Last Revision: Febbruary 1, 2021
The application of this Policy is subject to applicable laws, including legislation, regulations and the orders or lawful requests of any courts or legal authorities.
Personal information we collect
For the purpose of this Policy, “Personal Information” means any information, recorded in any form, about an identifiable individual, or an individual whose identity may be inferred or determined from such information, that can be used on its own or with other information to identify, contact or locate a single person, but does not include your name, title or information that is publically available, such as business contact information or information found in a telephone directory.
We collect our Website User’s Personal Information in order to effectively provide our Services to our Website Users. This information includes but is not limited to contact information (such as names, mailing addresses, e-mail addresses and telephone numbers), billing information and details of transactions you carry out through our Website, any identifier we may use to contact you, records and copies of your correspondence with us and your responses to surveys that we might ask you to complete for research purposes.
As you navigate through and interact with our Website, we may also collect certain information about your equipment and browsing actions and patterns, including but not limited to:
- Details of your visits to our Website, including traffic and location data, web pages and products viewed, websites or search terms which referred you to our Website, logs and other communication data and the resources that you access and use on our Website; and
- Information about your computer and Internet connection, including your IP address, operating system, browser type, time zone and pre-existing cookies installed on your device.
How we collect your Personal Information
We use different methods to collect your Personal Information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email or otherwise;
- Automated technologies such as cookies, web beacons and log files; and
- Third parties or publically available sources, such as social media platforms.
“Web beacons”, “tags” or “pixels” are small electronic files that permit us to count Users who have visited pages of our Website and for other related statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
“Log files” allow us to track actions which occur on our Website and to collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
We may also use automated technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Third parties, such as Google and Facebook, may collect or retrieve your Personal Information from our Website or elsewhere on the Internet to provide targeted ads. To learn more or to opt-out of tailored advertising, please visit the Network Advertising Initiative Website and Digital Advertising Alliance of Canada Opt-Out Tool. You can also opt-out of targeted advertising by visiting https://www.google.com/settings/ads/anonymous and https://www.facebook.com/help/568137493302217.
In using any of our Services through Zoom, you are also subject to Zoom’s various Terms and Policies, which you can access at the following link: https://zoom.us/privacy-and-legal.
How we use your Personal Information
We use the Personal Information we collect from you to:
- Present our Website and its contents to you;
- Facilitate communications between you and CAPSA;
- Provide you with the information, Services and/or support that you request from us;
- Carry out our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements;
- Complete a transaction with you when you make a donation through our Website;
- Screen for potential risk or fraud;
- Improve our Website or Services; measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you;
- Estimate our audience size and usage patterns and analyze trends and track movements around our Website;
- Gather demographic information about our User base;
- Store information about your preferences, allowing us to customize our Website to provide you with a personalized experience;
- Recognize you when you return to our Website;
- Fulfill the purposes for which you provided the information or that were described when it was collected; or
- Fulfill any other purpose with your consent.
The Personal Information that we collect may be assigned to a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change respecting CAPSA or our Website.
If you have any questions about how we use your Personal Information, please contact us.
When we disclose your Personal Information
CAPSA discloses Users’ Personal Information:
- As required or authorized by law or by order or requirement of a court, administrative agency or other governmental tribunal;
- To enforce or apply our Terms and Conditions (https://capsa.ca/terms-conditions) and other agreements;
- Where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
- Where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
- Where the information being disclosed or used is in the public domain.
We may also disclose your Personal Information to third parties in order to carry out our objectives listed in “How we use your Personal Information” above. For example, we use Google Analytics to help us understand how our Users use our Website. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
CAPSA will provide statistics and reports to Health Canada on its program operations. These reports will only use de-identified and/or aggregate data and will not contain personal information.
Knowledge and Consent
When you voluntarily provide us with your Personal Information, we will typically seek consent for the use or disclosure of such Personal Information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).
The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations of the individual in the circumstances. When you fill out a form on our Website, for instance, you imply that we may use that information for the purpose for which you filled out the form.
CAPSA keeps a record of its Website Users’ history with CAPSA, including participation in CAPSA’s Services. By using our Website, you acknowledge that we may keep this record and consent to such retention.
