1. SCOPE OF POLICY
4. LIMITS ON COLLECTION, USE, DISCLOSURE AND RETENTION
7. SAFEGUARDING PERSONAL INFORMATION
8. YOUR RIGHTS
9. CHANGES TO POLICY
10. DO NOT TRACK SIGNALS
This Policy addresses personal information about individuals and does not apply to information about corporate or commercial entities who are our suppliers or customers. “Personal Information” means information that can be used to identify an individual. In most cases, we collect Personal Information when you are referred to and/or enroll in a program or workshop (a “Program”) that we offer. Occasionally, we may collect Personal Information from a third party based on your consent or as otherwise permitted by law. Specifically, we may collect the following categories of Personal Information:
(a) your contact details: name, address, e-mail address, telephone number, credit/debit card or other payment details;
(b) employment and volunteer information;
(c) information about your enrolment in and completion of our Programs; and
(d) the communications you exchange with us or direct to us via letters, emails, calls and social media.
Personal Information may be subject to protection under other policies and practices and through contractual arrangements, including confidentiality agreements.
If you provide Personal Information to us about another person, you must have their consent to do so and you are responsible for telling the other person that you have provided their Personal Information to us. You must inform them that CCMI may use their Personal Information and refer them to this Policy. By providing Personal Information relating to another person to CCMI, you represent that you are legally permitted to provide such Personal Information, and CCMI will not be responsible for verifying any such authorization.
CCMI is accountable and responsible for Personal Information under its control. CCMI has designated a Privacy Officer who is accountable for CCMI’s compliance with this Policy.
CCMI will adopt procedures to protect Personal Information, receive and respond to complaints and inquiries, train staff regarding privacy policies and procedures and communicate policies and procedures to you.
CCMI collects your Personal Information for the following purposes:
(a) to authenticate your identity, register your account and authenticate you when you log into our account;
(b) to provide and administer Programs;
(c) customer services communications, including to manage our relationship with you and improve our Programs;
(d) to conduct research for the further development of our Programs in order to provide you and others with a better experience and drive growth and engagement in our Programs;
(e) to determine which Programs may meet your potential needs and to determine your eligibility for certain Programs;
(f) to investigate, respond to and resolve complaints, security and service-related issues;
(g) to inform the organization(s) that is funding and/or facilitating your participation in the Programs and/or your employer of your progress in and completion of Programs;
(h) to enforce our Terms of Service;
(i) credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes;
(j) to comply with legal and regulatory requirements; and
(k) for any other reasonable purposes for which you have provided your express consent.
The purposes listed above are in our legitimate interests in operating as a not-for-profit organization and providing and improving the Programs, and are a reasonably necessary part of your relationship with us.
When your Personal Information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by law.
CCMI will obtain your consent to collect, use or disclose Personal Information except where CCMI is authorized or required by law to do so without consent. Your Personal Information will only be used, collected or disclosed for the purposes set out herein, any additional purposes disclosed to and consented to by you, and as authorized by law.
CCMI will not collect Personal Information indiscriminately and will limit its collection of your Personal Information to where we have lawful bases. Lawful bases include consent, contract and legitimate interests. Where we rely on your consent to process Personal Information, you have the right to withdraw or decline your consent at any time and, where we rely on legitimate interests, you have the right to object.
CCMI will keep Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. To determine the appropriate detention period, we consider the amount, nature and sensitivity of the Personal Information, the purposes for which we process it and whether we can achieve those purposes through other means.
CCMI will destroy, erase or make anonymous documents or other records containing Personal Information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the Personal Information and retention is no longer necessary for legal or business purposes.
CCMI will take due care when destroying Personal Information so as to prevent unauthorized access to such information.
Your consent may be express, unambiguously implied, or given through your authorized representative.
Consent may be provided orally, in writing, electronically, through action or otherwise. For example, oral consent could be expressed over the telephone at the time information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application form.
