Last Revised, September 2015
Up With Women’s commitment to Privacy
Up With Women knows that people care about how their information is used and shared. To better protect one’s privacy, we have included this Privacy Notice to explain our information practices as well as our online identification practices. This document will also make individuals aware of the choices and the rights they have with regards to the way their information is used. By visiting www.upwithwomen.org, an individual accepts the information practices described in this Privacy Notice.
What an individual needs to know
In order to collect Personal Information online, we need an individual’s consent. When an individual sends their Personal Information to us through, for example, our online application, our Event page, or by leaving a comment, etc. they are giving us consent to collect and use that Personal Information. If an individual feels uncomfortable giving us Personal Information through one of these electronic methods, they can still inquire about Up With Women by emailing us directly through our Contact Us page.
This Privacy Notice is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and the regulations thereunder as amended from time to time.
Collection and using an individual’s Information
What is Personal Information?
“Personal Information” is any information that relates to an identifiable individual. Personal Information may include, but is not limited to, an individual’s name, mailing address, phone number, email address, business facsimile number, credit card number, Social Insurance Number, personal income, banking information, and creditor information. Personal Information, however, does not include the name, business title or business address and business telephone number in a person’s capacity as an employee of Up With Women.
How do we collect Personal Information?
We will always collect Personal Information by lawful means (for example, when an individual makes an application to participate in one of our programs, or participates in our events, use our website or speaks to an Up With Women representative). We collect Personal Information from individuals and from third party service providers, where we have obtained consent to do so or where we are otherwise permitted by law to do so.
What information is collected automatically?
We receive and store certain types of information when an individual interacts with our websites, emails, and online advertising. Our purpose in collecting this information is to allow the websites to work correctly, to evaluate use of the website, and to support website analytics and marketing campaigns. Some examples include:
- Collecting technical information such as a person’s internet protocol address, that person’s computer’s operating system and browser type, the address of a referring website, if any, and the path taken through our web pages.
- Collecting and using “cookies” to recognize an individual as they use or return to our sites. This may be done so that we can provide a continuous and more seamless online experience. A cookie is a small text file that a website or email may save to an individual’s browser and store on that individual’s hard drive to record which websites an individual has visited.
- Collecting and using web beacons. Beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our website and other sites were effective.
How Personal Information is used?
We identify the purposes for which we use Personal Information at the time we collect such information and obtain consent, in any case, prior to such use. In addition to uses permitted or required by law, we generally use Personal Information for the following purposes (the “Purposes”):
- to process a submitted application;
- to build relationships, facilitate networking opportunities and match clients with coaches, advisors or mentors;
- to assist with administrative or technical support;
- to gather opinions and feedback through surveys;
- to use in solicitations for fundraising;
- to include an individual on our mailing list;
- to process a submitted application for volunteer, employment or other opportunities, as the case may be, and
- other consistent uses that individuals might reasonably have expected at the time of collection (e.g. quality control ).
Employees, volunteers and contractors should only access personal information if the discharge of their duties reasonably require it.
What about Personal Information belonging to children?
We are committed to protecting children’s online privacy. Our website is a general audience website not geared towards children. In order to protect the privacy of children, Up With Women’s websites do not knowingly collect Personal Information from children under the age of 13 without prior, parental consent. Please contact us via the “Contact Us” section of this policy if you believe we may have collected information from your child and we will work to delete it.
How long do we use, keep, and share Personal Information
We may keep a record of an individual’s Personal Information, correspondence or comments in a file specific to that individual. We will use, disclose or retain Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.
Storing, protecting and sharing Personal Information
Where is Personal Information stored?
We will keep the Personal Information that we collect at our offices in Toronto, Ontario and Up With Women Regional Offices. Our service providers may, from time to time, also hold an individual’s Personal Information in connection with purposes for which that person provided consent.
In addition, we may send Personal Information outside of the country for the purposes set out above, including for process and storage by service providers in connection with such purposes, and it should be noted that while such information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
How is Personal Information protected?
We have implemented physical, organizational, contractual and technological security measures to protect Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
Who do we share Personal Information with?
We identify to whom, and for what purposes, we disclose Personal Information, at the time we collect such information from an individual and obtain consent to such disclosure. We will share Personal Information with partners including a client’s referring agency.
For example, we may disclose Personal Information to third party service providers with whom we have a contractual agreements that includes appropriate privacy standards, where such third parties are assisting us with the Purposes — for example, service providers may be used to provide telephone support, notify an individual of any special opportunities, and data storage.
We will only make disclosures of Personal Information to such persons for which an individual provides consent. Notwithstanding the foregoing, we may also make disclosures of Personal Information to a potential partner in connection with a merger or consolidation of Up With Women’s organization, or as otherwise permitted or required by law.
How do we ensure the privacy of Personal Information with third parties?
Obtaining consent for Personal Information
When and how do we obtain consent?
We obtain consent prior to collecting, and in any case, prior to using or disclosing Personal Information for any purpose. A person may provide consent to us either orally, electronically (by using this website or submitting Personal Information via the website) or in writing.
Accessing and updating Personal Information that we have collected
How can an individual review their Personal Information that we have collected?
If an individual makes a written request to access any Personal Information about them that we have collected, utilized or disclosed, we will endeavour to provide that person with any such Personal Information to the extent required by law. We will make such Personal Information available to that individual in a form that is generally understandable, and will explain any abbreviations or codes.
What if an individual’s Personal Information changes?
We will ensure that Personal Information is kept as accurate, complete and up-to-date as necessary for the purpose for which it was collected. We expect individuals, from time to time, to supply us with written updates to their Personal Information, when required.
At any time, a person can confirm the accuracy or completeness of their Personal Information in our records. If they successfully demonstrate that their Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. After accessing your information, if you wish to correct information that Up With Women stores about you, you are welcome to contact the [Executive Director, Lia Grimanis through the contact page] to make such a request. Where appropriate, we will transmit the amended information to third parties (ie. referral agencies, coaches, advisors, etc) having access to your Personal Information.
How long does it take to receive Personal Information?
We will attempt to respond to each written request for access to Personal Information not later than thirty (30) days after receipt of such requests. We will advise in writing if we cannot meet a request within this time limit. An individual has the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.
Does it cost anything to receive Personal Information?
How do we confirm an individual’s identity in that individual’s written request?
We may request that an individual provide sufficient identification (e.g. government-issues or photo identification) to permit access to the existence, use or disclosure of that individual’s Personal Information. Any such identifying information shall be used only for this purpose.
Contacting us about Personal Information
Who to contact when requesting either Personal Information or inquiring about Up With Women’s privacy practices?
Up With Women
75 Silverbirch Ave
Toronto ON, M4E 3L2