DATE: July 29, 2021
MyCity Impact Inc. (“MyCity”, “we”, “us” or “our”, as the context requires) is committed to protecting your Personal Information (as defined below) through ensuring that all Personal Information provided to us is treated with care and, subject to this Privacy Policy (“Policy”), is not used or disclosed in ways to which you have not consented. This Policy governs the collection, use and disclosure of your Personal Information in any communication or interaction you may have with us, whether it be in person, over the telephone, in writing, or electronically. This Policy applies to all staff of MyCity, its partner institutions and users of the Service (as defined below).
We comply with all of the requirements of applicable laws, including the federal Personal Information Protection and Electronic Documents Act, and other applicable provincial legislation (collectively, “PIPEDA”) as well as the federal Canada’s Anti-Spam Legislation (“CASL”). By submitting to us your Personal Information, or using our website (the “Website”) or the MyCity Application (the “App”) and the services offered therefrom (collectively with the Website and the App, the “Service”), you accept this Policy and consent to its terms and as otherwise described to you at the time of collection of your Personal Information. If you do not agree with the terms of this Policy, please do not use the Website, the App or any of the services offered therefrom or otherwise provide your Personal Information to us.
This Policy may be amended at our discretion, without notice to you. Please check back from time to time for such amendments. By continuing to access and use the Website or the App or any of the services offered therefrom, you agree to the terms of the then-current Policy, as amended.
“Personal Information” is personally identifiable information including your name, age, address and e-mail address. Publicly available information, such as business contact information or a public directory listing of your name, address, telephone number or information that is aggregated and not associated with a specific individual, including demographic information and statistics, is not considered Personal Information.
Your consent is required for the collection, use and disclosure of Personal Information, subject to certain exceptions. Such exceptions are set out in PIPEDA and other applicable legislation and include where legal, medical or security reasons make it impossible, or impractical, to seek consent. Your consent may be expressed in writing. It may also be given verbally, electronically, or through our, or your, authorized representatives. In certain circumstances, it will also be implied, such as by submitting to us your Personal Information or using the Service.
Subject to applicable law, you may withhold, modify or withdraw your consent for us to collect, use and disclose your Personal Information, as long as there are no legal or contractual reasons preventing you from doing so and upon reasonable notice. Depending on the circumstances, however, modification and/or withdrawal of your consent may impact our ability to continue to provide you with the products and services you have requested. Notwithstanding your modification and/or withdrawal of consent, we have a right to maintain the collection, use and disclosure of your Personal Information in certain circumstances, including if necessary in the performance of a task carried out in the public interest or for the establishment, exercise or defence of legal claims. Any withdrawal of consent may be submitted to our Privacy Officer.
We collect Personal Information by fair and lawful means. We limit the collection of Personal Information to what is necessary for the purpose for which it was collected unless we are required or permitted by law to collect additional information.
Personal Information is collected by MyCity when you provide it to us, such as when you create an account on our Website or our App, or contact us via the Website or the App, e-mail us or call us. We may also collect your IP address when you use the Website and we keep track of your dealings with us, including details of your visits to our Website and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data.
We may also receive Personal Information from our business partners and other third-parties, provided that such third-parties confirm to us that they have obtained your consent or we have obtained your consent in this regard.
Collection, Use and/or Disclosure of Personal Information
We collect, use and/or disclose your Personal Information primarily for the following purposes:
Certain disclosure of Personal Information to third-parties may be required as part of MyCity fulfilling its stated business duties and day-to-day operations, including, providing such information to our partner institutions in connection with our services. In other instances, information will only be disclosed to third-parties if we have received your consent to do so or they have entered into a written agreement with us to abide by this Policy. You always have the option to tell us not to share your Personal Information with third-parties. We will not refuse to provide a product or service to you if you choose not to provide us with your Personal Information, unless your failure to provide such information makes us unable to provide such product or service.
MyCity does not sell or distribute its client lists to any outside party other than charitable organizations with whom we partner. MyCity may provide aggregate information about our members, services selected, and Website information to other affiliate organizations, but such aggregate information will not include personally identifying data, except as otherwise provided in this Policy. We may also use this aggregate, non-identifying information for research purposes. This information may be shared with other organizations for the purpose of better understanding and improving services to individuals.
Other than as required by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations) or where we sell any or all of our business and/or assets to a third-party, your Personal Information will not be used for any other purpose except as described herein without your written consent. MyCity will request written consent from you prior to disclosing any Personal Information other than pursuant to this Policy.
Use of Cookies and Other Technologies [NTD: This should be reviewed by your IT group.]
For the improvement of the Service, the Website makes use of cookies, which automatically collect anonymous user data (such as user traffic patterns and server activity). A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer, allowing the Website administrator to identify your computer and passively track your activities on the Website.
We may use cookies to temporarily store some Personal Information. Cookies, by themselves, cannot be used to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Website. Most browsers are initially set up to accept cookies, but you can set your browser to refuse cookies. However, if you do not accept cookies, you may be limited in some areas of Website.
