Effective Date: April 22, 2021
If you are not resident in Canada and/or are located in Canada, you bear all responsibility for ensuring that your use of all Media is compliant with all applicable laws.
Personal Information may include, for example, your name and home address, your date of birth and gender, health information, your occupation, medical conditions or other health information, your personal financial records or credit information, or any personal identification numbers.
INFORMATION COLLECTED & USES
In the course of operating the Media, we may collect Personal Information and other information from you or relating to you.
Personal Information is collected by us when you choose to provide it to us. Some examples of such collection are provided herein, but these do not represent an exhaustive list of possible collection of Personal Information from you.
We collect Personal Information from you when you register or set up an account for any Media Sites. Also, if you choose to contact us either via telephone or email, we may keep a record of that phone call and/or correspondence which may contain Personal Information.
We may also receive Personal Information relating to you from our business partners and other third parties. For example, we will receive such information if you have provided consent for them to share such information with us.
If you donate to Salt + Light Media, some of your Personal Information is required to be collected in order for us to process your donation. For example, we may collect your name, address(es), phone number, email address, and payment information.
If you purchase a product from our online store, we will collect some of your Personal Information that is required to process your order. For example, we may collect your name, billing address, mailing address, phone number, email address, and payment information. This information is used to complete your order. We may store such information, including your telephone number which may be used to contact you further should there be a problem with your order or for another business-related purpose.
We further may collect, use or disclose Personal Information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:
- To allow you to participate in a contest;
- To receive and process your comments about the business, and for other business activities;
- To provide Media and/or access to any Media Site;
- To comply with our legal obligations and regulatory requirements;
- To provide information to anyone working with or for Salt + Light Media as needed for the provision of any Media, such as our agents, suppliers or service providers;
- To develop and manage our business and operations, including but not limited to for billing, accounting and debt collection services relating to any Media;
- To establish, maintain and manage our relationships with users of the Media;
- To respond to questions and concerns of users;
- To detect and protect Salt + Light Media and third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing Personal Information with our insurers, and to otherwise communicate with our insurers;
- To review potential fraud and as required in the course of activities to achieve credit risk reduction;
- To generate, maintain, and utilize (as required to provide the Media) a user’s account for any Media;
- To generate analytics and statistical data;
- to provide you with information you have requested from us, for example, we may, from time-to-time, use your Personal Information to contact you about changes or enhancements related to Salt + Light Media;
- to send you materials via email about products and services that we feel may be of interest to you (if you no longer want to subscribe to our emailed materials, you may do so by clicking unsubscribe at the bottom of the particular email. It typically takes 5 business days for complete removal); and
- For any other purpose for which Salt + Light Media has your consent.
Privacy legislation requires Salt + Light Media to obtain the consent of an individual to the collection, use or disclosure of Personal Information in many circumstances.
When we receive Personal Information from you for the purposes of providing you with any Media, or for other uses identified herein, you are providing us with consent as follows:
- to allow us to deal with that Personal Information in a reasonable manner;
- to allow us to provide your Personal Information to third parties we engage to provide or support the Media;
- to allow us to use and store your Personal Information for the purpose of providing you with the Media; and
- to allow us to transfer your Personal Information outside of Canada (whereby your Personal Information will be treated in accordance with applicable foreign laws) for the purpose of storage and use of your Personal Information by Salt + Light Media, and by any third-party service provider that controls the server where such Personal Information is stored, as required for such storage and for all uses by Salt + Light Media thereof.
If you need to provide us with Personal Information about other individuals, you represent and warrant to us that, where required by law and prior to your disclosure to us, you will obtain the consent of each individual to the collection, use and disclosure by us for the specific purpose(s) that the disclosure is made by you.
Providing us with your Personal Information is always your choice. When you request any Media from us we ask that you provide information that enables us to respond to your request and/or provide you with the requested Media. In doing so, you consent to our collection, use and disclosure to appropriate third parties of such Personal Information for these purposes.
There are legal exceptions where we will not need to obtain consent or explain the purposes for the collection, use or disclosure of Personal Information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if we must comply with a court order or governmental order.
