Adopted: August 2023
By providing any of your personal information to CIJA, including information obtained by us during your visits to or use of the website, other CIJA sites or microsites, social networking websites and web pages such as Facebook, Twitter, Instagram, YouTube or any other online site on which CIJA maintains a presence in connection with CIJA's activities (collectively, the "Site"), you hereby agree to all of the terms and conditions of this Policy and consent to the collection, use and disclosure of your personal information as described in this Policy. Please note that except as is set forth in this Policy, we reserve the right to share anonymized and/or aggregated data acquired by us through your provision of your personal information with third parties.
The terms "we", "us", and "our" used in the Policy refer, collectively, to CIJA and its departments, divisions, and their respective employees, mandataries, agents and other representatives (collectively, "CIJA Organization").
- WHAT IS "PERSONAL INFORMATION"?
- WHAT INFORMATION IS COLLECTED BY CIJA?
- HOW IS MY PERSONAL
- INFORMATION COLLECTED?
- HOW IS MY PERSONAL INFORMATION USED?
- TO WHOM MAY MY PERSONAL INFORMATION BE DISCLOSED?
- PERSONAL INFORMATION OUTSIDE OF CANADA
- PERSONAL INFORMATION OUTSIDE OF QUEBEC
- THIRD PARTIES & THIRD PARTY WEBSITES
- HOW DOES CIJA STORE AND SAFEGUARD MY INFORMATION?
- WHAT IS "PHISHING"?
- HOW DOES CIJA MANAGE CONSENT, AND HOW DO I EXERCISE MY CHOICES?
- HOW CAN I ACCESS OR CHANGE MY PERSONAL INFORMATION?
- CONTACTING US
WHAT IS "PERSONAL INFORMATION"?
"Personal information" is any information that identifies, or could be reasonably associated with, an individual ("individual" or "you"). This may include, for example, your name, contact information, email-address, and information relating to your account with us (as the case may be). It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.
WHAT INFORMATION IS COLLECTED BY CIJA?
Personal information we collect may include:
- Identifiers and contact information, such as your name, email and postal addresses, telephone number, photographs or videos or account information (for example, if you have downloaded our app or you have created an account upon signing up for our service);
- Demographic information and interests, such as your age, gender, occupation, languages, annual household income, types of activities you participate in and other interests;
- Contacts and Connections, such as the names of contacts and their connection to you, and your affiliations with companies, institutions, foundations and other organizations;
- Transactional information, such as bank account information, payment card details, donation amounts and donation history,
- Browsing activity on our Site, such as pages and events viewed, clickstream data, account login events, preferences, and IP addresses if it can identify you as an individual;
- Geolocation information collected when you use our Site;
- Any other information you provide to us.
HOW IS MY PERSONAL INFORMATION COLLECTED?
- Directly from you
We will also collect personal information from you when you provide information to us, such as by making a donation, signing up for an event, completing an entry form, ballot or survey, signing up for our newsletter (if any), by communicating with us by telephone, e-mail or otherwise, by setting up a user account and password, logging in as a registered user of the Site and providing information in your account(s), or by introducing or post any text, image, video, audio, or any information, content or other materials through any of CIJA social networking websites and web pages such as Facebook, Twitter, Instagram or YouTube. As a result of these actions, you might supply us with personal information, such as your name, date of birth, e-mail and postal addresses, telephone number(s), credit card information and financial information and in certain circumstances, your comments, suggestions, ideas, opinions and individual preferences. We may also maintain a record of your interests and acquire information about you from within the CIJA Organization.
Through Online Technologies
Each time you visit the Site, the following information may automatically be obtained and compiled: your internet protocol (IP) address and the domain name registry information associated with that IP address; identification of your internet browser, operating system and hardware platform you are using; the date and time of your visit; the name and address (URL) of the web page you viewed immediately prior to accessing the Site; your entire query (if any) that was entered into a search engine which led you to the Site; and any other "click stream" data. This information may be stored in our log files.
Additionally, the complete record of your actions at the Site, including all pages visited, the time spent on each page, the information sent or received and the names of all files uploaded or downloaded is collected. This tracking information may be compiled by us in the aggregate and be made available to third parties in order to identify demographic data regarding our users.
The technologies we use may include:
- Cookies, which are small data files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit our Site. In certain cases, this information is only kept during the session and is deleted when you close your browser. In other cases, the information is stored on your hard drive and, upon your next visit to the Site, the cookies are used to recall such information. Cookies may store a variety of information, including, a unique user ID that can be used to track the pages of the Site you have visited and the number of times that you view a particular page or other item on the Site, login or registration information and your preferences and your transaction history, where available.
- Web beacons and pixels, which are techniques used to track who is visiting a web page or has opened an e-mail. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e. in a manner that prevents us from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
- Other technologies, such as analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization or customization of content and other methods to gain insights into our customers' needs and preferences.
