Twice New Privacy Policy

Last updated: June 29, 2020

INTRODUCTION

The Women In Need Society Of Calgary ("WINS") is committed to protecting your privacy and the confidentiality of your personal information. This Privacy Policy sets out how WINS collects, uses, discloses and safeguards your personal information in connection with your use of our websites, including www.womeninneed.org, www.twicenewbywins.ca, www.winsyyc.ca and www.winsyyc.com, along with any services offered on such websites (collectively, our "Websites").

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, you must not use any of our Websites. By accessing or using our Websites, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy later in this document). Your continued use of our Websites after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

PERSONAL INFORMATION WE COLLECT

Your personal information is any information about you as an identifiable individual. In this section, we explain what personal information we collect from you and the purposes for which we collect that information.

WINS collects personal information to operate effectively and to provide you with the best experience possible using our Websites. Your personal information may be collected directly, such as when you email WINS. Your personal information may also be collected indirectly, such as when you provide information to a third party platform made available on the Websites. For example, the personal information collected indirectly from such third party platforms may be collected through:

• when you purchase items through the ‘Twice New by WINS’ online store on the Shopify platform;
• when you make a donation to WINS through the Kindful online platform; or
• when you subscribe to WINS’ newsletters and other periodic correspondence through the MailChimp online platform.

The personal information WINS collects includes the following:

• Name and contact information. Your first, middle, and last name, email address, postal address and phone number.
• Notes and comments. Information about any specific requests made by yourself in respect of any order, donation, or other service used by you on the Websites.
• Feedback surveys. Information you provide to us through feedback surveys.
• Limited Credit Card Information. The last four digits and expiry date of your credit card information.
• Other information. Other personal information you may choose to provide to WINS when corresponding with us by email, over the phone or otherwise.

Third-party platforms or websites used for the operation of our website may also collect, use, and disclose your personal information. While some of these third-party platforms may collect personal information on WINS’ behalf, including the information set forth above, they may also collect additional personal information about you or the devices that you use to access the Websites. We do not control these third party platforms or websites and note that such third parties also have their own privacy policies that govern how they collect, use and disclose your personal information. Links to these third party privacy policies have been reproduced below.

• MailChimp, in respect of our newsletter subscription services: https://mailchimp.com/legal/privacy/
• Kindful, in respect of donations may via the Websites to WINS: https://kindful.com/privacy-policy/
• Shopify, in respect of the Website’s ecommerce platforms: https://www.shopify.com/legal/privacy

We encourage you to read these third party privacy policies, along with the privacy policies of any other third-party websites, plug-ins, services, social networks, or applications linked to or made accessible through our Websites.

WHY WE COLLECT YOUR PERSONAL INFORMATION

WINS uses your personal information to facilitate your access to the Websites and to be able to effectively provide services to you over the Websites. WINS uses your personal information for the following purposes:

• To ship products to you that you purchase from us over the Websites.
• To provide you with a tax receipt for online donations made to WINS over the Websites.
• To otherwise provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To provide you with information about WINS activities and services, to the extent you subscribe to WINS’ email newsletters and other periodic correspondence.
• To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
• To notify you about changes to our Websites or any products or services we offer or provide though it.
• To improve our Website, products or services, marketing, or customer relationships and experiences.
• In any other way we may describe when you provide the information.

We may also use your information to contact you about WINS activities, soliciting donations for WINS or other services offered by WINS that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data or use the unsubscribe mechanism at the bottom of our e-mails.

HOW WE DISCLOSE YOUR INFORMATION

We may disclose personal information that we collect or you provide as described in this privacy policy:

• With your consent.
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of WINS' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by WINS about our customers and users is among the assets transferred.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 50 Calgarians clicked on the advertisement between 6pm and 8pm on weeknights. We may also use such aggregate information to help advertisers target a specific audience (for example, specific web browser users in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers' advertisement to that target audience.
• To contractors, service providers, and other third parties we use to support our business (such as delivery providers) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our Website Terms of Use, Terms of Sale (as applicable) and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of WINS, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

For example, we may transfer your personal information to the following service providers to the extent your use of the Websites engages these services providers. Links to the Privacy Policies of these services providers have been referenced – we encourage you to review these third party Privacy Policies:

• MailChimp, in respect of our newsletter subscription services: https://mailchimp.com/legal/privacy/
• Kindful, to process any donations made to WINS through the Websites: https://kindful.com/privacy-policy/
• Shopify, regarding any use of the Websites’ ecommerce platforms: https://www.shopify.com/legal/privacy
• Canada Post, in order to deliver products purchased from the Websites: https://www.canadapost.ca/cpc/en/our-company/about-us/privacy-policy/privacy-policy-introduction.page

Such third parties may process, store, and transfer your personal information outside of Canada in the United States. In those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. We encourage you to the review the privacy policies associated with such third parties to understand where your personal information may be processed, store or transferred.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing for the purposes set out in this privacy policy.

USER CONTRIBUTIONS

You may also provide information to be published or displayed (hereinafter, "posted") on public areas of the Websites or transmitted to other users of the Websites or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk although, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

CHILDREN UNDER THE AGE OF 13

Our Websites are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Websites. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on our Website, make any purchases through the Websites, use any of the interactive or public comment features of our Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@winsyyc.ca.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at twicenew@winsyyc.ca to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer/HR Manager at privacy@winsyyc.ca.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users of the Websites. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use [URL LINK TO WEBSITE'S TERMS OF USE].

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at twicenew@winsyyc.ca. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

CHANGE OF POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the www.twicenewbywins.ca home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

HR Manager (privacy@winsyyc.ca)

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.