Privacy Policy

This Privacy Policy describes how Turbo Sports and Performance Centre Corp. (“TSPC,” “Go Turbo,” “we,” “our,” or “us”) collects, uses, discloses, and protects personal information when you interact with our facility, website (goturbo.ca), mobile and web applications powered by Xplore Recreation and SportsEngine, and any related programs, services, or communications.

This Policy applies to all users of our services, including members, league participants, program registrants, facility renters, sponsors, and visitors to our website. It governs personal information collected online and in person.

By using our services, creating an account, registering for a program, or visiting our website, you agree to the collection and use of your personal information as described in this Policy.

1. Governing Law

TSPC operates in Collingwood, Ontario, Canada. We collect and process personal information in compliance with:

• The Personal Information Protection and Electronic Documents Act (PIPEDA), S.C. 2000, c. 5
• The Freedom of Information and Protection of Privacy Act (FIPPA), R.S.O. 1990
• Canada’s Anti-Spam Legislation (CASL), S.C. 2010, c. 23
• Applicable provincial consumer protection standards

Where applicable, we follow principles consistent with internationally recognized privacy frameworks, including GDPR where users from those jurisdictions may interact with our services.

2. Who This Policy Covers

This Policy applies to the following categories of individuals:

• Members — individuals who hold an active membership with TSPC through the Xplore Recreation platform
• League Participants — adults 18 and over registered in TSPC’s Adult Sport League through SportsEngine
• Program Participants — individuals registered in TSPC-owned or partner programs
• Youth on Family Accounts — minors under 16 who are added to a family account supervised by a parent or legal guardian
• Independent Account Holders (16+) — individuals aged 16 and older who create and manage their own accounts
• Facility Renters — businesses, organizations, and individuals who book TSPC spaces
• Sponsors — corporate and individual partners engaged through our sponsorship program
• Website Visitors — anyone who accesses goturbo.ca
• Email Subscribers — individuals who opt into TSPC’s marketing or transactional communications

2.1 Minors and Family Accounts

TSPC’s facility services through Xplore Recreation permit family accounts. These accounts are managed by a parent or legal guardian (the Account Holder) who must be 18 or older. A family account may include:

• Children of any age added by the Account Holder (e.g., an 8-year-old on a parent’s account)
• Youth aged 16 or older who may independently manage their own accounts with parental acknowledgment

By creating a family account and adding a minor, the Account Holder provides consent on behalf of that minor for the collection, use, and disclosure of the minor’s personal information as described in this Policy.

TSPC’s Adult Sport League (SportsEngine) is strictly for participants who are 18 years of age or older. No minors may independently register for league play.

TSPC does not knowingly collect personal information from children under 13 outside of a parent- or guardian-supervised family account. If we become aware that a child under 13 has independently provided personal information, we will promptly delete it.

3. What Personal Information We Collect

We collect personal information necessary to provide our services, process registrations and payments, communicate with you, and operate our facility safely and effectively.

3.1 Account and Identity Information

• Full legal name
• Date of birth
• Email address
• Phone number
• Home address and municipality
• Government-issued photo ID (required for adult league registration — collected via SportsEngine)

3.2 Health, Fitness, and Safety Information

This is sensitive data under PIPEDA and is subject to heightened protection.

• Health conditions and physical limitations relevant to participation
• Injury history where voluntarily disclosed during registration or waiver completion
• Fitness assessment data collected by TSPC instructors or programming partners
• Emergency contact name, relationship, and phone number

Emergency contact information is collected solely for the purpose of participant safety and will not be used for marketing or shared with third parties outside of an emergency situation.

3.3 Payment and Financial Information

• Credit and debit card information (processed and tokenized by Moneris — TSPC does not store raw card data)
• Billing address
• Transaction history (stored in QuickBooks for financial record-keeping)

TSPC never stores raw payment card data on our own systems. All payment processing is handled by Moneris Solutions Corporation, which operates in compliance with PCI-DSS (Payment Card Industry Data Security Standard). QuickBooks stores transactional records for accounting purposes only.

3.4 Media and Visual Content

• Profile photos voluntarily uploaded to your account
• Photos and video recordings taken during TSPC events, programs, leagues, and facility activities

Where TSPC captures or uses photos or video that identifies you, we will seek your consent either at account creation, via waiver, or at the point of capture. Separate consent is required for minors — guardian consent obtained at family account creation covers this unless you advise us otherwise.