We may use Personal Information without your knowledge or consent in limited circumstances whereby we are required to provide Personal Information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstances we may have a legal duty or right to disclose Personal Information without your knowledge or consent. Various government agencies and law enforcement, have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations.
Salt + Light Media does not actively or knowingly collect Personal Information from children or anyone below the age majority in their applicable jurisdiction. We are committed to protecting the privacy of children. If Personal Information has been collected inadvertently from a child, the guardian of the child may contact us for the purpose of deleting this information. If we believe any person under the age of majority in his or her jurisdiction of residence is using the Media we will not process any Personal Information of that person.
LIMITED USE, DISCLOSURE AND RETENTION
NON-PERSONAL INFORMATION & ANONYMIZATION
We may also collect non-personal information, being information that does not identify an individual. Examples of non-personal information we may collect include, but are not limited to, your web browser version or your operating system. We also may obtain information about which website you have come from or that you visit next after using any Media. Other non-personal information is collected or derived by us in the course of operating the Media. Non-personal information which is provided through your browser, or stored on a “Cookie”, occurs when you choose to visit some Media, such as our websites.
We may also generate anonymized data. Anonymized data will not include any information that specifically identifies an individual. We may further generate aggregated data, including, but not limited to, the number of visitors and average time spent on any Media.
We will only collect Personal Information that is deemed necessary to meet the purpose for which such Personal Information is collected.
SAFEGUARDING PERSONAL INFORMATION
We employ reasonable physical, electronic and procedural safeguards that are designed to protect our systems and Personal Information under our control against unauthorized access and use. In accordance with appropriate industry standards in Canada, all safety and security measures are appropriate to the sensitivity level of the information collected. At Salt + Light Media’s sole discretion, our safeguards may be subjected to penetration-testing at scale, and our system may be monitored and validated by third parties. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information.
We may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, and we do not have any control over such external servers or services. We have implemented measures to prevent theft and loss, as well as unauthorized access, disclosure, use, modification, transfer, or modification of Personal Information. However, we cannot guarantee that such measures will achieve absolute security for your Personal Information.
You will bear full responsibility for the storage, maintenance, control and protection for all data that is processed or otherwise utilized by our Media that require data input. We bear no responsibility for such data whatsoever.
LINKS TO OTHER SITES
Our Media may contain links to other websites, media and services of third parties. While we try to link only to websites, media and services that share our high standards and respect for privacy, we cannot say for sure if this is the case. As such, Salt + Light Media is not responsible whatsoever for the content of, or the privacy practices employed by, other third-party entities and their websites. Any use by you of such links is at your sole risk and liability.
THIRD PARTY SERVICE PROVIDERS
We may engage third party service providers to assist with the provision of Media. For example, third party service providers may store Personal Information and other information, may provide Media via their platforms, and if we obtain your credit card information, we may employ third party payment processors using industry standard encryption technology to receive such information and process payments therewith. Salt + Light Media shall not be responsible for the activities of any such third-party service providers and such third-party service providers may require you to agree and comply with their terms, conditions and policies. You bear all responsibility and liability relating to such terms, conditions and policies and your compliance therewith. We further do not bear any responsibility or liability for any Personal Information or other information you provide to such third-party service providers.
While we will take steps to protect your Personal Information, Salt + Light Media cannot guarantee the security of any information you transmit to us. Salt + Light Media will not be responsible whatsoever for the inadvertent disclosure of your Personal Information or theft of your Personal Information. Consequently, Salt + Light Media, its affiliates, related companies and arm's length companies and any directors, officers, employees, agents do not provide any representation, warranty or guarantee that your Personal Information will be protected against misuse, loss or modification. We do not accept and do not bear any liability for the security of your, or any other user's, Personal Information.
PRIVACY AND OUR WEBSITES:
Each time any Media is utilized by a user, our web server or other tools may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities relating to the Media and/or webpages linked thereto. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. We may use this non-personal information to optimize the Media.
