INVICTUS
PRIVACY POLICY
Vancouver Whistler Games Corporation (“Invictus“) is committed to maintaining the accuracy,
confidentiality and security of your personal information. This Privacy Policy describes the personal
information that Invictus collects from or about you, how we use it, and to whom we disclose that
information.
Privacy Policy Effective for Canada
It is Invictus’ policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of federal and provincial privacy laws in Canada, as applicable.
This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained
in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.
What Is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identifiable
individual, other than an individual’s business contact information when collected, used or disclosed for the
purposes of enabling the individual to be contacted in relation to their business responsibilities.
What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of the individuals with whom we interact. This may include an individual’s name, mailing address, phone number, e-mail address, nationality/citizenship, information regarding military service, athletic information, health information, insurance information, and travel information. Invictus is organizing the Invictus Games Vancouver Whistler 2025. As such, Invictus may also collect personal information from individuals impacted by these activities, including participating in the Invictus Games Vancouver Whistler 2025.
As described in further detail below, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. Where permitted or required by applicable law or regulatory requirements, we may collect your personal
information without your knowledge or consent.
Our Website
We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We may use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our other business purposes, such as: (i)
customizing certain content that we think you might like based on your usage patterns; (ii) improving our
products and services; and (iii) upgrading our website.
In connection with the foregoing, we may place a “cookie” on the hard drive of your computer to track your visit. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to our website so that we can understand your use of our website so that we can tailor the website to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have
your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.
In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by:
- applying for a position with Invictus through our website; or
- by corresponding with a representative of Invictus via e-mail using the hyperlinks created for that
- purpose.
Our website may contain links to other websites that may be subject to less stringent privacy standards. If
you click on a link to such a third party website, a third party may also place a cookie on your hard drive.
We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that
operate these websites. Invictus is not responsible for how such third parties collect, use or disclose your
personal information. You should review the privacy policies of these websites before providing them with
personal information.
Finally, we may use third party analytics tools to help us measure traffic and usage trends for our website.
These tools may use cookies and other technologies to collect information about your use of our website,
and collect information sent by your device or our website. This information may be used to, among other
things, analyze and track data, determine the popularity of certain content, better understand your online
activity, and assists us in improving our website.
For example, we use Google’s Universal Analytics to better understand who is using our website and how
people are using it. Google may use cookies, pixel tags and other technologies to collect and store
information such as website pages visited, places where users click, time spent on each website page, IP
address, type of operating system used, location-based data, device ID, search history, and phone number.
We use this information to improve our website and as otherwise described in this Privacy Policy. Please
see https://policies.google.com/technologies/partner-sites for information about how Google Analytics
uses this information, visit https://tools.google.com/dlpage/gaoptout for information about the Google
Analytics Opt-out Browser Add-on, and visit http://www.google.com/settings/ads to adjust the settings for
your Google account
Why Do We Collect Personal Information?
Invictus collects personal information to enable us to manage, maintain, and develop our operations,
including, for example:
- to organize the Invictus Games Vancouver Whistler 2025, including the competitions therein;
- to enable individuals to register for, apply for, and receive accreditation to the Invictus Games
- Vancouver Whistler 2025;
- to be able to provide any additional products and services that we may offer;
- to establish, maintain and manage our relationship with you;
- to be able to review the products and services that we provide to you so that we may: (i) understand
- your requirements for our products and services; and (ii) work to improve our products and
- services;
- to send you promotional and other marketing materials that we think might be of interest to you;
- to be able to comply with your requests;
- to monitor and investigate incidents and managing claims;
- to protect Invictus against error, fraud, theft, and damage to our goods and property;
- to enable us to comply with applicable laws or regulatory process; and
- any other reasonable purpose to which you consent.
- to the extent permitted by applicable law, we may also anonymize or otherwise de-identify your personal
- information for the purposes of: (i) improving our products and services; and/or (ii) creating aggregate data.
How Do We Use and Disclose Your Personal Information?
We may use and disclose your personal information:
- as permitted or required by applicable laws or regulatory requirements;
- for the purposes described in this Privacy Policy; and
- for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.
- we may also use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When Do We Disclose Your Personal Information?
We may share your personal information with our employees, contractors, consultants, affiliates, and other
parties who require such information to assist us with managing our relationship with you, including: (i)
third parties that provide services to us; and (ii) third parties that assist Invictus in the provision of services
to you.
For example, we may share your personal information from time to time with our third party information
technology, marketing, payment processing and data processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed
in the United States and Great Britain. As such, your personal information may potentially be accessible to
law enforcement and national security authorities of that jurisdiction.