You may request removal of identifiable photos or video of yourself (or your minor child) at any time by contacting info@turbosportsperformance.com.

3.5 Communication and Marketing Data

• Email address and communication preferences
• Email engagement data — open rates, click-through rates, link activity (via Omnisend and Google Workspace)
• Push notification preferences (via Xplore Recreation mobile app)
• CASL consent records — the date, method, and platform on which you consented to commercial communications

3.6 Platform Usage and Analytics Data

• IP address and approximate location (derived from IP, not GPS)
• Browser type, operating system, and device identifiers
• Pages visited on goturbo.ca, time spent, and navigation patterns
• Booking history, class attendance, and facility usage patterns via Xplore Recreation
• Social media interaction data (aggregated — see Section 7 for details)

3.7 Waiver and Legal Acknowledgment Data

When you create an account with TSPC through Xplore Recreation, you are required to accept our facility Terms and Conditions and Waiver of Liability as a condition of account activation. For adult league registration through SportsEngine, a separate waiver is required. We retain a record of:

• The date and version of the waiver or terms accepted
• The platform and mechanism by which acceptance was recorded
• Account-linked identity information at the time of signing

4. How We Collect Personal Information

4.1 Directly From You

• Account creation and registration on Xplore Recreation or SportsEngine
• Program, class, or event registration
• Waiver and terms acceptance
• Contact forms, waitlists, and inquiries on goturbo.ca
• In-person at the facility (front desk, POS transactions via Moneris)
• Verbal or written communication with TSPC staff

4.2 Automatically Through Technology

• Website cookies and similar tracking technologies on goturbo.ca
• Analytics tools including Google Analytics (see Section 6 — Cookies)
• Push notification system via Xplore Recreation mobile application
• Email analytics via Omnisend and Google Workspace (open and click tracking)

4.3 From Third Parties

• Social media platforms (Instagram, Facebook) — aggregated page and audience analytics
• SportsEngine — registration, team, and league data for adult participants
• Xplore Recreation — booking, membership, and program data

5. How We Use Your Personal Information

We use personal information only for the purposes for which it was collected, or for purposes that a reasonable person would consider appropriate in the circumstances.

5.1 Facility and Service Delivery

• Processing memberships, bookings, program registrations, and league sign-ups
• Managing family accounts and youth program participation
• Verifying identity for adult league participation
• Processing payments through Moneris at the facility POS and online
• Scheduling, waitlisting, and communicating service updates

5.2 Safety and Emergency Response

• Accessing emergency contact information in the event of an incident at the facility
• Reviewing health and limitation disclosures to ensure participant safety
• Complying with incident reporting obligations under Ontario law

5.3 Legal and Financial Compliance

• Maintaining financial records through QuickBooks as required by Canadian tax law
• Retaining waiver and consent records for liability and legal purposes
• Responding to regulatory inquiries or legal process

5.4 Communications

• Sending transactional communications — booking confirmations, receipts, schedule changes, account notices
• Sending marketing and promotional emails where you have provided CASL-compliant express or implied consent
• Sending league-related updates through SportsEngine
• Delivering push notifications through the Xplore Recreation app where you have opted in

You may withdraw consent to marketing communications at any time using the unsubscribe link in any email or by contacting info@turbosportsperformance.com. Withdrawal of marketing consent does not affect transactional communications required to deliver your booked services.

5.5 Facility Improvement and Analytics

• Understanding facility usage patterns to improve programming, staffing, and scheduling
• Analyzing website traffic and user behaviour to improve goturbo.ca
• Reviewing booking and membership trends for business planning

5.6 Marketing and Promotional Content

• Using photos and videos of facility activities for TSPC’s social media, website, and promotional materials, subject to consent
• Acknowledging sponsors and partners through league and facility channels

6. Cookies and Website Tracking

goturbo.ca uses cookies and similar tracking technologies to improve site functionality and understand how visitors use our website.

