1. Overview
This Privacy Policy describes the manner in which WB Toronto Inc. and its affiliates (collectively, “WB Toronto”, “we,” “our,” “us”) collect, use and disclose personal information (as defined below) in connection with:
- our business owning and operating the WNBA Toronto Team
- our community events and promotion
- our other services
- our websites and social media accounts
- our mobile and other software applications or services (each, an “app”) (collectively, our “Services”).
Please note that this Privacy Policy does not apply to the websites, social media accounts, apps, or services of the Women’s National Basketball Association, (the “WNBA”), which are governed by the privacy policy of the WNBA. Similarly, this Privacy Policy does not apply to the websites, social media accounts, apps, or services of certain parties who may be connected with us in some way – such as broadcasters, food service providers, sponsors, or ticket providers. We encourage you to review their privacy policies before providing them with personal information.
By providing us with your personal information and using our Services that link to this Privacy Policy, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy, as well as any other terms that are described to you when your personal information is collected. If you have any questions about this Privacy Policy, please contact us using the information listed in the Contact Us section below.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES.
2. This Privacy Policy May Be Amended
Please note that we may update this Privacy Policy from time to time to reflect changes in our privacy practices, with or without providing you with notice of the change, as required or permitted by applicable law. Notice may include but is not restricted to posting a link to the new Privacy Policy, posting a new Privacy Policy at www.wnba.com/toronto/privacy-policy, or sending you a link to the new Privacy Policy via contact information you have provided to us. Each time you use our Services that link or otherwise refer to this Privacy Policy, the version then posted will apply to that use. Please review the Privacy Policy periodically to see whether it has changed. Any use of the Services by you after we provide notice to you constitutes your acceptance of those modifications.
3. Personal Information We Collect and Receive
For the purpose of this Privacy Policy, “personal information” means any information that can reasonably be used to identify a person, directly or indirectly, but does not include anonymous information or information that relates to a group of people rather than individuals where the information does not otherwise contain identifying information.
We collect and receive the following types of personal information:
- Personal information you provide directly. We receive the personal information you provide when using our Services.
- For example, when you register for our Services, bid on or purchase products or Services from us, sign up to receive electronic or other marketing communications, subscribe to a newsletter, post on social media, enter a contest or sweepstakes, download or use an app, communicate with customer service, participate in a survey, promotional campaign or complete a questionnaire, you may be asked to provide some information about yourself depending upon which Services you are using. This personal information may include, but is not limited to, your first and last name, username, password, mailing address, phone number, date of birth, email address, mobile phone number, payment information, favourite teams or players, favourite music genres or performers, a photograph, and/or information about your use of our Services.
- If you use a “share with a friend” or “invite a friend” feature on our Services, we may collect your name and email address, or an electronic address, as well as the name and email address of the recipient if you share that with us. We do not use the names or email addresses submitted in these circumstances for any purpose other than sending an email on your behalf, unless we obtain your consent or the recipient’s consent, as appropriate. If you provide us with the name or email address of a friend or person other than yourself, you must first make sure you have their consent to do so and by providing it to us, you represent and warrant that you have such consent.
- Automatically collected information. We also may collect or receive information when you use our Services. We collect some of this information using cookies, pixels, beacons, and other technologies (see the end of this Privacy Policy for more information about what these are and how they work). This information that we collect automatically may be combined with information that you provide us directly in order to personalize content and advertising based on your interests and preferences. Depending on how you access and use our Services, we may receive:
- Log and analytics information. This is information we automatically collect and store when you use our Services. It may include, for example:
- Information about your interactions with our Services, including the content you view, the products or Services you view, bid on, or purchase, the amount of time spent on our Services, the date and time at which you accessed our Services, and information in cookies and similar technologies.
- Information about how you access our Services, including your browser or operating system, your Internet Protocol (“IP”) address, and the websites you visit before and after visiting our Services.
