a not-for-profit organization
POLICY NUMBER: 1.0 EFFECTIVE DATE: May 28, 2018
IMPORTANT – PLEASE CAREFULLY READ THE FOLLOWING
2. Defined Terms
3. Excluded Information
4. Binding Agreement
5. Consent & Revocation of Consent
6. Changes To This Policy & Notification
7. What Personal Information KEHILA May Collect
8. ‘Identified Purposes’ — Purposes of Collection
9. Privacy & Disclosure of Personal Information
10. Protection of Personal Information
11. Retention of Personal Information
12. Your Control Over Personal Information
13. Accuracy of Personal Information
14. Access To Personal Information
15. Visiting KEHILA’s Web Site
16. Use of Electronic Cookies
18. How To Contact KEHILA — Compliance Enquiries etc.
This Policy informs you of KEHILA’s practices concerning the collection, use, disclosure and protection of Personal Information (defined below) provided by you to KEHILA and constitutes a binding agreement between you and KEHILA (as further set out below).
KEHILA reserves the right to modify or change this Policy and will provide notification of any modifications and changes made to it as explained below.
KEHILA does not automatically gather your Personal Information; rather, it is obtained from you voluntarily and is used for the ‘Identified Purposes’ set out in this Policy.
When you register with KEHILA at its website at kehila.ca, contact KEHILA, register for one of its programs or events or support KEHILA activities, KEHILA is committed to protecting your Personal Information and to using your Personal Information in compliance with the provisions of this Policy, as they may from time to time be amended, supplemented, added to, deleted, substituted or otherwise modified or changed.
2. DEFINED TERMS
• “Identified Purposes” means, collectively, the purposes set out below under ‘Purpose of Collection’.
• “Participant” means you, and any other individual who registers as a user on, or visits, the KEHILA website or for any of its activities, or who is accepted as, or seeks to become, a member of KEHILA.
• “Personal Information” for purposes of this Policy means any information provided to, or collected by, KEHILA (recorded in any form) about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (such as name, title, business address, telephone and fax numbers and email address).
3. EXCLUDED INFORMATION
• information about more than one individual where the identity of the individuals is not known and cannot be inferred from the information (“Aggregated Information”)
• certain information excluded pursuant to applicable legislation and regulations, including such things as publicly available information or business contact information.
KEHILA retains, and is granted by you, the right to use Aggregated Information in any way that KEHILA reasonably determines is appropriate.
4. BINDING AGREEMENT
Your provision of Personal Information to KEHILA constitutes your:
• consent to KEHILA’s collection, use and disclosure of your Personal Information under this Policy.
If you do not agree with the provisions of this Policy, then do not provide any Personal Information to KEHILA.
5. CONSENT & REVOCATION OF CONSENT
Consent may be given in different ways such as a) expressly by signing a document, agreeing through electronic means or verbally; or b) implicitly by voluntarily providing your Personal Information.
If KEHILA wants to use your Personal Information for a purpose not included in the Identified Purposes when you provided that Information, then KEHILA will seek your consent to use the Information for such different purpose.
You have the right to revoke at any time your consent to KEHILA’s collection, use, and disclosure of your Personal Information. If you want to revoke your consent only as it extends to having your Personal Information disclosed to affiliated organizations, preferred suppliers, and other reputable organizations, contact KEHILA (see below).
Certain materials and services can only be offered and provided by KEHILA if you provide Personal Information to it. If you choose to revoke your consent or to not provide KEHILA with any required Personal Information, it may not be able to offer or provide you with those services.
6. CHANGES TO THIS POLICY & NOTIFICATION
7. WHAT PERSONAL INFORMATION KEHILA MAY COLLECT
KEHILA collects Personal Information in many forms (hard/soft copy, electronically, facsimile, telephone conversations/recordings, etc.), but will only do so by lawful means and only for the Identified Purposes.
It is impractical to list all types of Personal Information that KEHILA may collect, use or disclose. When you send KEHILA an email, post on the Site, or communicate with KEHILA in any way, you’re giving KEHILA information that it collects. The Personal Information we collect may include, among other things: your full name; gender, occupation, birth date, contact information (such as your address, telephone number, email address, job titles); other demographic information and information regarding your interests; whether you have subscribed or unsubscribed from any KEHILA mailing lists, or accepted any KEHILA invitations; information regarding your organization (including information regarding directors, officers, or employees); your payment information; your IP address; and any other Personal Information that you voluntarily choose to provide to KEHILA.
