Action Canada for Sexual Health and Rights understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our community and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under GDPR, CASL and PIPEDA.
1. Information About Us
Action Canada for Sexual Health and Rights is a Canadian non-profit and charity registered with Revenue Canada.
Our mailing address is:
2nd Floor, 251 Bank Street
Ottawa, ON K2P 1X3
2. What Does This Notice Cover?
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are Your Rights?
Under the various laws, you have the following rights, which we will work to uphold:
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do We Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Email address
- Telephone number
- Business or organization name
- Job title
- Payment information
- Information about your preferences and interests
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying our products or services to you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email or postal mail that you have opted-in to. You may unsubscribe or opt-out at any time by updating your communication preferences at secure.actioncanada.org.
- With your permission and/or where permitted by law, we may also use your personal data for marketing or fundraising purposes, which may include contacting you by email with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations, and you will always have the opportunity to opt-out.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
- Donation financial data will pass through this site and be stored by our payment processors until complete, and in our fundraising database offline;
- Event participation information will be stored on secure.actioncanadashr.org (our CRM) until the event has ended;
- Newsletter subscriptions (by interest, geography or site collected) will be stored on secure.actioncanadashr.org until you unsubscribe.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store data provided through our websites in Canada. Fundraising data is stored with our authorized vendor (Blackbaud) in a secure system in the United States. We occasionally export mailing information to a mailing house that will not store any personal data after use.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may sometimes contract with the following third parties to supply products or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
- Credit card payment processors (Blackbaud, iATS)
- Beyond the Basics order fulfilment.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request on within 10 business days of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: firstname.lastname@example.org
Telephone number: 613-241-4474 x14.
Postal Address: Privacy officer, Action Canada for Sexual Health and Rights, 2nd Floor, 251 Bank Street, Ottawa, ON K2P 1X3.
Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our organization in a way that affects personal data protection.
Any changes will be made available publicly on our websites.