- Device information. This is information we collect and store concerning the device you use when you access our Services. (Note that by “device,” we mean anything you use to access our online or digital Services). Device information may include, for example:
- The type of device you are using (e.g. your particular brand of phone, computer, or tablet);
- Browser type;
- Certain device identifiers which may be unique to your device;
- Your Internet service provider; and
- Content you have stored on your device, if you have granted us permission to do so in the “Permissions” or “Privacy” setting of your device.
- Location information. This information may include specific location information drawn from tickets and seating data, your device’s GPS, Bluetooth, or WiFi signals, including information about nearby WiFi networks, location beacons, and cell towers. We receive this information when you enable and use location-enabled services that we offer, and also when you use certain location-based informational, marketing, or public service applications that we or other parties offer. We may also obtain location information from our video surveillance system or from our telephone records (e.g. area code).
- Personal Information from Third-Party Sources. We may receive additional information about you from third parties and our business partners, as well as receive information about you that is publicly or commercially available, and we may combine that with the information we have collected or received about you in other ways. Also, we receive information about you when you choose to connect with social networking services while using our Services.
- To protect you, ourselves and others. We may collect or receive your personal information to protect you, ourselves, and others by enhancing our ability to detect, prevent, or otherwise address fraud, illegal activities, security or technical issues, or to protect against harm to the rights, property, or safety of WB Toronto, our customers, users or the public, or otherwise enforce our rights.
We also may collect or receive your information for other purposes that may be described to you at the point of collection or for which you provide your consent, or as permitted or required by applicable law.
4. How We Use the Information We Collect or Receive
We use the information we collect and receive for the following purposes:
- To provide our Services. We use the information we collect or receive to provide you with the Services and operate our business. For example, we use this information to:
- Create accounts;
- Process transactions;
- Provide technical or customer support and respond to user inquiries;
- Manage invoicing, accounting, and information security services related to our transactions with you;
- Perform internal management, including planning, resource allocation, policy development, quality improvement, monitoring, audit, evaluation, and reporting;
- Administer your participation in our events, contests, sweepstakes, games, or promotions; and
- Notify you about updates to our Services or send other communications that are relevant to your use of our Services.
- To personalize your content and improve our operations and Services. We also use the information we collect or receive to provide content you may find relevant and interesting and to maintain and upgrade our operations and our Services. For example, we may use this information to:
- Solicit input and feedback about our Services;
- Identify and address technical issues on our Services; and
- Customize your experiences based on location information or your online activities, including the content you view, the products you bid on or purchase, other Services of ours you use, and other information we collect or receive.
- To provide effective advertising and marketing. We also use the information we collect or receive to provide ads for our Services and certain third-party services and to send you promotional communications. For example, we may use this information:
- To show you ads (on and off our digital and mobile Services, including on third-party social media services) based on location information or your online activities, including the content you view, the products you bid on or purchase, the other Services of ours that you use, and other information we collect or receive.
- To help our business and advertising partners understand the effectiveness of their advertising and marketing campaigns and to compare the performance of those campaigns to ads displayed on other websites and apps.
- To send you electronic and other marketing messages about WNBA Toronto Team, WB Toronto, the WNBA, our venue, team sponsors, our community and charitable endeavors, or other third-party business partners that may be tailored to your preferences and interests. (Please see below the “Your Choices” section in connection with promotional messages.)
- To anonymize. Anonymization means rendering your personal information in a form that does not directly or indirectly identify you and where you can’t reasonably be re-identified through the use of that information or in combination with other information. We may take your personal information and anonymize it, after which we may use it for our analytics services (for instance, to better understand the types of people who use certain Services), study or research, the production of statistics, and such other purposes as permitted by applicable law.
- To protect you, ourselves and others. We may use your personal information to protect you, ourselves, and others by enhancing our ability to detect, prevent, or otherwise address fraud, illegal activities, security or technical issues, or to protect against harm to the rights, property, or safety of WB Toronto, our customers, users, business partners, or the public, or otherwise enforce our rights.
We also may use the information we collect or receive for other purposes that may be described to you at the point of collection or for which you provide your consent, or as permitted or required by applicable law.
