(Last Updated: April 24, 2018)
ActivityPro Inc. and its successors and assigns (collectively “AP”) are concerned about the protection of personal information, and this is reflected in how AP conducts itself (including operating its services (“Services”) and its web site (the “Web Site”)).
In this policy, AP describes:
(i) how AP collects personal information;
(ii) the types of personal information that AP collects;
(iii) how that personal information may be used;
(iv) how that personal information will be safeguarded; and
(v) when and to whom that personal information may be disclosed.
AP recognizes privacy and security as being concerns for most individuals.
COMPLIANCE WITH LAWS
Please note that AP complies with the federal and provincial laws relating to the protection of personal information that apply in the Province of Ontario, Canada.
You can find out more about these laws by visiting the following web sites:
• the web site of the Privacy Commissioner of Canada located at www.priv.gc.ca; and
WHAT IS YOUR RELATIONSHIP TO AP?
A “Client” is a business that is receiving Services from AP. If you are connected to AP through a Client, you are a Participant, Staffer, or Viewer.
A “Participant” is an individual whose record of participating in activities offered by a Client is maintained by the Client using the Services. A “Staffer” is an individual who works for the Client in a paid or unpaid capacity. A “Viewer” is not a Staffer, but is authorized by or on behalf of a Participant to view information about the Participant.
A “User” is an individual who uses any Service or the Web Site.
What personal information is collected by AP and for what purposes is it used?
3.1 Providing Services
When a Client uses any Service, the Client may choose to include personal information in its data. This data is used by AP to provide the Services to the Client. If you are a Participant or a Viewer, you should check with the applicable Client to learn what, if any, types of personal information are being collected about you.
3.2 Operating the Web Site
When a User visits the Web Site, AP may collect the following types of personal information relating to all Users:
• the IP address from which the individual is accessing the Web Site;
• location data based on the IP address;
• which pages were accessed and for how long they were accessed; and
• data relating to how individuals interact with the Web Site (for example, the amount of time spent on a certain page).
By using the Web Site, you consent to the collection and use of this information by AP and its use in aggregated form by AP for the following purposes and for other purposes reasonably ancillary to them:
• to better understand how the Web Site is being used in order to improve upon the Web Site; and
• to tailor how an individual experiences the Web Site.
PLEASE NOTE: AP aggregates and depersonalizes this information. AP uses the aggregated and depersonalised information to:
(i) better understand how the Web Site is being used in order to improve upon the Web Site;
(ii) better understand the Services being used in order to improve upon AP’s Services; and
(iii) seek investment or funding in AP.
(b) Web-based Services
When a User seeks access to any Service, AP asks for that User`s user name and password. As well, AP may ask one or more security questions. The information described in this section
3.2(b) is used by AP for:
(i) checking if the individual is an authorized to access the Services and the scope of that access;
(ii) administering and operating the Service; and
(iii) other purposes reasonably ancillary to those purposes.
As well, the Web Site provides Users with several opportunities to “opt in” to receive from AP additional information, announcements or special offers in addition to those that are part of any Service. If an individual opts to receive additional information or announcements from AP, the personal information that he or she provides to AP may be used to:
(i) provide the additional information and announcements; and
(ii) tailor the types of information and announcements provided by AP to the individual.
Additionally, an individual who has previously opted to receive additional information and announcements may subsequently “opt out” by following the directions for doing so on the Web Site.
(d) Cookies, web beacons and request headers
When a User accesses the Web Site, AP’s server may attach a small text file to the User’s hard drive – a cookie. The cookie is used to identify the individual whenever he or she returns to the Web Site. The information contained in the cookie is also used to tailor how the User experiences the Web Site. Please note, by changing the settings of their web browsers, Users can prevent cookies from being set or delete them, but this may prevent the Users from participating in certain activities available via the Web Site. The Web Site may use web beacons (also known as tags, transparent .GIF files and single pixel .GIF files). They are used to better understand how the Web Site is being used in order to improve upon the Web Site. When a User accesses the Web Site, the User’s browser will make certain requests of the Web Site. It is typical for a browser to provide information about itself (for example, type and version number) and its capabilities in the headers of such requests. AP retains and aggregates this information, and AP uses it to:
• better understand how the Web Site is being used in order to improve upon the Web Site;
• better understand how the Services are being used in order to improve upon the Services;
• tailor how an individual experiences the Web Site to the individual; and
• seek investment or funding in AP.
With whom does AP share my personal information?
AP may share personal information which it has collected with its directors, officers and employees who need to use that information in connection with one or more of the purposes for which that personal information was collected.
