What this page is for
This page tells you what you can ask us to do with personal information about you, how to ask, how long we take, and what to do if you are not satisfied.
It is written for parents or guardians asking about a child, for competitors asking about themselves, for account holders and for competition organizers. If you are asking about a child, read Requests about a child first, because the rule there is not the one most people expect.
Two different roles
Which role we play decides who is responsible for your information and who answers your questions.
Where you hold an account with us, or buy photographs and video, an event pass or extended hosting, we are responsible. We decide what is collected and why, our Privacy Policy governs it, and you exercise your rights with us.
Where a competition organizer runs a competition on our software and you enter or compete, the organizer is responsible. We hold that information on the organizer's documented instructions and act on those instructions, and on the permission described under "How we use competition information and media to improve our software" on the Privacy Policy. The organizer's own privacy policy governs it, and the organizer decides the outcome of a request about it.
We may use information and media handled through our software to improve the software itself, on the written permission of our Chief Executive Officer and our Privacy Officer, and you can ask us not to. What that covers and what we will never do with it is set out in the Privacy Policy under "How we use competition information and media to improve our software".
Here is what that means for you, in one sentence each.
- Where we are responsible: Send your request to us and we answer it.
- Where the organizer is responsible: Send your request to us anyway. We send it to the organizer on the day we receive it, tell you who they are, and act on their instruction. The organizer decides the outcome.
British Columbia's Personal Information Protection Act gives you the right to see and to correct your information against the organization that has it under its control. For a competition, that is the organizer. We hold the information on their instructions. We cannot answer a request about that information, or change or delete it, without the organizer's instruction. What we can do is get your request to them the same day and tell you who they are.
If a dance or cheer studio entered your family, you may never have dealt with the organizer or with us. Send your request to us all the same. We will tell you who is responsible for what you are asking about, and how to reach them.
What you can ask us to do
Who answers depends on which of the two roles above applies to the information you are asking about. The last column says where each right comes from.
| Right | What you can ask for | Who answers | What it rests on |
|---|---|---|---|
| Access | A copy of the personal information we hold about you, an account of how it has been used, and the names of the people and organizations it has been disclosed to. | We answer this where we are responsible. We send this to the organizer where the organizer is responsible. | British Columbia's Personal Information Protection Act. |
| Correction | Correction of personal information about you that is wrong or incomplete. | We answer this where we are responsible. We send this to the organizer where the organizer is responsible. | The same Act. |
| Deletion | When we act on a request to delete, we remove the details that identify you from our live systems: your name, contact details and anything else that points to you. Competition results and counts stay, without anything that identifies you in them, because organizers rely on them. What happens to backups, and the rest of the answer, is on the Privacy Policy under "What happens when you ask us to delete". | We answer this where we are responsible. We send this to the organizer where the organizer is responsible. | Our own undertaking. |
| Withdraw a consent | Withdrawal of a consent you gave us. Marketing email is the main case. Before the withdrawal takes effect we tell you what, if anything, changes as a result. | We answer this, where you gave the consent to us. | The same Act. |
| Stop marketing | That we stop sending you marketing email, for any reason or for none. | We answer this. Marketing email is always ours. | The same Act, and our own undertaking, which has no conditions. |
What access covers
Access is wider than a copy of the file, and most people ask for less than they are entitled to. You can ask for three things.
- The personal information itself.
- An account of how it has been used and is being used.
- The names of the people and the organizations it has been disclosed to.
Ask for all three in one request. You do not have to name a law or a section. The second and third are usually what a parent or guardian actually wants, because the question behind the request is who else has a child's scores, critiques, photographs and video.
If we do not make a correction you asked for
A refused correction does not leave you with nothing. We note the correction you asked for on the record, so that anyone who reads it afterwards sees your version alongside ours. When we do make a correction, we send it to every organization we gave the information to in the year before. That way the correction reaches the people who have a copy, not only us.
Other privacy laws
The table lists what you can ask for under Canadian law. Which other privacy laws may apply to something we do, and how we decide that, is set out on the Privacy Policy.
Stopping marketing email
You can tell us to stop sending you marketing email at any time, and we will stop. No reason is needed. It costs nothing, and it has no effect on your account or on any competition you have entered.
There are two routes. Use the unsubscribe link in any newsletter we send, or email our Privacy Officer at dpo@inchol.com and say you want the marketing to stop. How long each route takes is in How long we take.
For marketing email, nothing changes except that the email stops. For any other consent, we tell you what will change before the withdrawal takes effect.
How to make a request
Read this before you send us anything. If your request is about a competition, we pass it to the competition organizer who ran that competition. What we pass on includes your name, your contact details, what you have asked us to do, and the competition or event you have named. That is a disclosure of personal information about you to another organization, so we want you to know before you decide what to send.
If you would rather deal with the organizer yourself, ask us for their contact details and send us nothing else until you have them. Tell us only the competition and how to reply to you.
Who to send it to
- Inchol Solutions Inc.
