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CharityVillage Ltd. Privacy Policy

Updated effective January 12, 2015

Scope And Application Of The CharityVillage Ltd. Privacy Policy

CharityVillage Ltd. (“CharityVillage”) knows that protecting the privacy and confidentiality of your personal information (“Personal Information”) is of paramount importance. Collection, use, storage, retention, disclosure and destruction of Personal Information by CharityVillage is governed by the Personal Information Protection and Electronic Documents Act (the “Act“), and any applicable provincial legislation. This privacy policy (the “Privacy Policy”) explains what personal information is collected from users of the CharityVillage website located at the url: charityvillage.com (the “Website”) and how it is used. It also explains how you can ask questions, make suggestions, and complain about our privacy practices. This Privacy Policy applies to Personal Information (see below) collected by CharityVillage. Be aware that CharityVillage may contain links to other websites provided and maintained exclusively by third parties not subject to this Privacy Policy. Please review the privacy policies on any external websites to determine their information handling practices. CharityVillage will not be liable under any circumstances for any damages whatsoever, direct, indirect, incidental, consequential, special or indirect, resulting from any use of any third party website linked to any website owned and/or operated by CharityVillage.

The scope and application of the CharityVillage Privacy Policy are as follows:

The Privacy Policy applies to Personal Information that is provided to CharityVillage from Employees and “non-employee” Persons who interact with CharityVillage that is collected, used or disclosed by CharityVillage via its Website, or otherwise.

  • Employees” in this context includes past and present employees and independent contractors of CharityVillage.

  • “Non-employee Persons” in this context includes individuals who are viewers, readers, subscribers, members, advertisers, contest participants, job applicants, Internet users who are exposed to the media content of CharityVillage and about whom CharityVillage collects Personal Information, as more specifically defined below.

CharityVillage reserves the right to amend this CharityVillage Privacy Policy from time to time.

The application of the CharityVillage Privacy Policy is subject to the requirements or provisions of any applicable legislation, regulations or agreements (such as collective agreements), or the order of any court or other lawful authority.

Exclusions from privacy protection: The CharityVillage Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by CharityVillage: a) information that is publicly available, such as a Person's name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information shared publicly by a Person in their user profile, such as work or educational history, social media contacts, and other profile information; d) public information collected, used or disclosed in the course of journalistic activities; or e) aggregate information that cannot be associated with a specific person, such as demographic statistics about CharityVillage customers, or number of visitors and average time spent on a website.

What Personal Information is collected through the Website?

There are six main classes of non-Employee Persons who may access the Website and the information we collect about each one is different:

Visitors - Visitors to the Website may visit various pages on our Website to learn more about the services we offer and explore other information we publish on our site, including newsletter, videos and webinars. We do not collect any Personal Information from visitors to the Website until they specifically decide to sign up as a user, the type of which are defined below.

User – (Webinar Attendees & eLearners) – As a user of Webinars you will have to provide basic contact information to register (name, postal code and email address).  As a user of our eLearner services, you will need to provide your basic contact information to use the services (name, postal code and email address) unless the purchaser of the service is an organization who registers on behalf of its employees, in which case full billing information is required.  If any of the services you wish to access are paid services, we will require your credit card details to process the payments or your contact information for invoicing depending on the purchase price.

User – (Purchasers) – As a purchaser of one of the products which CharityVillage offers for purchase to Visitors from time to time, including but not limited to subscriptions and the CharityVillage Salary Survey, we will require your name, email address, and credit card details to process the payments or your contact information for invoicing, depending on the purchase price.  

User - (Job Poster) - As a Job Poster you will need to supply your basic contact information when you sign up to use the service (name, email address and organization). If you subsequently decide to use any of our paid services, we will require credit card details to process the payments for these services or your contact information for invoicing, depending on the purchase price.