6.1 Types of Cookies We Use

• Strictly Necessary Cookies — required for the website to function (login sessions, form submissions)
• Analytics Cookies — used to understand traffic and user behaviour (e.g., Google Analytics)
• Marketing Cookies — used to track the effectiveness of advertising and social media campaigns

6.2 Your Choices

When you first visit goturbo.ca, you will be presented with a cookie consent banner. You may accept all cookies, accept only necessary cookies, or adjust your preferences. You may also manage cookies through your browser settings at any time. Disabling analytics or marketing cookies will not prevent you from using the site.

6.3 Google Analytics

We use Google Analytics to collect anonymized data about website traffic and user behaviour. This data is processed by Google LLC and subject to Google’s Privacy Policy. We do not use Google Analytics to collect personally identifiable information. You may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

7. Social Media

TSPC maintains active profiles on Instagram, Facebook, and other social media platforms. When you interact with our social media pages (following, liking, commenting, sharing), the platform collects data about that interaction subject to its own privacy policy.

TSPC receives aggregated analytics data from these platforms (reach, engagement, audience demographics) but does not receive individually identifiable data about specific users from the platforms themselves.

If you send TSPC a direct message through a social media platform, the content of that message is subject to the platform’s data practices as well as this Policy.

We are not responsible for the data practices of Instagram (Meta Platforms Inc.) or Facebook (Meta Platforms Inc.). We encourage you to review their privacy policies directly.

8. Third-Party Service Providers

TSPC works with the following third-party service providers who may process personal information on our behalf. These providers are engaged under contractual terms that require them to protect your information and use it only for the purposes we specify.

We do not sell your personal information to any third party. We do not share personal information with advertisers for the purpose of targeting you with advertising on external platforms.

9. Canada’s Anti-Spam Legislation (CASL)

TSPC complies fully with Canada’s Anti-Spam Legislation (CASL). Any commercial electronic message we send is sent only where we have obtained express or implied consent.

9.1 Express Consent

You provide express consent when you actively check a consent box during account creation, registration, or form submission, specifically agreeing to receive commercial communications from TSPC.

9.2 Implied Consent

Implied consent may exist where you have an existing business relationship with TSPC — for example, if you have purchased a membership, registered for a league, or made a booking within the past 24 months.

9.3 Withdrawing Consent

You may withdraw consent to commercial communications at any time by clicking the unsubscribe link in any marketing email, or by contacting us at info@turbosportsperformance.com. Unsubscribe requests are processed within 10 business days.

9.4 Record of Consent

TSPC maintains records of the date, method, and platform through which each subscriber’s consent was obtained, as required by CASL.

10. Data Retention

• Active member or participant data — retained for the duration of the relationship plus 7 years
• Waiver and consent records — retained for a minimum of 7 years from the date of signing
• Email subscriber records — retained while active; deleted within 90 days of an unsubscribe request
• Incident and emergency records — retained for a minimum of 7 years
• Financial transaction records — retained for 7 years as required under the Income Tax Act (Canada)
• Photos and video — retained until no longer required or until a removal request is fulfilled

Upon expiry of the retention period, personal information is securely deleted or anonymized.

11. Your Rights Under PIPEDA

• Right of Access — to request a copy of the personal information we hold about you
• Right to Correction — to request correction of inaccurate or incomplete information
• Right to Withdrawal of Consent — to withdraw consent to collection or use, subject to legal or contractual limitations
• Right to Complain — to file a complaint with the Office of the Privacy Commissioner of Canada

To exercise any of these rights, contact us at info@turbosportsperformance.com with your full name, the account email address, and a description of your request. We will respond within 30 days.

12. Security

TSPC takes reasonable technical and organizational measures to protect your personal information against unauthorized access, disclosure, loss, or destruction. These measures include:

• Encrypted transmission of data over public networks (TLS/SSL)
• Moneris tokenization for all payment card data
• Access controls limiting staff access to personal information on a need-to-know basis
• Use of established, enterprise-grade platforms with their own security frameworks

No method of electronic transmission or storage is 100% secure. In the event of a material data breach, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required by law.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email and post the updated Policy on goturbo.ca with a revised effective date.

14. Contact Us

Turbo Sports and Performance Centre Corp.
140 Mountain Road, Collingwood, Ontario, Canada
Email: info@turbosportsperformance.com
Website: goturbo.ca

If you are not satisfied with our response, you have the right to contact the Office of the Privacy Commissioner of Canada:
30 Victoria Street, Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Website: priv.gc.ca