5. How We Share the Information We Collect or Receive
We may share information that we collect or receive with third parties as described below:
- Our affiliates. We may share information with current and future “affiliates”, a term that includes our parent and subsidiary companies, joint venture partners, registered charities operated by us or other companies we control, are controlled by, or with which we are under common control.
- Our service providers. We may provide information about you to service providers that perform certain functions or services on our behalf (for example, hosting our Services, storing our data, fulfilling orders, providing products and services, managing databases, performing analyses, administering our contests and sweepstakes, collecting location data, providing location-based services, processing credit card payments, providing customer service, providing marketing, promotional and branding services and campaigns, or sending communications for us). These companies are obligated to protect your information in a manner that is comparable to the way we protect your information, and are only allowed to use it for the purpose it was collected (e.g. they are not permitted to sell it).
- Operational partners. We partner with third parties to operate certain of our Services. From time to time, we may provide information about you to these operational partners. For example, we partner with Ticketmaster to sell tickets to our games, and we therefore may share information about you with such third parties, their service providers, their successors and permitted assigns, and their affiliates in connection with the operation and delivery of our Services. While these operational partners may use information about you to operate the Services, you should presume that these operational partners may use your information for their own purposes in accordance with their respective privacy policies.
- Business partners. With your consent, we may share information about you with other select business partners that are not service providers, such as our sponsors, other retailers, and broadcast partners, so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. We may also share information about your use of our websites, social media sites, and apps with our social media, advertising, and analytics partners. These other business partners are expected to protect the confidentiality, integrity, and security of any information we share with them. However, when you agree to share your information in this way, we are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.
- We may share information about you with the WNBA (including your contact information, demographic information, and information about your interactions with WB Toronto), and the WNBA may use this information for purposes including: providing you with special offers, promotional materials, and other information that may be relevant to you; improving their products and services; and performing internal analysis. Where required by applicable law, we will seek your consent before sharing your information with the WNBA for promotional purposes. Please note that WNBA websites and services are not controlled by WB Toronto and are subject to their own individual privacy policies. We are not responsible for the privacy practices of the WNBA.
- Fraud, security, or technical protection partners. We may share your personal information internally or with service providers or business partners to detect, prevent, or otherwise address fraud, security, or technical issues, or to protect against harm to the rights, property, or safety of WB Toronto, its customers, users, business partners, or the public.
- Other parties in response to legal process or when necessary to protect us or our Services. We or the other recipients of your personal information described above may disclose that information — including the contents of your communications — to other parties when required or permitted by applicable law, such as when we have reasonable grounds to believe that:
- Doing so is necessary to respond to lawful governmental requests or legal process (for example, a court order, search warrant, or subpoena);
- The information is relevant to a crime that has been or is being committed;
- An emergency exists that poses a threat to your safety or the safety of another person or persons; or
- Doing so is necessary to protect or give notice of our rights or property, the rights or property of another person or persons, or to enforce our terms of service.
- Other parties in connection with certain prospective or completed business transactions. In the event that the ownership of WB Toronto (or any portion of our assets) becomes part of a potential business transaction or changes as a result of a business transaction (for instance, a merger, acquisition, financing, corporate reorganization, or insolvency event), your information may be transferred to another entity for review in connection with a potential business transaction or to complete a business transaction. If such a transaction is completed, you will be notified in an update to this Privacy Policy or through another appropriate means.
- Interactive features. We may share information with third parties when you post information to a public user profile or a public area of our Services. If you post information to these interactive features, it may be publicly available and you may receive unsolicited messages from other parties. We cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when using these features and do not post sensitive personal information.
- Games and contests. We may share information with third parties in connection with the administration or marketing of games or promotional contests connected to our Services. This might include, for example, names of the winners of a contest or in connection with a game leaderboard.
- Aggregated or anonymized information. We also may share other information with third parties in a manner that does not identify particular users.
In addition to the above, we may share the information we collect or receive for other purposes that may be described to you at the point of collection or for which you provide your consent. We may also share the information we collect or receive as permitted or required by applicable law.
