Maintaining the privacy of minors is critical to WTA. For persons under the age of 18, we require parental or guardian consent prior to opening an account, and we reserve the right to verify the existence of that consent.
“collection” means the act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the user or by an authorized representative. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from an user’s action or inaction.
“user” means an individual who uses the Service provided by WTA, including anyone who accesses or visits the Sites.
“disclosure” means making personal information available to a third party.
“personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual. For a registered user, such information may include (but is not limited to) account information and any recorded complaints.
“registered user” means an individual who has created and registered an account with WTA.
“third party” means an individual other than the user, or the user’s agent, or an organization outside WTA.
“use” means the treatment, handling, and management of personal information by and within WTA.
WTA may collect any or all of the following personal information if the information is reasonably required to provide the services accessed or requested by you:
(a) information that you provide when you become a registered user or otherwise complete forms on the Service, such as your name, email and postal address, age, and country of residence;
(b) your log-in and password details in connection with your WTA account, including your username;
(c) information that you provide to WTA in order to give donations, including credit card information;
(d) your correspondence with WTA employees, including any questions, concerns or comments you may have about the Service or problems that you report;
(e) comments, photographs and other content that you may post to the Service; and
(f) details of your requests made through the Service.
3. Purpose of Collection and Use of Personal Information
WTA collects your personal information and will use your personal information as is reasonably required for the following purposes:
(a) if you are a registered user, to establish and maintain your Winnipeg Trails account;
(b) to provide the Winnipeg Trails application, or the other services or information that you request;
(e) to verify your identity if you submit comments, photographs or other content to the Service;
(f) to allow you access to submit comments, photographs or other content to the Service;
(g) to respond to questions, comments, requests or complaints that you submit to WTA;
(h) to process your donations;
(i) to provide income tax receipts, where applicable;
(j) to process your registration for certain events or contests;
(k) if you are a member of a Winnipeg Trails team, to allow you to send messages to and receive messages from your team mates and to otherwise participate in team activities;
(l) to edit and moderate comments and content posted to Service and to otherwise administer the interactive features of the Service;
(m) to track WTA’s communications with you;
(n) to analyze use of the Service and to improve the Service;
(o) to send emails, newsletters, regular mail or other communications you have consented to receive from WTA;
(p) to send prizes and/or gifts that you have qualified to receive;
(q) to provide Service-related announcements or notifications to you;
(r) to fulfill a purpose that we disclose to you when we request your personal information;
(s) to meet legal and regulatory requirements.
Personal information gathered by WTA is kept in confidence. WTA staff are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained. Personal information will only be collected and used by authorized staff in a manner consistent with the activities of WTA.
WTA may disclose your personal information to:
(a) its employees, agents, partners, volunteers, and service providers as is reasonably necessary to enable these parties to perform a business, professional, charitable or technical support function for WTA;
(b) a person who, in the reasonable judgment of WTA, is seeking the information as your agent; and
(c) a third party or parties, where you consent to such disclosure or the disclosure is required by law.
If you voluntarily submit or post any information, photographs or other content (“User Content”) to any WTA blog or forum, Twitter pages, Facebook pages or other social networking pages/sites, certain of your personal information may be automatically included in the posting, including without limitation, your user name and email address, and this information may be collected and used by others. WTA has no control over and is not liable for the collection, use or disclosure of any posted User Content or your included personal information by users of the Service, including any blog, forums, Twitter pages, Facebook pages or other social networking pages/sites. You are responsible for ensuring the protection of any of your personal information that you post to any WTA blog, forum, Twitter Page, Facebook Page or other social networking page or site. We recommend that you do not include your home address, job title, telephone number or other more sensitive personal information in any User Content, unless you are entirely satisfied that such information should be made public.
5. Safeguarding Your Personal Information
WTA is committed to safeguarding your personal information. WTA uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction regardless of the format in which it is held. The methods of protection and safeguards used by WTA include, but are not limited to, locked filing cabinets, need-to-know access and technological measures including the use of passwords, encryption and firewalls. While WTA cannot guarantee that risks such as loss, theft, unauthorized access or disclosure of personal information will not occur, WTA will make every effort to prevent such unfortunate occurrences.
WTA takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information. WTA also ensures that its employees with access to personal information are made aware of the importance of maintaining the confidentiality of personal information. Finally, WTA protects personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
WTA is committed to keeping your personal information as complete, up-to-date, and accurate as is necessary for the purposes for which it is to be used. WTA will promptly correct or complete any personal information found to be inaccurate or incomplete. Where appropriate, WTA will transmit amended information to third parties having access to the personal information in question. Upon request, WTA will provide you with a reasonable opportunity to review the personal information in your file to review its accuracy. Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.
Also upon request, WTA will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information. In providing an account of disclosure, WTA will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list.
8. Withdrawing Consent
You may withdraw your consent to the collection, use or disclosure of your personal information by WTA at any time, subject to legal or contractual restrictions and reasonable notice. In certain circumstances, your withdrawal of consent will result in the inability of WTA to continue providing aspects of the Service to you. Please contact WTA for more information regarding the implications of withdrawing consent.
9. Non-Personal Information
Non-personal information is information that does not identify you and which we are unable to connect to other information in order to identify you. WTA may collect any or all of the following non-personal information:
(a) Data that you submit to the Service regarding traffic counts;
(b) Aggregate data regarding traffic and traffic patterns in your neighbourhood or community;
(d) We may also use additional analytics programs from time to time to process non-personal information about you.
We make no attempt to link this non-identifying information with the identity of individuals using the Service. Your non-identifying information may be permanently archived for future use.
Winnipeg Trails Privacy Officer
Mailing Address: 306 Edwin Street, Winnipeg, MB, R3B 0Y6
Telephone No.: 1-204-797-1962
E-mail: info at winnipegtrails.ca
Date: Oct 9, 2018
©Winnipeg Trails, 2018, Winnipeg.