1. OUR COMMITMENT
In this privacy policy (this “Privacy Policy”), “Personal Information” means information about an individual. Personal Information does not include information that cannot be attributed to an individual. For example, information of an aggregate or anonymous nature.
The privacy of the Personal Information of individuals (“you”, “your”) is a priority for us. We take the privacy of your Personal Information very seriously. In developing this Privacy Policy, we want to assure you that we have taken into account your privacy and concerns about your Personal Information and those of others. We encourage you to review this Privacy Policy. We have created and implemented this Privacy Policy so that you understand how your Personal Information may be utilized and disclosed and how it is protected.
We are subject to the Personal Information Protection and Electronic Documents Act (Canada) and our privacy practices and this Privacy Policy reflect that.
If you have questions regarding this Privacy Policy or our privacy practices, then please contact our Privacy Officer. Their contact information is set out at the bottom of this Privacy Policy.
2. DEALING WITH US
By providing Personal Information in your dealings with us and using the Website with knowledge of this Privacy Policy, we will assume that you have consented to the collection, use and disclosure of Personal Information in accordance with the terms set out in this Privacy Policy.
In using the Website and in dealing with us you will have the ability to control the amount of Personal Information you are providing and therefore you may restrict the disclosure of Personal Information by not providing Personal Information to the Website or us in the first place. If you choose to limit the Personal Information you provide, it may limit the manner in which you can make use of the Website or otherwise interact with us.
3. COLLECTION
Generally, we will collect Personal Information directly from you. At the time of collection, the purpose of collection should be apparent or otherwise described in this Privacy Policy.
In some instances, we may collect your Personal Information directly from a third party. In that case, we will generally either obtain your consent to do so or we will require that the third party confirm to us that they are entitled to disclose your Personal Information to us.
4. USE
Except as otherwise provided in this Privacy Policy, when we use your Personal Information we will ensure that you previously provided your consent to that use or if you had not previously provided that consent, we will then obtain your consent if that use is not set out in this Privacy Policy or if that use was not readily apparent at the time we collected your Personal Information.
Set out below are certain circumstances where we may use your Personal Information without obtaining any further consent. By providing Personal Information to us, we are assuming that you are consenting to these uses unless you inform us otherwise. These are:
in connection with our marketing, operational and support services including email marketing campaigns;
using identification information and contact information, such as your name and e-mail address to provide information about us and the Website when you request that information;
using identification information and contact information, such as your name and e-mail address so that we can identify you and deliver services, including in connection with the Website, that you request and to communicate with you regarding those services;
using payment method preferences and related financial information that you provide to us so that we can obtain payment for the services that you request;
using information relating to your preferences so that we are able to deliver our services, including in connection with the Website, to you in accordance with those preferences;
using relationship information such as your service requests, instructions, comments and feed back to assist us in delivering services, including in connection with the Website, in accordance with your wishes;
using Personal Information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose. For example, if you send us an e-mail with a question or comment, we will use your e-mail address to respond to you. Further, we may store your e-mail and e-mail address and a copy of our response for future reference;
using your e-mail address to provide you with information about new features or enhancements to our services and the Website;
analyzing how Personal Information is being used to assist us in developing and enhancing our services and the Website; and
analyzing how Personal Information is being used to assist us in conducting market analysis and strategic planning.
Except as otherwise provided in this Privacy Policy, we will not use your Personal Information for any other purpose.
5. DISCLOSURE
Except as otherwise provided in this Privacy Policy, when we disclose your Personal Information we will ensure that you previously provided your consent to that disclosure or if you had not previously provided that consent, we will then obtain your consent if that disclosure is not set out in this Privacy Policy or if that disclosure was not readily apparent at the time we collected the Personal Information.
Set out below are certain circumstances where we may disclose your Personal Information without obtaining any further consent. By providing Personal Information to us, we are assuming that you are consenting to these disclosures unless you inform us otherwise. These are:
Personal Information that is supplied to the Website will be disclosed in accordance with the description of disclosures as set out in the related documentation for the Website or as may be readily apparent through the general operation of the Website;
In the event we transfer or are considering transferring control of any or all of our operations or services to another organization, we reserve the right to transfer and disclose Personal Information to that organization. However, we will require that the organization agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose Personal Information as we are similarly entitled under this Privacy Policy;
In the event we amalgamate with another organization, we reserve the right to permit that amalgamated organization to continue to use and disclose Personal Information. However, we will require that the amalgamated organization agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose Personal Information as we are similarly entitled under this Privacy Policy;
We may engage certain service providers. Those providers may provide services to us to assist us in our activities. Other providers may provide services directly to you at our request. As such, it may be necessary for us to disclose Personal Information to these providers. However, we will take steps to ensure that these providers will only use and disclose Personal Information as necessary to provide the services and that they will adhere to the terms of this Privacy Policy or their own similar privacy policy; and
We may work with other organizations towards some common purpose consistent with our objectives, including initiatives relating to The Common Platform. In that case, it may be necessary for us to disclose your Personal Information to these organizations. However, we will require that these organizations agree that they will only use and disclose your Personal Information as necessary for the common purpose and that they will adhere to the terms of this Privacy Policy.
