Purpose

Gusto Running™ is committed to keeping the Personal Information, as defined below, of its clients accurate, confidential, secure and private. Our Privacy Policy is modeled after the Canadian Standards Association Model Code for the Protection of Personal Information and is complaint with Federal and provincial privacy laws including the federal Personal Information Protection and Electronic Documents Act, SC 2000, c.5 (“PIPEDA”), as amended from time to time. 

Application

The Privacy Policy applies to Personal Information about the clients of Gusto Running™ and other individuals that is collected, used or disclosed by Gusto Running™.

Personal Information Protection Principles

1. Accountability

Gusto Running™ is accountable for the protection of all Personal Information within the organization's possession or control, including any Personal Information that has been transferred to a third party for regulatory, legal or processing purposes. Gusto Running™ will require a comparable level of protection of this information from its third party relations.

2. Identifying Purposes

Personal Information includes but is not limited to:

            (a) client’s name and address and other contact information, such as telephone numbers, email addresses;

            (b) date of birth;

            (c) running and fitness goals;

            (d) employment information;

            (e) in case of emergency contact information;

            (f) medical information;

            (g)  parent/guardian contact information when applicable; and

            (h) other identifiable information such as credit card or banking information.   

Referred to collectively as (“Personal Information”)

Personal Information does not include information that is otherwise available to and made public. 

3. Limiting Collection & Use of Personal Information

Gusto Running™ limits the amount and type of Personal Information it collects to that which is necessary for the provision of Services outlined in the Terms of Use and as permitted by law, unless consent is otherwise provided. If Gusto Running™ identifies other purposes for which the Personal Information may be used, Gusto Running™ will seek the individual's consent prior to such use. Gusto Running™ will advise that it is the individual's right to refuse permission for Gusto Running™ to use Personal Information for any new purposes.

4. Consent

The knowledge and consent of an individual are generally required for the collection, use or disclosure of personal information and Gusto Running™ will seek to obtain consent before or when it collects, uses or discloses Personal Information about an individual. An individual can provide consent to the collection, use and disclosure of Personal Information about them expressly or implicitly. However, Gusto Running™ will collect, use or disclose Personal Information without an individual's knowledge and consent only in limited circumstances and as permitted by law, such as in the case of an emergency where the life, health or security of an individual is threatened, or by order of the court. Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of Personal Information about them at any time. Under certain exceptional circumstances, Gusto Running™ may have a legal duty or right to disclose Personal Information without the individual's knowledge or consent.

5. Retention

Gusto Running™ will retain closed client files (electronic and hard copy) for two years, after which the Personal Information will be destroyed or made anonymous.

6. Accuracy

Gusto Running™ shall take all reasonable steps to ensure that all Personal Information will be kept accurate, complete and up to date. Any client of Gusto Running™ can have access to the Personal Information about them that Gusto Running™ has in its possession or control. Individuals may challenge the accuracy and completeness of Personal Information about them and have it amended, as appropriate.

7. Safeguards

In executing its responsibilities with respect to the confidentiality of personal information, Gusto Running™ will employ a number of safeguards appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include but are not limited to: physical measures, organizational measures and technological measures, for example locked filing cabinets, and the use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.

8. Openness

Gusto Running™ will make its policies and practices relating to the protection of Personal Information available to its clients.

9. Challenging Compliance

Any client of Gusto Running™ may challenge Gusto Running’s™ compliance with this Privacy Policy by contacting Gusto Running™ directly. The challenge will be investigated and results and recommended steps shall be reported to the client as soon as practicable.