You may withdraw your consent at any time by written notice to CCMI. Upon receipt of your written notice, CCMI will stop collecting, using or disclosing your Personal Information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law, and CCMI will inform you of the consequences of the withdrawal, which may include the inability of CCMI to provide certain products or services for which the delivery of that Personal Information is a prerequisite.
You hereby consent to CCMI disclosing your Personal Information to certain third party providers under contract with CCMI for the purposes of assisting CCMI in providing and developing Programs and associated services. We may share your Personal Information with the following categories of third parties for this purpose:
(a) credit and debit card companies which facilitate your payments to us to process payment or ensure the security of your payment transaction;
(b) providers of outsourced information technology services; and
(c) legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in, in order to enforce our legal rights in relation to our contract with you.
In such circumstances the third party shall hold and use your Personal Information in compliance with privacy laws and shall not disclose your Personal Information without your consent pursuant to this Policy. Some service providers may be located outside of Canada where Personal Information may be subject to the laws of those jurisdictions. Such locations include India, the United States, the Netherlands, China, Germany and Ireland. We require all service providers to process and store your Personal Information in a secure manner and in accordance with European and Canadian laws on data protection.
It is possible that we will need to disclose Personal Information about you when required by law, subpoena or other legal process or if we have a good faith reason to believe that disclosure is reasonably necessary. We will take commercially reasonable steps to inform you of such disclosure.
CCMI will make a reasonable effort to ensure that the Personal Information it is collecting, using or disclosing is accurate and complete. CCMI will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate.
If you notify CCMI of the inaccuracy or incompleteness of Personal Information, CCMI will amend the information as required. If appropriate, CCMI will send the amended Personal Information to third parties to whom the Personal Information has been disclosed.
When a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, CCMI will annotate the Personal Information under its control with a note that a correction was requested but not made.
CCMI protects the Personal Information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
You should be aware that confidentiality and security are not assured when Personal Information is transmitted through e-mail or wireless communication. CCMI will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when Personal Information is transmitted by e-mail or wireless communication.
We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, and unauthorized access, disclosure, copying, use or modification. The Personal Information you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet. All payment details are transmitted over dedicated network infrastructure and stored in compliance with Payment Card Industry Data Security Standards.
You have the following rights:
(a)the right of access to the Personal Information under CCMI’s control, information about the ways in which that Personal Information is being used, and a description of the individuals and organizations to whom such Personal Information has been disclosed;
(b)the right of rectification of inaccurate Personal Information and right of completion of incomplete Personal Information;
(c)the right to erasure of Personal Information in certain circumstances;
(d)the right to restrict Personal Information processing in certain circumstances;
(e)the right to object to Personal Information processing for direct marketing purposes and other purposes;
(f)the right to Personal Information portability in certain circumstances; and
(g)the right to launch a complaint with a supervisory authority.
CCMI may charge a reasonable fee for providing Personal Information in response to an access request if such request is clearly unfounded or excessive and will provide an estimate of any such fee upon receiving an access to personal information request. CCMI may require a deposit for all or part of the fee.
CCMI will make Personal Information available within the lesser of 30 days or one calendar month from the date of request or will provide written notice and explanation if additional time is required to fulfill the request.
Where a request is refused in whole or in part, CCMI will notify you in writing, giving the reason for refusal and outlining further steps which are available to you.
To keep pace with economic and technological changes, CCMI may revise this Policy from time to time. The revised Policy will be posted on our website and will come into effect 30 days after it is posted. If the changes are materials, we will provide notice to you by email or a notice on our website to provide you with the opportunity to review the changes before they become effective. If you object to any changes, you may close your account or unsubscribe.
We have not implemented the necessary program changes to honour “Do Not Track” browser signals for users in the U.S.
PO Box 1343, Vernon, BC, V1T6N6
I hereby consent to CCMI collecting, using, disclosing, and processing my personal information as set out herein.
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