Third Party Social Networks
CIJA has installed on the Site various social media plug-in protocols, such as Facebook's "Like" button, which allow you to share your likes and interests in CIJA statements, events, special programs and initiatives with your friends and contacts. When you use one of these social media plug-in protocols, CIJA will have access to this information as well.
We may also obtain and use analytical and statistical information from third-party social networks to help us measure performance and effectiveness of content we display on social networks, for example, by measuring impressions and clicks on the content CIJA promotes.
HOW IS MY PERSONAL INFORMATION USED?
We use your personal information for the following purposes:
Providing Programs and Services
We use your personal information in order to provide programs and services, such as:
- Determining your eligibility for a program, or event;
- Verifying your identity;
- Enrolling you in an event or providing additional information (updates, changes, related or similar events etc.), including by email, telephone, text messaging or through social media;
- Fundraising, including donor engagement;
- Taking or verifying instructions from you; and
- Fulfilling your requests and responding to your inquiries.
Managing Our Operations
We use your personal information to manage our operations, for instance:
- Deploying and managing our information technology applications and systems, including managing our Site;
- Notifying you of changes to our services, terms, conditions or policies and to provide you administrative messages, updates, legal notices, technical notices or security alerts;
- Enabling your participation in programs, events or initiatives;
- Maintaining the security of the public, our users and our employees;
- Protecting ourselves and third parties from errors and fraud;
- Maintaining our services;
- Processing your employment application; and
- Meeting our contractual, legal and regulatory obligations.
We use your personal information to inform you about news, programs, services, events, donation opportunities, surveys or initiatives offered by CIJA and other affiliated or unaffiliated organizations within our community that we believe may be of interest to you. We may do this by communicating with you in a variety of ways, such as by email, telephone, direct mail, text message or through social media.
If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message. For more information on managing your preferences, please see "How does CIJA Manage Consent, and How Do I Exercise My Choices?", below.
Conducting Research and Analytics
We may use your personal information in order to conduct research and data analytics by tracking and analyzing current or previously collected information for the following purposes:
- Improving or developing new services;
- Managing and developing our operations;
- Understanding the Jewish community' interests and priorities and those of its allies and supporters;
- Measuring the effectiveness of our programs, events, activities, and marketing; and
- Understanding how visitors interact with our Site and ensuring it works correctly.
When possible, we will use your information in an aggregated and/or de-identified format.
In order to better serve you and the Jewish community at large, we may combine information you provide to us either in person, online, by telephone or in writing for any purpose. We may also combine your information with readily available demographic information in order to enable us to communicate with you, by telephone (including by way of automated dialing answering device) e-mail, mail or other electronic means about our services, surveys, events and other initiatives.
TO WHOM MAY MY PERSONAL INFORMATION BE DISCLOSED?
We will not disclose your personal information to any non-affiliated third party without your prior consent, other than as provided below:
- We may disclose your personal information with the Jewish Federations of Canada or United Israel Appeal of Canada (UIA), whose advocacy agent CIJA is so that they may communicate with you (whether by e-mail, telephone, post or otherwise) and provide you with promotional materials and additional information about its services, special programs, events and initiatives that may be of interest to you, or collect and use that information subject to and for other purposes contemplated by this Policy.
- When you agree to participate in a group trip or group activity, some of your personal information (and that of any minors in your care) may be shared from time to time with other members of the group, for purposes related to that trip or activity. For example, we may send group electronic communications (such as emails or texts) that may include names and email addresses or telephone numbers of group members. We will limit such sharing to the type and amount of information that is reasonable in the circumstances. By agreeing to participate in such activities, you are also agreeing to our sharing such personal information with group members for those purposes.
- We may transfer personal information to non-affiliated third party service providers for processing on our behalf (such as technical support, delivery services and financial institutions). We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and adhere to confidentiality as well as security procedures and protections.
- We may decide to transfer all or part of our operations or activities to a third party, to merge with another entity, or to engage in another form of legal transaction. If your personal information is required in connection with any such transactions, we will comply with the legal requirements for the disclosure of personal information and ensure that the handling of your personal information complies with applicable privacy legislation in Canada.
- Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect the property, interests and rights of CIJA, our members, , our employees, donors, or others. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.
Other than as listed above, we may, with your implied or express consent, share or disclose your personal information outside of CIJA, in accordance with applicable laws.
PERSONAL INFORMATION OUTSIDE OF CANADA
Your personal information may in some cases be transferred to jurisdictions outside Canada, to service providers or affiliated organizations. As a result, you understand that your personal information will be subject to the laws of other jurisdictions than Canada and may be available to foreign government authorities under lawful orders and laws applicable in such jurisdictions. Regardless of the company or person who processes your information and where it is processed, we will take steps to protect your information in accordance with applicable data protection laws and this Policy.
