ChangeIt Privacy Policy - Canada

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1 ChangeIt Privacy Policy - Canada 1. Policy on Privacy of Personal Information Formulating Change Inc. ( FCI, we, us or our ) is committed to protecting the privacy and security of your Personal Information obtained because of your relationship with FCI. This Privacy Policy outlines: (a) how we will collect your Personal Information; (b) how we will use your Personal Information; (c) to whom we may disclose your Personal Information; and (d) how you can verify and correct your 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. This Privacy Policy applies to Personal Information (as defined below) of Canadians collected by FCI in connection with our operations and services. This Policy also applies to Personal Information collected through our website, changeit.com, and its related subdomains and all other sites owned and operated by FCI that redirect to changeit.com and link to this Privacy Policy ( Website ), as well as the services offered by FCI (collectively, Services and each is a Service ). This Privacy Policy is incorporated into and forms part of the terms of service for any applicable Service or terms of use of any Website. By using a Website, a Service or otherwise providing us with your Personal Information, you are accepting the practices described in this Privacy Policy, as they may be amended by us from time to time, and are agreeing to our collection and use of your Personal Information in accordance with this Privacy Policy. If you do not agree to the collection, use and disclosure of your Personal Information in this way, please do not use the Website, our Services or otherwise provide FCI with your Personal Information 2. What is personal information? "Personal Information" means information about an identifiable individual but, to the extent permitted by the law, does not include the contact information of an employee of an organization (e.g. name, title, business address or business telephone number). Personal Information does not include anonymous or non-personal Information (i.e. information that cannot be associated with or traced to a specific individual). 3. We are accountable to you FCI is responsible for all Personal Information under its control, including any Personal Information that is transferred to third parties for processing, storage or other purposes. We have employees who are accountable for compliance with these privacy and security principles. 4. We let you know why we collect and use your personal information We may collect your Personal Information in many forms (hard/soft copy, electronically, telephone conversations/recordings, etc.), but will only do so by lawful means and only for necessary purposes that have been disclosed to you. 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 identify any additional purposes for which we will collect your Personal Information, before or at the time of collection, and we will obtain your consent to collect, use or disclose your Personal Information for such additional purpose(s).

2 By using the Website and/or the Services, you will be deemed to consent to our use of your Personal Information for the following purposes: communicating with you generally; responding to your requests, for example, where you ask for products, services or information; processing your donations; processing and keeping track of donations and reporting back to you; manage and promote the business activities of FCI; protecting against fraud or error; providing services requested by you; identifying your needs and/or preferences; performing statistical analyses of user behaviour and characteristics, to measure interest in and use of the various sections of the Website 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; protecting against fraud or error; 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. 5. We limit collection of your personal information FCI collects only the minimum information required to provide our services to you and only by clear, fair and lawful means. Depending on the sensitivity of the Personal Information that we collect from you and as permitted by the applicable law, your consent to our collection, use and/or disclosure may be express or implied. Generally, we will seek your consent to our use and/or disclose your Personal Information at the time of collection. For example, under the terms of service that you agree to when you sign up for a Service. In some circumstances, we may seek consent after we have collected your Personal Information but before we use it (for example, if we want to use the Personal Information for different purposes than previously identified). The amount of Personal Information provided by you and collected by FCI depends on the circumstances and the Personal Information we collect may include contact, demographic or other types of information. We also collect certain types of non-personal Information ( Non-PII ) whenever you interact with us through the Website. Non-PII is anonymous and does not identify you personally. Non-PII is generally collected through the Website from four different sources: Internet protocol addresses and web logs; cookies; pixel tags and other similar technologies; and other Non-PII that you voluntarily provide (as explained below). When you visit and interact with the Website, We and third parties with whom We have contracted to provide services to us, may collect Non-PII (for example, a catalog of the Website pages you visit). i. IP Protocol Addresses and Web Logs The Website s web servers automatically collect the Internet Protocol (IP) addresses and log files of visitors. Your IP address is an identifying number that is automatically assigned to your computer or other device by your Internet Service Provider (ISP). This number is identified and

