Personal Information 

For the purposes of this Privacy Policy, the term “Personal Information” means any information that is defined to be personal information under applicable privacy laws. Usually, personal information refers to any information about an identifiable individual or any information that can be used to identify an individual. Personal Information may include, for example, your name and home address, your date of birth, payment information, your occupation, medical conditions or other health information, your personal financial records or credit information, certain video or images of you, or any personal identification numbers. Publicly available information, such as information in a public directory, is not Personal Information under this Privacy Policy. 

Consent for the collection, use and disclosure of Personal Information 

Privacy laws require us to obtain the consent of an individual to the collection, use or disclosure of Personal Information in many circumstances. Providing us with your Personal Information is always your choice. By accessing our website or submitting your Personal Information through the Site, you consent to the collection, use, and disclosure of such information in accordance with this Privacy Policy and as otherwise permitted or required by law. 

When we receive Personal Information from you for the purposes of providing you with our Site services, or for other uses identified herein, you are providing us with consent as follows: 

i. to allow us to deal with that Personal Information in a reasonable manner, and to deal with Personal Information as set out in this Privacy Policy; 

ii. to allow us to provide your Personal Information to third parties we engage to provide or support the Site services; 

iii. to allow us to use and store your Personal Information for the purpose of providing you with the products and services you purchase from us and to utilize the Site; and 

iv. to allow us to transfer your Personal Information outside of Canada and outside of the province of Ontario (whereby your Personal Information will be treated in accordance with applicable laws of the jurisdiction to which it is transferred, whether the laws of provinces outside of Ontario or the laws of any foreign jurisdiction) for the purpose of storage, processing and use of your Personal Information by us. 

If you need to provide us with Personal Information about other individuals, you hereby represent and warrant to us that, where required by law and prior to your disclosure to us, you will obtain the consent of each individual to the collection, use and disclosure by us for the specific purpose(s) that the disclosure is made by you, including all purposes set out herein. 

If we sell our organization or merge with another party, you hereby consent to the transfer of your Personal Information and all information you provide to us, to our successor for the same purposes as set out in this Privacy Policy. 

Consent Exceptions 

There are legal exceptions where we will not need to obtain consent or explain the purposes for the collection, use or disclosure of Personal Information. Some examples of situations where consent is not required include an emergency that threatens the life, health or security of an individual, or if we must comply with a court order or governmental order. 

We may use Personal Information without your knowledge or consent in limited circumstances whereby we are required to provide Personal Information to third parties for legal or regulatory purposes. For example, under certain exceptional circumstances we may have a legal duty or right to disclose Personal Information without your knowledge or consent. Various government agencies such as the Canada Revenue Agency, Human Rights Commission, Canadian Radio-television and Telecommunications Commission, and law enforcement, may have the authority to review our files and interview our staff when deemed necessary. These agencies have their own strict privacy obligations. 

What information do we collect? 

We collect information provided by you when you sign up for an account, complete a transaction through the Site, or fill out a form on the Site and we may collect information from you at other instances in the course of and in relation to the Site. For example, we may collect your name, address, telephone number, e-mail address or other information when it is submitted to us via the Site. When completing any forms or otherwise using the Site, as appropriate, you may be asked to enter your name, e-mail address, mailing address, phone number, payment information and other Personal Information. Except as otherwise set out herein we only collect personal information from you on a voluntary basis. 

Our various funders require us to report data to show accountability and quality of service. More information about the data reporting requirements can be found in our client handbook. We may also use non-identifying data and/or quotes in proposals, research projects and social media for the purpose of seeking funding, promoting and making service improvements within our agency, region and beyond. Internally, we use non-identifying aggregate data to plan services, manage risks, and improve service quality. 

We may from time to time use “cookies” to automatically collect technical and non-personal information from you when you browse our website or use our other Site. The information we collect automatically is statistical data and does not include Personal Information. For more information about cookies, see the “Do we use cookies?” section below. 

We use standard computer programs which will count and analyze a range of user activities, and we utilize the information that is generated by such programs to help us improve our website. 

What do we use your information for? 

Startling Community Services uses your Personal Information for the purposes for which it was collected and for other purposes for which you have given consent. This includes, but is not limited to, the following purposes: 

• Marketing: In accordance with anti-spam laws, we may obtain your consent in order to send you commercial electronic messages. We do not share email addresses or other contact information with third parties without your permission. 

