Can Praxis EAL Privacy Policy

1. PURPOSE AND SCOPE

Can Praxis EAL (“Can Praxis”) respects your privacy and is committed to protecting your personal information. This privacy policy contains information on how we collect and manage your personal information when you visit our Website at canpraxis.com (the “Website”) and provides information about your privacy rights and how this policy complies with the Personal Information Protection Act 2003 c P-6.5 (the “Act”).

By submitting personal information to Can Praxis or its service providers and agents (collectively referred to as Can Praxis, “we”, “us” or “our” in the Privacy Policy), you agree that we may collect, use and disclose such personal information in accordance with this Privacy Policy and as permitted or required by law.

Subject to any applicable legal or contractual requirements, you may refuse or withdraw your consent to one or more identified purposes at any time by contacting us.

If you refuse or withdraw your consent, we may not be able to provide you, or continue to provide you, with certain services or information.

2. COLLECTION OF YOUR PERSONAL INFORMATION

Can Praxis is a registered Canadian charity. We provide mental health programming and engage in a variety of services to facilitate fundraising in Canada.

Can Praxis collects and processes personal information through:
• our website for donors, which offers a user-friendly way for individuals to donate to Can Praxis; and
• the use of software tools and online payment processing technologies to collect donations and launch fundraising events online.

3. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

Personal information means any information about an identifiable individual. It does not include personal information where all references to the identity of the relevant individual have been removed (anonymous personal information). Personal information that Can Praxis collects includes both personal information you provide as well as automatically gathered personal information.

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

• Identity Personal information includes:
o username or similar identifier,
o first name, last name, title, company you work for, and in the case of individuals representing charities using our service, your job title, role and/or level of experience.
• Contact Personal information includes address, email address and telephone numbers.
• Financial Personal information includes bank account, credit card details and securities related information in the event you donate securities or mutual funds to Can Praxis (including your mutual fund or security name, number of units, investment firm, account number, financial advisor name, email, phone number.)
• Transaction Personal information includes details about payments from you and the purchase of products.
• Technical Personal information includes internet protocol (IP) address, your personal login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Profile Personal information includes your username and password, donations made by you, your interests, preferences, surveys, and feedback.
• Usage Personal information includes information about how you use our Website and our Services.
• Marketing and Communications Personal information includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share aggregated personal information such as statistical or demographic information. When information is aggregated and not “about an identifiable individual”, the information is not personal information for the purposes of the Act. For example, we may aggregate your Personal Usage information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated personal information with identifiable data so that it can directly or indirectly identify you, we treat the combined information as personal information, which will only be used in accordance with this Privacy Policy and the Act.

We do not collect any Special Categories of Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric information). Nor do we collect any information about criminal convictions and offences.

If you provide Can Praxis with personal information of another individual, you represent that you have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.
This Website is not intended for children under the age of 18 and we do not knowingly collect personal information relating to children.

4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect personal information from and about you, including through:
1. Direct interactions. You may give us your Identity, Contact, Transaction and Financial Personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal information you provide when you:
A. make a donation (including one-time gifts, recurring gifts, gifts of securities, and receive a tax receipt, if applicable;
B. subscribe to our publications or to contact us or provide feedback;
C. request marketing to be sent to you; or
D. give us feedback or contact us.
2. Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Personal information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Personal information about you if you visit other websites employing our cookies.
3. Third parties or publicly available sources. We will receive personal information about you from various third parties as set out below (the “Parties”):
. Technical Personal information from:
A. analytics providers such as Google Analytics and Kindful;
B. digital marketing service platforms such as MailChimp and WordPress;
C. Contact, Financial and Transaction Personal information from providers of technical, payment processing and delivery services. Securities or mutual fund donations are processed by our broker.
4. Cookies. Like many websites, Can Praxis uses “cookies” to track user activity on the Website. A cookie is a commonly used piece of software that tracks user activity on the Website and is capable of enhancing your visit to the site. Cookies enable our Website to save and retrieve information that you enter (for example, user language preference). Cookies may remain on your computer after you leave the Website (until the cookie expires or is deleted by you). You can disable cookies by adjusting the settings on your internet browser, however, disabling cookies may affect your ability to access some pages on the Website.

5. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
• Where you consent to such collection and use, such as by consenting to this Privacy Policy.
• Where we need to comply with a legal obligation.

Note that we may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your personal information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

We have set out below a description of all the ways we plan to use your personal information, and the types of personal information required in the context. We have also identified our interests where appropriate.

(a) Purposes for which we will use your personal information:

Donations
To make a donation, including one-time and monthly monetary donations, and donations of securities and mutual funds and receive a charitable tax receipt, if applicable, CanPraxis requires the following types of personal information:
a) Identity
b) Contact
c) Financial
d) Transaction

Our interests include the performance of a contract with you (e.g. facilitating your donation according to your directive), and to recover sums due to us. We share your Financial personal information only with our third-party payment processor or broker, depending upon the type of donation. If you make a donation through a page created by a Team or Individual to fundraise for charity, we share your name and email with page owner so they can thank you for your contribution; we only share your name, donation amount and/or message to the fundraiser publicly on the page if you provide us explicit consent to do so.

Educational Services and Publications
To subscribe to our educational services or publications; to contact us or provide us feedback; to participate in a survey CanPraxis requires the following types of personal information:
a) Identity
b) Contact
c) Profile

This information is necessary to fulfil the performance of a contract with you, and for marketing purposes.

Marketing Programs
To improve the performance of our marketing programs, and to deliver relevant content and advertisements to serve you better and grow charitable giving CanPraxis requires the following types of personal information:
a) Identity
b) Contact
c) Profile
d) Usage
e) Marketing and Communications
f) Technical

This information is necessary to ensure that we provide the very best services to you. We share your personal information with a variety of third party analytics and digital marketing service providers to assist us with these activities such as Google Analytics, SproutSocial, Google Adwords, MailChimp, and Facebook.

Website and Charity Protection
To administer and protect our charity and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) CanPraxis requires the following types of personal information:
a) Identity
b) Contact
c) Technical
This information is necessary for running our business, provision of administration and IT services, network security and to prevent fraud.

Marketing
1. We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
2. We may use your Identity, Contact, Technical, Usage and Profile Personal information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services may be relevant for you.
3. Where Canada’s Antispam Legislation (CASL) applies to Can Praxis communications with users, donors or volunteers. Can Praxis is committed to complying with CASL and, in particular, the provisions setting out the requirements for sending commercial electronic messages.
4. You will receive marketing communications from us if you have requested information from us or made a donation to us, and you have not opted out of receiving that marketing.
5. We will get your express opt-in consent before we share your personal information with any third party for marketing purposes.
6. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
7. Where you opt-out of receiving these marketing messages, we may continue to use your personal information to provide you with the services you have requested from us.
8. Where our use of your personal information requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
• by informing us by email, post or phone using the contact details set out in this Privacy Policy; or
• by registration through our Website.

Change of Purpose
1. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or request your consent as appropriate.
3. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may share your personal information with the Parties set out above for the purposes set out under Item 4, Purposes for which we will use your personal information in this Privacy Policy.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

7. HOW DO WE PROTECT THE CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION?
We are committed to keeping the personal information provided to us secure, and we will take reasonable precautions to protect personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures that are intended to protect the personal information that we have under our control from:
• unauthorized access;
• improper use or disclosure;
• unauthorized modification; and
• unlawful destruction or accidental loss.
All of our members, employees, workers and personal information processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with, the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Website and all users of our services.

