Last Update: April 6, 2018
The Factory is committed to protecting your privacy and the confidentiality of your Personal Information. This Policy describes how The Factory collects, protects, uses and discloses Personal Information in the course of its operations, as required by PIPEDA.
“Personal Information” means information about an identifiable individual, but does not include information about a business or aggregated information that cannot be associated with a specific individual.
“PIPEDA” means the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, as may be amended from time to time.
“Privacy Officer” means the individual(s) appointed to oversee and be accountable for The Factory’s compliance with the Policy and the PIPEDA.
“Record” includes any correspondence, memorandum, book, plan, map, drawing, diagram, pictoral or graphic work, photograph, film, microform, sound recording, videotape, machine-readable record and any other documentary material, regardless of physical form of characteristics, and any copy of the foregoing.
Principles of Fair Information Practices
The Factory is responsible for all Personal Information under its control and has designated the Business Manager as the Privacy Officer to be accountable for compliance with this Policy and the PIPEDA. The Privacy Officer may delegate any responsibilities set out in this Policy to another employee of The Factory. All employees of The Factory who will have access to Personal Information will be informed about this Policy and its implications and will receive training in the proper handling of Personal Information.
The Factory collects Personal Information through its website and on-premises kiosks and in-person for the following purposes:
- to create and maintain a user account for each guest of The Factory;
- to create and maintain a master schedule of guest activities;
- to communicate with guests for the purpose of confirming activity registration, providing a copy of signed waivers and providing general information relating to The Factory;
- to maintain systems for billing and the collection of payments;
- to process transactions and administer services;
- to respond to website inquiries;
- to promote upcoming events and offers (only if you opt in);
- to comply with insurance requirements, including accident investigations; and
- to assemble demographic and other information to assist The Factory with long-range and strategic planning (collectively, the “Purposes”).
The information we may collect in order to fulfill the Purposes includes, without limitation:
- name and contact information, including address and postal code;
- credit card or other payment information;
- age and/or birth date;
- existing medical conditions or allergies (to assist with onsite medical assistance);
- biometric data (i.e. height and weight), where this information is required in connection with the activity in which you are participating;
- photographic identification to identify you as a registered guest; and
- status as the parent or guardian of a minor, if applicable.
In some cases, you may provide us with Personal Information relating to a family member or other individual. By providing us such Personal Information, you represent that you have the consent of that person, or his or her parent or guardian, to use the Personal Information for the Purposes.
When you visit The Factory website, your web browser sends us certain information, depending on the web browser that you use and your security settings. This information may include your IP address, the name and version of your operating system, the name and version of your web browser, other technical data information, whether you accessed the website from a computer or mobile device, when you open emails that we send to you, the date, time and duration of your visit to the website, and geolocation data. This information helps us with system administration, traffic reposting, and auditing. It also helps us better understand our guests, how they use our services, and what we can do to improve their website experience. The Factory may use the information to offer you products or services and to create aggregate statistics.
Your consent to The Factory’s collection, maintenance and use of Personal Information for the Purposes shall be deemed to be obtained and is understood to be implicit upon your submission of Personal Information, whether through our website, kiosk or in-person registration system, unless explicit instructions are received not to use the information for any of the Purposes. In such case, The Factory’s ability to provide services to you may be impaired.
Except as may be required by law or where disclosure is legally permitted and determined to be in the best interests of The Factory, acting reasonably, The Factory will obtain your consent prior to the disclosure of Personal Information where disclosure is for a purpose other than the Purposes.
4. Limitations on Collection
The Factory only collects Personal Information by fair and lawful means and will only store such information as is necessary to fulfill the Purposes.
5. Limitations on Use, Disclosure and Retention
The Factory will only use or disclose Personal Information in accordance with the purposes for which it was originally collected, unless you have otherwise consented, or as required by law.
The Factory will not disclose Personal Information to other persons or organizations, except to its insurance provider, as required by its insurance policies, to its third party service providers, including, without limitation, Med-On-Site, Mystery Escape Rooms, Next Level VR, Intellitix and FareHarbor, or where reasonably required, and only to the extent necessary to specifically fulfill the Purposes.
The Factory will retain Personal Information only for so long as is required to fulfill the Purposes or as required by law.
The Factory will make reasonable efforts to keep the Personal Information collected as accurate, complete and up to date as is necessary, taking into account the purpose(s) for which the information is collected.
The Factory will take reasonable measures, consistent with industry standards and commensurate with the sensitivity of the information concerned, to safeguard Personal Information against loss, theft, unauthorized disclosure, copying, use or alteration. Specifically:
- Personal Information may only be accessed by approved employees who have received training in the proper handling of Personal Information, and only to the extent necessary to fulfill the Purposes;
- Personal Information will be disclosed to a third party only where:
- reasonable steps are taken to identify the individual requesting the Personal Information;
- the individual requesting the Personal Information is able to establish his or her right to access the Personal Information requested; and
- the proposed use of the Personal Information requested is consistent with the consent given with respect to the collection, use and/or disclosure of the Personal Information;
- Personal Information may only be stored, modified or deleted by the Privacy Officer or his or her delegate;
- physical safeguards, including restricted physical access to secure storage areas within The Factory’s premises, will be implemented; and
- technological safeguards, including restricted electronic file access, computer passwords, firewalls and file encryption procedures, will be implemented.
This Policy will be posted on The Factory’s website and will be made available to registered guests and members of the public upon request.
9. Individual Access
Registered guests may access their Personal Information as retained by The Factory to ensure its accuracy and completeness.
10. Challenging Compliance
An individual will be able to address a challenge concerning The Factory’s compliance with this Policy to the Privacy Officer. The Factory has implemented procedures to receive and respond to inquiries or complaints about its policies and procedures relating to the handling of Personal Information. The Factory will investigate all complaints. If a complaint is found to be justified, The Factory will take appropriate measures, including amending its policies and procedures, if necessary.
Individuals may obtain more information on The Factory’s privacy policies, or make a complaint, by contacting:
100 Kellogg Lane
London, ON N5W 2T5
Individuals also have recourse to the Office of the Privacy Commissioner of Canada if they consider that The Factory has not responded satisfactorily to their complaint or inquiry.
Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3
Note: The Privacy Commissioner of Canada’s office does not accept complaints by email, as security cannot be ensured.