1. How the Centre for Holocaust Education and Scholarship (CHES) Protects Your Privacy

CHES is committed to respecting your privacy and protecting the personal information you provide when you access CHES’s website.

The following Privacy Policy, created in compliance with Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), explains why CHES collects information, how the information collected is used, disclosed and retained, how the information’s confidentiality is protected, and how you can make a request or complaint about the collection of your personal information.

2. Your Consent

CHES collects personal information from you only when you voluntarily provide it or else only with your consent as required by PIPEDA or other applicable law. By visiting and using this website, you agree to this Privacy Policy and the website terms of use [link].  If you do not agree to this Privacy Policy, do not use this website or provide personal information to CHES.

You may withdraw your consent to use your personal information at any time, subject to any legal or contractual restrictions. If you wish to withdraw your consent, please contact us at info@chesatottawa.ca.

3. Collection, Use, Disclosure and Retention

 Collection of Personal Information

By making a donation, requesting information, or registering for an account on our website, you are giving CHES permission to collect some of your personal information and to contact you by way of that information for the purposes outlined in this policy statement.

The personal information that you voluntarily provide to CHES is protected under the provisions of Canada’s federal privacy legislation. Depending on the nature of the transaction, CHES generally collects the following personal information from its users:

  • Full name
  • Account user name and password
  • Address (post and electronic)
  • Telephone number
  • Financial and payment information related to donations, including credit card information
  • Donation history

CHES may request demographic information such as your date of birth, gender and language preference for marketing and fundraising purposes, but you are not obligated to provide these.

Unless otherwise noted, CHES does not automatically gather any other specific personal information from you. The only way CHES would get this information is if you give it to us, for example by submitting a Survivor Listing or a Victim Listing on our website. Our online Survivor Listing and Victim Listing applications ask for more detailed personal information. As such, they have their own information collection and disclosure consent statement within the listing submission forms.

Web servers automatically collect certain information about a visit to a website, including the visitor’s Internet Protocol (IP) address. IP addresses are unique numbers assigned by Internet Service Providers (ISP) to all devices used to access the Internet. Web servers automatically log the IP addresses of visitors to their sites. The IP address, on its own, may not identify an individual. However, in certain circumstances, it could be used to identify an individual using the site. For this reason, we consider the IP address to be personal information, particularly when combined with other data automatically collected when a visitor requests a web page. This information can include the name of the page you visited and the date and time of your visit.

Personal information gathered by CHES on visitors to its website is protected and not provided to third parties, unless specifically authorized by you, with the possible exception of third party suppliers with whom CHES has entered into a contract that includes a confidentiality clause.

Uses

We use the information collected through CHES’s website for the following purposes:

  • To facilitate donation collection and processing
  • To provide tax receipts for online donations
  • To allow users to create and manage accounts on this website
  • To communicate relevant news and updates
  • To administer pre-authorized recurring donations
  • To provide client support and help
  • To provide relevant information to other charities to which a user makes a donation

CHES is committed to limiting the collection of personal information to that which is reasonably necessary for the identified purpose. CHES does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as permitted or required by law.

Disclosure

Your personal information is not shared, sold, rented, traded, or otherwise disclosed to any outside third party except with your consent or where authorized and/or required by law. CHES uses external services and suppliers to assist it in various functions, such as processing donations. Through agreements with these partners, and their commitment to protect your privacy, CHES manages and protects your information with the same level of sensitivity as it does its own. All outside third parties that enter into business relationships with CHES are required to adhere to this privacy policy, PIPEDA, and any other applicable law dealing with the protection of personal information.

CHES may have to disclose personal information to satisfy a law, regulation, or government request, or to satisfy a subpoena, search warrant, or court order.

CHES reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual sale, lease, merger, amalgamation, or any other type of acquisition, disposal, transfer, conveyance, or financing of all or part of CHES in order for you to continue to receive the same services from the third party.

Retention

Personal information is retained by CHES only so long as required by law or as is reasonable to fulfill the purposes for which it has been collected. Your consent to such purposes remains valid after termination of our relationship with you. CHES may retain personal information as a matter of course for business record retention such as commercial transactions, donor management and program and/or service management.

Collection of Non-Personal Information

CHES may also collect non-personal information about visitors to the website.

When you visit CHES’s website, CHES may automatically receive and temporarily store on CHES’s web server information that is supplied by your browser. Information automatically collected by CHES’s web server includes the following:

  • Network location and the Internet Protocol (IP) address of the computer you are using to contact CHES website;
  • Name of the domain you are using to access the Internet (e.g., “.com,” “.org,” “.net,” and “.ca”);
  • Type of browser you are using (e.g., Internet Explorer and Google Chrome);
  • Type of operating system you are using (e.g., Windows and Mac OS);
  • Date and time you accessed the site;
  • Pages of the site that you have accessed and documents you have downloaded from it; and
  • Internet address of the website from which you linked directly to our site, if applicable.

