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Privacy Policy

COMMONWEALTH GAMES FOUNDATION OF CANADA INC.

Operating Name: Commonwealth Sport Canada Foundation (CSCF)
CSCF 50/50 RAFFLE PROGRAM PRIVACY POLICY
Effective Date: December 1, 2025
Approved by: Board of Directors
Contact: privacy@commonwealthsport.ca

 

1. PURPOSE AND SCOPE

1.1 Purpose of Policy.
The Commonwealth Games Foundation of Canada Inc., operating as the Commonwealth Sport Canada Foundation (“CSCF”, “we”, “our”, or “us”), is committed to safeguarding the privacy, confidentiality, and integrity of all Personal Information entrusted to us. This Privacy Policy (“Policy”) sets out the principles and practices governing CSCF’s collection, use, disclosure, retention, and protection of Personal Information.

1.2 Scope.
This Policy applies to all Personal Information processed by CSCF in connection with:

• Charitable activities, fundraising, donation processing, and receipting;
• Electronic raffles, 50/50 draws, contests, and charitable gaming;
• Community programs, events, and volunteer participation;
• Websites, digital platforms, online stores, and electronic communications;
• Administrative, financial, and operational activities.

This Policy does not apply to Personal Information where its collection, use, or disclosure is superseded by the:

• Freedom of Information and Protection of Privacy Act; or
• Federal Access to Information Act and Privacy Act.

1.3 Compliance.
CSCF complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws in Ontario, Alberta, and British Columbia, as well as the requirements of relevant gaming authorities, including AGCO, AGLC, and GPEB.

1.4 Consent.
By purchasing tickets, entering a raffle, making donations, communicating with us, or using our services, individuals consent to the collection, use, and disclosure of their Personal Information in accordance with this Policy and applicable privacy laws.

 

 

2. DEFINITIONS

2.1 “Personal Information” means information about an identifiable individual, including but not limited to name, address, email, phone number, age verification data, payment and transaction information, donation history, and digital identifiers such as IP address.

2.2 “ERS Provider” means any approved Electronic Raffle System provider used by CSCF

2.3 “Payment Processor” means any third-party payment service provider used to securely process payments on behalf of CSCF

2.4 “Service Providers” means external organizations contracted by CSCF to perform services such as hosting, data storage, payment processing, analytics, auditing, legal support, and raffle administration.

2.5 “Minor” means an individual under 18 years of age or the age threshold required by gaming legislation in their jurisdiction.

 

3. INFORMATION WE COLLECT

3.1 Information Provided Directly by You.
CSCF may collect Personal Information including:

• Name, mailing address, email address, phone number;
• Payment information (processed securely);
• Age and residency verification required for gaming compliance;
• Ticket purchase history, raffle numbers, and transaction records;
• Donation records and CRA-required receipting information;
• Volunteer and event registration information;
• Communication preferences and consent records.

3.2 Technical and Digital Information.
We may collect non-identifiable technical information, such as:

• IP address and device identifiers;
• Browser type, operating system, session logs;
• Cookies and tracking technology;
• Event and Security Analytics;
• Error and performance diagnostics.

3.3 Sensitive Information.
CSCF does not intentionally collect sensitive Personal Information unless legally required or expressly provided with consent.

 

4. PURPOSES FOR USE OF PERSONAL INFORMATION

CSCF uses Personal Information only for legitimate charitable, operational, and regulatory purposes, including:

4.1 Administration of Charitable Gaming Events.

• Ticket sales processing;
• Eligibility verification;
• RNG-based draw administration;
• Communicating with potential winners;
• Distributing prizes.

4.2 Regulatory Compliance.

• Reporting to AGCO, AGLC, GPEB, and other authorities;
• Fulfilling licence conditions;
• Tax reporting and CRA compliance.

4.3 Communications.

• Providing confirmations, updates, and results;
• Delivering newsletters, fundraising updates, impact stories, and promotional materials where consent has been provided.

4.4 Security and Fraud Prevention.

• Validating transactions;
• Detecting and mitigating suspicious activities;
• Protecting CSCF systems and participants.

4.5 Program Development and Improvement.

• Analyzing participation trends;
• Enhancing user experience;
• Improving fundraising and community engagement programs.

4.6 Other Lawful Purposes.
Any additional uses where consent has been obtained or as required or permitted by law.

 

5. CONSENT AND WITHDRAWAL OF CONSENT

5.1 Forms of Consent.
CSCF may rely on express consent, implied consent, or deemed consent consistent with Canadian privacy legislation.

5.2 Withdrawal of Consent.
You may withdraw consent at any time by contacting privacy@commonwealthsport.ca,subject to legal or contractual limitations.

5.3 Consequences of Withdrawal.
Withdrawal of consent may impact CSCF’s ability to provide certain services such as raffle participation, tax receipting, or communications.

 

6. DISCLOSURE OF PERSONAL INFORMATION

6.1 Service Providers.
CSCF may disclose Personal Information to third-party Service Providers who perform functions on our behalf. These may include providers that support:

• Electronic raffle systems (e.g., platforms that manage raffle administration);
• Payment processing services for secure transaction handling;
• Cloud hosting and data storage services;
• Customer relationship management (CRM) and donor management systems;
• Auditors, legal advisors, and compliance consultants;

All Service Providers are required to:

• Maintain confidentiality;
• Use Personal Information only for authorized purposes;
• Comply with Canadian privacy legislation.

6.2 Corporate Transactions.
In the event of a merger, reorganization, or transfer of assets, Personal Information may be transferred as part of the transaction.

