1. Policy on Privacy of Personal Information
Our policies and practices have been designed to comply with the Personal Information Protection and Electronic Documents Act (Canada) and corresponding provincial privacy acts.
2. What is personal information?
Personal information is information that refers to an individual specifically and is recorded in any form. Personal information includes such things as age, income, date of birth, contact information and credit records.
3. We are accountable to you
4. We let you know why we collect and use your personal information
FCI identifies the purpose for which your personal information is collected and will be used or disclosed. If that purpose is not listed below we will do this before or at the time the information is actually being collected. You will be deemed to consent to our use of your personal information for the purposes of:
- communicating with you generally;
- processing your donations;
- processing and keeping track of donations and reporting back to you;
- protecting against fraud or error;
- providing services requested by you;
- identifying your needs and/or preferences;
- performing statistical analyses of user behaviour and characteristics, in order to measure interest in and use of the various sections of this site so as to improve design and navigation and to gather marketing information (only aggregated data from these analyses, not individual data, will be used for this purpose);
- administering and managing our business operations;
- complying with legal and governmental requirements; and/or
- fulfilling any other purpose that would be reasonably apparent to the average person at the time we collect it from you.
Otherwise, FCI will obtain your express consent (by verbal, written or electronic agreement) to collect, use or disclose your personal information. You can change your consent preferences at any time by contacting FCI (please refer to the “How to contact us” section below), where our employees can help direct your call to the appropriate department within FCI.
5. We limit collection of your personal information
We receive and store any information you enter on the changeitcanada.com website or other websites owned and operated by FCI (collectively, the “Websites”) or give us in any other way. You can choose not to provide certain information.
We also receive and store certain types of information whenever you interact with us. For example, like many websites, we obtain certain types of information when your web browser accesses a Website.
FCI employs software programs that monitor network traffic. These programs record the Internet Protocol (“IP”) addresses of computers, mobile and other devices that visit the Websites. They also may record the date and time of visits, the pages viewed, and the browsers and operating systems used by visitors. We do not attempt to link this information to the identities of individual users, unless an attempt to damage the Websites has been detected.
Portions of the Websites use statistical tools that may be operated by third party providers (collectively, the “Analytical Tools”). The Analytical Tools may use “cookies” and/or web beacons. A cookie is a small piece of information that a website transfers to the hard drive of a visitor’s computer for record-keeping purposes. A web beacon, also known as a "clear GIF" (a common format for image files), is an invisible file located on web pages that you visit. They are often used in combination with a cookie to track navigation of a website. If you visit a page on the Website that contains a web beacon, it communicates with your computer to determine, among other things, whether you have been to that page before or viewed a particular advertisement.
A cookie is used to help a website distinguish a user's browser as a previous visitor and thus save and remember any preferences that may have been set while the user was browsing that website. Cookies do not contain information that identifies you personally.
The information generated by the cookies and/or web beacons about your use of the Website (including your IP address) will be transmitted to and stored on servers located outside of Canada including, but not limited to, the United States, by the applicable third party provider of an Analytical Tool. This information will be used for the purpose of evaluating your use of a Website, compiling reports on the activities of a Website and providing other services relating to Website activity and Internet usage. The third party providers of Analytical Tools may also transfer this information to other third parties where they are required to do so by law, or where such third parties process the information on their behalf. By using a Website, you consent to the processing of data about you by third party providers of Analytical Tools in the manner and for the purposes set out above.
6. Collection and Disclosure of Information in the Donation Process
You have the right to choose not to share that information with the charity to which you make the donation. By selecting the option to donate anonymously, your personal information will not be viewable by the charity you donated to. [The only information accessible will be donation date, time, amount, and the type of credit card used.]
7. We limit disclosure and retention of your personal information
- during the course of your donation, your credit card information is processed by credit card providers
- we may use service providers located outside of Canada, and, if applicable, your personal information may be processed and stored in other countries and therefore may be subject to disclosure under the laws of those countries;
- in the unlikely event that FCI or substantially all of its assets are acquired, customer information of course will be one of the transferred assets;
- as described elsewhere in this privacy notice; and/or
- where we otherwise have your explicit consent.
You are deemed to consent to disclosure of your personal information for those purposes. If your personal information is shared with third parties, those third parties are bound by appropriate agreements with FCI to secure and protect the confidentiality of your personal information.
