Effective Date: August 10, 2020
Brain Canada Foundation plays a unique and invaluable role as a national convenor of the community of those who support and advance brain research. Brain Canada’s main areas of focus are fundraising, granting and strengthening the brain research community.
Table of Contents
- Scope and Application
- Definition of “Personal Information”
- What Personal Information do we Collect?
- How we Collect Personal Information
- How we Use Personal Information
- How we Share Personal Information
- Third Parties
- How we Manage Consent
- Your Privacy Choices
- How we Store and Safeguard Personal Information
- Accessing and Correcting Your Personal Information
- California Consumers
- European Economic Area Individuals
- Whom Do I Contact With Privacy Questions?
1. Scope and Application
2. Definition of “Personal Information”
“Personal information” is any information that identifies, or could be reasonably associated with, an individual and their household (collectively, “individual” or “you”). This may include, for example, your name, contact information, email-address, and information relating to your application for research funding or your donation. It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be personal information.
3. What Personal Information do we Collect?
We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. We collect personal information in a variety of ways, including: directly from you, from third parties, and when you are interacting with us through our Website.
Personal information we collect may include:
- Contact information, such as your name, email and postal addresses, telephone number, or account information (for example, if you have created an account in order to apply for a grant);
- Information pertaining to your grant applications and funded research, such as letters of intent, research proposals, curriculum vitae, letters of reference, descriptions of research and financial reporting;
- Demographic information and interests, such as your age, sex, occupation, schooling, languages, and types of activities you participate in;
- Contacts and Connections, such as the names of business and personal contacts and their connection to you, and your affiliations with companies, institutions, foundations and other organizations, such as your position as a member of the board, business owner, or scholar at a research institution;
- Transactional information, such as bank account information, payment card details, donation amounts and donation history, amounts disbursed for research and expenses;
- Browsing activity on our Website, such as pages viewed, clickstream data, account login events, opt-out preferences, and IP addresses (as further detailed in the How we Collect Personal Information section) if it can identify you as an individual;
- Geolocation information that may be collected when you use our Website, although this information may not identify you as an individual;
- Employment application information, which may include some of the information described above, as well as letters of motivation and any additional information provided by you in the application form;
- Any other information you provide to us (as further detailed in the How we Collect Personal Information section).
4. How we Collect Personal Information
We collect personal information in a variety of ways, including: directly from you, from other sources, through online technologies (such as when you are interacting with us through our Website) and from third-party social networks.
More specifically, we collect personal information in the following ways:
a. Directly From You
You may provide personal information to us by mail, by email, over the telephone, through our Website or in any other direct manner, for instance when you apply for a grant, participate in a survey, communicate with us via telephone or email, submit a job application or upload content to our Website or social network pages (including photos or videos).
b. From Third Parties
We may receive personal information from third parties, including but not limited to organizations that partner with Brain Canada in respect of research program initiatives, fundraising or other projects. In these cases, we receive your personal information from third party organizations only if we have obtained your consent to do so, if you provided your consent to the third party, or if the law requires or permits us to do so.
For example: We may ask for your permission for an organization to release your personal information and share it with Brain Canada, and we may share this permission with that organization when we facilitate a program or initiative led by such organization, or when we partner with other organizations to provide programs or undertake initiatives.
c. Through our Digital Properties and Online Technologies
We may collect certain types of information electronically when you interact with our Website, email or social media accounts, or through the use of our or a third party’s technologies, which may include cookies, web beacons, pixels or analytics engines. This information supports the functioning of our Website, and helps us understand what actions you take on our Website and whether our website is working properly.
We may combine this information with other information, such as your donation or grant application history. We do this to support our understanding of donors, grant recipients, visitors to our Website and other individuals who interact or communicate with us. To learn more about the privacy choices available to you, please see Your Privacy Choices.
- We may collect information about your device and your browser, IP address, account login events, page views, session data, clickstream data, event data, crash data, and other technical data when you visit our Website.
- We may collect, combine and categorize your personal information on an aggregated basis to identify transaction and other usage patterns to help us analyze participation in our programs and the use of our services, to better serve users of our Website and the core purposes of Brain Canada.
The technologies we use include:
- Cookies, which are small text files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit our Website.
- Web beacons and pixels, techniques used to track who is visiting a web page or has opened an e-mail. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e. in a manner that prevents us from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
- Other technologies, such as analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization or customization of content and other methods to gain insights into our customers’ needs and preferences.
You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our Website. To learn more about the privacy choices available to you, please see Your Privacy Choices.
d. Third Party Social Networks
We may also obtain and use analytical and statistical information from third-party social networks to help us measure performance and effectiveness of content we display on social networks, for example, by measuring impressions and clicks on the content Brain Canada promotes.
5. How we Use Personal Information
We may use all categories of personal information detailed in section 3 to provide you with services, to manage our operations, to communicate offers and information we think might interest you, to generally enhance your experience with us, and as otherwise permitted or required by law.
Learn more about how we use your personal information for: providing services, managing our operations, advertising, and conducting research and data analytics.