6. Third Parties that Provide Content, Advertising, or Functionality on Our Services
Some of the content, advertising, and functionality on our Services may be provided by third parties that are not affiliated with us. Such third parties include, for example:
- Content providers, which may operate contests, sweepstakes, games, or public forums on our Services;
- Retail and other companies (such as those that operate our mobile applications, our online retail store, or our online auction service, or those that operate other Services), which may process transactions, provide customer service, and perform other functions;
- Advertising providers, which help us and our advertisers provide ads (on our Services or elsewhere online) that are tailored to users’ interests and understand users’ response to those ads;
- Audience-measurement companies, which help us measure the overall usage of our Services and compare that usage to other online services;
- Social networking services (such as Facebook, Instagram, and Twitter), which enable you to log in to certain of our Services, to comment on content available on our Services, and to share things you find on our Services with your social network;
- Customer service providers, who (among other things) offer “bots” that help us provide answers to frequently asked questions about our Services, including by collecting and analyzing questions asked by visitors to our websites, apps, and other online services to improve the quality of answers provided, as well as to better understand the preferences of individual customers; and
- Mobile location analytics providers, which use location-specific data to facilitate the transmission of informational, marketing, and public service communications to you.
These and other third parties may collect or receive information about your use of our Services, including through the use of cookies, pixels, beacons, mobile advertising identifiers, and other technologies, and this information may be collected over time and combined with information collected on different websites and online services, including, for example, to deliver ads that are more relevant to you, both on and off our websites and apps. Social networking services may be able to collect information about you, even if you do not click on or interact with their content on our Services or have an account with the social networking service.
The third party social networking services with which we partner may notify your friends and other connections, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your friends and other contacts on those social networking services. We may use the information pursuant to this Privacy Policy, but the main purpose for our use is to enhance your personal and social experience on our Services. For example, we might show you content that is popular among your friends or connections on a social networking service or provide you with a snapshot of the responses of your friends and other connections to that content.
You also may be able to link an account from a social networking service to an account through our Services. This may allow you to use your credentials from the other site or service to sign in to certain features on our Services. If you link your account from a third-party site or service, we may collect information from those third-party accounts, and any information that we collect will be governed by this Privacy Policy.
7. Your Choices
You have a number of choices about how we handle information we collect or receive about you.
- You may opt out of receiving future promotional email communications from us by clicking the “Unsubscribe” link in the footer of promotional email communications and updating your preferences. You may also identify specific email publications about our Services which you would like to receive by visiting our website. Please note that we may continue to send you transactional or service-related emails regarding your account.
- SMS and MMS. You may opt out of receiving promotional SMS and MMS messages (e.g. text messages) from us by replying “STOP” to any message, which is free of charge. Please note that we may respond to your opt-out request with a message confirming that you have successfully opted out.
- Access, Update, or Correct Information. We are obliged to keep your personal information accurate and up to date. Please help us to do this by advising us of any changes to your personal information. In accordance with applicable law, you may have the right to access, update, or correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. If you would like to access, review, or update your information, please email us at info@torontownba.com. Please include your first name, last name, user name (if you have an account with us), and email address.
- Location Information. If you choose to use location-enabled Services or apps covered by this Privacy Policy, you may be provided with an opportunity to opt out of having your location information collected and/or used for certain purposes. For example, our use of “location beacons” allows us to offer time-sensitive special offers to you when you are near a WB Toronto concession stand or retail outlet. Location beacons are not enabled unless you turn on the Bluetooth setting on your device and opt in to receive signals from location beacons for our apps. However, if you disable location information, you may not be able to enjoy all of the functionalities offered by those Services or apps. You also may be able to limit the collection of your location information when you enable our apps or through changing the location service settings on your device or browser.
- Cookies. You can opt out of receiving certain cookies [via our cookies banner when you first user our website or] by adjusting your browser settings to refuse certain cookies or to alert you when a cookie is placed. Your browser settings may not permit you to block the use of certain non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques.
