Hard Feelings Privacy Policy
Our Privacy Commitment
Hard Feelings is committed to maintaining the accuracy, security and privacy of the Personal Information that we collect from our donors, clients, volunteers and other individuals from whom we collect Personal Information (“You”) in accordance with applicable privacy laws.
Your Consent
BY SUBMITTING PERSONAL INFORMATION TO HARD FEELINGS OR OUR AGENTS AND SERVICE PROVIDERS, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY APPLICABLE LAWS. Subject to legal and contractual requirements, and reasonable notice, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting Hard Feelings’ Chief Privacy Officer. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide us with the Personal Information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such individual to enable us to collect, use and disclose such Personal Information for the purposes set forth in this Privacy Policy.
What is Personal Information?
Canadian privacy laws define Personal Information broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, Personal Information means information about an identifiable individual as defined from time to time in applicable privacy laws. Generally speaking, Personal Information does not include what is considered to be business contact information: your name, title or position, business address, telephone number, facsimile number, or e-mail address.
What Personal Information do we Collect?
The types of Personal Information that Hard Feelings may collect about you includes your e-mail address, name, home/and or work address, postal code and phone numbers. Hard Feelings may also collect anonymous demographic information, such as your age, gender, marital status, and program preferences. Such information is used by Hard Feelings to provide general statistics regarding the use of our services and to determine appropriate services.
Why do we Collect your Personal Information?
Hard Feelings limits the collection, use and disclosure of your Personal Information, both in the amount and type of Personal Information, to that which is necessary to fulfill the purposes identified within this Privacy Policy. We will identify the purposes for which your Personal Information is collected at or before the time your Personal Information is collected. In general, Hard Feelings may collect, use and disclose your Personal Information for the following purposes:
(a) to register you for a group;
(b) to understand your needs and assist in serving you better;
(c) to send you information such as newsletters, events information, invitations, updates or to invite you to recognition or information sessions;
(d) to administer your donation and contact you about renewal;
(e) to respond to your information requests;
(f) to thank our donors and, with their consent, to recognize their gift;
(g) as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
(h) for any other purpose to which you consent.
To Whom do we Disclose Your Personal Information?
From time to time, Hard Feelings may disclose your Personal Information to:
(a) service providers, including an organization or individual retained by Hard Feelings to perform functions on its behalf, such as marketing, data processing, document management and office services;
(b) a person who, in the reasonable judgment of Hard Feelings, is providing or seeking the information as your agent;
(c) any other third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.
Where do we Store Your Personal Information?
Your Personal Information is stored in secured locations and on servers controlled by organizations retained by Hard Feelings to perform functions on its behalf, located either at our offices or at the offices of our service providers. Hard Feelings retains your Personal Information only for as long as is necessary in order to fulfill the purposes identified within this Privacy Policy, or for as long as may be required to comply with applicable laws.
How do we Protect your Personal Information?
To help protect the confidentiality and security of your Personal Information, Hard Feelings employs administrative and technological safeguards appropriate to the sensitivity of your Personal Information. If your Personal Information is sent to a third party for processing, we make sure, through our contracts with such third parties, that all of your Personal Information is kept secure. We also operate secure data networks protected by industry standard firewall and password protection systems. Your Personal Information is kept as accurate, complete and up-to-date as is necessary to fulfill the purposes identified in this Privacy Policy. We do not routinely update your Personal Information. Access to your Personal Information is restricted to Hard Feelings employees, trained volunteers and authorized service providers who need it to provide appropriate services to you.
Privacy and our Website
(a) Cookies – When an individual visitor accesses the Hard Feelings website, we may use a browser feature called a ‘cookie’ to collect information such as the type of Internet browser and operating system the visitor uses, the domain name of the website from which the visitor came, date and duration of the visit, number of visits, average time spent on our website, pages viewed and number of cookies accumulated. A cookie is a small text file containing a unique identification number that identifies the visitor’s browser, but not necessarily the visitor, to our computers each time our website is visited. Unless a visitor specifically informs us (e.g. by registering for an event or sending us correspondence from the website), we will not know who the individual visitors are. In addition to the identified purposes described in our Privacy Policy, we may use this website information and share it with other organizations with which we have a commercial relationship to measure the use of our website, to improve the functionality and content of the website and to facilitate usage by a visitor. Visitors can reset their browsers either to notify them when they have received a cookie or refuse to accept cookies. However, if a visitor refuses to accept cookies, he or she may not be able to use some of the features available on our website.
(b) Online Communications – In order to provide our website visitors with a service or information, visitors may voluntarily submit Personal Information to us for purposes such as asking a question, obtaining information, reviewing or downloading a publication or participating in a seminar or other event. If you are known to Hard Feelings as a registered user of an online service, we may combine and store Personal Information about your use of our website and the online information you have provided with certain other online and offline information we may have collected.
(c) E-Mail Communications – Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful, including information about Hard Feelings and other third parties with whom we have a relationship. We will include instructions on how to unsubscribe and inform us of preferences if you decide you do not want to receive any future marketing or promotional e-mails from Hard Feelings.
(d) Links – Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than Hard Feelings, and Hard Feelings has no responsibility for such third party websites.
We also use Google Analytics to help us understand how our customers use the Site — you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
How can you Obtain Access to Your Personal Information?
Upon your written request, and subject to certain exceptions, Hard Feelings will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information. Access requests should be sent to Hard Feelings’ Chief Privacy Officer using the contact information outlined below.
If access to your Personal Information is denied, Hard Feelings will notify you in writing, give reasons for the denial, and inform you of the recourses open to you. If access is granted, Hard Feelings will give you a reasonable opportunity to review your Personal Information. Your Personal Information will be provided to you in an understandable form within a reasonable time, generally within 30 days. Hard Feelings may extend such 30 day period by up to an additional 30 days if meeting the time limit would unreasonably interfere with the activities of Hard Feelings or the time required to undertake any consultations necessary to respond to your request would make the time limit impracticable to meet. You will be able to challenge the accuracy and completeness of your Personal Information and have it amended as appropriate.
How can you Obtain Further Information Regarding this Policy?
Hard Feelings has appointed a Chief Privacy Officer to oversee compliance with this Privacy Policy and applicable privacy laws. For more information on Hard Feelings’ privacy practices, please visit our website or contact our Chief Privacy Officer at:
Hard Feelings Chief Privacy Officer
Kate Scowen
353 Church Street
Toronto, ON
M5B 0B2
Tel: 647-740-3335
Email: [email protected]
Changes to our Privacy Policy
Hard Feelings reserves the right to modify or supplement this Privacy Policy at any time. If we make a change to this Privacy Policy, we will post such changes on our website at hardfeelings.org and make such revised policy and changes available upon request to the Hard Feelings Chief Privacy Officer. However, Hard Feelings will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those for which your consent is obtained unless otherwise required or permitted by law.
Board Approved: September 10, 2017