6.3 Legal Disclosures.
CSCF may disclose Personal Information where required to:

• Comply with court orders;
• Respond to regulatory inspections;
• Assist law enforcement;
• Investigate fraud or security incidents.

6.4 Prohibited Disclosures.
CSCF does not sell, rent, trade, or exchange Personal Information.

 

7. PAYMENT INFORMATION & PCI-DSS COMPLIANCE

7.1 Secure Processing.
All payment transactions are handled exclusively by the contracted Payment provider, a PCI-DSS Level 1 compliant provider.

7.2 No Storage of Financial Data.
CSCF does not store complete credit card or banking information.

7.3 Dispute Resolution.
Payment information may be used to resolve chargebacks, disputes, or transaction issues.

 

8. ELECTRONIC COMMUNICATIONS & CASL

8.1 Email Communications.
CSCF sends electronic communications in compliance with the Canadian Anti-Spam Legislation (CASL).

8.2 Unsubscribe Rights.
Individuals may unsubscribe from promotional communications at any time via visiting the CSCF website or by contacting CSCF.

8.3 Transactional Messages.
Emails containing ticket confirmations, receipts, or regulatory information are not subject to unsubscribe requests.

 

9. TELEPHONE COMMUNICATIONS & DO NOT CALL LIST

9.1 Charity Exemption.
Registered charities are permitted to contact individuals for fundraising purposes even if listed on the National Do Not Call List.

9.2 Opt-Out.
Telephone preferences may be managed by contacting privacy@commonwealthsport.ca.

 

10. COOKIES, TRACKING TECHNOLOGIES & ANALYTICS

10.1 Use of Cookies.
CSCF uses cookies to:

• Enable core website functions;
• Improve performance;
• Analyze visitor behaviour;
• Support security measures.

10.2 Categories of Cookies.

• Necessary Cookies
• Functional Cookies
• Analytics Cookies

10.3 Managing Cookies.
Users may modify browser settings to disable cookies; however, certain functions may be impaired.

 

11. CHILDREN’S PRIVACY

11.1 Age Requirements.
CSCF’s gaming and raffle activities are restricted to individuals aged 18+.

11.2 Accidental Collection.
If CSCF learns that Personal Information of a Minor has been collected, it will be deleted promptly.

 

12. CROSS-BORDER DATA TRANSFERS

12.1 International Processing.
CSCF’s Service Providers are primarily located in Canada. In limited cases, Personal Information may be accessed or processed outside of Canada if required to support our technology systems or security protections. In all cases, CSCF ensures that any Service Provider meets strict confidentiality, privacy, and security standards consistent with Canadian law.

12.2 Protection Measures.
CSCF ensures:

• Contractual safeguards;
• Privacy impact assessments;
• Compliance with PIPEDA accountability requirements.

 

13. DATA RETENTION & DESTRUCTION

13.1 Retention Periods.
Personal Information is retained only for as long as necessary to meet:

• Legal and regulatory obligations (typically 7 years for gaming records);
• CRA tax receipting requirements;
• Audit and financial reporting needs;
• Dispute resolution and operational requirements.

13.2 Secure Destruction.
After the retention period expires, data is securely destroyed, anonymized, or deleted using industry-standard methods.

13.3 Retention of Consent Records.
Records of consent withdrawal are retained as required for audit and compliance.

 

14. SECURITY SAFEGUARDS

14.1 Technical Safeguards.

• Encryption in transit (TLS/SSL);
• Secure servers;
• Firewalls, intrusion detection, MFA;
• Regular security assessments.

14.2 Organizational Safeguards.

• Mandatory privacy training;
• Access controls and confidentiality obligations;
• Documented policies and procedures.

14.3 Breach Notification.
If a breach poses a real risk of significant harm, CSCF will notify:

• Affected individuals;
• The Office of the Privacy Commissioner of Canada;
• Applicable gaming regulators.

 

15. AUTOMATED DECISION-MAKING

CSCF does not engage in automated decision-making or profiling that produces significant legal or financial effects on individuals.

 

16. INDIVIDUAL RIGHTS

Individuals may exercise the following rights:

16.1 Access.
Request access to Personal Information held by CSCF.

16.2 Correction.
Request correction of inaccurate or incomplete data.

16.3 Withdrawal of Consent.

16.4 Deletion (Where Permitted).

16.5 Restriction or Objection.

16.6 Portability (Where Required by Law).

Requests must be submitted to: privacy@commonwealthsport.ca

 

17. GOVERNANCE & ACCOUNTABILITY

17.1 Privacy Officer.
CSCF’s Privacy Officer oversees compliance with this Policy.

17.2 Annual Review.
This Policy is reviewed and updated at least annually.

17.3 Training.
Authorized personnel receive privacy and data protection training.

 

18. COMPLAINTS & EXTERNAL OVERSIGHT

18.1 Internal Complaints.
Complaints may be directed to:

Privacy Officer
Commonwealth Sport Canada Foundation
[Mailing Address]
Email: privacy@commonwealthsport.ca

18.2 External Complaints.
If issues remain unresolved, individuals may contact the Office of the Privacy Commissioner of Canada or relevant provincial privacy authorities.

 

19. CHANGES TO THIS POLICY

19.1
CSCF may amend this Policy from time to time.

19.2
Material changes will be posted on:
https://commonwealthsport.ca/foundation

19.3
Where changes materially affect use of Personal Information, CSCF will provide notice and obtain consent as required.

 

END OF POLICY