- Mobile Advertising Identifiers. These are unique strings provided by your mobile device’s operating system. They facilitate the delivery of targeted advertisements to your mobile device. For information on how to reset your advertising identifier and/or limit advertising tracking, please refer to the instructions for your mobile device’s operating system.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw your consent for us to use your personal information at any time by contacting our Privacy Officer at privacy@torontownba.com. Such withdrawal may affect your ability to use our Services, and could, in certain cases, prevent you from using one or more Services altogether.
8. Security
We have adopted physical, technical, and administrative safeguards to help protect against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification of the information we collect or receive. The nature of the safeguards will vary depending on the sensitivity of the information. However, no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot and do not guarantee or warrant the security of any information you disclose or transmit to our Services and cannot be responsible for the theft, loss, destruction, or inadvertent disclosure of your information, or any other disclosures out of our control.
Your online access to some of your information may be protected with a password that you select. You should not disclose your password to anyone, choose an easily guessed password, or reuse passwords that you have used for other accounts. Taking steps like avoiding dictionary words or proper names, and adding extra character and punctuation marks can also help protect you. If you believe your password has been compromised, you should change it immediately. We will never ask you for your password in any unsolicited communication (such as letters, phone calls, texts or email messages).
9. Children’s Privacy
We take our responsibilities with respect to our younger users of our Services seriously. In addition to the steps that we take to safeguard the privacy and integrity of personal information submitted by adults, we adhere to the following principles and practices regarding personal information requested from or provided by children (meaning under 13 years old or as otherwise defined under applicable law):
- We will not knowingly collect personal information from children (such as full name, home address, email address, phone number, etc.). We may use age-screening mechanisms to help us determine if a user is a child. If we determine that the user is a child, they will be directed to content that does not involve the submission of personal information.
- From time to time, we may post information on our Services about other promotions, contests, or games that are open to children but that require personal information to participate. For these contests, children will be required to provide proof of consent from their parent or legal guardian. Children are not permitted to provide personal information on any WB Toronto site or to enter these contests absent the consent of their parent or legal guardian.
- If, at any time, a parent or legal guardian becomes aware that their child has provided us with information without their consent, or wishes to withdraw their consent to our use or maintenance of personal information collected from their child, the parent or guardian should contact us at privacy@torontownba.com, and we will promptly remove such information from our database(s). Please note that we may request proof of identity and relationship to the child before doing so.
- If you have any comments or questions on policies related to children’s personal information or about our commitment to protecting your and your children’s privacy, please contact us using the information listed in the Contact Us section below.
10. Use of Automated Systems
We may use both manual and automated systems, such as machine learning and artificial intelligence, to: analyze your personal information to improve our website or apps; make decisions; personalize your experience; automate certain aspects of our website or apps; aggregate or anonymize your information; provide you with certain features; and protect the safety and security of our website and apps.
11. Third Party Links
Our Services may contain links to other sites that we do not own or operate. Also, links to our Services may be featured on third-party services on which we advertise. Except as described in this Privacy Policy, we will not provide any of your personal information to these third parties without your consent. We provide links to third party services as a convenience to our users. These links are not intended as an endorsement of or referral to the linked services. The linked services should have separate and independent privacy statements, notices, and terms of use, which we recommend you read carefully. We do not have any control over such services, and therefore we have no responsibility or liability for the manner in which the entities that operate such linked services may collect, use, disclose, secure, or otherwise treat your information.
12. Your California Privacy Rights
To the extent that any California data privacy law applies, we will provide California residents with information to which they are entitled upon request (“Data Subject Request”). The information below outlines how California residents can make a Data Subject Request and the information they can receive.
If you are a California resident and would like to submit a Data Subject Request to receive information about our data collection practices as they relate to your data, please contact us using the information listed in the Contact Us section below. If you submit a Data Subject Request, you must provide us with enough information to identify you and enough specificity on the requested data. We will use the information we receive only for verification. We will not be able to disclose information if we cannot verify that the person making the Data Subject Request is the person about whom we collected information, or someone authorized to act on that person’s behalf.