8. ‘INDENTIFIED PURPOSES’ — PURPOSES OF COLLECTION
KEHILA collects, may use and disclose Personal Information that you provide to it in writing (including via electronic media), verbally or otherwise for the following purposes (being the ‘Identified Purposes’):
• establishing your identity, as well as for KEHILA’s internal record keeping
• communicating with you and other Participants to develop, maintain, enhance and manage KEHILA’s relationship with, and those between and among, Participants (including to understand their needs and preferences)
• answering your inquiries and providing you information or materials you have asked to receive
• administering the Site and to enable your access to, and use of, the Site and KEHILA’s information, materials and services
• research, marketing, distribution of publications, invitations to events and providing information, products, services, and promotions to Participants, including by email to Participants who have subscribed to a KEHILA mailing list
• permitting affiliated organizations and preferred suppliers to offer or provide products, services, and information to Participants
• keeping your information and preferences accurate. For example, from time to time, KEHILA may ask you (by email or otherwise) to review your contact details and mailing list preferences and update them as necessary or appropriate
• billing: which may include the collection of names, addresses, banking and/or financial details
• analytics: KEHILA may also use and analyze the Personal Information you provide to it to offer you additional services or products, as well as to track and manage your consent preferences, event reservations and any unsubscribe requests
• any purpose permitted or required by applicable law or that is in connection with any legal proceedings or possible legal proceedings including, but not limited to, establishing, exercising or defending KEHILA’s legal rights
• such purposes not specified above that are related to or consistent with the above purposes
• such additional purposes that KEHILA discloses to you, and to which you consent.
KEHILA also collects and uses Aggregated Information about the use of the Site, such as how many visitors KEHILA receives and the types of services used. This information is collected for statistical analysis, marketing, and promotional functions.
9. PRIVACY & DISCLOSURE OF PERSONAL INFORMATION
Personal Information of a Participant is held in strict confidence and, except in limited circumstances, is not revealed to anyone unless expressly or implicitly authorized by the Participant and as provided for in this Policy.
KEHILA may disclose Personal Information to organizations that perform services for it. Personal Information will only be provided to such organizations if they agree in writing to provide appropriate protection for such Information. KEHILA requires those service providers to use that Personal Information solely for the purposes of providing services to the Participant concerned or to KEHILA and to have appropriate safeguards for the protection of that Personal Information.
Your Personal Information under KEHILA’s control is accessible only by KEHILA’s management, employees, authorized contractors and representatives that KEHILA’s management has determined have a ‘need to know’ for the Identified Purposes. When KEHILA discloses your Personal Information to its management, employees, authorized contractors or representatives, the individual in question will be obligated to use that Information in accordance with the provisions of this Policy.
KEHILA will not distribute, sell, trade, barter, license, lease or exchange to third parties for consideration any Personal Information it has obtained without your prior consent, except when lawfully required by a government body or agency, or as permitted or required by law or this Policy.
KEHILA may lease or license the name, address, telephone number and email address of Participants to affiliated organizations, preferred suppliers and other reputable organizations for use when:
• in the opinion of KEHILA, such use constitutes a service or includes information pertinent to Participants, and
• KEHILA has the written agreement of such organizations to adhere to specific requirements with respect to their use of such Information.
There are circumstances where the use and/or disclosure of Personal Information without consent may be justified or permitted or where KEHILA is obliged to disclose information. Such circumstances may include where:
• required by law or by order or requirement of a court, administrative or other governmental bodies, agency or tribunal
• KEHILA believes, on reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group
• it is necessary to establish or collect fees or to permit KEHILA to pursue available remedies or limit any damages that KEHILA may sustain
• the information is public.
Where obliged or permitted to disclose Personal Information without consent, KEHILA will not disclose more of such Information that is required for the purpose that obligates or permits it to disclose such Information.
KEHILA allows certain authorized third party providers to track and store certain information about visitors to the Site (including domain names, IP addresses and page views as described below).
10. PROTECTION OF PERSONAL INFORMATION
KEHILA employs safeguards to protect your Personal Information against loss or theft, unauthorized access, disclosure, copying, use, or modification. Such safeguards include physical measures, for example restricting access to files, offices, limiting access on a “need to know” basis, use of passwords and encryption.
The Site is hosted in a secure server environment that uses a firewall and other advanced technology to prevent interference or access from outside intruders. KEHILA endeavours to maintain appropriate physical, procedural and technical security with respect to storage of information to prevent loss, misuse, unauthorized access, disclosure, or modification of Personal Information under its control. This also applies to KEHILA’s disposal or destruction of Personal Information.
KEHILA may provide unique usernames and passwords that must be entered each time a Participant desires to log in to the Site. These safeguards, when used, help to prevent unauthorized access, maintain data accuracy and ensure the appropriate user access.