3 logged automatically in our server log files whenever you visit the Website, along with the time(s) of your visit(s) and the page(s) that you visited. This information is collected in an aggregate form only and does not contain any PII. We use your IP address, and the IP addresses of all users, for purposes such as calculating Website usage levels, helping diagnose problems with the Website s servers, and administering the Website. Collecting IP addresses is standard practice on the Internet and is done automatically by many sites. In addition to the Non-PII usage of IP Addresses described above We also may link your IP address to personally identifiable information for fraud prevention purposes. ii. Pixel Tags We and our service providers may also use so-called pixel tags, web beacons, clear GIFs or similar means (collectively, Pixel Tags ) in connection with some Website pages and HTMLformatted messages to track your use of the Website to provide you with more useful information and a more personalized experience the next time you visit. A Pixel Tag is an electronic image, often a single pixel (1x1) that is ordinarily not visible to Website visitors and may be associated with cookies on the visitors hard drives. Pixel Tags do not contain any PII and allow us to count users who have visited certain pages of the Website, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted messages, Pixel Tags can tell the sender whether and when an has been opened. iii. Cookies We and our third party service providers may use a standard technology called a cookie to collect information about how you use the Website. Cookies reside on your computer and help the Website recognize your computer s browser as a previous visitor. On occasion the Website may also set a session cookie that helps us administer the Website. The session cookie expires when you close your browser and does not retain any information about you after it expires. If you do not want information collected through the use of cookies, you should be able to modify your browser preference to provide you with choices relating to cookies. If you choose to reject cookies, you may be unable to use certain Website services (e.g., those services that require you to log on to the Website to participate). Understand that technology is ever changing and We move forward to employ the latest forms of technology to assist us in providing our customers with better experiences. This may include the future use of behavioral marketing and cookies associated therewith. iv. Analytical Tools Portions of the Website use statistical tools that may be operated by third party providers (collectively, the Analytical Tools ). The Analytical Tools may use a combination of the above means to collect Non-PII. The information generated by cookies and/or Analytic Tools about your use of the Website (including your IP address) may 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.

4 The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on s settings or visiting the website of its manufacturer. Because cookies allow you to take advantage of some of essential features of the Website, we recommend you leave them turned on. 6. Collection and Disclosure of Information in the Donation Process When you donate to a charity through FCI, we collect only enough information about you to process your donation. FCI will disclose your name, address, or other required Personal Information to the charity, so that, if applicable, they can provide you with a tax receipt for your donation (if your donation qualifies for a tax receipt) and/or to further communicate with you in accordance with their privacy policy. You have the ability to select the option to instruct the charity to not communicate with you outside of providing a tax receipt. 7. We limit disclosure and retention of your personal information FCI does not disclose Personal Information to any organization or person for any reason except for the services of credit card providers and banking systems used to process your donation. We may also transfer your Personal Information to trusted third party service providers who assist us in administering and providing our Services. These third party service providers will have access to your Personal Information that is needed to perform their functions, but may not use it for other purposes. You are deemed to consent to disclosure of your Personal Information for the foregoing circumstances and 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. 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. We may disclose your Personal Information when we believe release is appropriate to comply with the law, enforce our policies, or protect our or others rights, or property, or for safety. Information, including Personal Information, which we collect from our customers, visitors to the Website and others, is considered to be a business asset. As a result, in the unlikely event that we go out of business, enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, your Personal Information may be disclosed or transferred to the third party acquirer in connection with the transaction. Personal Information collected in any form will only be retained by us so long as it is required: a) for the purpose for which it was collected; b) to be retained by law; c) to address any issues that may arise at a later date. When your Personal Information is no longer required for these identified purposes, FCI uses secure procedures to destroy, delete, erase or convert the Personal Information into an anonymous form.

5 8. We keep your personal information up to date and accurate FCI keeps your Personal Information up-to-date, accurate and relevant for its intended use. 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 FCI is fully compliant with the Payment Card Industry Data Security Standards (PCI-DSS) and we take extensive steps to safeguard your Personal Information, regardless of the format in which it is held. Our methods of protection will include physical measures (for example, locked filing cabinets and restricted access to offices or designated areas), organizational measures (for example, security clearances and limiting access on a "need-to-know" basis) and technological measures. 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. When we engage third parties to provide services to us, we use contractual means to ensure a comparable level of protection is maintained while the Personal Information is in the possession of the third party. In some cases, these third parties may be located outside of Canada (e.g. the United States) and the Personal Information may become subject to the laws of that country and no contractual provision can override those laws. Similar to Canadian law, law enforcement agencies or other governmental authorities in the U.S. or other jurisdictions may obtain access to Personal Information but only where access is permitted by Canadian law, U.S. law, or the law of the applicable jurisdiction.

