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Privacy Policy

Purpose

This Privacy Policy is designed to comply with applicable privacy legislation in Canada including PIPEDA (The Personal Information Protection and Electronic Documents Act which governs how for private-sector and charitable organizations collect, use and disclose personal/private information in the course of commercial activity in a manner that recognizes the right to privacy of individuals with respect to their personal information and the need of organizations. (Please visit the PIPEDA web site for further details).

This Policy is also designed to help individuals understand how their private information is managed at The Regent Theatre Foundation. (“The Regent”). 

 

Scope

Those individuals protected by this Privacy Policy include individuals that are customers, Regent Theatre staff, members, volunteers, sponsors, subscribers, prospective customers and customer of other third-parties for which The Regent may provide outsourced services. This Privacy Policy applies only to information collected during the course of commercial activities. 

 

Exceptions

If the policies and procedures outlined in this document do not address a specific situation, individuals are expected to contact The Regent’s Privacy and Security Manager for guidance or clarification (see Challenging Compliance section for details). 

Intent

The Regent is committed to protecting and respecting the personal information of its customers, business partners, and all other entities it interacts with in accordance with PIPEDA. It is The Regent’s intent and the guiding principles of this policy to ensure compliance with PIPEDA requirements.

Definitions

Breach of security safeguards –  means the loss of, unauthorized access to, or unauthorized disclosure of personal information resulting from a breach of security safeguards or from a failure to establish those safeguards.

Personal information – Information about an identifiable individual.

Security safeguards – Security safeguards include the following:

  • Physical measures, for example, locking filing cabinets and restricted access to offices;
  • Organizational measures, for example, security clearances and limiting access on a “need-to-know” basis; and
  • Technological measures, for example, the use of passwords and encryption.

Significant harm – Includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record, and damage to or loss of property

All definitions sourced from the PIPEDA website reference above.

The Principles

Our Privacy Policy is designed to comply with applicable privacy legislation in Canada. It incorporates the following 10 principles: 

 

  1. Accountability
  2. Identifying Purpose
  3. Consent
  4. Limiting Collection
  5. Limiting Use, Disclosure and Retention
  6. Accuracy of Information
  7. Safeguarding Information
  8. Openness
  9. Access to Information
  10. Challenging Compliance

 

Any changes to our Privacy Policy will be reflected in updates to our official Privacy Policy wherever it is made available. The Regent’s objective is that individuals will always know what information we collect, how we use it and how we protect it. When information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified to the individual prior to use. 

Accountability

The Regent is responsible for maintaining and protecting the personal information under its control. Accountability for this function within our organization is held by: 

General Manager. (the “Privacy and Security Manager”)

You may obtain the name and contact information for the Privacy and Security Manager by calling The Regent’s general number or emailing at Privacy@TheRegentTheatre.org. 

Identifying Purpose

The Regent will identify the purposes for which information is collected at or before the time the information is collected. Generally, The Regent collects information for the following purposes: 

In the day-to-day business transactions:

  • To manage and develop The Regent’s business and operations, including personnel and employment matters; and
  • To meet legal and regulatory requirements.

However, there may be other circumstances that require such information to be collected and used.

The Regent collects the following information from individuals during the course of normal commercial activities. The information obtained includes name, and general contact information, levels of interest for our services and topics, and transaction activity with The Regent.

This information is used primarily to determine an individual’s entitlement to The Regent’s services. In addition, this information may be used to:

  • Inform individuals about The Regent’s products and services that we believe may be of interest to them.
  • Better understand an individual’s interests in our products and services.
  • Develop, enhance or improve products and services.

The Regent routinely collects anonymous, non-personal information through our Web servers. This is information that is not associated with or traced back to a specific individual. Gathered electronically, this information includes the type of Web browser used, and the Internet Protocol address. This information may be used for research and analytical purposes, to examine how the Web site is being used and to determine how it can be improved. 

The Regent uses cookies. A cookie is a small piece of information that is sent to your computer when you access a Web site. There are two kinds of cookies:

Session cookie – stored temporarily in your computer’s memory. A session cookie is destroyed as soon as you close your browser.

Persistent cookie – a more permanent line of text that gets saved to your hard drive.

We use session cookies on all The Regent Web sites to allow you to gain access to the site. Persistent cookies are used to store your encrypted user ID and password, so that you won’t have to type it in each time that you access our site. A persistent cookie is only set if you click on “Remember my sign-in information.”