User - (Job Seeker) - There is no charge for Job Seekers, so we will not require any information relevant to payment such as credit card details.  However, as a job seeker you will need to supply your basic contact information when you sign up for the service (name, postal code and email address). If you subsequently either apply for a job and/or create a CV IQ profile you will be required to enter information to complete your application or profile. This information includes information typically found in a resume, such as your experience and education, as well as responses to questions asked in relation to the position you are applying for (e.g., "How many years of experience do you have in a direct sales role?"). All Job Seekers who create a CV IQ profile who are applying for a job for which the Job Poster has included as part of its application process a section called “Talent Predictor” will also need to complete our personality assessment which involves responding to between 50 and 100 questions.  These answers will be processed by a third party software partner to CharityVillage which is itself bound by the same terms and conditions of this Privacy Policy.  For further information on sharing and keeping your Personal Information secure see more details described below.   

User - (Event/Volunteer Postings & Volunteers) – There is no charge for posting event or volunteer positions or for volunteering, so there is no payment information required.  However the Organization posting the Volunteer position or Event listing will have to submit basic contact information when you sign up to use the service (name, email address and organization) and details about the position.  As a Volunteer, you will need to supply your basic contact information when you sign up for the service (name, postal code and email address). If you subsequently apply for the volunteer position you will be required to enter information to complete your application.    

As you explore the Website, we may also collect information via frequently used information-tracking tools, such as "cookies". These cookies collect information such as your browser type, your Internet Protocol (IP) address and the actions you take on the website (i.e. pages views and links clicked).

Purposes for Collection of Personal Information

CharityVillage has collected and collects Personal Information for the following general purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible CharityVillage corporate re-organization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of CharityVillage, provided that the Personal Information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Privacy Policy.

As examples of the above:

i) CharityVillage may from time to time use a Person's Personal Information to contact the Person about changes, enhancements or similar notices related to CharityVillage products and services;

ii) if a Person indicated that he/she was interested in receiving offers or information from CharityVillage or certain of our selected sponsors or advertisers, CharityVillage may send the Person materials about products and services that CharityVillage feels may be of interest to the Person;

iii) if a Person enters a contest or other promotion offered on a CharityVillage website, CharityVillage may, under the rules of the promotion, use the Person's name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion;

iv) If a Person is a Job Poster becomes a user and wants to use our services to create a job posting CharityVillage may use the Personal Information provided by the Job Poster to create posting, process payments, communicate with Job Poster to provide CV IQ service, online assistance and troubleshooting advice and other business communications and services consistent with industry practices, our services and applicable law; and

v) if a Person is a Job Seeker and becomes a user and wants to create a CV IQ profile on our Website, CharityVillage may use the Personal Information provided by the Job Seeker to communicate with the Job Seeker, organize profile, and provide the Personal Information to the Job Poster who posted the job posting for which the Job Seeker submitted the Personal Information, and for the other purposes disclosed elsewhere in this Privacy Policy.

How is this information used?

The information we gather through use of cookies is used only in the aggregate and not tied to personally identifiable information. For example we may track the number of visitors to a specific area of our Website or determine which of our services are used most frequently. We do this so we can continually work to improve our Website and ensure that we are providing the content and services that our visitors want to see and use.

The information we gather from users who have signed up for a Job Poster account ("Job Poster(s)") allows us to communicate with each Job Poster individually and provide them with the transactional communications necessary for their account. We may additionally use this information to send marketing or other communications unless the Job Poster has opted-out (see below).

The information we gather from users who have signed up for a job seeker account ("Job Seeker(s)") will be used to communicate with each Job Seeker individually and provide them with the transactional communications necessary for their account. We may additionally use this information to send marketing or other communications unless the job seeker has opted-out (see below).  Additionally, any information the Job Seeker has included in his or her profile or in a specific job application will be made available to the Job Poster who posted the job in order to help that Job Poster to sort and select candidates to create the best shortlist for the position they are looking to fill. If the job seeker has chosen to make their profile "open", certain aspects of it (resume, experience, education, etc.) will be visible to other Job Posters who may be looking for candidates.

Do you share my information with anyone?

Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share Personal Information with third parties. We will never sell or rent your Personal Information to third parties for their use without your consent.  As a Job Seeker who uses our services, you have given your consent to our sharing your Personal Information with the Job Poster who posted the job you are applying for as well as our third party software service provider whose severs and systems are encrypted to maintain confidentiality and security of data to industry standards and who is contractually bound to protect and maintain your Personal Information in accordance with this Privacy Policy.

CharityVillage also uses a third-party company to manage credit card processing. This company is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on CharityVillage's behalf and they are required to maintain the confidentiality of the information we provide to them.

We may also share non-personally identifying information in the aggregate with third parties, such as the media, industry observers, potential customers or partners. For example, we may disclose the number of users that have been exposed to, or clicked on, through our Website.

CharityVillage also partners with a third party software supplier that works with a scientific partner in order to perform the personality assessment offered through some of the CV IQ services. The responses to the personality assessment questions will be provided to the scientific partner in a non-identifiable format in order to permit the scoring of those responses. In other words, as a Job Seeker, none of your personally identifiable information will be provided to, or otherwise associated with your responses to the personality assessment questions provided to the external scientific partner solely for the purpose of permitting scoring of your assessment so there will be no ability for the scientific partner to identify you when scoring the personality assessment. All communications with our scientific partner will be done via a secure interface and no personal details of the Job Seeker will be transmitted with the response or the returned scores.

As mentioned, if you are a Job Seeker and have created a CV IQ profile to apply for a job posting we will share your Personal Information you have submitted to us to the Job Poster who posted the job for which you are applying.

To whom does CharityVillage disclose Personal Information and why?

i) CharityVillage shares some of your Personal Information with third-party service providers for the purpose of delivering to you certain services if you have purchased these services from us (this does not apply to Job Seekers, Volunteer Postings or Volunteers who are not obliged to pay for these services unless they have otherwise purchased a product or service from CharityVillage which is offered for sale generally to Visitors) This may involve the delivery or actual services or use of third party platforms or technology.  We provide as much information to the third-party service providers as is necessary. We will only share Personal Information with a third-party service provider if you purchase something or register for something relating to that particular service. Any such third party service provider that we retain directly is and will continue to be contractually bound to safeguard your Personal Information, not to use it for any purpose other than the delivery of their services and to otherwise comply with all privacy laws. Use of such third party services, platforms and/or technology by you directly, through redirection from the Website or otherwise, will be subject to such third party service provider’s then current terms and conditions of use and privacy policy. For a list of third party service provider used by CharityVillage, please contact the CharityVillage privacy officer by e-mail at privacy@CharityVillage.com.

ii) If you elect to subscribe to our mailing list, we will send you updates about us, our products and other offerings and those of third party vendors that we believe may be of interest to you. You may at any time opt out from further receipt of any such e-mail communication.  Please note, however, that by unsubscribing, you will no longer receive e-mail notices of changes to our the Website’s terms and conditions of use, terms of sale and/or this privacy policy and you will therefore be required to periodically review these to ensure that no changes have been made since your last visit.

iii) CharityVillage may also disclose or share non-personally identifiable information with partners, advertisers, merchants and/or prospective merchants to help explain our business and the effectiveness of our business or for promotional purposes. For example, we may disclose aggregated demographic information which does not include any personally identifiable information.

iv) CharityVillage may transfer your Personal Information to service providers acting on its behalf in order to perform processing and other specialized services, for example, prize fulfillment of our contests, collection of overdue accounts, investigations regarding potential breaches of your obligations, product delivery, or credit card processing.

v) Your Personal Information may be processed and stored outside of the province in which you reside and/or outside of Canada by us, an affiliate or a third party service provider for the purposes set out in this Privacy Policy and, under the laws of these other jurisdictions, in certain circumstances foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal Information.

vi) CharityVillage may disclose your Personal Information to unrelated parties if we find you have violated any stated terms and conditions of use or terms of sale, or if we need to comply with applicable laws and lawful requests made by law enforcement bodies, governmental bodies or other legal and regulatory authorities.

vii) CharityVillage may disclose your Personal Information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. We will require such parties to treat your Personal Information in accordance with this Privacy Policy and to use and disclose it only for the purposes for which it was collected.