FCI retains your personal information only as long as it is required for our relationship or as required by federal and provincial laws.
8. We keep your personal information up to date and accurate
You may request access to the personal information we have on record in order to review and amend the information, as appropriate. In circumstances where your personal information has been provided by a third party, we will refer you to that party. To access your personal information, refer to the “How to contact us” section below.
9. The security of your personal information is a priority for FCI
- physical security measures such as restricted access facilities and locked filing cabinets;
- electronic security measures for computerized personal information such as password protection, database encryption and personal identification numbers. We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you enter;
- revealing only the last five digits of your credit card numbers and only the last four digits of your debit card numbers when confirming a donations. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing;
- organizational processes such as limiting access to your personal information to a selected group of individuals; and
- contractual obligations with third parties who need access to your personal information requiring them to protect and secure your personal information.
It is important for you to protect against unauthorized access to your password and your computer. Be sure to sign off when you have finished using any shared computer.
10. What About Links to Other Websites?
11. We are open about our privacy and security policy
12. We provide access to your personal information stored by FCI
- inform you about what type of personal information we have on record or in our control, how it is used and to whom it may have been disclosed
- provide you with access to your information so you can review and verify the accuracy and completeness and request changes to the information
- make any necessary updates to your personal information.
13. We respond to your questions, concerns and complaints about privacy
14. How to contact us
- by clicking the Live Chat link at the bottom of this page.
- by clicking on the Send Us a Message link at the bottom of this page.
- by mailing us at Formulating Change Inc., 151 Charles Street, Suite 180, Kitchener, Ontario, Canada, N2G 1H6, attention: Privacy Officer
Our business changes constantly and this privacy notice will change also. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, but you should check our website frequently to see recent changes. We are, however, committed to protecting your information and will never materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.
15. What information do we collect from you during a live chat session?
When the online customer service chat first begins, you may be asked to enter your name or other personal information to facilitate service. By providing such personal information, you consent to LivePerson, the service provider, collecting and processing such personal information on behalf of itself or its customers. Also, during the chat, you will enter into a live question and answer session with an operator. LivePerson and FCI maintain dialogue transcripts of these chats. After the chat, FCI customer service agents may ask you to fill out an exit survey in order to obtain valuable feedback. Filling out the exit survey is completely voluntary. The surveys may ask for contact information (e.g., email address) and for demographic information (e.g., zip code, age or income level). The surveys vary by end user so that FCI may obtain feedback specific to its website and business, as well as feedback regarding LivePerson’s service.
LivePerson logs browser information (e.g., Internet Protocol addresses and browser types) to help diagnose problems with its server, gather broad demographic information and administer its site. By choosing to engage in a chat and use the services, you consent to such logging and processing of IP address.
16. Does LivePerson disclose my information to third parties?
LivePerson accesses the information it collects for certain purposes including, but not limited to, the following: to provide maintenance, support or professional services to FCI, to aggregate the information, to monitor the use of the service during certain chats and for other lawful purposes.
Your information contained in the dialogue transcripts and the exit surveys may be shared with FCI, on whose website you accessed the live chat service. Furthermore, such information may be shared with others on an aggregate basis. Personally identifiable information related to you (supplied voluntarily during the chat or in the exit survey) will not be shared by LivePerson with parties other than the FCI, except as required by law.
We do not sell, trade or rent the personally identifiable information that you provide.
17. How does LivePerson protect my information?
LivePerson’s site has security measures in place to protect the loss, misuse and alteration of the information under their control. It offers secure sessions for chats so that data passed between you and operators cannot be decrypted. To achieve this level of security, we use Secure Socket Layer (SSL) encryption that encodes information as it is being sent over the Internet between you and the operator. All chats and user data are maintained and archived on secure servers. Access to stored data is password protected and passwords are account-specific. Therefore, no LivePerson customer can view data for another LivePerson customer. LivePerson also uses appropriate firewall technology within its facility to prevent unauthorized access. For another level of protection, all data is backed up daily, and archives are stored off-site in a secure location.
18. What about cookies?
19. Opt-Out Policy
20. Safe Harbor
21. Business Transfers
22. In summary
Last updated: Oct 1, 2012