PFEC Privacy Statement as at February 8, 2019
At Peel Family Education Centre, your trust is very important to us. This Privacy Statement (“Privacy Statement”) describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding our processing of your Personal Data.
A reference to “PFEC”, “we,” “us” or the “Company” is a reference to Peel Family Education Centre.
- Processing activities covered
This Privacy Statement applies to the processing of Personal Data collected by us when you:
- Visit our website that displays or links to this Privacy Statement;
- Visit our branded social media pages;
- Visit our offices;
- Receive communications from us, including emails, phone calls, texts or fax;
- Register for our events, webinars or contests; or
- Participate in community and open source development.
Our website may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which we encourage you to review to better understand those third parties’ privacy practices.
- Responsible Salesforce entity
PFEC is the controller of your Personal Data as described in this Privacy Statement, unless expressly specified otherwise.
What Personal Data do we collect?
3. Personal Data we collect directly from you
The Personal Data that we collect directly from you includes the following:
- If you express an interest in obtaining additional information about our services, request customer support, use our “Contact Us” or similar features, register to use our website, sign up for an event, webinar, volunteer or membership, or download certain content, we may require that you provide to us your contact information, such as your name, address, phone number, email address or username and password;
- If you complete a course, we may request socio-demographic data
- If you register for an online community that we host, we may ask you to provide a username, photo and/or biographical information, such as your occupation, social media profiles, company name and areas of expertise;
- If you use and interact with our website, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data (please see the “What device and usage data we process” section, below); and
- If you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
If you provide to us or to our service providers any Personal Data relating to other individuals, you represent that you have the authority to do so and permit us to use the Personal Data in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information in the “Contacting us” section, below.
- What device and usage data we process
We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information that may contain Personal Data from your computer or mobile device as you navigate our websites or interact with emails we have sent to you.
4.1 Log Files
As is true of most websites, we gather certain information automatically via log files. This information may include your IP address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into our services as part of our security features.
4.2 Cookies, web beacons and other tracking technologies
We use cookies and similar technologies such as web beacons, tags and JavaScript alone or in conjunction with cookies to compile information about the usage of our websites and interaction with emails from us.
When you visit our websites, we or an authorized third party may place a cookie on your browser, which cookie collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track overall usage, determine your browsing preferences and improve and customize your browsing experience.
We use both session-based and persistent cookies. Session-based cookies exist only during one session and disappear from your computer when you close your browser or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but choosing to disable cookies may limit your use of certain features or functions on our websites and services.
We also use web beacons on our websites and in email communications. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. Such technologies are used to operate and improve our websites and email communications.
4.3 Opt-Out from the collection of device and usage data
You may opt-out from the collection of device and usage data (see the “What device and usage data we process” section, above) by managing your cookies at the individual browser level. In addition, if you wish to opt-out of interest-based advertising please click the UNSUBSCRIBE button in any sales emails that are sent to you. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the website.
4.4 Social Media Features
Our website and learning management system may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks, the latter may receive information that you have visited our website from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our website with your social media profile.
We also allow you to log in to certain of our website using sign-in services such as Facebook Connect. These services will authenticate your identity and provide you the option to share certain Personal Data with us such as your name and email address to pre-populate our sign-up form.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.
4.5 Telephone log information
If you use certain features of our services on a mobile device, we may also collect telephone log information (like phone numbers, time and date of calls, duration of calls, SMS routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language), and location information (through IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers).
- Purposes for which we process Personal Data and the legal basis on which we rely
We collect and process your Personal Data for the purposes and on the legal bases identified in the following:
- Providing our website: We process your Personal Data to perform our contract with you for the use of our website and to fulfill our obligations under applicable terms of use/service; where we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our website and to provide you with content you access and request (e.g., to download content from our website);
- Promoting security of our websites: We process your Personal Data by tracking use of our websites, creating aggregated, non-personal data, verifying accounts and activity, investigating suspicious activity and enforcing our terms and policies, to the extent this is necessary for our legitimate interest in promoting the safety and security of the systems and applications used for our websites and in protecting our rights and the rights of others;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
- Handling contact and user support requests: If you fill out a “Contact Me”, “volunteer” or “donation” web form or request user support, or if you contact us by other means, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
- Managing event registrations and attendance: We process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you, to perform of our contract with you;
- Developing and improving our websites: We process your Personal Data to analyze trends and to track your usage of our websites and interactions with our emails to the extent it is necessary for our legitimate interest in developing and improving our website and providing our users with more relevant and interesting content;
- Registering office visitors: We process your Personal Data for security reasons, to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our offices and our confidential information against unauthorized access.
