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PRIVACY POLICY

DEFINITY INSURANCE FOUNDATION /
LA FONDATION DEFINITY ASSURANCE
(THE “FOUNDATION”)

Last updated August 11, 2021

The Foundation recognizes the importance of privacy and is committed to maintaining and protecting the accuracy, confidentiality and security of the personal information that is provided to us. This Privacy Policy describes the personal information we collect, how we manage that information, and the circumstances under which we may disclose that information.

As most of the Foundation’s activities would be deemed non-commercial in nature, the federal Personal Information Protection and Electronic Documents Act (PIPEDA) would rarely apply to the Foundation. Nonetheless, the Foundation has voluntarily agreed to abide by the principles laid out in this Privacy Policy.

Changes to this Privacy Policy

The Foundation regularly reviews its privacy practices and will update its Privacy Policy as required. The Foundation reserves the right to change this Privacy Policy from time to time. 

The Privacy Policy posted at any time or from time to time via this website shall be deemed to be the Privacy Policy then in effect. We recommend that you check this Privacy Policy periodically so that you are aware of any changes. The Foundation treats personal information in a manner consistent with the Privacy Policy under which it was collected, unless we have your consent to treat it differently.

This website may offer links to other third party websites. You should be aware that operators of linked websites may also collect your personal information (including information generated through the use of cookies) when you link to their websites.  The Foundation is not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarize yourself with their privacy policies before providing them with your personal information.

What is Personal Information?

Personal information includes any factual or subjective information about an identifiable individual and may include an individual’s name, address, email, telephone number, age, financial information, etc. Personal information does not include most business contact information such as the name, position, title, business address, or business telephone or fax number of an individual. 

Privacy Principles

The Foundation is committed to the following 10 privacy principles:

  1. Accountability
    • The Foundation is responsible for personal information in our custody or under our control. We have designated a Privacy Officer to be accountable for overseeing this Policy and the Foundation's compliance with it. There are other individuals within the Foundation who are responsible for day-to-day collection and management of personal information.
    • The Foundation has procedures in place to implement and comply with this Privacy Policy, including procedures relating to the collection, handling, disclosure, storage, and destruction of personal information.
    • The Foundation is responsible for personal information transferred to a third party for processing. The Foundation uses contractual means to provide a comparable level of protection for the transferred information. The Foundation requires all third parties to adhere to this Privacy Policy, PIPEDA and any other applicable law regarding the protection of personal information.
  2. Identifying Purposes
    The Foundation collects and uses personal information for the following purposes:
    • To keep you informed about the Foundation’s grants, programs, events, and activities
    • For fundraising and administrative purposes
    • To provide official donation receipts to donors and/or to administer pre-authorized recurring donations
    • For internal research purposes
    • To provide you with support and help 
  3. Consent to use your personal information
    • The Foundation collects personal information about you only when you voluntarily provide it or otherwise only with your consent. You may provide your consent to us either orally or in writing.
    • The Foundation will seek consent for the use or disclosure of personal information at the time of its collection. 
    • The Foundation will not require you to consent to the collection, use or disclosure of information beyond that required to fulfill the specified and legitimate purposes for which the information is being provided.
    • Upon giving the Foundation reasonable notice, an individual may withdraw consent to use their personal information at any time, subject to any legal or contractual restrictions. If you wish to withdraw your consent, please contact the Privacy Officer of the Foundation as described below.  We will inform you of the implications of withdrawing consent.
    • If you do not wish to receive communications from us or participate in more personalized information and services, you may easily unsubscribe by following the directions provided in the communication or by contacting the Privacy Officer of the Foundation as described below.
    • By visiting and using the Foundation’s website, the visitor agrees to the Privacy Policy. If you do not agree to the Privacy Policy, do not use this website or provide personal information to the Foundation. 
  4. Limiting Collection

    The Foundation limits the collection of personal information to that which is reasonably necessary for the identified purpose. The types of information the Foundation collects can be summarized as follows: 

    Personal Information provided to the Foundation: The Foundation collects certain personal information directly from individuals who interact with us, including the following:

    • Contact information (such as name, address, e-mail address and telephone number); an
    • Information required to issue official donation receipts.
  5. Limiting Use, Disclosure and Retention
    • The Foundation does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as permitted or required by law.
    • The Foundation may have to disclose personal information to satisfy a law, regulation or government request, or to satisfy a subpoena, search warrant or legitimate court order.
    • The Foundation may share personal information with third parties engaged to assist us in providing our services. Such third parties are contractually bound to protect your personal information as explained above under “Accountability”. 
    • The Foundation reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual merger or amalgamation of the Foundation in order for you to continue to receive the same information and services from the third party.  
    • The Foundation retains personal information only as long as is necessary for the fulfillment of those purposes for which it was collected or as required by law, and your consent to such purposes remains valid after termination of our relationship with you.
    • The Foundation does not disclose credit card account information provided by users except to the appropriate banking institutions or payment processing provider in order to process a credit or debit authorization for payment, or to resolve a dispute.
  6. Accuracy

    The Foundation makes commercially reasonable efforts to keep personal information accurate, complete and as up to date as is necessary for the purposes for which it is being used. Individuals are permitted to check on the accuracy of their personal information and may make, or request, modifications or corrections, if necessary. 

  7. Safeguards
    • The Foundation makes commercially reasonable efforts to protect personal information from loss, theft, unauthorized access, copying, use, modification, disclosure and destruction by establishing and maintaining security safeguards appropriate to the sensitivity level of the information.
    • All the Foundation’s volunteers and staff members are made aware of the need to maintain strict confidentiality of all personal information.
  8. Openness

    The Foundation makes information about our policies and practices related to the management of personal information readily available to users of our service and the general public. Our Privacy Policy, which informs users of the type of information we collect, what it is used for, and to whom the information may be disclosed, is posted on our website. Additional information about our privacy policies and practices can be obtained from the Privacy Officer as described below. 

  9. Individual Access
     

    Upon request the Foundation will:

    1. Inform users of the existence and use of their personal information.
    2. Inform users whether their personal information has been disclosed to any authorized third parties.
    3. Provide users with information about their personal information in our custody or under our control subject to legal restrictions.
     

    Requests are to be directed to:

    Privacy Officer of Definity Insurance Foundation / La Fondation Definity Assurance
    Address: 36 Toronto Street, Suite 600, Toronto ON M5C 2C5    

    The Foundation will make every effort to respond to requests for access to personal information in a reasonable and timely manner.

  10. Challenging Compliance

    Any questions, requests, or concerns regarding the Foundation’s compliance with respect to the Privacy Policy or about our privacy practices may be directed to the Privacy Officer as described above.