We use your personal information for the following purposes:
a. Providing Programs and Services
We use your personal information in order to provide programs and services, for instance:
- Fundraising, including donor engagement and tailoring your experience as a Brain Canada donor;
- Processing your transactions and providing charitable tax receipts;
- Verifying your identity;
- Determining your eligibility for a program or service;
- Responding to your inquiries;
- Taking or verifying instructions from you;
- Creating, administering, and maintaining your accounts;
- Fulfilling your requests and inquiries.
b. Managing Our Operations
We use your personal information to manage our operations, for instance:
- Notifying you of changes to your account or our Website services, terms, conditions or policies and to provide you administrative messages, updates, legal notices, technical notices or security alerts;
- Deploying and managing our information technology applications and systems, including managing our Website;
- Managing and facilitating the use of our Website, which may include using cookies and other similar technology (as further detailed in the How we Collect Personal Information section);
- Managing and deploying our web and social media campaigns;
- Enabling your participation in programs or surveys;
- Maintaining the security of the public, our users and our employees;
- Protecting ourselves and third parties from errors and fraud;
- Maintaining our services;
- Processing your employment application;
- Reporting to Canada Revenue Agency and Revenu Québec;
- Reporting to Health Canada about donations and research programs; and
- Meeting our contractual, legal and regulatory obligations.
We use your personal information to inform you about news, programs, services, events, engagement opportunities, competitions or surveys, both on our own behalf and those of third parties, that we believe may be of interest to you. We may do this by communicating with you in a variety of ways, such as by email, telephone, or direct mail.
If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message. For more information on managing your marketing preferences, please see Your Privacy Choices.
d. Conducting Research and Data Analytics
We may use your personal information in order to conduct research and data analytics by tracking and analyzing current or previously collected information for the following purposes:
- Improving or developing new services;
- Managing and developing our operations;
- Understanding our donors’ interests and priorities and tailoring our fundraising activities;
- Monitoring the progress and expenses of funded research;
- Measuring the effectiveness of our programs, fundraising activities, and marketing; and
- Understanding how visitors interact with our Website and ensuring it works correctly.
When possible, we will use your information in an aggregated and/or de-identified format.
6. How we Share Personal Information
Learn more about how we may share personal information: with third parties, with service providers, in the course of a transfer of operations, for other permitted reasons, and with your consent.
a. Third Parties
b. Service Providers
In the course of providing our services we may share all categories of personal information detailed in the section What Personal Information do we Collect? with third party service providers who perform services on our behalf. These service providers help us operate and manage our technology systems and applications, internal procedures, infrastructure and marketing. They provide services to us, such as reviewing and processing grant applications and donations, monitoring funded research, sending emails and postal mail, data hosting, survey administration, providing marketing or fundraising campaign services, and analytics services (e.g. tracking effectiveness of our campaigns and analyzing usage of our Website). We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and adhere to confidentiality as well as security procedures and protections.
c. Transfer of Operations or Activities
We may decide to transfer all or part of our operations, assets or activities to a third party, to merge with another entity, or to engage in another form of corporate transaction. If your personal information is required in connection with any such transactions, we will comply with the legal requirements for the disclosure of personal information and ensure that the handling of your personal information complies with applicable privacy legislation in Canada.
d. Other Permitted Reasons
Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect Brain Canada, our employees, donors, grant recipients, volunteers or others. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.
e. With Your Consent
Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of Brain Canada, in accordance with applicable laws.
7. Third Parties
Third parties that you connect with directly through hyperlinks or other information provided on our website, such as our fundraising partners, may link and combine information about you to other personal information they may have collected on you, to achieve their own goals and purposes. We do not collect, use or disclose such information, which is subject to the privacy policies of the third party organization. Brain Canada encourages you to review the privacy policies of such organizations as well.
How we Manage Consent
If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the programs, opportunities to donate, services, surveys or information that you requested or that could be offered to you.
9. Your Privacy Choices
We want you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences, including, for example: managing your preferences within your account when applicable, applying or contacting us directly, changing your browser settings on your device, and/or, where available, using third party functionality.
Learn more about how to change your privacy choices through your account, when you apply or contact us directly, changing your browser settings and using third party functionality.
a. Within Your Account
If you have a Brain Canada account through our Smartsimple service, you can update or change your personal information.
b. When You Apply or Contact Us Directly
You may opt in to receiving email or other electronic communications at the time that you donate or enter our surveys, or any time thereafter. We may also have your implied consent to send you such electronic communications under applicable laws, or be exempt from the application of such laws for certain message content or certain circumstances.
You may opt out of receiving email communications by using the unsubscribe method provided within emails you receive.
Please note the following regarding withdrawal of consent or changes in your privacy preferences:
- Even if you have opted out of receiving marketing communications from us, we may still contact you for transactional purposes, in compliance with applicable laws (e.g., for customer service, information regarding the status of your grant application or other program information, or service or reminder notices). We may also need to contact you with questions or information regarding your service inquiries; and
- It may take some time for all of our records to reflect changes in your preferences (e.g., if you request that you not receive campaign or marketing communications from Brain Canada, your preference may not be captured for a campaign already in progress).
c. Changing Browser Settings
We use technologies to manage your interactions with our Website and to enhance your experience. For example, technologies such as cookies allow us to recognize when you use or return to our Website, providing you with a more frictionless experience. You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features of our Website.