How do you keep my information safe and secure?

We are committed to protecting the security of your Personal Information. We employ reasonable technical, administrative and physical safeguards to protect the confidentiality of your Personal Information, employing industry-recognized technical safeguards, such as firewalls, and have adopted and implemented security procedures to protect your information from loss, misuse or unauthorized alteration. Notwithstanding our efforts, we cannot guarantee absolute or unqualified protection of this information given the open nature and resulting instability of the Internet and World Wide Web, and we make no representations or warranties as to the effectiveness of our security and assume no liability for security breaches due to “hackers” or any failure in the security of your computer equipment, your Internet service provider or other networks and communications providers.

CharityVillage maintains personal information in a combination of paper and electronic files. We take technical, contractual, administrative and physical security measures to protect your personal information, including:

  1. Only employees who need the information to provide services to an individual or relating to an individual are granted access to personally identifying information about such individual.
  2. We have certain secure databases where we store data. We also may store your Personal Information in paper document files in our offices.
  3. The processes of our business include sharing your Personal Information with others to carry out our services.
  4. Access to this information will be based on a “need to know” basis as prescribed by the requirements of their job function only.

Not all CharityVillage interactions require that credit card information be provided. If you provide credit card information to us, we work to help protect the security of your credit card information by using industry standard secure encryption technology.

Please be aware that electronic communications through the Internet (either in terms of online forms or questionnaires or by email) are not a secure medium, and any personal information you send to us through the Internet could be intercepted or captured. If your communication is very sensitive, or includes information such as your credit card number, you should not send it electronically unless the email is encrypted, you have adequate and up-to-date security software installed, you have no reason to believe that the system that you are using has been compromised and/or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other internet users or identity theft.

Obtaining Consent

CharityVillage will make reasonable commercial efforts to make sure Persons understand how their Personal Information will be used by CharityVillage.  CharityVillage will obtain consent from Persons before or when it collects or uses the Personal Information. CharityVillage will never attempt to deceive Persons into giving consent.

Person's consent can be express, implied, or given through an authorized representative. A Person can withdraw consent at any time, with certain exceptions noted herein. CharityVillage, however, may collect, use or disclose Personal Information without the Person's knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.

When you sign up as a user of the Website we explicitly ask you to confirm you agree to this Privacy Policy. Continued use of the Website constitutes on-going consent to this Privacy Policy. Additionally, we ask when you sign up whether you want to opt-in to non-transactional communications (e.g. product updates, news and marketing materials). This preference can be changed at anytime.  Also you can withdraw consent for the use of your Personal Information.  See ”Refusing or Withdrawing Consent” below.)

Note: If any Person at any time has any questions or concerns about CharityVillage's privacy practices, the Person can write to Customer Service - Privacy, CharityVillage Ltd., 8170 Lawson Road, Milton, Ontario, Canada, L9T 5C4 or email to privacy@charityvillage.com.

Refusing or Withdrawing Consent

Subject to legal and contractual requirements, a Person can refuse to consent to CharityVillage's collection, use or disclosure of Personal Information about the Person, or a Person may withdraw the Person's consent to CharityVillage's further collection, use or disclosure of Personal Information at any time in the future by giving CharityVillage reasonable notice and sending such request to privacy@charityvillage.com, unless: i) the consent relates to certain information required for credit approval which a Person applies for or accepts, ii) the consent is otherwise required by law or iii) the use or disclosure is permitted by law or is related to the legal or regulatory requirements described herein. If a Person refuses or withdraws the Person's consent, CharityVillage may not be able to provide the Person or continue to provide the Person with some products, services or information which may be of value to the Person.

Internet Aspects

Personal Information may be collected by CharityVillage or third-party service providers on CharityVillage's behalf. Although information collected, used or disclosed on the Internet as described below usually does not constitute Personal Information (and to the extent that such is the case, then the obligations under the CharityVillage Privacy Policy do not extend to such information), CharityVillage provides the details below about Internet aspects of CharityVillage’s services for the purposes of disclosure.