6 10. What About Links to Other Websites? The Website may have links to third party websites that FCI does not own or maintain. Links to other websites or other resources that are not created or controlled by FCI ( Linked Sites ) are intended for convenience only. Linked Sites are wholly independent from FCI, therefore FCI has no control over any products, services, materials, or other information contained in or available through these third party websites. We make no representations or warranties about the privacy practices of those websites. Therefore, access to any third party websites through the Website, regardless of whether the third party website is a Linked Site or not, is entirely at your own risk and it is your responsibility to take all protective measures to guard against viruses or other destructive devices, programs. FCI makes no representation or warranty regarding, or endorses, any Linked Sites or the information appearing thereon or any of the products or services described thereon. You should refer to the privacy policies of third parties if you have any questions. 11. We are open about our privacy and security policy We are committed to providing you with understandable and easily available information about our policy and practices related to management of your Personal Information. This policy and any related information is available at all times on the Website or on request. To contact us, refer to the How to contact us section below We provide access to your Personal Information stored by FCI You can request access to your Personal Information stored by FCI. Requests to review or verify your Personal Information must be made to us in writing. Upon receiving such a request, FCI will: 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. We will need specific information from you to enable us to search for, and provide you with, the Personal Information we hold about you. We may charge you a small administrative fee depending on the nature of your request and we will advise you of any fee before proceeding with your request. If we are unable to provide some of the Personal Information we hold about you, we will tell you why. To request to review or verify your Personal Information, refer to the How to contact us section below. 13. We respond to your questions, concerns and complaints about privacy FCI responds in a timely manner to your questions, concerns and complaints about the privacy of your Personal Information and our privacy policies and procedures. 14. Your Consent and Electronic Messages FCI will only send s or other commercial electronic messages to you if you have asked for or otherwise agreed (either expressly or implicitly as may be permitted under the applicable law) to receive or other commercial electronic messages from FCI. Any commercial electronic message that you receive from FCI will identify FCI as the sender, enable you to contact FCI directly and provide for a means of unsubscribing from further commercial electronic messages from FCI. 15. Changes to our Privacy Policy FCI reserves the right to modify this Privacy Policy at any time. We will promptly reflect any such modifications to this Privacy Policy on the Website and will indicate at the bottom of this page the date this Privacy Policy was last amended. Your continued access to and/or use of the Website and/or

7 Services after any such changes constitute your acceptance of, and agreement to be legally bound by, this Privacy Policy, as revised. Please periodically review this Privacy Policy so that you know what Personal Information we collect, how we use it, and with whom we may share it. 16. How to contact us You may contact us by Clicking on the Contact Us link at the bottom of this page; or by mailing us at Formulating Change Inc., 460 Phillip Street, Suite 301, Waterloo, Ontario, Canada, N2L 5J2, attention: Privacy Officer For Charities Only: If you are or represent a charity, you may choose to engage in a live chat session ( Live Chat ) with us, which is only available for charities using the Website. The Live Chat service may be offered by a third party service provider ( Chat Provider ). When a Live Chat begins, you, as the authorized charity representative, may be asked to enter your name or other Personal Information to facilitate the Live Chat Service. By providing your Personal Information, you consent to us and the Chat Provider collecting and processing such Personal Information in order to provide the Live Chat service to you. During the Live Chat, you will enter into a live question and answer session with an operator. We, and Chat Provider, maintain dialogue transcripts of your Live Chats communications. After a Live Chat, Our customer service agents may ask you to fill out an exit survey in order to obtain feedback from you. Providing information under an exit survey is completely voluntary. The surveys may ask for contact information (such as, your address) and for demographic information (such as, your postal code). The surveys vary by end user so that we may obtain feedback specific to your website and business, as well as feedback regarding Chat Provider s service. Effective Date: This privacy policy was lasted on, and is effective as of, October 30, 2014.

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