PRIVACY POLICY
LEC Guest Text Messaging Service
Langley Events Centre | Ten Feet Sports and Entertainment, Ltd.
Your privacy matters. This policy explains how Ten Feet Sports and Entertainment Ltd. ("TFSE", "we", "us" or "our") collects, uses, protects, retains and discloses personal information when patrons use the LEC Guest Text Messaging Service at the Langley Events Centre ("LEC") (the "Service").
IMPORTANT - NOT AN EMERGENCY SERVICE
The Service is not a substitute for 911 and may not be monitored continuously. If there is an immediate threat to safety, a crime in progress or a medical emergency, call 911 and alert the nearest LEC staff member.
1. Scope and responsibility
TFSE operates the Langley Events Centre and is responsible for the operation of this Service. This policy applies only to personal information collected through the LEC guest messaging channel and related operational records. It does not replace privacy notices that apply to other TFSE, LEC or Township of Langley websites, applications, ticketing systems or services.
TFSE is committed to handling personal information responsibly, in accordance with applicable privacy requirements, contractual obligations and reasonable information-security practices.
2. Purpose of the Service
The Service allows patrons to contact LEC personnel by SMS or MMS during venue activities. It is intended for operational guest assistance, including:
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safety, security and conduct concerns;
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accessibility assistance and accommodation-related requests;
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facility, housekeeping, or maintenance issues;
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seating, ticketing, food & beverage, or other venue-service issues;
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lost-person, lost-property or wayfinding assistance; and
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other guest-service questions or concerns requiring an operational response.
We do not use information collected through the Service to send advertising, ticket promotions or other unrelated marketing communications.
3. Information we collect
When you use the Service, we may collect and create the following information:
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your mobile telephone number;
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the content of your messages and the date and time they are sent or received;
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photos, videos or other files you choose to attach, including metadata contained in those files where available;
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the location you describe or identify in your report;
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responses from LEC personnel and records of actions taken;
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the operational or incident classification assigned to the conversation;
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internal notes and follow-up records created by authorized personnel;
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information you provide about other individuals involved in or relevant to a report; and
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technical and delivery information generated by the messaging platform, telecommunications providers or your device, where applicable.
The Service is not anonymous because your telephone number is visible to the system. Sending a text message does not, by itself, allow TFSE to continuously track your precise location. However, location information may be included in your message, an attachment or associated file metadata.
4. How we collect and use information
Most information is collected directly from you when you voluntarily send a message or attachment. Additional records are created when authorized personnel respond, classify, document or follow up on the matter. By choosing to use the Service, you acknowledge that the information you provide will be used to receive, assess and respond to your report.
We may use the information to:
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communicate with you and provide the assistance you requested;
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assess, respond to, document and resolve safety, security, service or facility issues;
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dispatch or coordinate appropriate LEC personnel or external responders;
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create or supplement an incident, complaint, maintenance or operational record;
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investigate events, address complaints and manage potential or actual claims;
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protect patrons, personnel, property, systems and legal rights;
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meet legal, regulatory, contractual, insurance and records-management obligations; and
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prepare aggregated or de-identified operational reporting and improve venue services.
TFSE does not use the Service to make solely automated decisions about patrons. Staff remain responsible for assessing messages and determining an appropriate response.
5. Please limit sensitive information
Only provide information reasonably necessary for LEC personnel to understand and respond to the situation. Standard SMS and MMS communications are not guaranteed to be private or secure while travelling through mobile networks. Avoid sending passwords, payment-card information, government identification numbers, detailed medical records or other highly sensitive information.
If your report concerns another person, provide only information relevant to the concern and do not include unnecessary personal details. Submitting false, threatening, harassing, unlawful or deliberately misleading reports may result in the conversation being restricted or referred to the appropriate authorities.
6. Service providers and processing outside Canada
TFSE uses 24/7 Software, Inc. to provide and support the messaging and incident-management platform. 24/7 Software and its authorized subcontractors process information on TFSE's behalf to deliver, secure, maintain and support the Service. These providers may include cloud-hosting, database, telecommunications and technical-support providers.
