Personal Information Protection Policy

At VGAME, we are committed to providing our website visitors with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our website visitors, protecting their personal information is one of our highest priorities.

While we have always respected our website visitors’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our website visitors of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting website visitors’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our website visitors’ personal information and allowing our website visitors’ to request access to, and correction of, their personal information.

Scope of this Policy

Definitions

Personal Information – means information about an identifiable individual including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information]. Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that VGAMEcomplies with this policy and PIPA.

  1. Policy 1 – Collecting Personal Information

    1. Unless the purposes for collecting personal information are obvious and the website visitors voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.We do not use cookies on our website.

    2. We will only collect website visitors information that is necessary to fulfill the following purposes:
      • To verify identity;
      • To verify creditworthiness;
      • To contact our website visitors;
      • To identify our website visitors’ preferences;
      • To understand the needs of our website visitors;
      • To open and manage an account;
      • To deliver requested products and services
      • To process a subscription or transaction;
      • To provide goods or services to the website visitor;
      • To enrol the website visitor in a program;
      • To send out association membership information;
      • To ensure a high standard of service to our website visitors;
      • To meet regulatory requirements;
      • To improve our website.

  2. Policy 2 – Consent

    1. We will obtain the website visitors’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

    2. Consent can be provided electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the website visitors’ voluntarily provides personal information for that purpose.

    3. Consent may also be implied where a website visitor is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the website visitor does not opt-out.

    4. Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), website visitors can withhold or withdraw their consent for VGAMEto use their personal information in certain ways. A website visitors’ decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the website visitor in making the decision.

    5. We may collect, use or disclose personal information without the website visitors’ knowledge or consent in the following limited circumstances:
      • When the collection, use or disclosure of personal information is permitted or required by law;
      • When the personal information is available from a public source (e.g., a telephone directory);
      • When we require legal advice from a lawyer;
      • For the purposes of collecting a debt;
      • To protect ourselves from fraud; and
      • To investigate an anticipated breach of an agreement or a contravention of law

  3. Policy 3 – Using and Disclosing Personal Information

    1. We will only use or disclose the website visitor’s personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
      • To conduct surveys in order to enhance the provision of our services;
      • To contact our website visitors directly about products and services that may be of interest;

    2. We will not use or disclose website visitor personal information for any additional purpose unless we obtain consent to do so.

    3. We will not sell lists or personal information to other parties.

  4. Policy 4 – Retaining Personal Information

    1. If we use personal information to make a decision that directly affects the website visitor, we will retain that personal information for at least one year so that the website visitor has a reasonable opportunity to request access to it.

    2. Subject to policy 4.1, we will retain website visitor personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

  5. Policy 5 – Ensuring Accuracy of Personal Information

    1. We will make reasonable efforts to ensure that the personal information is accurate and complete where it may be used to make a decision about the website visitor or disclosed to another organization.

    2. Website visitors may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer.

    3. If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the website visitors’ correction request in the file.

  6. Policy 6 – Securing Personal Information

    1. We are committed to adopting commercially reasonablesecuritymeasures to protectour website visitors’ personal information from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

    2. We will use appropriate security measures when destroying personal information such asshredding documents and/or deleting electronically stored information.

    3. We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

  7. Policy 7 – Providing Website Visitors with Access to their own Personal Information

    1. Website visitors have a right to access their personal information, subject to limited exceptions.

    2. A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

    3. We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

    4. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the website visitor of the cost and request further direction from the website visitor on whether or not we should proceed with the request.

    5. If a request is refused in full or in part, we will notify the website visitor in writing, providing the reasons for refusal and the recourse available to the website visitor.

  8. Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

    1. The Privacy Officer is responsible for ensuring VGAME’scompliance with this policy and the Personal Information Protection Act.

    2. Website visitors should direct any complaints, concerns or questions regarding VGAME’scompliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the website visitor may also write to the Information and Privacy Commissioner of British Columbia. Contact information for VGAME’s Privacy Officer: legal@vgame.ca