Privacy Policy

1.0 Background 

Capitalize for Kids is committed to protecting the privacy of all who interact with us. We are committed to complying with PIPEDA. We aim to build trust and recognize that maintaining this trust requires that we be transparent and accountable in our treatment of the Personal Information (as defined below) that all choose to share with us. We do not trade, rent, or sell the names of anyone who interacts with us. 

2.0 Policy and Scope 

This policy applies to all individuals that disclose Personal Information to the organization, including without limitation the organization’s Board of Directors, employees, volunteers, event participants, and donors (“C4K Community Members”). This Privacy Policy sets out the Personal Information practices for Capitalize for Kids (“the organization”). The organization may update this Privacy Policy at any time; the ongoing participation by C4K Community Members in the organization’s activities, programming, or other efforts will constitute acceptance of any such update. 

3.0 Accountability for Personal Information 

“Personal Information” is any information about an identifiable individual. This information includes whether an individual has donated to the organization, how much has been donated and an individual’s private contact information. 

Capitalize for Kids keeps Personal Information that is provided to us in strict confidence. Business contact information and certain publicly available information, such as names, addresses and telephone numbers that are published in publicly available sources are not considered personal information. 

Our employees, Board members, and volunteers sign confidentiality agreements and only access Personal Information on a need-to-know basis in order to perform their job function. Safeguards are in place to ensure that Personal Information is not accessed, disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed. Individuals may access their Personal Information at any time to ensure that it is correct and current. Capitalize for Kids does not receive personal health information from clients of our beneficiary agencies. 

4.0 Collection, Use, Disclosure and Retention of Personal Information 

“Personal Information” means information about an identifiable individual and includes any information that can be used to distinguish, identify or contact a specific individual. Personal Information includes the fact that an individual has donated to the organization, how much has been donated and an individual’s personal contact and payment information. Business contact information (i.e., the name, title, business address or business phone number) is not considered Personal Information. 

4.1 Collection of Personal Information 
 
Capitalize for Kids abides by the following: 

• The organization limits the collection of personal information. 

• Capitalize for Kids collects Personal Information in a variety of ways when a donor, volunteer, or prospective donors (donor) interacts with the organization. Some examples are: 

1. when a donor makes an online donation; 
2. when a donor registers for the Capitalize for Kids Investors Conference; and 
3. when a donor provides information related to the Capitalize for Kids Bay Street Games or other potential events. 

• The organization limits the collection of Personal Information to that which is necessary for the purposes identified at the time of collection. 

• A donor may always choose to not provide personal information to the organization. The organization will take all reasonable precautions to maintain Personal Information in strict confidence. 

4.2 Use of Personal Information 

• The organization limits the use and disclosure of Personal Information. 

• Personal Information collected by the organization will only be used or disclosed in order to provide the donor with the information/services the donor has requested, or otherwise for the purposes described in this Privacy Policy (including special exemptions for charities, as considered by Canadian Anti-Spam Legislation – CASL). 

4.3 Disclosure of Personal Information 

• Personal Information will not be used or disclosed for purposes other than those for which it was collected, which may include updates on the organization, research distributions, and other similar activities. 

• The organization may use and disclose a donor’s Personal Information to comply with the law, or protect the organization’s or others’ rights, property, or safety. 

4.4 Retention of Personal Information 

• We limit the retention of Personal Information. 

• Personal Information will be retained only as long as necessary for the fulfillment of those purposes identified at the time of collection. Where Personal Information is no longer required to fulfill the identified purposes, or where an individual has requested that we delete their Personal Information, it will be made anonymous or will be destroyed in a manner that will protect it from unauthorized access or disclosure, in accordance with our retention policies. 

5.0 Personal Information and Third-Parties 

• The organization does not trade, rent, or sell Personal Information to third parties. 

• We have relationships with different agents and third-party service providers who help us administer, design, maintain and improve our website, our systems and our computer security. We use third parties to analyze data collected on our website. 

• The organization will not disclose a donor’s personal information to anyone other than our employees, our affiliates, agents and those third parties that require such information in order to provide the donor with the services/information that they have requested. When the organization allows a third-party service provider to have access to a donor’s Personal Information, they will only be permitted to take it or use it for purposes that are consistent with this Privacy Policy. 

In order to provide a donor with the services/information that they have required, a donor’s Personal Information may be transferred, stored and/or processed outside of Canada by a third-party service provider. In that case, a donor’s personal information would be subject to the laws of the country to which it is transferred. That country may have laws that require your personal information be disclosed to the government under different circumstances than in Canada. For more information about Capitalize for Kids’ policies and practices regarding service providers located outside of Canada, or if a donor has questions regarding the collection, use, disclosure or storage of their personal information by these service providers, please contact the organization at [email protected]. 

6.0 Protection of Personal Information 

Capitalize for Kids is committed to protecting the security of a donor’s Personal Information. The organization has put in place physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use a donor’s Personal Information. Although Capitalize for Kids will make reasonable efforts to protect personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems. 

7.0 Accuracy and Access to Personal Information 
A donor has the right to access, update, and correct their Personal Information that is under the organization’s control, subject to certain exceptions prescribed by law. A donor may request to access, update and correct inaccuracies in their Personal Information by contacting Capitalize for Kids’ Privacy Officer & Corporate Secretary at [email protected]. 

8.0 Transparency of Capitalize for Kids’ Privacy Practices 
The organization makes its practices relating to the management of Personal Information available to our constituents via the Capitalize for Kids’ website and the disclosure of this privacy policy. 

If there is a concern about the organization’s compliance with its privacy policy, please contact Capitalize for Kids’ Privacy Officer & Corporate Secretary at [email protected]. The organization will investigate all complaints and act accordingly. Concerns will be acknowledged within 7-10 business days. 

If anyone is not satisfied with the organization’s response, they may contact: Office of the Privacy Commissioner of Canada_30 Victoria Street Gatineau, QC K1A 1H3 1-800-282-1376 or the provincial privacy commissioner of the province where the personal information was collected or is stored. More information, including contact information for the provincial privacy commissioners, can be obtained at the Federal Privacy Commissioner’s website, www.priv.gc.ca.