What is Personal Information?
Personal information is any information about an identifiable individual, other than the person’s business title or business contact information (such as business phone number and business address). Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).
What Personal Information do we Collect?
We collect and maintain different types of personal information about individuals with whom we interact which is relevant for purposes that a reasonable person would consider appropriate for a donor-charity relationship.
- Contact and identification information, such as your name, address, telephone number and e-mail address;
- Donation information such as date of gift, amount of gift, appeal (the campaign you contributed to), name of spouse or partner if it was a joint gift; receipt number. As much of our communication (thank you, mailings etc) is in either English or French, not bilingual, we also collect preferred language.
- Financial information such as your payment methods and preferences, billing and banking information (credit card number and expiry date or chequing account transit numbers, whichever payment type you prefer in order to process your donation);
- Product and service related information concerning the sale of greeting cards, books and gifts and other products or services that we provide to you;
- Other personal information used for purposes that a reasonable person would consider appropriate in light of the circumstances.
As a general rule, SmileChina collects your personal information directly from you and will not collect personal information about you from a third party without your consent. However, we occasionally exchange the names of some of our supporters with other like-minded charities and so, we may also receive information (name and contact information only) collected by those other charities. Where this is the case, we will take reasonable steps to ensure that those other charities have represented to us that they have the right to disclose your information to us.
Why Do We Collect Personal Information?
SmileChina collects personal information to further its fundraising and public education and advocacy commitments, as well as to establish, maintain and manage our relationship with you. Certain of the information is collected to satisfy the requirements of Canada Customs and Revenue Agency (CCRA).
How do we Use Your Personal Information?
When do we Disclose Your Personal Information?
SmileChina does not sell your personal information to any third party. We will share your personal information with employees who require such information to establish, maintain and manage our relationship with you. Third party service providers may be engaged by SmileChina to perform a variety of functions, such as to mail our brochures, to process your donation, to fulfill your order or to provide technical services for our Web site etc. These third party suppliers have access to personal information if needed to perform the functions for which they are retained. However, we direct that those third party suppliers may only use such personal information for the purpose of performing their roles and may not use it for any other purpose. In these cases, where the information is transferred to a third party, SmileChina will demand reasonable assurance that the third parties will protect your information in conformity with our privacy practices.
SmileChina will not otherwise disclose your personal information for purposes other than those for which it was collected, except as may be permitted or required by law, or with your consent.
It is important to us that we only collect, use or disclose your personal information which is not publicly available, where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.
Typically, we will seek your consent at the time that we collect the personal information. In certain circumstances, your consent may be obtained after collection but prior to its use or disclosure. If we plan to use or disclose your personal information for a purpose not previously identified, we will advise you of this purpose before such use or disclosure.
You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting SmileChina Supporter Relations Department as set out above. In some circumstances, a change in or withdrawal of consent may severely limit our ability to acquire products or services from, or provide products or services to, you. If you are a SmileChina donor or supporter, we are required, by law, to maintain certain of your personal information for CCRA purposes.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable legal and regulatory requirements.
How is Your Personal Information Protected?
SmileChina maintains physical, electronic and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to prevent your personal information from loss and unauthorized access, modification or disclosure.
Updating Your Personal Information
Since we use your personal information to contact you, it is important that the information contained in our records is both accurate and current. If you wish to verify, correct or update your personal information, or if your personal information happens to change during the course of our business relationship, you are responsible for keeping us informed of such changes. Please contact firstname.lastname@example.org to update your information.
Access to Your Personal Information
You can request to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. At that time, we will need specific information from you to enable us to search for, and provide you with, the personal information that we hold about you. A nominal fee may apply depending on the type of information requested.
SmileChina’s Web Site
Non-personal information, such as the name of the domain from which you access the Internet, the dates and times you access our Web site and the Internet address of the Web site from which you may be linking directly to our Web site, is collected and used to determine the volume of traffic on our Web site. This information also enables us to identify ways in which our Web site can be improved to serve you better.
The security of personal information is a high priority at SmileChina and its affiliates. We maintain this Web site and all associated data with technical, administrative and physical safeguards to protect against loss, unauthorized access, misuse, modification and improper disclosure. All underlying machines and firewalls at network access points have restricted access. While no computer system can ever be fully protected against every possible hazard, we provide reasonable and appropriate security controls to protect our Web site and its information.
Our Web site contains links to other Web sites that may be subject to less stringent privacy standards. SmileChina cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these Web sites. You should review the privacy policies of these Web sites before providing them with personal information.
Inquiries, Concerns and Requests for Access