(Last updated: May 16, 2022)
1. WHO WE ARE AND WHAT WE DO
Project Sunflower Aid Society is an incorporated Society in the Province of Alberta. We also provide a variety of services to facilitate the resettlement of those affected by the Ukraine crisis.
Project Sunflower Aid Society collects and processes personal information through the following areas of operations:
Our website for donors offers a user-friendly way for individuals to donate or fundraise in support of resettlement. Project Sunflower Aid Society collects and processes the donor’s personal information submitted through the Website. At the donor’s express request, Project Sunflower Aid Society may also disclose personal information about its individual donors to the charities they support.
All donations made through our tools and are made directly to Project Sunflower Aid Society (who is not a registered Canadian Charity and cannot offer tax receipts). We have terms in place to ensure transparency to individuals using services in regards to the role of Project Sunflower Aid Society and any associated fees.
2. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
Personal information means any information about an individual from which that person can be identified. It does not include personal information where all references to the identity of the relevant individual have been removed (anonymous 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 Project Sunflower Aid Society (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 to you (refunds) and from you (donations) and purchase of products (including a Charity gift card).
Technical Personal information includes internet protocol (IP) address, your login personal 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 our third parties and your communication preferences.
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.
This website is not intended for children under the age of 18 and we do not knowingly collect personal information relating to children.
3. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We use different methods to collect personal information from and about you including through:
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 personal information you provide when you:
Sign-up for an account and update your account;
Make a donation (including one-time gifts, recurring gifts, gifts of securities, and donations made to purchase a charity gift card) and receive a tax receipt, if applicable;
Subscribe to our educational services or publications or to contact us or provide feedback;
Request marketing to be sent to you; or
Give us feedback or contact us.
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.
Third parties or publicly available sources. We will receive personal information about you from various third parties as set out below:
Technical Personal information from:
analytics providers such as Google Analytics;
digital marketing service platforms such as MailChimp, Sprout Social and Hootsuite;
advertising networks such as Google Adwords, DoubleClick, 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 use of our site (including the performance of our ads) and to retarget ads.
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.
4. 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 needed to perform the service you are requesting.
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 Canada’s Antispam Legislation (CASL) applies to Project Sunflower Aid Society’ communications with users, donors or volunteers, Project Sunflower Aid Society is committed to complying with CASL and, in particular, the provisions setting out the requirements for sending commercial electronic messages
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.
We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
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. If you are receiving marketing messages from another charity to which you made a donation through our Website and you no longer wish to receive such messages, then you should contact that charity to make this request.
Where you opt out of receiving these marketing messages, we may continue to use your personal information in order to provide you with the services you have requested from us.
Where our use of your personal information requires your consent, you can provide such consent:
at the time we collect your personal information following the instructions provided; or
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.
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.
5. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
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.
6. INTERNATIONAL TRANSFERS
By providing us with Personal information, you acknowledge and agree that your Personal information may be processed in other countries, including the United States, where laws regarding processing of Personal information may be less stringent than the laws in your country. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the Personal information. This will include putting appropriate contractual safeguards in place to ensure an adequate level of protection for the Personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal information out of Canada.
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:
improper use or disclosure;
unauthorised 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 Site and all users of our Services.
We have put in place procedures to deal with any suspected personal information breach and 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 anonymise 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
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.
Your right to rectification
If the Personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your Personal information with others, we’ll let them know about the rectification where possible and where this would not involve 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.
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 possible and where this would not involve disproportionate effort. 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.
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.
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.
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.
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.
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.
Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of Project Sunflower Aid Society’ 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, Project Sunflower Aid Society is the “data controller” and is responsible for your personal information.
Telephone number: 1-587-327-6020
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.
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