The Website may also use Google Analytics, Web Trends, or other technologies. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with cookies. If you don’t want your cookie information to be associated with your visits to these pages, you can set your browser to turn off cookies. If you turn off cookies, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded.
We also collect information from or about the computers, phones, or other devices where you install or access our Services. We may associate the information we collect from your different devices, which helps us provide consistent Services across your devices. Here are some examples of the device information we collect:
The Website may present links to other websites. You should be aware that operators of linked websites may also collect your Personal Information and information generated through the use of cookies when you link to their websites. MyCity is not responsible for how such third-parties collect, use or disclose your Personal Information, so it is important to review their privacy policies before providing them with your Personal Information.
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational, and technological measures to protect Personal Information.
For example, only members of MyCity staff or staff of our partner institutions that are authorized users, using a password, can access the data stored in our electronic database. We also use a secure server, which protects your Personal Information from being observed in transmission by a third-party when you are contacting us on our Website or via the App. Backup copies of your Personal Information are stored off-site in secure locations. We may use the services of third-parties for such storage, or for processing, or other third-party services related to services rendered by us, but we ensure that those third-parties agree to only use your Personal Information for specified purposes and that your Personal Information is protected at least as well as it is protected by MyCity, as described in this Policy.
Your Personal Information may be processed and stored outside of the province in which it was collected by us or a third-party service provider for the purposes set out in this Policy. Any third-party service provider that processes or stores Personal Information will have sufficient protections and will be required to adhere to this Policy. We will ensure that any processing or storage of Personal Information outside of the province in which it was collected (including transfers within or outside Canada) is permitted by applicable law prior to permitting same. However, if your Personal Information is transferred outside of Canada, your Personal Information will be subject to the laws of the country in which it is stored. In certain circumstances, foreign courts, law enforcement agencies or regulatory agencies may be entitled to access your Personal Information without notice to you. By submitting your Personal Information, you agree to this transfer, storing or processing.
Please note that no method of transmitting, processing or storing information is completely secure. While we take appropriate steps to safeguard information under our control, there is always a risk that it may be lost, intercepted, altered or misused. There is an inherent risk involved in the exchange of information using any form of communication, such as e-mail, telephone, fax and courier service. We cannot guarantee that exchanges of information will always be received, or that such communications and documents will be virus free. We assume no liability for any loss, costs or damages you may suffer as a result of the loss, interception, alteration or misuse of information during such transfers.
How does MyCity Destroy or Dispose of Personal Information?
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. MyCity will destroy the paper copies of its files, subject to any limitations that may be required by law, in a secure manner.
Subject to applicable law, MyCity’s electronic files, which include images of documents, are kept indefinitely, unless you ask us to delete our electronic files that contain Personal Information about you, in which case we will delete such files, to the extent not impossible or infeasible to do so, in a secure manner.
How to Access and Correct Personal Information
We want to ensure that information about you is accurate, complete and current. Please inform us of any change of name, address, or other Personal Information.
In addition, you have the right to access the Personal Information that MyCity has collected, stored, and disclosed about you, subject to any legal restrictions. If there are errors in the information in your files, you may request that it be changed. If we have disclosed inaccurate information about you to a third- party, we will be pleased to contact the third-party in order to advise them of the error.
In order to access this information, you must put your request in writing to the individual referred to below. Please allow up to four weeks for a response.
MyCity supports the transmission of responsible electronic communication as outlined in CASL.
Under CASL, a Commercial Electronic Message (“CEM”) is any message transmitted to an electronic account (e.g., emails, text/sound/voice messages, messages using social media websites) that encourages participation in a commercial activity. “Commercial Activity” is defined as “any particular transaction, act or conduct or any regular course of conduct that is of a commercial character, whether or not the person who carries it out does so in the expectation of profit.”
In compliance with CASL, MyCity will not:
Consents to receive or unsubscribe from CEMs (including associated Personal Information) will be kept confidential in accordance with the Policy. All requests to change or withdraw consent to receive CEMs will be processed no later than 10 days after receipt.
To unsubscribe or change your preferences to receive CEMs, please contact our Privacy Officer.
MyCity is accountable for all Personal Information in its control. MyCity has a designated Privacy Officer who is ultimately accountable for the handling of all Personal Information under the control of MyCity. The Privacy Officer is also responsible for ensuring that the principles set out in this Privacy Policy are being complied with. If you wish to challenge our compliance with this policy, if you wish to request access to your Personal Information, if you wish to withdraw your consent under CASL to receiving CEMs, or if you have questions about this Privacy Policy or the information that we have collected about you, please contact our Privacy Officer as follows:
e-mail: privacy@mycity.org
Privacy Officer
MyCity Impact Inc.
261 Davenport Road, Suite 200
Toronto, Ontario M5R 1K3 Canada