- Privacy Officer: Kevin Sun, Chief Technology Officer
- Email: dpo@inchol.com
- Telephone: 1-877-807-2183
- Post: #300, 3056 Glen Drive, Coquitlam, BC V3B 0V1, Canada
The address dpo@inchol.com reaches our Privacy Officer.
The telephone number is toll free within Canada and the United States. It may not be reachable from outside North America. If you are in the United Kingdom, the European Economic Area or anywhere else outside North America, please use email or post.
If your complaint is about the Privacy Officer, write to the postal address above marked for the attention of the Chief Executive Officer, who then takes the decisions the Privacy Officer would normally take.
What to tell us
- What you want us to do.
- Your name, and an email address or a postal address we can reply to.
- The competition or the event, if your request is about one.
- Enough detail for us to find the records. A competitor's name and the year usually does it.
You do not need a form, and you do not need any particular wording. We will help you put the request together if you are not sure what to ask for, and we answer as accurately and completely as we can. If a request is unclear or we cannot find the records, we come back to you and ask rather than refuse.
There is no charge for a request.
How we confirm who you are
We confirm who you are before we release or change anything. A record about a competitor is worth protecting from whoever happens to ask for it.
If you hold an account with us, replying from the email address on that account is usually enough.
Many people reading this page hold no account with us, because a competition organizer or a studio entered the family. If that is you, tell us what you are asking about and we will tell you what we need from you before you send anything else. We ask for an identity document only where we cannot confirm who you are another way, and when we do ask, we say what we need and why.
How long we keep information is on the Privacy Policy under "How long we keep it", and what happens to a copy in a backup is under What happens when you ask us to delete.
We also remove personal information about other people from a record before we give it to you. The law requires that, and it is not a choice we make case by case.
Requests about a child
This is the part of the page most often misread, so here is the rule in full.
A child's privacy rights belong to the child. A parent or guardian does not automatically hold them.
British Columbia's law lets the guardian of a child act for the child where the child cannot act for themselves. That is the rule we follow, and three things come from it.
- A guardian acts for a child who cannot act for themselves. If your child is young, or cannot deal with a request on their own, you make the request for them.
- An older competitor deals with us directly. If you are a competitor who can handle a request yourself, write to us yourself. You do not need a parent or guardian to ask for you, and we will not require one to be involved.
- We ask for evidence of guardianship. Telling us you are a parent is a statement about yourself, not evidence. On its own it is not enough for us to release a competitor's scores, critiques, photographs or video.
What we need from you is photo identification in your own name, a document showing that you are the child's parent or guardian, and the details the child is registered under on the competition platform. A birth certificate naming you as a parent, or a court order granting guardianship, is the usual document. If you are not sure what to send, ask us first and we will tell you before you send anything.
Where a competitor writes to us themselves and we need to know their age before we answer, we ask for a birth certificate or photo identification. We ask for it only when their age decides whether we answer them or their parent, and we tell them why we are asking.
The two roles apply to a child's information in the same way they apply to anyone's, so a request about a competition goes to the organizer in the way described under Two different roles.
What happens to a child's photographs and video, and who can see them, is on the Privacy Policy.
How long we take
This is the only page in our set that says how long we take to answer a request or a complaint. If another page of ours gives you a different figure for that, this table is the one to rely on.
| What you asked for | When you get an answer | Where the period comes from |
|---|---|---|
| Access or correction, where we are responsible and British Columbia's law governs | Within 30 days of the day we receive your request, counted in days as the Act counts them. The Act allows us up to 30 further days, and a longer period only with the Commissioner's permission. We tell you if we take an extension. | British Columbia's Personal Information Protection Act, section 29(1)(a), and section 31(1) for the extension. |
| Access, where the information crosses a provincial or national border in the course of business and Canada's federal law governs | With due diligence, and in any case within 30 days of the day we receive your request. | Canada's federal privacy law, the Personal Information Protection and Electronic Documents Act (PIPEDA), section 8(3). |
| Any request about information a competition organizer is responsible for | We send it to the organizer on the day we receive it, and we tell you who they are. When the organizer's instruction reaches us, we carry it out and tell you that we have. If you have heard nothing, ask us and we will tell you what we sent the organizer and when. | Our undertaking. |
| Stopping marketing email, by the unsubscribe link | Immediately. That is what the link does. | How the link works. |
| Stopping marketing email, by writing to us instead | We act on your message when we read it and confirm to you that we have. We have not set ourselves a fixed period for this route, so if you want the email to stop at once, use the link. | Our undertaking. |
| Acknowledging a complaint | Within five business days of the day we receive it. | Our undertaking. |
| Answering a complaint in writing | Within 30 days of the day we receive it. If we need longer, we tell you why and when to expect our answer. | Our undertaking. |
Every period in the table starts on the day we receive your request, not on the day we open it.
How the days are counted. Where British Columbia's Act fixes 30 days, they are counted as that Act counts them, and that leaves out some days a calendar includes. So 30 days under the Act runs longer than 30 calendar days. A business day, where this page uses the term, is a day other than a Saturday, a Sunday or a statutory holiday in British Columbia.