Misuse of Personal Information by any:
• management member or employee of KEHILA, or
• other individual or organization who provides services to or for KEHILA and/or any Participants
will be considered a serious act for which disciplinary action may be taken, up to and including termination of employment or termination of any agreement between KEHILA and that individual or organization.
KEHILA will audit its procedures and security measures from time to time to confirm their effectiveness.
Participants who visit the Site are cautioned that no network, including the internet, is entirely secure.
11. RETENTION OF PERSONAL INFORMATION
KEHILA retains your Personal Information only for as long as necessary for: (a) fulfillment of the Identified Purposes; (b) compliance with applicable laws surrounding information retention, and (c) to address any issues that may arise at a later date. After the foregoing is no longer necessary, KEHILA will destroy or render your Personal Information unidentifiable.
KEHILA uses secure procedures to destroy, delete, erase or convert the Personal Information into an anonymous form.
12. YOUR CONTROL OVER PERSONAL INFORMATION
You can choose to disclose as much or as little Personal Information as you are comfortable with.
You may at any time decline to provide any Personal Information. This may prevent KEHILA from providing you certain materials, information or services, features and capabilities available to you while visiting the Site, but it will not prevent you from otherwise visiting the Site.
13. ACCURACY OF PERSONAL INFORMATION
KEHILA assumes that the Personal Information you provide to it is accurate.
You may request the correction of inaccuracies in your Personal Information on file with KEHILA. Correction of such Information may be done directly by you via access provided by KEHILA on the Site or arranged by you contacting KEHILA’s Privacy Officer as provided for below. If you contact KEHILA with a request, it will take appropriate steps to update or correct the Personal Information that is under its control.
KEHILA will respond to you within 30 days after receipt of your written request or will notify you if a longer period is required by it in order to fully address your request, provided that an extension of the 30-day period is permitted by applicable privacy laws.
If KEHILA becomes aware that Personal Information is inaccurate, incomplete or out of date, it will revise the Personal Information and, if necessary, use reasonable efforts to inform third parties provided with inaccurate information so that they may correct their records. Personal Information about a former Participant is not actively maintained — for so long as it is held by KEHILA, it cannot assure the accuracy of such Information.
14. ACCESS TO PERSONAL INFORMATION
KEHILA provides a Participant with a reasonable right of access to and review of the Participant’s Personal Information held by it. KEHILA will endeavor to provide such Participant his/her Information within a reasonable time and no later than 30 days following its receipt of a written request. KEHILA requires verification to its satisfaction of a Participant’s identity prior to providing any Personal Information.
KEHILA will not charge a Participant for verifying or correcting such Participant’s Personal Information.
There may be circumstances where access cannot be granted. For example, where access would lead to the disclosure of Personal Information of another individual and that individual refuses to provide consent to the disclosure, or if the information is subject to privilege or other legal restrictions. In such cases, you will be notified of the reason why it is not possible to grant access to your Personal Information.
Currently, KEHILA maintains Personal Information in virtual servers that may be located in Canada, the United States or elsewhere. The principal place in which KEHILA servers currently hold Personal Information is Scottsdale, Arizona, U.S.A. Any ‘hard copy’ of Personal Information is maintained by KEHILA in Toronto and Vaughan, Ontario.
15. VISITING KEHILA’S WEBSITE
A visitor to the Site is not required to reveal any individually identifiable information, such as name, address, or telephone number. Nor is such information collected passively by electronic means. To access certain parts of the Site, Participants will need to provide certain Personal Information. Such personal information will only be used for the Identified Purposes.
Personal Information is collected when an individual voluntarily completes an online registration or application form, a consent to contact form, completes an online survey or questionnaire, or participates in a contest. That Information is collected, used or disclosed in a manner consistent with this Policy. Email addresses are also collected during an individual’s online registration or application or another on-line process, but individuals are given the option to indicate that they do not wish to receive any unsolicited electronic communication.
KEHILA’s web server collects visitor information in the form of the visitor’s domain or Internet Protocol (IP) address and information regarding which pages of the Site a visitor is accessing. KEHILA uses this information internally to better serve visitors by helping us to:
• manage our sites;
• diagnose any technical problems; and
• improve the content of the Site.
16. USE OF ELECTRONIC COOKIES
KEHILA’s Privacy Officer is responsible for ensuring KEHILA’s compliance with its obligations under this Policy.
18. HOW TO CONTACT KEHILA — COMPLIANCE ENQUIRIES etc.
If you are not satisfied with the way KEHILA has responded to a complaint, you may contact the Office of the Privacy Commissioner of Canada.