We have put in place procedures to deal with any suspected personal information breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

8. HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances, you can ask us to delete your personal information: see your legal rights Section below for further information. In some circumstances, we will anonymize your Personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. CONTACTING US
We have appointed a privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our privacy manager using the details set out below. If you have any questions about this Privacy Policy or our privacy practices, please contact our privacy manager in the following ways:

Can Praxis EAL (Attn. Chief Privacy Officer)
Steve Critchley
Box 10 Torrington, Alberta, Canada T0M 2B0
403-852-0907
Steve@canpraxis.com

You have the right to make a complaint at any time to the relevant supervisory authority for personal information protection issues. In Canada, you can contact the Office of the Privacy Commissioner of Canada (“OPC”), see https://www.priv.gc.ca/en/contact-the-opc/. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

(i) Links to other websites

This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the Privacy Policy of every Website you visit.

(ii) Changes

Can Praxis EAL reserves the right to modify or supplement this Privacy Policy at any time. If any changes are made to this Privacy Policy, a copy of the Privacy Policy as amended will be posted on our Website as soon as practicable following that update. Your continued use of the Website following such posting will signify your consent to its revised terms.

TRAIL SOFTWARE, INC. PRIVACY POLICY

This Privacy Policy (this “Privacy Policy”) describes Trail Software’s (d/b/a Kindful) (“Trail Software”, “Kindful,” “we,” “us,” or” “our”) collection, use, and disclosure of “personal information” that may be collected by Kindful anytime you (“you” or “user”) visit our website, [https://www.kindful.com] (this “Site”). “Personal information” means information about an identifiable individual who can be directly or indirectly identified, which does not include information of an aggregate or anonymous nature where a specific individual or individuals cannot be identified.

BY SUBMITTING YOUR INFORMATION THROUGH THIS SITE, YOU CONSENT TO THIS PRIVACY POLICY AND TO KINDFUL’S) COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION ACCORDING TO THE TERMS OF THIS PRIVACY POLICY. THIS SITE IS A GENERAL AUDIENCE SITE AND DOES NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE. IF YOU ARE UNDER 13 YEARS OF AGE, YOU ARE NOT PERMITTED TO USE THIS SITE.

This Privacy Policy is applicable only to this Site and does not apply to any third party websites or to other companies or persons. This Site may contain links to, and media and other content from, other sites. Because of the dynamic media capabilities of this Site, it may not be clear to you which links are embedded in this Site and which are embedded in third-party media or content. Kindful cannot and does not guarantee the privacy policies and practices of any third party. Kindful does not control, operate, or endorse any information, products, or services of any third-party websites that may be reached through links from this Site. The use of any personal information provided by you to such third party will be governed by that party’s privacy policy. If you are unsure whether a website is controlled, affiliated, or managed by Kindful, you should review the privacy policy at each linked website to determine how that site treats your personal information.

TRAIL SOFTWARE MAY CHANGE THIS PRIVACY POLICY FROM TIME TO TIME. THE REVISED POLICY WILL BE POSTED ON THIS SITE. Your continued use of this Site after Kindful posts a revised Privacy Policy signifies your acceptance of the revised Privacy Policy and your consent to Kindful’s collection, use, and disclosure of your personal information according to the terms of the updated Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. This Privacy Policy was last revised on July 1, 2019.

Information we collect and how we may use it

If you are a customer of Kindful, we collect certain information about you in order to provide you with our donor management system and/or online payment service (the “Service”). When you register for the Service we will request some personal information such as your name and email address, and information about your organization such as the name of your organization, Tax ID, mailing address, and tax designation. Furthermore, if you are opening a merchant account, Kindful may also obtain information about you from third party sources, including, without limitation, consumer reporting agencies. This information is used to contact you about the services on our Site for which you have expressed an interest. As part of the Service, we may also collect donor information on behalf of your organization. Except as may be expressly set forth herein, we will not use any donor information collected on your behalf for any purpose other than to provide the Service. Any tax or financial information we collect is used only to bill you for the Service. If you purchase the Service by credit card, this information will be transmitted to our credit card merchant account provider, and may be forwarded to your credit card provider. We do not store credit card information.