Please note that we may use your IP Address to display more appropriate and relevant content, based on your geographic area. Aggregate information derived from IP Addresses may be used to quantify how many visitors from a particular region visited our site.
We may collect anonymous information as you navigate and/or interact with the Media. We may use anonymous information to operate and improve the Media. We may also use anonymous information to track what visitors to the Media are looking at most frequently so we can recognize and deliver more of the desired features, products, services and Media.
We may collect information pertaining to you from third party sources, including but not limited to, for the purpose of generating your account for our Media. It is your responsibility to review such information in your account to ensure its accuracy.
We may use web beacons alone or in conjunction with cookies to compile information about you and your usage of the Media, as well as your interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you view a particular website tied to the web beacon, and a description of a website tied to the web beacon. For example, we may use web beacons to operate and improve the Media and email communications. We may use information from web beacons in combination with Personal Information about you to provide you with information about us and our Media.
Cookies are small text small text files that a website saves on your computer or mobile device when you visit the site. They save and retrieve pieces of information about your visit to the website - for example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can often give you tailored options based on the information it has stored about you on your last visit. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another.
On our Media, cookies can be set by us (first party cookies) or by our partners (third party cookies).
We cannot provide the names and purposes of the third-party cookies as we do not have access to that information, however they are necessary for us to provide our Media. These third parties face serious consequences if they are in breach of applicable privacy laws.
This is because some of the cookies we use are essential for parts of our Media to operate. Likewise, you may not be able to use some products and services on other websites without cookies.
To find out more about cookies, including to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
If you do not wish to accept cookies from our Media, please leave the Media immediately and then delete and block all cookies from the Media.
EUROPEAN UNION (EU) NOTICE
Transfers of Personal Information: We are a data controller and responsible for your personal data, which we process and store in Canada. The European Commission has decided that Canada ensures an adequate level of protection of individuals’ personal data. We may use the following safeguards when transferring your personal data to a country, other than Canada, that is not within the EU: (i) only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of protection for personal data; and (ii) where we use certain service providers, we may use specific contracts which give personal data the same protection it has in the EU.
Individual Rights – Actions you can take: Under the GDPR and other countries’ privacy laws, you may have certain rights with respect to the processing of your personal data. We have listed below the rights that you may be able to exercise in respect of the processing of your personal data, subject to applicable law. We take every reasonable step to ensure that the personal data that we process is limited to the personal data that is reasonably required in connection with the purposes set out in this Policy.
Please note that upon exercising any of the rights listed below, you may be requested to provide additional information for identification purposes. Such additional information shall not be used for any other purpose and will be removed after successful identification. Please note that some of the rights outlined below are described in more detail elsewhere in this Policy.
- Providing your data: You may choose not to provide your personal data to us. It should be noted that some features of our Services may not be fully available to you if you choose not to provide us with your personal data (e.g., we may not be able to process your orders without the necessary details).
- Right of access: You may have the right to request access to, or copies of, your personal data, together with information regarding the nature, processing and disclosure of that data.
- Unsubscribing: We include an unsubscribe link in all commercial electronic messages we send to you. You may withdraw your consent to receive commercial electronic messages at any time. If you do so, we will promptly update our databases, and will not send you further commercial electronic messages, but we may continue to contact you to the extent necessary for the purposes of any products or Services you have requested, as permitted in accordance with applicable laws.
- Checking and editing your personal data: Should you have an online user account, you may edit and complete your personal data directly yourself. If you do not have an online user account, you may contact us, and we will upon your request as soon as possible rectify, remove or complete the information which is incorrect, unnecessary, lacking or outdated.
- Blocking and deleting cookies: You may block the cookies using your browser settings. Please note that blocking the cookies may affect the usability of our websites. You may also delete the cookies from your browser via its settings, in which case the information collected by the previous cookie will not affect the account created based on the information collected after such deletion.
- Advertising. If we engage in online targeted advertising, you can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/, the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or your local equivalent organization, if any.
- Allowing use of location data: You may provide us with your consent for the use of location data in the options of your device should our Services request such location data. You may also withdraw such consent at any time by contacting us.