- Displaying personalized advertisements and content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent (please see the “Your rights relating to your Personal Data” section, below, to learn how you can control how the processing of your Personal Data for personalized advertising purposes);
- Sending marketing communications: We will process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the “Your rights relating to your Personal Data” section, below, to learn how you can control the processing of your Personal Data for marketing purposes);
- Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our website or learning management system, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.
Where we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
- Who do we share Personal Data with?
We may share your Personal Data as follows:
- With our contracted service providers, who provide services such as IT and system administration and hosting, as well as other service agencies that you/they request (upon your approval) we share information with (other family service providers) for the purposes to the legal bases described above; such service providers will all be located in Canada.
- With our funders where required. Generally, our funding reports are generic and do not reflect the personal information of users. The aggregated data of all users will be presented to funders.
- If you use our websites to register for an event or webinar organized by one of our affiliates, with the affiliate to the extent this is required on the basis of the affiliate’s contract with you to process your registration and ensure your participation in the event; in such instances, our affiliate will process the relevant Personal Data as a separate controller and will provide you with further information on the processing of your Personal Data, where required. Such companies include Mailchimp, PayPal, Google Analytics, StatCounter.
- If you attend an event or webinar organized by us, or download or access an asset on our website, with sponsors of the event. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. If you do not wish for your information to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 10 below;
- With third-party social media networks, advertising networks and websites, which usually act as separate controllers, so that we can market and advertise on third party platforms and websites;
- In individual instances, with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
Any Personal Data or other information you choose to submit in communities, forums, blogs or chat rooms on our website or learning management system may be read, collected and used by others who visit these forums, depending on your account settings.
For further information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section, below.
7. Children
Our website is not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section, below, and we will take steps to delete such Personal Data from our systems.
8. How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data and the legal bases on which we rely” section, above). We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
For further information on applicable data retention periods, please contact us by using the information in the “Contacting us” section, below.
9 Your rights relating to your Personal Data
9.1 Your rights
You have certain rights relating to your Personal Data, subject to local data protection laws. To access your Personal Data held by us (right to access);
- To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
- To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
- To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
- To transfer your Personal Data to another controller, to the extent possible (right to data portability);
- To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
- Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our websites; and
- To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
At any time, you may ask us to remove content or information that you have posted to our website or learning management system. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been re-posted by another visitor to our website or learning management system.
9.2 How to exercise your rights
To exercise your rights, please contact us by using the information in the “Contacting us” section, below. We try to respond to all legitimate requests within two weeks and will contact you if we need additional information from you in order to honor your request.
Some registered users may update their user settings, profiles, settings and event registrations by logging into their accounts and editing their settings or profiles.
To discontinue your account and/or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contacting us” section, below.
9.3 Your preferences for email and SMS marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our marketing emails, by replying or texting ‘STOP’ if you receive SMS communications or by turning off push notifications on our apps on your device. Additionally, you may contact us using the information in the “Contacting us” section, below. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.
10. Security
We take precautions including organizational, technical and physical measures to help safeguard against the accidental or unlawful destruction, loss, alteration and unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of our website and learning management system after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting us” section, below.
11. Changes to this Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements and other factors. If we do, we will update the “effective date” at the top of this Privacy Statement. If we make an update, we may provide you with notice prior to the update taking effect, such as by posting a notice on our website or by contacting you using the email address you provided.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.
12. Contacting us
To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please e-mail us at:
admin@familyedcentre.org
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.