PRIVACYPOLICY

PRIVACY POLICY

1. PURPOSE AND SCOPE

Can Praxis EAL (“Can Praxis”) respects your privacy and is committed to protecting your personal information. This privacy policy contains information on how we collect and manage your personal information when you visit our website at canpraxis.com (the “Website”) and provides information about your privacy rights and how this policy complies with the Personal Information Protection Act 2003 c P-6.5 (the “Act”). By submitting personal information to Can Praxis or its service providers and agents (collectively referred to as Can Praxis, “we”, “us” or “our” in the Privacy Policy), you agree that we may collect, use and disclose such personal information in accordance with this Privacy Policy and as permitted or required by law. Subject to any applicable legal or contractual requirements, you may refuse or withdraw your consent to one or more identified purposes at any time by contacting us. If you refuse or withdraw your consent, we may not be able to provide you, or continue to provide you, with certain services or information.

2. COLLECTION OF YOUR PERSONAL INFORMATION

Can Praxis is a registered Canadian charity. We provide mental health programming and engage in a variety of services to facilitate fundraising in Canada. Can Praxis collects and processes personal information through:

• our website for donors, which offers a user-friendly way for individuals to donate to Can Praxis; and
• the use of software tools and online payment processing technologies to collect donations and launch fundraising events online.

3. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

Personal information means any information about an identifiable individual. It does not include personal information where all references to the identity of the relevant individual have been removed (anonymous personal information). Personal information that Can Praxis collects includes both personal information you provide as well as automatically gathered personal information. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

• Identity Personal information includes:
  • username or similar identifier,
  • first name, last name, title, company you work for, and in the case of individuals representing charities using our service, your job title, role and/ or level of experience.
• Contact Personal information includes address, email address and telephone numbers.
  • Financial Personal information includes bank account, credit card details and securities-related information in the event you donate securities or mutual funds to Can Praxis (including your mutual fund or security name, number of units, investment firm, account number, financial advisor name, email, phone number.
• Transaction Personal information includes details about payments from you and the purchase of products.
• Technical Personal information includes internet protocol (IP) address, your personal login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Profile Personal information includes your username and password, donations made by you, your interests, preferences, surveys, and feedback.
• Usage Personal information includes information about how you use our Website and our Services.
• Marketing and Communications Personal information includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated personal information such as statistical or demographic information. When information is aggregated and not “about an identifiable individual”, the information is not personal information for the purposes of the Act. For example, we may aggregate your Personal Usage information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated personal information with identifiable data so that it can directly or indirectly identify you, we treat the combined information as personal information, which will only be used in accordance with this Privacy Policy and the Act. We do not collect any Special Categories of Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric information). Nor do we collect any information about criminal convictions and offences. If you provide Can Praxis with personal information of another individual, you represent that you have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy. This Website is not intended for children under the age of 18 and we do not knowingly collect personal information relating to children.

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect personal information from and about you, including through:

1. Direct interactions. You may give us your Identity, Contact, Transaction and Financial Personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal information you provide when you:
   1. make a donation (including one-time gifts, recurring gifts, gifts of securities, and receive a tax receipt, if applicable;
   2. subscribe to our publications or to contact us or provide feedback;
   3. request marketing to be sent to you; or
   4. give us feedback or contact us.
2. Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Personal information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Personal information about you if you visit other websites employing our cookies. 
3. Third parties or publicly available sources. We will receive personal information about you from various third parties as set out below (the “Parties”):
   1. Technical Personal information from:
      1. analytics providers such as Google Analytics and Kindful;
      2. digital marketing service platforms such as MailChimp, Hootsuite, and WordPress;
      3. advertising networks such as Google Adwords, DoubleClick, Instagram, Facebook and Twitter. We use unique tracking codes in our emails and pixels on our Website to allow us to share your technical information with such providers to track the use of our Website (including the performance of our ads) and to retarget ads.
4. Contact, Financial and Transaction Personal information from providers of technical, payment processing and delivery services. Securities or mutual fund donations are processed by our broker.
5. Cookies. Like many websites, Can Praxis uses “cookies” to track user activity on the Website. A cookie is a commonly used piece of software that tracks user activity on the Website and is capable of enhancing your visit to the site. Cookies enable our Website to save and retrieve information that you enter (for example, user language preference). Cookies may remain on your computer after you leave the Website (until the cookie expires or is deleted by you). You can disable cookies by adjusting the settings on your internet browser; however, disabling cookies may affect your ability to access some pages on the Website.

5. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where you consent to such collection and use, such as by consenting to this Privacy Policy.
• Where we need to comply with a legal obligation.

Note that we may process your Personal information for more than one lawful basis depending on the specific purpose for which we are using your personal information. Please contact us if you need details about the specific legal ground we are relying on to process your Personal information where more than one ground has been set out in the table below. We have set out below a description of all the ways we plan to use your personal information, and the types of personal information required in the context. We have also identified our interests where appropriate.

(a) Purposes for which we will use your personal information:

Donations

To make a donation, including one-time and monthly monetary donations, and donations of securities and mutual funds and receive a charitable tax receipt, if applicable, CanPraxis requires the following types of personal information:

a) Identity

b) Contact

c) Financial

d) Transaction

Our interests include the performance of a contract with you (e.g. facilitating your donation according to your directive), and to recover sums due to us. We share your Financial personal information only with our third-party payment processor or broker, depending upon the type of donation. If you make a donation through a page created by a Team or Individual to fundraise for charity, we share your name and email with page owner so they can thank you for your contribution; we only share your name, donation amount and/or message to the fundraiser publicly on the page if you provide us explicit consent to do so.