From time to time, AP may engage service providers to provide certain limited services such as hosting the Web Site. AP will only provide those service providers with the personal information they need to deliver the service for which they were retained. AP will also require those service providers, through contractual means, to safeguard such information, maintain its confidentiality and not to use that information for any purpose other than providing the services for which they were retained. Please note that such services providers may not be located in Canada.
AP may access and/or disclose any personal information which it has collected if required or permitted to do so by law (for example, in order to comply with a legal requirement including but not limited to one imposed by a warrant, subpoena, court order or like instrument served on AP or in urgent circumstances to protect the life, health or security of any person).
AP may access and/or disclose any personal information which it has collected in order to prevent, take action or defend against or investigate:
(i) possible illegal or unlawful activities, fraud or suspected fraud;
(iii) any legal claims involving AP.
Please be aware that AP may disclose personal information to its successor or any assignee of:
(i) all or substantially all of its assets; or
(ii) all of its assets in relation to any Service.
4.2 Other Third Parties
Before disclosing personal information relating to an individual to a third party other than as set out in this policy, AP will obtain the affected individual’s consent to the disclosure.
AP WILL NOT ASK FOR YOUR PASSWORD BY EMAIL, TEXT OR OTHER MEANS OF ELECTRONIC MESSAGING
If you receive any unsolicited message claiming or appearing to come from AP that requests password information or user ID information, do not respond to it and report it to AP by forwarding a copy of it to [email protected]
What about information security?
AP uses physical, organizational and technological safeguards to protect personal information in its possession. When deciding what safeguards to implement, AP takes into account the sensitivity of the information being protected and the format in which the information is held. For example, AP uses encryption to safeguard certain types of personal information such as passwords when they are being transmitted over the Internet. However, please note that no data transmission over the Internet can be guaranteed to be completely secure. Consequently, AP expressly disclaims all representations, warranties and conditions (whether express or implied) that any information transmitted to or by AP over the Internet will be completely secure.
Inquiries, Requests for Access and Submitting Corrections
AP welcomes comments regarding this policy. If any User believes that AP has not adhered to this policy or would like to request access to or an amendment to his or her personal information being held by AP, please contact AP’s Privacy Officer by e-mail sent to the Privacy Officer via the Web Site (i.e. by using the “Contact Us About Privacy” button on the page on which this policy is displayed) or by regular mail sent to the following address:
1621 McEwen Dr., Suite 28
Whitby, ON L1N 9A5
Telephone: (905) 433-0040
Use the same method and address if you are requesting access to or an amendment of any personal information being held by AP that relates to another individual who lacks capacity and for whom you are parent, guardian or substitute decision maker. Depending on the type and volume of information requested, a fee may apply to processing it.
Retention and Destruction
AP has set retention schedules for any back-up of data relating to any Service or the back-up of the Web Site that it may create as part of AP’s routine operations. For information regarding retention periods relating to personal information that is part of a Client’s data, Users should talk to the applicable Client. With respect to any personal information supplied to AP other than as part of a Client’s data, AP keeps that personal information only for as long as the personal information is required for the purposes for which it was collected and compliance with laws and regulations. Consequently, there is no single retention period applicable to all instances of such personal information, but when that personal information is no longer required by AP for the purposes for which it was collected, AP destroys the personal information in a manner which takes into account the sensitivity of that information.
Changes to this Policy
AP will occasionally update or change this policy. When AP makes any change to this policy, an updated copy will be posted to the Web Site and for a period of at least 60 days, the word “updated” will appear next to the link to this policy on:
(i) the introductory page of the Web Site; and
(ii) the log-in page for the Web Site.
The date that this policy was last updated will appear at the top of the copy of it posted on the Web Site.
10.1 Giving Consent
By using the Website or any Service, one is consenting to AP’s collection, use and disclosure of his or her personally identifiable information in accordance with this policy.
10.2 Opting Out of Promotional Emails and Newsletters If an individual no longer wishes to receive newsletters and promotional communications from AP, the Individual may opt-out of receiving them by following the instructions included in each newsletter or the User may communicate its wish by emailing AP at [email protected] Please type “UNSUBSCRIBE” in the subject line and set out the affected email address.
10.3 Method for Withdrawing Any Other Consent If any individual wishes to withdraw any consent other than one related to newsletters and promotional communications from AP, he or she may do so by emailing AP at [email protected] Please type “WITHDRAWAL OF CONSENT” in the subject line, and clearly describe the consent being revoked. Please note that by refusing to provide certain types of personal information or by denying or withdrawing consent to use or disclose personally identifiable information for purposes identified in this policy, an individual may be unable to use the Services or the Web Site.