privacy Statement to explain in plain terms what we do and what we will not do with your personal information.
GCGC’s activities in British Columbia are subject to the British Columbia Personal Information Protection Act, and GCGC’s commercial activities in other provinces are governed by the federal Personal Information Protection and Electronic Documents Act and Provincial laws as applicable. These laws set out how GCGC may collect, use and disclose your personal information. In addition, some of our activities and obligations may be governed by freedom of information legislation in the jurisdictions where we operate. In this Privacy Statement, the term “Applicable Privacy Laws” will refer to the privacy and freedom of information laws as they apply to GCGC.
For the purposes of this Privacy Statement, “personal information” does not include business contact information (to the extent that it is excluded from the application of Applicable Privacy Laws), or aggregate and de-identified data that does not relate to an identifiable individual and cannot be reverse engineered alone or in combination with other available information.
Collection and Use of Personal Information
GCGC only collects personal information that we require for reasonable business purposes, including:
• Name, address, phone number, date of birth, gender, driver’s licence number, passport number, vehicle plate number, vehicle description – This information is collected in connection with security incidents, investigations and monitoring of potentially illegal activity on our property. Such information is used for security purposes, including to enforce bans from our property and to report incidents to law enforcement.
• Name, address or email address, telephone number – This information is collected when you register for contests, promotions, our newsletter, or services that require registration or subscription, and will be used only for the purpose that it is collected and consistent purposes (e.g., to communicate the results of the contest or provide the requested service). We will not send you electronic advertising or marketing messages without your consent. If you no longer want to receive e-mail or other mail from us, you can let us know by emailing us at firstname.lastname@example.org or by using the unsubscribe mechanism that will be included in each electronic message.
• Video images and photographs – This information is collected when you enter one of our properties, and is collected for security purposes and compliance with applicable laws. In addition, hand scan technology is used to restrict access.
• Information submitted by you and telephone recordings – We collect information that you submit to us in connection with your inquiries, complaints and other feedback (e.g., via phone, email, mail, or our website). Such information is used for the purposes of responding to you and for customer research purposes. We may also monitor and record phone calls for customer service and training as well as record keeping purposes.
• Information relevant to employment relationships – This information is collected when you apply for a position (through our website or otherwise) and/or work for GCGC and will be used for reasonable purposes related to establishing, managing or terminating the employment relationship.
• We may also collect and use your personal information as authorized or required under the applicable laws (including, without limitation, the Proceeds of Crime (Money Laundering) and Terrorist Financing Act).
We will only use personal information for the purpose for which it is collected or consistent purposes in accordance with Applicable Privacy Laws. Your personal information will not be used for a new purpose unless we have your consent. If we use your personal information to make a decision that directly affects you we will make reasonable efforts to ensure that such information is accurate, complete and up-to-date.
We will only collect personal information directly from you, unless you have consented to collection from other sources or Applicable Privacy Laws require or allow collection from third parties or other sources. For example, some information may be obtained from law enforcement in the course of investigating a security incident or other potentially unlawful activity.
In most cases, we will provide you with clear notice when we collect your personal information. When we provide notice, we will state the reason for which we will use your information and we will obtain your express or implied consent to allow us to use your personal information for the purposes stated. For example, our properties contain signage notifying individuals of surveillance, and consent will be implied for individuals who choose to enter such properties.
However, there are some circumstances where Applicable Privacy Laws do not require the giving of notice or the obtaining of consent. For example, depending upon Applicable Privacy Laws in the relevant jurisdiction, you may not be provided with notice and/or your consent may not be sought when personal information is collected for certain purposes related to law enforcement, investigations or protection of property.
Other Information Collected through our Website
GCGC also collects certain information through our website. For example, when you visit our web pages, we gather the date and time of your visit as well as your browser type, ISP, referring site, pages requested, and IP address. Typically this information will not allow us to identify you personally. We use this information for our internal security audit log, trend analysis and system administration, and to gather broad demographic information about our user base for aggregate use. This information may be shared with third parties in order to provide services to us or to analyze, store or aggregate the information. If you object to the collection of this information, you should not use or access our web pages.
To the extent that our web sites contain links to other websites, the owners of those sites are responsible for the privacy practices or content of those other sites. We do not endorse and will not be responsible for the privacy practices on third party websites.