PERSONAL INFORMATION OUTSIDE QUEBEC
Your personal information may be transferred outside of the province of Quebec, to service providers, third party contractors, affiliated organizations, and CIJA regional offices. As a result, you understand that your personal information, in these instances, will be subject to the laws of other jurisdictions within Canada and outside of Canada and may be available to a foreign government authorities under lawful orders and laws applicable in such jurisdictions. Regardless of the company or person who processes your information and where it is processed, we will take steps to protect your information in accordance with applicable data protection laws and this Policy.
THIRD PARTIES & THIRD PARTY WEBSITES
Third parties that you connect with directly through hyperlinks or other information provided on our Site may collect, use or disclose your personal information, or link and combine information about you to other personal information they may have collected on you, to achieve their own goals and purposes.
When personal information is collected by any such third parties, CIJA does not collect, use or disclose such information, which is subject to the privacy policies of the third party organization. We do not control the collection, use or disclosure of such personal information and CIJA encourages you to review the privacy policies of such third party organizations.
HOW DOES CIJA STORE AND SAFEGUARD MY INFORMATION?
We have adopted physical, technological and organizational processes and procedures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used.
We will store your personal information for as long as necessary to fulfill the purposes for which it was collected and in accordance with CIJA's automatic computer back-up procedures and document retention policies, except where otherwise required or permitted by law.
WHAT IS "PHISHING"?
"Phishing" is a scam designed to obtain personal information. If you receive an e-mail which appears to be from CIJA requesting any personal information, please do not respond. We do not request any personal information by e-mail. Note that for certain programs, you may receive an e-mail inviting you to provide certain information through an online platform. Please ensure that the address is legitimate and not a "Phishing" scam. If you are uncertain, please contact our privacy officer.
In light of the importance of protecting children's privacy, we do not intend the Site for child audiences, and we do not seek to purposely collect, process or use on the Site any information relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her parent or other legal representative. If a parent or guardian discovers that his or her child has provided us with personally identifiable information, such parent or guardian has the right, upon request, to view the information provided by the child and/or to require that it be deleted from our records. In such a case we ask that the parent or guardian of the child contact us at the contact information provided in the "Contacting Us" section below for such purpose.
HOW DOES CIJA MANAGE CONSENT, AND HOW DO I EXERCISE MY CHOICES?
By accessing the Site, donating funds, responding to surveys or emails or otherwise providing information to us in connection with our programs, events, services or initiatives, you are providing your consent to the collection, use and disclosure of personal information as set out in this Policy. In some cases, your consent may be "implied", i.e., your action or inaction at the point of collection, use or sharing of your personal information is interpreted as evidence of consent.
We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Policy or in the terms and conditions of a specific program, event, fundraising campaign, service or survey that you applied to, signed up for, or participated in. Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us.
If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, you may not be able to use, obtain or participate in the programs, events, opportunities to donate, services, surveys or information that you requested or that could be offered to you.
In the event that you have already consented to the collection, use and/or disclosure of your personal information, you may subsequently withdraw your consent at any time, subject to legal or regulatory requirements or contractual obligations and reasonable notice, by contacting our privacy officer in the manner described in the section entitled "Contacting us" below. Our privacy officer will also be able to provide you with more information regarding the implications of withdrawing consent.
In respect of requests not to receive promotional communications from us, you may withdraw consent by following the "unsubscribe" instructions provided in any promotional communications sent to you, or by contacting us in the manner described in the section entitled "Contacting us" below. It may take up to ten (10) days to process your request, during which period you may continue to receive communications from CIJA.
We use technologies to manage your interactions with our Site and to enhance your experience, such as cookies. You may delete or disable certain of these technologies via your browser. Please refer to your browser instructions or help screen to learn more about how to block, delete and manage cookies on your computer or mobile device. We may also use third parties (e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behaviour as you visit our Site. You can manage your privacy preferences with respect to certain third parties by using the functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our Site.
HOW CAN I ACCESS OR CHANGE MY PERSONAL INFORMATION?
You are entitled to request access to, and, if necessary, correct your personal information collected by us. In order to make such a request, please contact our privacy officer in writing (see "Contacting us" below). It is your responsibility to provide accurate, correct and complete information.
You can also contact our privacy officer for any questions about or to make any complaint in relation to this Policy, as well as CIJA's privacy practices in general (see the "Contacting us" section below).
If you have any questions about how we handle your personal information, please contact us as indicated below. If you are participating in a program, event, service, initiative, competition or survey that is offered by us jointly with a third party, the third party may hold your personal information. If you have any questions or concerns, we will direct you to the appropriate party so that you may make enquiries as to that party's privacy policies and practices.