In addition, your personal information may be disclosed or transferred to another party during the course
of the grant of a security interest in Invictus assets, or completion of, all or a part of Invictus through, for
example, an asset or share sale, or some other form of business combination, merger or joint venture,
provided that such party is bound by appropriate agreements or obligations and required to use or disclose
your personal information in a manner consistent with the use and disclosure provisions of this Privacy
Policy, unless you request otherwise.
Finally, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of Invictus regular reporting activities;
- to protect the rights and property of Invictus; during emergency situations or where necessary to protect the safety of a person or group of persons; and with your consent.
Your Consent Is Important to Us
It is important to us that we collect, use and / or disclose your personal information only where we have
your consent to do so, or as otherwise provided for in this Privacy Policy. Depending on the sensitivity of
the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express.
Express consent can be given orally, electronically or in writing. Implied consent is consent that can
reasonably be inferred from your action or inaction. For example, when you enter into an agreement with
us, we will assume your consent to the collection, use and disclosure of your personal information for
purposes related to the performance of that agreement and for any other purposes identified to you at the
relevant time.
Typically, we will seek your consent at the time that we collect your personal information. In certain
circumstances, your consent may be obtained after collection but prior to our use or disclosure of your
personal information. If we plan to use or disclose your personal information for a purpose not previously
identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before
such use or disclosure.
As we have described above, we may collect, use or disclose your personal information without your
knowledge or consent where we are permitted or required to do so by applicable law or regulatory
requirements.
Choice/Opt-Out
Invictus You may change or withdraw your consent at any time, subject to legal or contractual obligations and
reasonable notice, by contacting our Privacy Officer using the contact information set out below. All
communications with respect to such withdrawal or variation of consent should be in writing and addressed
to our Privacy Officer. In certain circumstances, the withdrawal of consent may render us unable to
continue to provide products or services where the collection, use or disclosure of your personal information
is necessary to provide the product or service.
We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure
of your personal information as explained in this Privacy Policy.
How Is Your Personal Information Protected?
Invictus endeavors to maintain physical, technical and procedural safeguards that are appropriate to the
sensitivity of the personal information in question. These safeguards are designed to prevent your personal
information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal
or destruction. Unfortunately, we cannot guarantee complete security: for example, (i) unauthorized access
use, or disclosure, (ii) hardware or software failure, and (iii) other events may compromise the security of
your personal information at any time.
The security of your personal information is important to us, please advise our Privacy Officer immediately
of any incident involving the loss of or unauthorized access to or disclosure of personal information that is
in our custody or control.
We also have procedures in place to deal with any suspected data security breach. Where required to do so
by applicable privacy and data protection law, we will notify you and any applicable supervisory authority
of a suspected data security breach.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal
information happens to change during the course of our relationship, please keep us informed of such
changes.
In some circumstances, we may not agree with your request to change your personal information and will
instead append an alternative text to the record in question.
Access to Your Personal Information
You can ask to see the personal information Invictus holds about you. If you want to review, verify or
correct your personal information, please contact our Privacy Officer. Please note that any such
communication must be in writing, including by email.
When requesting access to your personal information, please note that we may request specific information
from you to enable us to confirm your identity and right to access, as well as to search for and provide you
with the personal information that we hold about you. We may charge you a fee to access your personal
information; however, we will advise you of any fee in advance. If you require assistance in preparing your
request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances
where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been
destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavor to
inform you of the reasons why, subject to any legal or regulatory restrictions.
Inquiries or Concerns?
If you have any questions about this Privacy Policy or concerns about how we manage your personal
information, please contact our Privacy Officer by telephone, in writing or by e-mail. We will endeavor to
answer your questions and advise you of any steps taken to address the issues raised by you. If you are
dissatisfied with our response, you may be entitled to make a written submission to the Office of the Privacy
Commissioner of Canada or the Privacy Commissioner in your jurisdiction.
Privacy Officer
We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact
information for our Privacy Officer is as follows:
Jeff Garrad
Vancouver Whistler Games Corporation
605 Robson Street, 10th Floor
Vancouver, BC, V6B 5J3
Attention: Privacy Officer
E-mail: [email protected]
Revisions to this Privacy Policy
Invictus from time to time, may make changes to this Privacy Policy to reflect changes in its legal or
regulatory obligations or in the manner in which we deal with your personal information. We will post any
revised version of this Privacy Policy on our website, and we encourage you to refer back to it on a regular
basis.
This Privacy Policy was last updated on April 30, 2024.
Interpretation of this Privacy Policy
Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy
Policy includes examples but is not intended to be restricted in its application to such examples; therefore
where the word “including” is used, it shall mean “including without limitation”.
This Privacy Policy does not create or confer upon any individual any rights, or impose upon Invictus any
rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and
provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this
Privacy Policy and any applicable federal and provincial privacy laws, this Privacy Policy shall be
interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