Disclosure of Personal Information
Generally GCGC will only disclose your personal information with your informed consent. We do not sell your personal information to third parties. However, subject to Applicable Privacy Laws, we may disclose your personal information without your knowledge and/or consent in the following circumstances:
• To provide our services and/or comply with our contractual obligations to third parties. We may share personal information with our crown agency partners and other government bodies or institutions, provided they are authorized to collect such information under applicable laws, including the Ontario Lottery and Gaming Corporation, British Columbia Lottery Corporation, New Brunswick Lotteries and Gaming Corporation, and Nova Scotia Provincial Lotteries and Casino Corporation.
• To our service providers – In some cases we share personal information with other companies who provide services to us or perform services on our behalf, and in these instances we provide them only with the information needed to perform those services. In such cases we will enter into contractual or other arrangements to protect the security and confidentiality of your personal information. Some of our service providers rely upon cloud computing, which means that some customer information will be stored in multiple countries outside Canada, and may be subject to the laws and lawful disclosure requirements in the recipient jurisdictions.
• To comply with our legal obligations – Gaming is a highly regulated activity and is subject to oversight by provincial and federal regulatory bodies. Personal information may be disclosed in response to a subpoena or search warrant, or otherwise for compliance with legal processes or regulatory obligations. Personal information may also be disclosed to the Alcohol and Gaming Commission of Ontario, as well as regulators in other jurisdictions.
• To assist law enforcement to investigate illegal activity, and for other purposes related to law enforcement – Information related to security incidents and other potentially unlawful activities may be disclosed to police and other law enforcement authorities upon request to aid in investigations.
• Otherwise as required or permitted by Applicable Privacy Laws.
In addition to the above, from time to time we may be involved in transactions to sell or restructure parts of our business or assets or merge with other businesses. Where permitted by Applicable Privacy Laws, some personal information may be disclosed as required to facilitate such transactions. In such cases, the information that is shared is limited to what is necessary to accomplish the transaction, and we take appropriate steps to protect the information from improper use or disclosure.
We will take reasonable physical, technical and organizational steps to secure and safeguard your personal information. Access to personal information is restricted to only those with a legitimate business need. We provide appropriate orientation and training to our employees so that those handling your personal information understand how to protect it. We have appointed employees who are specifically responsible for the management of information privacy and privacy matters.
Retention of Personal Information
Personal information is generally only retained as long as it is needed for business or legal purposes. If such information is used by GCGC, it will be retained for at least one year in order to give you a reasonable opportunity to obtain access to it. In addition, information that is subject to an access request will be retained even if access is denied in accordance with Applicable Privacy Laws until the requestor has exhausted all recourses and/or appeal mechanisms under such laws.
Certain personal information collected by GCGC is retained in a personal information bank, as required under the Ontario Freedom of Information and Protection of Privacy Act, R.S.O 1990, c. F31.
Subject to restrictions and exceptions under Applicable Privacy Laws, upon request we will provide you with access to your personal information as well as information about the collection, use and disclosure of your personal information and a listing of the individuals or organizations to which your information has been disclosed. To review records containing your personal information, you will be required to submit a formal, written request to our Privacy Officer at:
Great Canadian Gaming Corporation
95 Schooner Street
Coquitlam, BC, V3K 7A8
Such requests should include sufficient information to allow us to locate the records that you are seeking. Reasonable fees may apply to access requests, where permitted under Applicable Privacy Laws.
We will generally respond to access requests within 30 days, except where an extension is permitted under Applicable Privacy Laws. If access is denied, we will provide you with a written explanation in accordance with Applicable Privacy Laws.
You may also be able to access some information held by GCGC under applicable provincial freedom of information legislation. Such requests should be submitted to the applicable institution or public body in accordance with its policies and procedures. For example, in Ontario, such requests should be submitted to the Ontario Lottery and Gaming Corporation.
Inquiries and Complaints
If you have questions or concerns about GCGC’s collection of your personal information, compliance with this Privacy Statement, handling of your personal information, or our use of service providers outside Canada, you may contact GCGC’s Privacy Officer at email@example.com, the address listed above under “Access” or at (604) 303-1000. If any concerns are not resolved to your satisfaction, you may contact the applicable privacy regulator, as follows:
Office of the Information & Privacy Commissioner for British Columbia
PO Box 9038, Stn. Prov. Govt
Victoria, B.C. V8W 9A4
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Office of the Information and Privacy Commissioner Nova Scotia
Halifax, NS B3J 2M4
Office of the Access to Information and Privacy Commissioner New Brunswick
65 Regent Street, Suite 230
Fredericton, NB E3B 7H8
GCGC reserves the right to modify this Privacy Statement at any time by notifying customers through the Great Canadian Casinos website.