Internet Protocol Address (IP Address)

When the user's web browser requests a web page from another computer on the Internet, it automatically gives that computer the address where it should send the information. This address is called the computer's "IP address." For most users accessing the Internet from an Internet service provider (ISP), the IP address will be different every time the user logs on.

CharityVillage may use the user's IP Address to:

  • Facilitate the diagnosis and remedy of a technical problem reported by the user's or CharityVillage’s technical team.

  • Display (or allow the display by Third Party advertising providers of) more appropriate and relevant content and advertising, such as content and advertising based on the user's geographic area, demographic profile and Website session behaviour.

  • Estimate user traffic from specific countries or organizations. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.

Cookies

A cookie is a small text file, which often includes an anonymous unique identifier that is sent to the user's web browser from a website's computers and is stored on the user's computer's hard drive. Cookies cannot be used to run programs or deliver viruses to a user's computer.

CharityVillage may use cookies to:

  • Improve the operation and performance of the CharityVillage services and to make CharityVillage services easier and more convenient to use. For example, cookies help CharityVillage provide more personalized services by recalling user preferences on subsequent visits. Cookies also allow CharityVillage to save passwords and preferences for a user so that the user will not have to re-enter them on the next visit to the CharityVillage site;

  • Measure aggregate user traffic and demographic statistics related to CharityVillage services and advertisements (e.g. number of users, average time spent, average age and similar statistics). This information helps CharityVillage to better understand when to update, change or offer new services and provides CharityVillage with details as to the performance of Third Party advertisements and content. This information may be reported, in aggregate form only, to CharityVillage’s current and prospective sponsors, advertisers and business partners. No Personal Information will be disclosed in such reports;

  • Display advertisements. CharityVillage and Third Party advertising providers may use cookies when serving advertisements on CharityVillage sites. In some cases, advertisements from Third Party advertisers are delivered to users (in conjunction with CharityVillage Services) by such Third Party advertisers, or by separately contracted advertising providers on their behalf, and not by CharityVillage; as such, the Third-party advertisers' use of cookies is subject to their own privacy policies, not the CharityVillage Privacy Policy, and users should consult the privacy policies of such Third Party advertisers.

  • Most browsers are initially set up to accept cookies. If a user prefers, the user can reset his/her browser either to notify the user when the user has received a cookie, or to refuse to accept cookies. The user should understand that while CharityVillage does not require a user to use cookies, certain CharityVillage services will not function properly if a user sets his/her browser to not accept cookies.

Links To Other Sites And Advertisements

A CharityVillage service may contain links to other websites and services. While CharityVillage tries to link only to sites and services that share CharityVillage’s high standards and respect for privacy, a user should understand that CharityVillage is not responsible for the content of, or the privacy practices employed by, other companies or websites. This CharityVillage Privacy Policy applies only to the CharityVillage services related to this CharityVillage Privacy Policy.

The majority of the advertisements that are displayed in connection with CharityVillage services are served through one or more reputable Third Party advertisement-serving companies that deliver the advertisements to users in conjunction with CharityVillage services.

International Use

We are headquartered in Canada. Personal information may be accessed by us or transferred to us in Canada through use of our services or by visitors or users of the Website elsewhere in the world. By providing us with Personal Information, you consent to this transfer. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored, however you explicitly acknowledge and consent to the fact that Personal Information stored or processed in Canada will be subject to the laws of Canada, including the ability of governments, courts or law enforcement or regulatory agencies of Canada to obtain disclosure of your Personal Information.

Please note that privacy laws in some provinces are different than those in Ontario (where the Website’s registered office is based) or under federal Canadian law. Thus, Canadian individuals accessing this policy who reside in B.C., Alberta or Quebec should be advised that additional privacy practices may apply in those provinces to the provision of personal information by BC, Alberta or Quebec residents.

Additional Information

CharityVillage automatically collects certain information about the user's computer hardware and software. This information may include: browser type, operating system type, domain names, access times and referring website addresses. This information is used by CharityVillage to operate the service, to maintain the quality of the service, and to provide general statistics regarding use of the CharityVillage Website.