Consent

An individual’s knowledge and consent are required before The Regent is allowed to collect, use or disclose his or her information. Where possible, The Regent or its client/ third-parties will obtain consent directly from the individual concerned at the time of collection.   Every effort will be made to ensure the individual is advised of the purposes for which the information will be used in such a manner the individual understands the nature, purpose, and consequences of the collection, use, or disclosure of the personal information.  By subscribing to our services, registering for access to our sites and systems, access to our on-line information services, calling our business or otherwise indicating approval, individuals consent to the collection and use of their information for the purposes identified in this Privacy Policy.

In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use.

The Regent will not, as a condition of supplying our products or services, require you to consent to the collection, use or disclosure of information beyond that required to provide our products or services to you.

The form of consent sought by The Regent may vary, depending upon the circumstances and type of information collected, taking into account the sensitivity of the information.

After having provided consent, an individual has the right to withdraw consent at any time by providing 30 days written notice to The Regent’s Privacy and Security Manager.  If your request requires that we delete your registration information, we may no longer be able to provide you with the services or products for which you have subscribed. Cancellation will be subject to the terms and conditions of the subscription or services provided, as applicable.

In limited circumstances, The Regent may use or disclose information without the knowledge or consent of the individual or with the implied consent of the individual, for example, for purposes of debt collection, breaches of agreements, as required by governmental bodies acting with authority, or as authorized or required by applicable legislation.

Limiting Collection

The Regent collects only the information that is necessary for the purposes outlined in this Privacy Policy or for purposes identified by The Regent at the time of collection of such information or before use of such information.

Limiting Use, Disclosure and Retention

The Regent does not use information for purposes other than those for which it was collected, except with an individual’s consent or as required or permitted by law. Once information is no longer required to fulfill the identified purposes or other legal requirements, it will be destroyed, deleted or made anonymous.

The Regent sometimes uses the services of external firms to assist us in communicating with individuals (e.g., surveys and mail distribution) or as a means of providing more effective and efficient services to these individuals (e.g., technology support). Our external suppliers are contractually obligated to keep the information confidential, to use the information only for the purpose requested and to destroy the information when it is no longer required.

Customer information is shared with external service providers only to the extent required for the provision of such services. Furthermore, The Regent does not sell information to third-party organizations.

Information is retained only as long as necessary for the fulfillment of the purposes stated in this policy.

Accuracy of Information

Information is kept as accurate, complete and up to date as necessary for the purposes for which it is to be used. Individuals are encouraged to provide updates to their information as changes occur, to enable us to continue to provide services to them.

The information of customers can be reviewed and modified either directly on-line or by contacting our:

Privacy and Security Manager
The Regent Theatre
224 Main Street
Picton, ON K0K 2T0

Privacy@TheRegentTheatre.org

Safeguarding Information

Information, whatever its form, will be protected by security safeguards appropriate to the sensitivity of the information. The safeguards will protect information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The measures of protection include:

  • physical measures, for example, locking filing cabinets and restricted access to offices;
  • organizational measures, for example, security passes and limiting access to the information on a “need-to-know” basis;
  • technological measures, for example, the use of passwords and encryption; and
  • Procedural measures, for example, the shredding of sensitive information.

Openness

The Regent is committed to being open about its policies and practices with respect to the handling of information. Our Privacy Policy is available through our home page site. If a hard copy or additional information is required, requests for such information may be made to the Privacy and Security Manager.

Access to Information

An individual may inquire as to the existence, use and disclosure of his or her personal information and may obtain a copy or be given access to that information held at The Regent by submitting a written request to the Privacy and Security Manager at the address below in the Challenging Compliance. Acceptable proof of identification is required before such information is given out. If you feel the information we have about you is inaccurate, you may request that it be reviewed and, if inaccurate, changed, by contacting the Privacy and Security Manager.

Please note access to information may be limited if access would likely reveal personal information about a third party without that third party’s consent.

If access to information is denied, the reasons for doing so shall be provided to the individual upon request.  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-client privilege or litigation privilege.

Complaint Response

All privacy complaints and access request will be received by the Privacy and Security Manager (see Challenging Compliance section for details). They will be tracked in the PIPEDA LOG. Complaints and access request will be investigated and resolved in a timely manner.

Challenging Compliance

An individual can challenge compliance with the above policy by providing written details of the challenge to the Privacy and Security Manager via:

Mail at:
The Regent Theatre
224 Main Street
Picton Ontario
K0K 2T0

Email at:

Privacy@TheRegentTheatre.org

The Regent shall investigate all complaints.  If a complaint is found to be justified, The Regent will take appropriate measures, including, if necessary amending its policies and practices.

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, The Regent shall amend (by correction, deletion or addition) the information as required.  Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.

Review and modification

We continue to review our policies and procedures to assure that they are effective in meeting our commitments to our customers. The Regent reserves the right to change this Privacy Statement without notice at any time and from time to time to comply with applicable local, provincial and federal laws and regulations.

 
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