If you are a donor for a Kindful customer, we collect certain information from you in order to process your donation (“Donor Information”). Kindful will use Donor Information during the course of providing the Service to such Kindful customer. Kindful may also use Donor Information at an aggregate level for internal business analyses and fraud prevention. During the course of providing the Service to Kindful customers, Kindful may disclose Donor Information to banks, processors, card associations, and other financial institutions that are involved in the course of processing or screening the transaction applicable to the Donor Information.

We may use personal information for internal purposes to provide you with other products and services, or to contact you regarding administrative notices or communications relevant to you on this Site. In addition, we may use personal information to provide or improve products or services that you have requested.

Please note that personal information does not include “aggregate” information, which is data we collect about a group or category of users, from which individual identities or other personal information has been removed. This Privacy Policy in no way restricts or limits our collection, use, or our ability to sell such aggregate information.

Additional Limits on Use of Google User Data: Notwithstanding anything else in this Privacy Policy, the following types of your Google data will be subject to these additional restrictions:

We will only use access to read Gmail message bodies (including attachments), metadata, headers, and settings to display emails to authorized users of Kindful and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
We will not use this Gmail data for serving advertisements.
We will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for our internal operations and even then only when the data have been aggregated and anonymized.

When we disclose your information

Kindful takes your privacy very seriously. The information we collect is used to provide the Service, and, in general, is not shared with or sold to other organizations for commercial purposes. However, there are times when it may be advantageous for Kindful to make certain personal information about you available to companies that Kindful has a strategic relationship with or that perform work for Kindful to provide products and services to you on our behalf. These companies may help us process information, deliver products or services to you, provide customer service, manage and enhance user data, assess your interest in our products and services, or conduct user research or satisfaction surveys. We may also disclose your personal information, if you have authorized us to act on your behalf to initiate the creation of a merchant account for the purpose of accepting donations by credit card.

At times we may be required by law or litigation to disclose your personal information. We may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary.

In addition, Kindful may sell, transfer or otherwise share some or all of its assets in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. In such an event, personal information may be one of the assets transferred.

How we protect your personal information

Kindful takes precautions to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission that can be guaranteed against any interception or other type of misuse.

You can help us by also taking precautions to protect your personal data when you are on the internet. Do not share your registration information with anyone, and make sure you use a secure web browser.

Accessing your information

This Site may contain web pages through which you can correct or update some of the personal information you have provided to us. Kindful will make a good faith effort to make requested changes and correct your data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate purposes.

Cookies and other technologies

To make this Site more useful to you, we automatically gather general statistical information about this Site and its visitors, such as IP addresses (and information tied to IP addresses, such as screen size, color depth, language, java enabling, flash version, page title, host name, referring source, and page path), browsers, pages viewed, number of visitors, services purchased, etc. In doing so, we do not reference you by name, email, mailing address, or any similar personal information. We use this data in the aggregate to learn about our visitors and to improve our ability to cater to their needs. We may use third party vendors to gather general statistical information about this Site and its visitors as well as to perform certain services on behalf of this Site, such as hosting this Site, designing or operating this Site’s features, or performing other administrative services. We may provide these companies with access to your personal information to carry out the services they are performing for you or for Kindful.

As part of our service, we also use cookies to store and sometimes track information about you. A “cookie” is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. Generally, we use cookies to remind us who you are, to give you easier access to repeatedly used account information, to gather statistical information about usage, to research visiting patterns, and to help target advertisements based on user interests. In some instances, our partners and advertisers appearing at this Site may use their own cookies. Your web browser settings, which you may change at any time, determine if and how a cookie will be accepted. By changing those settings, you can accept all cookies, be notified when a cookie is set, or simply reject all cookies. If you decide to reject all cookies, please be aware that you may be required to re-enter your information more often and certain features of this Site may be unavailable to you.

Your California Privacy Rights

Residents of the State of California, under a provision of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes. Alternatively, the law provides that if the company has a privacy policy that gives either an Opt-out or Opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.

Kindful qualifies for the alternative option; it has a comprehensive privacy policy and provides you with details on how you may either Opt-out or Opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.

If you are a California resident and request information about how to exercise your third party disclosure choices you must send a request to support@kindful.com.