Certain CharityVillage Services may be co-branded and offered in conjunction with another company or Organization. If a user registers for or uses such services, both CharityVillage and the other company or organization may receive information collected in conjunction with the co-branded services.

The CharityVillage Privacy Policy Principles

Definitions

Collection

: the act of gathering, acquiring, recording or obtaining Personal Information from any source, including third parties, by any means.

Consent

: voluntary agreement with the collection, use and disclosure of Personal Information for defined purposes. Consent can be either express or implied and can be provided directly by the Person or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of CharityVillage. Implied consent is consent that can reasonably be inferred from a Person's action or inaction.

Disclosure

: making Personal Information available to a Third Party.

Employee

: an employee or independent contractor (including freelancers)1 of CharityVillage

1The inclusion of independent contractors, including freelancers, within the definition of "Employee" is for convenience of reference only, and does in no manner imply that such individuals are employees of the company within the meaning of employment legislation or are in an employee-employer relationship with the company.

Individual

: an individual other than an Employee who (a) corresponds with CharityVillage , including complaints and including applications for employment; (b) enters an contest sponsored by CharityVillage ; or (c) uses, or applies to use, the products or services of CharityVillage .

Person

: an Employee or an Individual.

Personal Information

: information about an identifiable Person, but not: a) information that is publicly available, such as a Person's name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; c) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or d) aggregate information that cannot be associated with a specific person, such as demographic statistics about CharityVillage  customers, or number of visitors and average time spent on a website.

Third Party

: a person other than the Person or his agent, or an organization other than CharityVillage

Use

: the treatment, handling, and management of Personal Information by CharityVillage

Principle 1 - Accountability

CharityVillage is responsible for Personal Information under its control and shall designate one or more persons who are accountable for CharityVillage 's compliance with the following principles.

1.1 Responsibility for ensuring compliance with the provisions of the CharityVillage  Privacy Policy rests with the senior management of CharityVillage , which shall designate one or more persons to be accountable for compliance with the CharityVillage  Privacy Policy. Other people within CharityVillage may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to- day collection and processing of Personal Information.

1.2 CharityVillage has designated a Chief Privacy Officer to oversee compliance with the CharityVillage  Privacy Policy. The Chief Privacy Officer can be contacted at Chief Privacy Officer, CharityVillage Ltd.,

8170 Lawson Road, Milton, Ontario, Canada, L9T 5C4 or email to privacy@charityvillage.com.

1.3 CharityVillage is responsible for Personal Information in its possession or control, including information that has been transferred to a Third Party for processing. CharityVillage  shall use appropriate means to provide a comparable level of protection while information is being processed by a Third Party (see Principle 7).

1.4 CharityVillage is continually in the process of implementing and updating policies and procedures to give effect to the CharityVillage  Privacy Policy, including: a) implementing procedures to protect Personal Information and to oversee CharityVillage 's compliance with the CharityVillage  Privacy Policy; b) establishing procedures to receive and respond to inquiries or complaints; c) training and communicating to staff about CharityVillage 's policies and practices; and d) developing public information to explain CharityVillage 's policies and practices.

Principle 2 - Identifying Purposes for Collection of Personal Information

CharityVillage  has collected and collects Personal Information for the purposes set out below, and shall identify the purposes for which Personal Information is collected at or before the time the information is collected.

2.1 CharityVillage  has collected and collects Personal Information for the following purposes: a) to establish and maintain responsible commercial relations with Individuals and to provide ongoing service; b) to understand Individual needs; c) to develop, enhance, market or provide products and services; d) to manage and develop its business and operations, including personnel and employment matters; and e) to meet legal or regulatory requirements, including to protect or defend a legal interest, and in connection with an actual or possible CharityVillage  corporate re-organization, merger or amalgamation with another entity, or an actual or possible sale of all or a substantial portion of the assets of CharityVillage, provided that the Personal Information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Privacy Policy.