Please refer to your browser instructions or help screen to learn more about how to block, delete and manage cookies on your computer or mobile device.
d. Third Party Functionality
We may use third parties (e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behaviour as you visit our Website. You can manage your privacy preferences with respect to certain third parties, such as Google, by using the functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our Website.
We also may embed links to other websites, including social media websites, on our Website. For more information about social media plug-in protocols for services such as Twitter, Facebook or Instagram and their impact on your privacy rights, please visit the appropriate social media help centre (e.g., Facebook’s Help Center at https://www.facebook.com/help/).
10. How we Store and Safeguard Personal Information
We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. Your personal information may be stored in foreign jurisdictions, in which case it will be subject to foreign laws. We store your personal information for as long as it is necessary to provide you with our services and for a reasonable time thereafter, or as permitted or required by law.
Learn more about how we protect personal information, where we keep personal information and cross-border transfers and how long we keep personal information.
a. How we Protect Personal Information
We employ organizational, physical and technological measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your personal information.
b. Where we Keep Personal Information and Cross-border Transfers
We may store personal information within Canada or the United States. Some of our service providers may also access, process or store your personal information outside of the country where you reside. We use reasonable safeguards to ensure that our service providers protect your personal information wherever it is used or stored.
As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
c. How Long we Keep Personal Information
We will store your personal information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your personal information will be securely destroyed or anonymized (so that the information no longer identifies you).
11. Accessing and Correcting Your Personal Information
You may have the right to access and rectify the personal information we hold about you under the law applicable in the jurisdiction where you reside. In this case, upon request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.
You can request access or rectification by contacting the Privacy Officer as described in the “Who Can You Contact With Privacy Questions?” section.
12. California Consumers
This section describes the rights you have under the California Consumer Protection Act (“CCPA”) if you are a consumer residing in California as defined under the CCPA.
a. How we Protect Personal Information
Once every 12 months, you may submit a verifiable request that we disclose the following information to you:
- The categories and specific pieces of personal information that we have collected about you in the last 12 months, as well as the sources from which personal informal is collected, the business and commercial purposes for collecting it, the categories of third parties with whom we have shared it; and
- The categories of personal information about you that we have disclosed for a business purpose in the last 12 months.
b. Right to Request that we Delete your Personal Information
You may submit a verifiable request that we delete any personal information that we have collected about you, subject to the exceptions provided for by the CCPA.
c. Methods for Exercising your Rights
You may exercise these rights using one of the methods described in section 16.
d. Non-Discrimination Right
We will not, because you have exercised any of the rights detailed in this section 12, deny you any goods or services, charge different prices or rates for goods or services, or provide you with a different level or quality of goods or services.
13. European Economic Area Individuals
If you are located in the European Economic Area (EEA), we will only process your personal data for the above purposes when we have a valid legal ground for the processing.
Our valid legal grounds for processing include:
You consented to the use of your personal data. For example, we may seek to obtain your consent to process your payment information when you make a donation, to send you newsletters or to process personal data deemed sensitive under applicable law;
We need your personal data to respond to your inquiries or to process an application (e.g. a job application);
The processing is necessary for compliance with a legal obligation or other regulatory obligations;
We have a legitimate interest in using your personal data, such as:
- Charity governance, including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes;
- Administration and operational management, including responding to solicited enquires, providing information and services, research, events management, the administration of volunteers as well as employment and recruitment requirements;
- Fundraising and campaigning, including administering campaigns and donations, and sending direct marketing and thank you letters by post and email.
If you are located in the EEA, in addition to the rights described in section 11, you may have the following rights:
- You have the right to ask us to stop using or to restrict the processing of your personal data in certain cases, i.e. where it is not needed to do what you provided it to us for, or if there is some disagreement about its accuracy or legitimate use.
- In some cases, you have your personal data deleted from our database (“right to erasure”) or to have it transferred to another organisation (“right to data portability”). Where you have requested that we don’t send you marketing materials, we will need to keep some limited information in order to ensure that you’re not contacted in the future.
We do not knowingly request or collect personal information from children under 13 years of age without prior verifiable consent of his or her parent or legal guardian and complying with any other legal requirements. If we become aware that we have unknowingly collected personal information about a child without verifiable parental or legal guardian consent, we will delete this information from our records or take reasonable available steps to de-identify the information.
16. Whom Do I Contact With Privacy Questions?
If you have any questions about how we handle your personal information, please contact us as indicated below. If you are participating in a program, event, fundraising initiative, competition or survey that is offered by us jointly with a third party, the third party may hold your personal information. If you have any questions or concerns, we will direct you to the appropriate party so that you may make enquiries as to that party’s privacy policies and practices.
Brain Canada Privacy Officer can be contacted at the following address:
Data Protection Officer
Brain Canada Foundation
1200 McGill College Avenue