The table states the periods under the two Canadian laws. If another privacy law reaches a particular thing we do, that law's own period applies to that activity.
If we cannot do what you asked
Some refusals the law requires of us, and some it only permits. The difference matters, because you cannot talk us out of the first kind. If giving you information would reveal personal information about somebody else, we must refuse that part. For any other refusal, we tell you which reason we are relying on.
If we refuse any part of a request, our refusal tells you three things.
- The reasons for the refusal, and the provision of the law the refusal rests on.
- The name, position title, business address and business telephone number of someone here who can answer your questions about it.
- That you may ask the Office of the Information and Privacy Commissioner for British Columbia to review the refusal, and that you have 30 days from being told to do it.
The 30 days start on the day we tell you. Section 47(2) of British Columbia's Personal Information Protection Act gives you 30 days from being notified of the refusal to ask the Commissioner for a review, unless the Commissioner allows you longer. If you wait a few weeks and then complain to us, you may have lost the review. Ask for the review first. You can still talk to us afterwards.
If a competition organizer is responsible for the information, a refusal is the organizer's and not ours. We tell you that it came from them and who they are, and you take it up with them.
If you are not satisfied
Tell us. Write to our Privacy Officer at dpo@inchol.com or at the postal address above, and mark it as a complaint.
We record the complaint, look into the facts, answer you in writing and record anything we change as a result. Our answer tells you that you may also complain to a regulator. How long we take to acknowledge a complaint and to answer it is in the table under How long we take.
Two kinds of complaint take a different route, and it is fairer to say so at the start.
- A decision a competition organizer made about information they are responsible for. We cannot overturn it. What we do is tell you who the organizer is and give you their contact details, so that you can take it up with them.
- A complaint about our Privacy Officer. Our Privacy Officer is also our Chief Technology Officer, and a complaint about how that person handled a matter must not be decided by that person. Send it to the postal address under How to make a request, marked for the attention of the Chief Executive Officer.
You do not have to come to us first. Going straight to a regulator is open to you, and Who regulates us says which one.
If your information is exposed
If personal information we are responsible for is lost, or reached by someone who should not have it, we do what the law governing that activity requires. If the law leaves it to us, we decide whether to tell you and record why, and we do not decide against telling you about a breach likely to cause you significant harm without our Chief Executive Officer's written agreement.
Where the information is held on a competition organizer's documented instructions, we tell the organizer. The decision whether to contact the people affected is the organizer's and not ours, unless the organizer instructs us in writing to contact you or the law places that duty on us directly.
What we do when something goes wrong, and who we have to tell, is set out on How We Protect Your Information.
Reporting a security or privacy problem
If you have found a problem rather than a request to make, that is a different route. Another family's information showing in your account, an account you think has been taken over, or a flaw you have found in our software all belong there.
How to report one, and what to include, is on How We Protect Your Information. Please use that route, so that it reaches the right people quickly.
Who regulates us
Which office is the right one depends on what your complaint is about, not on where you live, and the table is arranged by subject for that reason.
| What your complaint is about | Which office | How to reach it |
|---|---|---|
| How personal information was handled within British Columbia | Office of the Information and Privacy Commissioner for British Columbia | oipc.bc.ca. Telephone (250) 387-5629. From outside Victoria, the office asks you to call Service BC toll free and ask to be transferred to (250) 387-5629. Service BC is (604) 660-2421 in Vancouver and (800) 663-7867 elsewhere in British Columbia. |
| Personal information that crossed a provincial or national border in the course of business | Office of the Privacy Commissioner of Canada | priv.gc.ca. Telephone 1-800-282-1376. |
| Something European Union privacy law covers, where that law reaches what we do | The data protection authority for your country in the European Economic Area | The list of authorities is at edpb.europa.eu. You may complain where you live, where you work, or where the problem happened. |
| Something United Kingdom privacy law covers, where that law reaches what we do | Information Commissioner's Office | ico.org.uk. Telephone 0303 123 1113. |
Telephone numbers change, so check the number on the office's website before you rely on it.
Either Canadian office may be the right one for the same complaint, depending on what it is about. If you complain to us first, our written answer says which office we think covers it and why.
If your complaint is about a decision a competition organizer made, the organizer is the organization complained of, and the office that covers the organizer is the one to approach.
Where to find the rest
- Privacy Policy. What we collect about you, why, who else sees it, where it is held and how long we keep it.
- Cookies and Analytics. What cookies and tags our websites serve, what each does, and what you can do about it.
- How We Protect Your Information. How we protect personal information, what we do when something goes wrong, and how to tell us about a problem.
- Service Providers and Subprocessors. Which outside companies handle personal information for us, what each does with it and where it is.
- Privacy and Security Policies. Where to find the answer to your question, in one step.
Questions about these policies? Email our Privacy Officer at dpo@inchol.com.