As examples of the above:

i) CharityVillage may from time to time use a Person's Personal Information to contact the Person about changes, enhancements or similar notices related to CharityVillage products and services;

ii) if a Person indicated that he/she was interested in receiving offers or information from CharityVillage  or certain of our selected sponsors or advertisers, CharityVillage  may send the Person materials about products and services that CharityVillage  feels may be of interest to the Person; and

iii) if a Person enters a contest or other promotion offered on a CharityVillage  website, CharityVillage  may, under the rules of the promotion, use the Person's name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion.

Further references to "identified purposes" mean the purposes identified in this Principle 2.

2.2 CharityVillage shall specify orally, electronically or in writing the identified purposes to the Person at or before the time Personal Information is collected. Upon request, persons collecting Personal Information shall explain these identified purposes or refer the Person to a designated person within CharityVillage  who shall explain the purposes.

2.3 Unless required by law, CharityVillage  shall not use or disclose, for any new purpose, Personal Information that has been collected without first identifying the new purpose and obtaining the consent of the Person.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of a Person are required for the collection, use or disclosure of Personal Information, except where inappropriate.

3.1 Generally, CharityVillage shall seek consent to use and disclose Personal Information at the same time it collects the information. However, CharityVillage  may seek consent to use and disclose Personal Information after it has been collected but before it is used or disclosed for a new purpose.

3.2 In obtaining consent, CharityVillage shall use reasonable efforts to ensure that a Person is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the Person.

3.3 CharityVillage  will require Individuals to consent to the collection, use or disclosure of Personal Information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.

3.4 In determining the appropriate form of consent, CharityVillage shall take into account the sensitivity of the Personal Information and the reasonable expectations of the Persons.

3.5 In general, the use of products and services by an Individual, or the acceptance of employment or benefits by an Employee, constitutes implied consent for CharityVillage to collect, use and disclose Personal Information for all identified purposes.

3.6 An Individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact CharityVillage for more information regarding the implications of withdrawing consent.

3.7 In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Person. For example, CharityVillage may collect or use Personal Information without knowledge or consent if it is clearly in the interests of the Person and consent cannot be obtained in a timely way, such as when the Person is a minor, seriously ill or mentally incapacitated.

CharityVillage  may also collect, use or disclose Personal Information without knowledge or consent if seeking the consent of the Person might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.

CharityVillage may also use or disclose Personal Information without knowledge or consent in the case of an emergency where the life, health or security of an individual or property is threatened.

CharityVillage may disclose Personal Information without knowledge or consent to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise related to the legal or regulatory requirements described herein.

The CharityVillage, its outside suppliers and other third parties to whom we disclose information under this policy may perform activities outside of Canada. As a result, your information may be securely used, stored or accessed in other countries and may be subject to the laws of those countries. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries.

Principle 4 - Limiting Collection of Personal Information

CharityVillage shall limit the collection of Personal Information to that which is necessary for the purposes identified by CharityVillage

CharityVillage shall collect Personal Information by fair and lawful means.

4.1 CharityVillage collects Personal Information primarily from Individuals or its Employees.

4.2 CharityVillage may also collect Personal Information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.

Principle 5 - Limiting Use, Disclosure and Retention of Personal Information

CharityVillage shall not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the Person or as required by law. CharityVillage shall retain Personal Information only as long as necessary for the fulfillment of the purposes for which it was collected.

5.1 In certain circumstances Personal Information can be collected, used or disclosed without the knowledge and consent of the Person. (See Principle 3.7)

5.2 In addition, CharityVillage may disclose a Person's Personal Information to: a) a person who, in the reasonable judgment of CharityVillage, is seeking the information as an agent of the Person; b) a Third Party or Third Parties, where the Person consents to such disclosure or disclosure is required by law.

5.3 CharityVillage may disclose Personal Information about its employees: a) for normal personnel and benefits administration; b) in the context of providing references regarding current or former employees in response to requests from prospective employers; or c) where disclosure is required by law.

5.4 Only those Employees of CharityVillage who require access for business reasons, or whose duties reasonably so require, or properly designated representatives of CharityVillage, are granted access to Personal Information about Individuals and Employees.