- Erasure, or restriction of our processing, of your data: Should you believe that we are process inaccurate data relating to you; the processing is illegal; we are not processing your data in accordance with the processing purpose; or you want to oppose the processing, you may contact us to request the erasure, or restrictions on the processing, of your data. Please note that we will investigate your request reasonably promptly, before deciding what action to take.
- Right to object: You may have the right to object, on legitimate grounds, to the processing of your personal data.
- Withdrawing your consent. You may at any time decide to withdraw your consent to the processing of your personal data. If your consent is withdrawn, it does not prevent us from processing your personal data based on other legal bases, in accordance with applicable law. However, it should be noted that your account(s) for our Services will be altered, and advantages granted to you via your account will be reset. Please note that withdrawal of consent does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal.
- Right to data portability: You may have the right to have your personal data transferred to another controller, in a structured, commonly used and machine-readable format, to the extent applicable.
- Right to Lodge a Complaint: If you feel that our processing of your personal data infringes on data protection laws in an applicable jurisdiction, you may have a legal right to lodge a complaint with a supervisory authority responsible for data protection in such jurisdiction.
GOOGLE ANALYTICS AND RECAPTCHA
While Salt + Light Media collects the Personal Information that you supply, it does so with the understanding that any such information that you supply is accurate. It is important to us that your Personal Information held by us is accurate and complete. Having accurate information about you enables us to provide you with better products and services. You can help us keep Personal Information up-to-date by keeping us informed of any changes, such as a change of address, telephone number or any other circumstances. We will not be able to provide you with any notices if we do not have accurate contact information for you and we will bear no responsibility for any action or omission as a result of our lack of accurate contact information for you.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
The amount of time we will retain Personal Information varies, depending on the Media we have provided and the nature of the Personal Information that we hold. We retain Personal Information for such a period of time as is necessary for us to maintain sufficient information so we may respond to any issues that arise at a later date or as is required by law.
When Personal Information is no longer required by us or by law, we will either convert it into an anonymized form or an aggregated non-identifying form, or we will appropriately destroy or erase the Personal Information in a manner that is in accordance with our current policies and procedures.
ACCESS AND CORRECTION
We recognize that you may have the right to access your Personal Information. Any access request must be made in writing to: email@example.com
We may charge a reasonable fee for providing information in response to an access request, and, upon request, we will provide an estimate of any such fee upon receiving a request to access information. We may require a deposit for all or part of the fee.
Where applicable or permitted, we will make the information available within 30 days or provide written notice when we require additional time to respond to a request for access to information.
In some situations, we may not be able to provide access to certain Personal Information as the right to access Personal Information is not absolute. If we do not provide you with the requested information, we will notify you in writing and explain our reason(s) for not fulfilling your request.
If you are unsure whether we have a record containing any of your Personal Information and would like to confirm the same, please send an email indicating all email addresses that you may have given us. We will endeavour to respond to you within 5 business days and correct any errors.
If you decide at any time that you do not want to receive any email materials to which you have subscribed, you may choose to unsubscribe to these emails by following the instructions at the end of the email message. Alternatively, you can contact us by email or by phone. We will endeavour to respond to you within 5 business days.
WITHDRAWAL OF CONSENT
You may, at any time, withdraw your consent to Salt + Light Media’s collection, use and disclosure of your Personal Information, subject to reasonable notice and any legal and/or contractual restrictions.
Should you choose to withdraw your consent, Salt + Light Media may be unable to provide, or continue to provide, the Media that can only be provided if we receive appropriate and required Personal Information.
Please contact Salt + Light Media to obtain further information about our policies and procedures, to seek access to Personal Information we may have about you, or if you have any unresolved inquiries or concerns. We will respond to you promptly and try to resolve your concerns. We may need to ask you for Personal Information to verify your identity. We can be contacted at: firstname.lastname@example.org or call us at +1 416.971.5353
SUCCESSORS AND ASSIGNS
© Salt and Light Catholic Media Foundation, 2021.