In most circumstances, this is anonymous statistical data, and CHES makes no attempt to link this data, or the IP addresses of the computers that have contacted its website, with the identity of the individual visiting the website—unless an attempt to damage the website has been detected or it is required by law. This automatic collection is never used to gather specific personal information, such as your name, your telephone number or your email address.

Cookies

Cookies are small files that may be placed on your hard drive by a website, without your knowledge, in order to monitor your use of the site. CHES uses “persistent” and “session” cookies to monitor usage of its website. The cookies used do not allow CHES to identify individuals. The cookies are compiled into statistical information on traffic patterns and are used to assess and improve the efficiency of its website.

Session cookies are cookies that are used on some portions of CHES’s website to store information within a session. During your visit to CHES’s website, your browser exchanges information with CHES’s web server. Session cookies facilitate this exchange by reminding the server which computer is making the request. No personal information is kept in session cookies, and session cookies are only stored in your browser’s temporary (i.e., cache) memory. When you log out of your session, the session cookie is no longer valid; it is discarded when you close your browser.

Persistent cookies are more permanent cookies that can be reread when you return to the website. The information in them is written onto your hard drive and remains there until the expiry date of the cookie or until you delete the file. Persistent cookies are used for tracking traffic patterns to and from CHES’s website and are also used to find out how visitors access, navigate and use the website. More information on tracking can be found in the section on Google Analytics.

Google Analytics

CHES uses Google Analytics, a web analytics service provided by Google Inc. to help measure traffic patterns to, from, and within CHES’s website. This analytics measurement tool uses “session” and “persistent” cookies to collect standard Internet log information and to track visitor behaviour in an anonymous form. When your computer requests CHES website, the following types of information are collected and used for web analytics:

  • the originating IP address
  • the date and time of the request
  • the type of browser used
  • the page(s) visited
  • referral website

The information generated by the cookies about your use of CHES’s website will be transmitted to Google. No personally identifying information is recorded or provided to Google. If you wish, you may opt out of being tracked by Google Analytics by disabling or refusing the cookies, by disabling JavaScript within your browser, or by using the Google Analytics Opt-Out Browser Add-On. Disabling Google Analytics or JavaScript will still permit you to access comparable information or services from CHES’s website; however, you might have difficulties accessing any secure services. To disable cookies or JavaScript, please refer to your vendor’s browser instruction guide

The information gathered by Google Analytics is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for CHES. The aggregate data and statistical reports are only used to help CHES make its website more useful to visitors and are only made available to web managers and other designated staff who require this information to perform their duties. CHES retains information collected for web analytics for a maximum period of eighteen (18) months. The information is not disclosed to any external third party service provider.

Data collected for Web analytics purposes may go outside of Canada to Google servers and may be processed in any country where Google operates servers. As such, data may be subject to the governing legislation of that country. For further information, consult the Google Analytics privacy policy.

Use of Websites by Children

CHES does not solicit personal information from children on its website. Visitors under the age of majority, in particular those under the age of thirteen (13), are required to obtain parental or guardian consent before submitting any personal information to CHES website.

4. Our Commitment to Data Security

CHES makes reasonable effort to protect personal information from loss, theft, unauthorized copying, use, modification, disclosure, and destruction. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, CHES has implemented appropriate physical, electronic, and managerial procedures to safeguard and secure the information it collects online. For example, CHES uses [state type of security encryption] to encrypt sensitive information including passwords and credit card numbers during your online transactions. Our servers are maintained in a secure location with access restricted to authorized personnel only.

5. Third Party Websites

This website may offer links to other third party websites. Be aware that operators of linked third party websites may also collect your personal information (including information generated through the use of cookies) when you access their websites. CHES is not responsible for how such third parties collect, use, or disclose your personal information.

6. Canada’s Anti-Spam Legislation

CHES is committed to complying with CASL as it applies to communications with users of this website, and particularly the requirements for sending commercial electronic messages.

7. Questions, Comments, and Complaints

If at any time you would like to access, correct or add to your personal information that CHES maintains, make a complaint regarding the management of your personal information, or be removed from any CHES contact lists, CHES encourages you to contact the Privacy Officer at CHES who will address your concerns, complaints and questions. Upon request, CHES will inform you of the existence and use of your personal information, inform you whether your personal information has been disclosed to any authorized third parties, and provide you with access to your personal information in our custody or under our control subject to legal restrictions.

If you have any questions or comments about this Privacy Policy, please contact us at info@chesatottawa.ca

If CHES is unable to resolve your complaint in a satisfactory manner, or you would like more information on the Personal Information Protection and Electronic Documents Act, you may contact the Office of the Privacy Commissioner of Canada at http://www.priv.gc.ca.

8. Changes to this Privacy Policy

CHES reviews and updates its policy practices as required. We recommend that you check this privacy policy periodically so that you are aware of any changes. The privacy policy in the form posted from time to time on this website shall be the privacy policy in effect at that time.