However, please note that our practices relating to personal information and data sources will not exceed what is contained in this Privacy Policy. Additionally, we are not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. We are also not required to re-identify personal information if it is not stored in that manner already, nor are we required to provide personal information to you more than twice in a twelve-month period.
You may request that we delete your personal information. Your deletion request should be submitted through a Data Subject Request. Subject to certain exceptions, we will, on receipt of a verifiable Data Subject Request, delete your personal information from our records and direct any service providers to do the same.
We may not, and will not, treat you differently because of your Data Subject Request activity. As a result of your Data Subject Request activity, we may not and will not deny Services to you, charge different rates for Services, provide a different level quality of Services, or suggest any of the preceding will occur.
In addition, if you are a California resident under the age of 18 and are a registered user of our Services, you may request us to remove content or information posted on our Services or stored on our servers by submitting a request in writing using the contact information in the Contact Us section below and clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, we are not required to erase or otherwise eliminate content or information in all cases. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.
13. International Transfers of Personal Information
WB Toronto’s offices are located in Canada, and regardless of where you use our Services or otherwise provide information to us, your personal information may be transferred to, maintained, and processed by WB Toronto, its affiliates, and our operational partners and service providers in Canada (or, for residents of Quebec, outside of Quebec) and the United States. Please note that Canadian and United States privacy laws, regulations, and standards may not be equivalent to the laws in your place of residence and such information may be subject to lawful access by the courts of the applicable jurisdiction, law enforcement, and governmental authorities, or in connection with legal process in those jurisdictions. By using our Services or by providing us with your information, you consent to this collection, transfer, storage, and processing of personal information to, in, and out of Canada (and Quebec) and the United States.
14. Contact Us
If you have any questions about this Privacy Policy, our privacy practices or our policies and practices regarding the use of non-Canadian service providers, please contact our Privacy Officer at privacy@torontownba.com.
15. Cookies, Pixels, Beacons, and Other Online Recognition and Authentication Technologies
Our Services may use online technologies called “cookies”, “pixels”, and “beacons”, as well as other local storage technologies. This section explains what these technologies are and how they may be used.
Cookies, Pixels and Other Local Storage Technologies. Generally speaking, “cookies” are text files that are placed in your device’s browser that can be used to help recognize your browser across different web pages, websites, and browsing sessions. A “pixel” is a tiny image embedded onto a website that loads when you visit and performs a similar functionality through the use of cookies. Your browser or device may offer settings related to cookies. For example, you may be able to configure your browser not to accept cookies, remove cookies, or to notify you when a cookie is being sent. For more information about whether these settings are available, what they do, and how they work, visit your browser or device’s help material. If you decide not to accept cookies from us, you may not be able to take advantage of all of the features of the Services.
- Cookies are stored on your device or in “local storage”. We may also use other types of local storage technologies, such as “Local Shared Objects” (sometimes called “Flash cookies”), in connection with our Services. These technologies are similar to cookies in that they are stored on your device and can be used to maintain information about your activities and preferences.
- Our Services may use cookies, pixels, or other local storage technologies in combination with other information about you to enhance and personalize your experience on our Services (or elsewhere online), including:
- to help authenticate you when you use our Services;
- to remember your preferences and registration information;
- to enable a shopping cart;
- to present and help measure and research the effectiveness of our Service, advertisements, and email communications (by determining which emails you open and act upon); and
- to customize the content and advertisements provided to you through our Services and on other websites and services you visit.
Beacons. Beacons are small pieces of code placed on web pages, videos, and in emails that can communicate information about your browser and device to a server. Beacons can be used, among other things, to count the users who visit a web page or read an email, or to deliver a cookie to the browser of a user viewing a web page or email. These “beacons” should not be confused with “location beacons”, which are small devices in our venues or retail locations that enable alerts (such as a time-sensitive special offer) to be sent to your mobile device.