Information handled through the Service may be stored, accessed or processed outside Canada, including in the United States. While outside Canada, information may be subject to the laws of the country where it is stored or accessed and may be available to courts, law-enforcement agencies or other government authorities in accordance with those laws. TFSE requires its service providers to use the information only for authorized service purposes and to protect it through contractual confidentiality and security obligations.
7. When information may be disclosed
TFSE limits access and disclosure to what is reasonably necessary. Information may be disclosed:
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within TFSE and LEC to authorized personnel who need it for guest service, safety, security, facility operations, investigation, management or administration;
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to 24/7 Software and other contracted service providers supporting the Service;
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to the facility owner, the Township of Langley, where reasonably necessary for coordinated response, risk management, claims, records administration or legal obligations;
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to police, fire, ambulance, medical personnel or other emergency responders when necessary to respond to a situation or protect a person;
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to insurers, adjusters, auditors, investigators and legal or professional advisers where necessary to manage a complaint, investigation, claim or proceeding;
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where you consent or direct us to make the disclosure; or
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where the disclosure is authorized or required by law, court order or lawful process, or is reasonably necessary to protect people, property or legal rights.
TFSE does not sell personal information collected through the Service.
8. Security
TFSE and its service providers use administrative, technical and physical safeguards designed to protect personal information against unauthorized access, collection, use, disclosure, alteration, loss or disposal. Measures include limiting access to authorized users, confidentiality requirements, account and access controls, security monitoring, staff practices and service-provider security obligations appropriate to the nature of the information.
No messaging, transmission or storage system can be guaranteed completely secure. If TFSE becomes aware of a privacy or security incident affecting Service information, it will assess and respond to the incident and provide notices where required by applicable law.
9. Retention and disposal
Routine guest-service conversations that do not become part of an incident, investigation, complaint, claim or other official record are normally retained for no longer than thirty days after the conversation is closed. They are then securely deleted or de-identified, subject to normal system backup and deletion cycles.
If a conversation relates to a safety or security incident, investigation, complaint, insurance matter, actual or anticipated claim, legal proceeding or other recordkeeping obligation, relevant information may be transferred to or retained as part of the applicable operational or incident record. In those cases, it will be kept in accordance with the applicable TFSE or Township of Langley records schedule, legal hold, contractual or insurance requirement, or for as long as reasonably necessary for the purpose. Information will be securely deleted, destroyed or de-identified when it is no longer required.
e-identified when it is no longer required.
10. Your choices and requests
Use of the Service is voluntary. You may instead speak directly with an LEC staff member or contact LEC through another available channel. Message and data rates may apply, and delivery or response cannot be guaranteed. You may stop messaging at any time; however, this may prevent us from providing further assistance through the Service.
You may contact TFSE to ask about its handling of your information or to request access to, correction of or deletion of personal information associated with the Service. TFSE may need to verify your identity and may retain or withhold information where permitted or required by applicable law, including where a record contains information about another person or is required for an investigation, claim, safety matter or legal obligation.
11. Use by young patrons
Where reasonably possible, patrons under 16 are encouraged to seek assistance from an accompanying parent, guardian or other responsible adult when using the Service. However, a young patron should not delay requesting help or reporting safety, security or other urgent concerns if an adult is not readily available. The Service remains available to patrons of all ages.
12. Changes to this policy
TFSE may update this policy to reflect changes to the Service, legal requirements or privacy and security practices. The current version will be posted with its effective date. Material changes will apply prospectively unless otherwise permitted or required by law
13. Privacy contact
For questions, concerns or requests regarding this policy or personal information handled through the Service, contact:
Steve Tuckwood
Associate Director, Experience and Service
Ten Feet Sports and Entertainment, Ltd.
7888 200 Street
Langley, British Columbia V2Y 3J4
Telephone: 604-455-8802
Email: steve.tuckwood@tfse.ca