6. OTHER COLLECTION, USE AND DISCLOSURE
We may monitor your use of the Website to ensure the proper use and operation of the Website and your compliance with any terms of use related to the Website or other related agreements.
As well, the law permits or requires the collection, use and disclosure of Personal Information without the knowledge or consent of the individual in a number of circumstances. We reserve the right to collect, use and disclose your Personal Information in these circumstances without your knowledge or consent as the law may permit or require.
7. WHEN YOU USE OUR SYSTEMS
We may also collect information which is not Personal Information such as aggregated Personal Information and other information submitted to us. Such information will not identify you personally – it is statistical data about our visitors and their use of our web-based systems. This statistical data does not identify any personal details whatsoever.
8. THIRD-PARTY SERVICE PROVIDERS
We engage a number of third-party service providers who assist us in our operations, including the following:
Google Apps for email and document creation and Google Analytics for Websites use:
Google LLC (hereafter “Google”)
1600 Amphitheater Parkway
Mountain View, CA 94043 USA
WordPress
Aut O’Mattic A8C Ireland Ltd.
Grand Canal Dock, 25 Herbert Pl
Dublin, D02 AY86
9. CONTACTING US
If you send us a message via application or contact forms on the Website, we will process the Personal Information inputted in the form fields, in particular, your name, your email address and your message. If you send us a message by email, we will save your message along with the sender details (your name, e-mail address, and any additional information added by your email program) in order to be able to answer it and also to respond to possible subsequent questions. This data processing is based on our legitimate interest to answer your request and handle possible follow-up requests from you.
10. USE OF COOKIES, BEACONS AND SCRIPTS
When you visit the Website, we place a small “cookie” text file on your device and use log files, web beacons (also knowns as clear GIFs and pixel tags) and embedded scripts (programming code) that are designed to collect information about your interactions including the pages, links and information you access. The “cookie” allows us to recognize your device when you return to the Website for a later visit. With the help of the cookie we can also analyze certain website use behavior, for example, which parts of the Website you use, how long you stay on the Website and when and how often you return to the Website. The cookie is deleted based on your browser settings or your manual cookie clearing. This data processing is carried out on the basis of our legitimate interest to better tailor our online presence to our visitors’ interests and the technology used by them (device and browser types), to analyse and optimise the Website’s functions and the efficiency of advertising measures. You can prevent the placing of cookies by going to the cookie settings of your Internet browser and switching off the use of cookies for the Website. In your browser settings, you can also delete cookies already stored.
11. GOOGLE ANALYTICS
We gather information about your use of the Website so the Website can be improved. We use Google Analytics, a web analytics service of Google. Google places a cookie on your device. With this cookie, Google can collect information about how you use the Website. The information we collect in this manner may include details about the computer, mobile phone, or other device used to access the Website and include other items such as your browser type, operating system, IP address, referring URLs/system and information on actions taken or interaction with the Website. This information is transmitted to a server in the US, where it is evaluated by Google and made available to us for our legitimate interest in the evaluation and optimization of the Website. We use Google Analytics with activated IP anonymization. This means that your IP address will usually be shortened so that the IP can no longer be traced back to you. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. The IP address provided by your browser will not be merged with other data provided by Google. You may prevent the use of cookies by selecting the appropriate settings on your browser.
12. SECURITY OF PERSONAL INFORMATION
We recognize our obligation to protect Personal Information in its possession and will make reasonable arrangements to secure that Personal Information against unauthorized access. These measures will be reasonable in the circumstance and may include providing access to only those individuals with a need to know the information, and electronic security measures as well as contractual measures, such as non-disclosure or confidentiality agreements.
13. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at any time by posting a new privacy policy in place of this one.
14. LIMITED NATURE OF THIS PRIVACY POLICY
Nothing contained in this Privacy Policy is intended to create a contract or agreement between us and you and you may not rely on it as such.
15. CONTACTING OR COMMUNICATING WITH US
If you:
have any questions with respect to our privacy policies or practises;
have any questions with respect to our handling of your Personal Information;
if you wish to request access to or correction of your Personal Information under our care or control; or if you are dissatisfied with our handling of your Personal Information,
please contact our Privacy Officer at:
The Opening Door
192 Spadina Avenue
Toronto, Ontario, Canada
M5T 2C2
email: support[at]theopeningdoor[dot]co