You may withdraw consent to the collection, use or disclosure of your Personal Information at any time, subject to legal restrictions (such as information kept to protect CAPSA from liability) and reasonable notice. If you wish to withdraw your consent, please contact us by email at firstname.lastname@example.org. We will inform you of the implications of withdrawing your consent as appropriate.
How we protect your Personal Information
The safety and security of your Personal Information is very important to us. While we cannot guarantee complete protection of your Personal Information, we follow commercially reasonable practices to protect Personal Information collected from you against accidental loss and unauthorized access, use, alteration and disclosure.
Our Website is hosted by HostUpon Inc., who provides us with the online platform through which we sell our products and provide our Services to you. Your data is stored through cloud data storage databases behind a firewall on a secure server.
Because the transmission of information via the Internet is not completely secure, any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website. Your Personal Information, save and except for Payment Information, may be unencrypted and may be transmitted over various networks and be subject to changes in order to conform and adapt to technical requirements of connected networks or devices. We urge you to be cautious about giving out information in any public areas of our Website or during the use of our Services.
Retention of your Personal Information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as is necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements or to protect us from liability in the event of a dispute.
Unless you explicitly withdraw your consent, we will retain your name and contact information so that we may archive your participation in CAPSA. When you explicitly withdraw your consent to us retaining your Personal Information, or if your Personal Information is no longer necessary or relevant for the identified purposes or is not required to be retained by applicable laws, CAPSA will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We reserve the right to use anonymous and de-identified data for any legitimate business purpose without further notice to you and without your consent.
CAPSA uses reasonable business practices to ensure we have adequate controls, schedules and practices for information, retention of records and destruction, which apply to your Personal Information. We will make reasonable business efforts to comply with a request to delete your Personal Information as long as technological restraints or legal constraints do not limit our ability to fulfill the deletion request. Where a request for deletion of Personal Information is declined, the individual making the request will be provided with the reasons for declining the request.
We reserve the right to modify this Policy at any time. The Policy posted on the Website shall be deemed to be the Policy in effect. A current Policy can be obtained by contacting us. If we make any material changes to this Policy regarding how we treat our users’ Personal Information, we will notify you through a notice on our Website homepage. We also include the date the Policy was last revised at the top of the Policy.
You are responsible for ensuring that we have an up-to-date, active and deliverable email address for you and for periodically visiting our Website and this Policy to check for any changes.
Correcting or Updating your Information
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.
You may contact us if you would like to review, verify, correct or withdraw consent to the use of your Personal Information. We may request certain Personal Information for the purposes of verifying the identity of the individual seeking access to their Personal Information records. We may not accommodate a request to view or change information if we believe that:
- The identity of the person requesting access cannot be confirmed;
- The Personal Information is not readily retrievable, and the burden or cost of providing it would be disproportionate to the nature or value of the Personal Information;
- The requested Personal Information does not exist, is not held or cannot be found;
- Disclosure of the Personal Information would compromise the confidentiality of another individual or threaten the safety of another person; and/or
- Non-disclosure of the Personal Information is required or permitted by law.
Where a request for access or alteration of Personal Information is declined, the individual making the request will be provided with the reasons for declining the request, subject to any legal or regulatory restrictions.
Links to Other Websites
Our Website may contain links or references to other websites and services owned or operated by third parties. These third-party platforms and websites are not governed by this Policy. This Policy does not extend to the collection of Personal Information or Payment Information by third parties, and we are not responsible for the privacy practices, policies or actions of third parties. When visiting third party websites or platforms, whether linked to our Website or otherwise, you do so at your own risk, and you assume all responsibility associated with the same. We encourage you to review the privacy policies and terms and conditions of each website and platform visited prior to using them or disclosing Personal Information or Payment Information to third parties.
If you have questions about our treatment of your Personal Information or compliance with this Policy, you may contact us by e‑mail at email@example.com or by regular mail using the details provided below:
Community Addictions Peer Support Association
Anthony Esposti, CEO and Privacy Compliance Officer
P.O. Box 23121 Fairlawn Plaza, Ottawa, ON