Educational services and publications

To subscribe to our educational services or publications; to contact us or provide us feedback; to participate in a survey CanPraxis requires the following types of personal information:

a) Identity

b) Contact

c) Profile

This information is necessary to fulfil the performance of a contract with you, and for marketing purposes.

Marketing Programs

To improve the performance of our marketing programs, and to deliver relevant content and advertisements to serve you better and grow charitable giving CanPraxis requires the following types of personal information:

a) Identity

b) Contact

c) Profile

d) Usage

e) Marketing and Communications

f) Technical

This information is necessary to ensure that we provide the very best services to you. We share your personal information with a variety of third party analytics and digital marketing service providers to assist us with these activities such as Google Analytics, SproutSocial, Google Adwords, MailChimp, Instagram and Facebook.

Website and Charity Protection

To administer and protect our charity and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) CanPraxis requires the following types of personal information:

a) Identity

b) Contact

c) Technical

This information is necessary for running our business, provision of administration and IT services, network security and to prevent fraud. This information is also necessary to comply with a legal obligation.

Marketing

1. We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
2. We may use your Identity, Contact, Technical, Usage and Profile Personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services may be relevant for you.
3. Where Canada’s Antispam Legislation (CASL) applies to Can Praxis communications with users, donors or volunteers. Can Praxis is committed to complying with CASL and, in particular, the provisions setting out the requirements for sending commercial electronic messages.
4. You will receive marketing communications from us if you have requested information from us or made a donation to us, and you have not opted out of receiving that marketing.
5. We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
6. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
7. Where you opt-out of receiving these marketing messages, we may continue to use your personal information to provide you with the services you have requested from us.
8. Where our use of your personal information requires your consent, you can provide such consent:
   1. at the time we collect your personal information following the instructions provided; or
   2. by informing us by email, post or phone using the contact details set out in this Privacy Policy; or
   3. by registration through our Website.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or request your consent as appropriate.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may share your personal information with the parties. Parties set out above for the purposes set out under Item 4, Purposes for which we will use your personal information in this Privacy Policy. We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

7. HOW DO WE PROTECT THE CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION?

We are committed to keeping the personal information provided to us secure, and we will take reasonable precautions to protect personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures that are intended to protect the personal information that we have under our control from:

• unauthorized access;
• improper use or disclosure;
• unauthorized modification; and
• unlawful destruction or accidental loss.

All of our members, employees, workers and personal information processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with, the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Website and all users of our services. We have put in place procedures to deal with any suspected personal information breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

8. HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?

We will only retain your Personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In some circumstances, you can ask us to delete your personal information: see your legal rights Section below for further information. In some circumstances, we will anonymize your Personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

The vast majority of our donors and Website users are Canadians, therefore this Privacy Policy was drafted to help ensure compliance with applicable Canadian law. However, we have noted that (although we do not target our services to EU data subjects) some of our individual donors are from outside of Canada, including from the European Economic Area (“EEA”). For the benefit of such users, we also endeavour to provide adequate protection for the personal data of EU data subjects in accordance with applicable EU data protection laws and regulations, including the EU General Data Protection Regulation. Subject to certain exemptions, you have the following rights in relation to the Personal information we hold about you:

1. Your right of access. If you ask us, we’ll confirm whether we’re processing your Personal Information and, subject to any applicable exemptions, provide you with a copy of that Personal information within the timescales provided for by law. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. If you require additional copies, we may need to charge a reasonable fee.

2. Your right to correction. If the Personal information we hold about you is inaccurate or incomplete, you’re entitled to have it corrected. If you are entitled to correction and if we’ve shared your Personal Information with others, we’ll let them know about the correction where possible, and where this would not involve a disproportionate effort. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your Personal information with so that you can contact them directly.

3. Your right to erasure. You can ask us to delete or remove your Personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your Personal information). If you are entitled to erasure and if we’ve shared your Personal information with others, we’ll take reasonable steps to inform those others. Where it is possible and lawful for us to do so, if you ask us, we will tell you who we’ve shared your personal information with so that you can contact them directly.

4. Your right to restrict processing. You can ask us to “block” or suppress the processing of your Personal Information in certain circumstances such as where you contest the accuracy of that Personal information or you object to us. If you are entitled to restriction and if we’ve shared your Personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your Personal information with so that you can contact them directly.

5. Your right to personal information portability. You have the right, in certain circumstances, to obtain Personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

6. Your right to object. You can ask us to stop processing your Personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your Personal information, except if we can demonstrate compelling legal grounds for the processing; or
• processing your Personal information for direct marketing.

7. Your rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

8. Your right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your Personal information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

9. Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of CanPraxis’ privacy practices, including the way we’ve handled your Personal information, you can report it to the relevant supervisory authority.

10. CONTACTING US

For the benefit of EU data subjects, Can Praxis is the “data controller” and is responsible for your personal information. We have appointed a privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our privacy manager using the details set out below. If you have any questions about this Privacy Policy or our privacy practices, please contact our privacy manager in the following ways – Can Praxis (Attn. Chief Privacy Officer):

• Mail: P. O. Box 10, Torrington, Alberta, T0M 2B0
• Phone: 403-631-2489
• Email: steve@canpraxis.com

You have the right to make a complaint at any time to the relevant supervisory authority for personal information protection issues. In Canada, you can contact the Office of the Privacy Commissioner of Canada (“OPC”), see: https://www.priv.gc.ca/en/contact-the-opc/. EU data subjects can contact their relevant data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

(i) Links to other websites

This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Policy of every Website you visit.

(ii) Changes

Can Praxis reserves the right to modify or supplement this Privacy Policy at any time. If any changes are made to this Privacy Policy, a copy of the Privacy Policy as amended will be posted on our Website as soon as practicable following that update. Your continued use of the Website following such posting will signify your consent to its revised terms.