5.5 CharityVillage shall keep Personal Information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where Personal Information has been used to make a decision about a Person, CharityVillage shall retain, for a period of time that is reasonably sufficient to allow for access by the Person, either the actual information or the rationale for making the decision.

5.6 CharityVillage shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy of Personal Information

Personal Information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

6.1 Personal Information used by CharityVillage shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a Person.

6.2 CharityVillage shall update Personal Information about Persons as and when necessary to fulfill the identified purposes or upon notification by the Person.

Principle 7 - Security Safeguards

CharityVillage shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.

7.1 CharityVillage shall protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. CharityVillage shall protect the information regardless of the format in which it is held.

7.2 CharityVillage shall protect Personal Information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

7.3 All employees of CharityVillage with access to Personal Information shall be required as a condition of employment to respect the confidentiality of Personal Information.

Principle 8 - Openness Concerning Policies and Practices

CharityVillage shall make readily available to Persons specific information about its policies and practices relating to the management of Personal Information.

8.1 CharityVillage shall make information about its policies and practices easy to understand, including: a) The title and address of the person or persons accountable for the compliance with the CharityVillage  Privacy Policy and to whom inquiries or complaints can be forwarded; b) The means of gaining access to Personal Information held by CharityVillage; and c) A description of the type of Personal Information held by CharityVillage , including a general account of its use.

8.2 CharityVillage shall make available information to help Persons exercise choices regarding the use of their Personal Information.

Principle 9 - Access to Personal Information

CharityVillage shall inform a Person of the existence, use and disclosure of his or her Personal Information upon request and shall give the Person access to that information.

A Person shall be able to challenge the accuracy and completeness of the Personal Information and have it amended as appropriate.

9.1 Upon request, CharityVillage shall afford to a Person a reasonable opportunity to review the Personal Information in the Person's file. Personal Information shall be provided in understandable form within a reasonable time and at minimal or no cost to the Person.

9.2 In certain situations, CharityVillage may not be able to provide access to all of the Personal Information that they hold about a Person. For example, CharityVillage may not provide access to information if doing so would likely reveal Personal Information about a Third Party or could reasonably be expected to threaten the life or security of another person. Also, CharityVillage may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law, or if the information was collected as part of journalistic activities. If access to Personal Information cannot be provided, CharityVillage shall provide the reasons for denying access upon request.

9.3 Upon request, CharityVillage shall provide an account of the use and disclosure of Personal Information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, CharityVillage shall provide a list of organizations to which it may have disclosed Personal Information about the individual when it is not possible to provide an actual list.

9.4 In order to safeguard Personal Information, an individual or employee may be required to provide sufficient identification information to permit CharityVillage to account for the existence, use and disclosure of Personal Information and to authorize access to the individual's file. Any such information shall be used only for this purpose.

9.5 CharityVillage shall promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the Person's file. Where appropriate, CharityVillage shall transmit to third parties having access to the Personal Information in question any amended information or the existence of any unresolved differences.

9.6 A Person can obtain information or seek access to his or her Personal Information by contacting a designated representative at CharityVillage principal office.

9.7 An employee can obtain information or seek access to his or her Personal Information by contacting his or her immediate supervisor within CharityVillage

Principle 10 - Challenging Compliance

A Person shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of CharityVillage  with the CharityVillage  Privacy Policy.

10.1 CharityVillage shall maintain procedures for addressing and responding to all inquiries or complaints from Persons about CharityVillage 's handling of their Personal Information. If any Person at any time has any questions or concerns about CharityVillage 's privacy practices, the Person can write to Customer Service - Privacy, CharityVillage Ltd.,

8170 Lawson Road, Milton, Ontario, Canada, L9T 5C4 or email to privacy@charityvillage.com

10.2 CharityVillage shall inform Persons about the existence of these procedures as well as the availability of complaint procedures.

10.3 The person or persons accountable for compliance with the CharityVillage Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

10.4 CharityVillage shall investigate all complaints concerning compliance with the CharityVillage  Privacy Policy. If a complaint is found to be justified, CharityVillage shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A Person shall be informed of the outcome of the investigation regarding his or her complaint