• Notifications: We will ask you if you wish to receive notifications about services that you request. If you agree, we will send you email or text messages to notify you about the status of your requests, such as product orders. 

• Uses in accordance with our Terms of Use, including administration of any user account you may have for the Site. 

Do we disclose any information to outside parties? 

We do not sell your Personal Information. 

We may share some of the Personal Information we collect about you with third party companies, such as our trusted partners, affiliates and related entities, and our third party service providers, or other third parties which provide services or products similar to or complementary with your requested services or products, so long as those parties agree to keep your information confidential and to handle such information in compliance with applicable privacy laws. 

Your Personal Information will also be shared to facilitate the services needed in order to properly and efficiently handle duties related to your requests and use of the Site. For example, we may share information with lawyers, accountants, and auditors. We may share your Personal Information with government agencies to fulfill legal, reporting, and regulatory requirements and we may release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or other’s rights, property, or safety. 

We may also provide our employees, affiliated companies, subsidiaries, and agents with your Personal Information so they may offer you additional services or perform analysis to determine your qualification to receive future services. We may provide non-personally identifiable visitor information to other parties for marketing, advertising, or other uses. 

Donors 

The contact information we receive from you as a donor and the amount of your donation is the minimum information that we are required by Canada Revenue Agency to provide for the issuance of an official tax receipt. We will not provide or share your personal information as a donor with third parties for purposes other than those set out in these Terms unless: 

1. you authorize to share your donor information; 

2. sharing of the information is necessary to process a donation; or 

3. We are required to disclose donor information by law. 

How do we protect your information? 

We implement a variety of security measures to maintain the safety of your Personal Information. We use physical, organizational and technical industry-standard security safeguards commensurate to the sensitivity of Personal Information and other data collected, used or disclosed. We have implemented and maintain reasonable and appropriate security measures, procedures and practices to protect against the loss and unauthorized access, use, modification, destruction or disclosure of your Personal Information while it is in our custody or under our control. 

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

NOTWITHSTANDING THE FOREGOING, THERE ARE INHERENT RISKS TO ANY TECHNOLOGY HOWEVER REMOTE THAT COULD CAUSE SECURITY PROTOCOLS TO FAIL OR TO BE BREACHED AND WHICH COULD RESULT IN THE UNAUTHORIZED COLLECTION, USE OR DISCLOSURE OF YOUR PERSONAL INFORMATION. 

Do we use cookies? 

We may, from time to time, use “cookies” for security and authentication purposes. Most websites use cookies in order to make them work, or to work more efficiently, as well as to provide information to the owners of the website. They help us to understand how users access our website so we can develop and improve the design, layout, content and function of the Site. In particular, we use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may also use cookies to collect information about your computer and internet connection, including your IP address, operating system, and browser type. 

Should you provide us with information, such as in the registration of an account, your personal information may be linked to the data stored in the cookies. 

Cookies are small text files that a website saves on your computer or mobile device when you visit the site. They save and retrieve pieces of information about your visit to the website - for example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can often give you tailored options based on the information it has stored about you on your last visit. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don't have to keep re-entering them whenever you come back to the site or browse from one page to another. 

On our Site, cookies can be set by us (first party cookies) or by our partners (third party cookies). 

We may set cookies for the purposes set out below: 

• analytics; 

• collecting page views; 

• viewing history 

• personalizing your experience on the website; 

• improving the content and services offered on the website; 

• to save your password in a password-protected area; 

• to provide updates, programs or services to you in relation to the website and/or the Site; and 

• session cookies – for keeping users logged in while browsing (for a duration of up to one hour). 

Third-party analytics services (among others) may set cookies and have access to your IP address based upon your use of our website. We cannot provide the names and purposes of the third party cookies as we do not have access to that information; however, they are necessary for us to provide our services. These third parties face serious consequences if they are in breach of applicable privacy laws. 

If you are uncomfortable with the use of cookies, you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your computer. You can also delete any cookies that are already stored on your computer's hard drive. However, please be aware that if you do delete and block all cookies, some parts of our Site may not work. This is because some of the cookies we use are essential for parts of our Site to operate. Likewise, you may not be able to use some products and services on other websites without cookies. 

To find out more about cookies, including to see what cookies have been set and how to manage and delete them, visit All About Cookies.Org 

If you do not wish to accept cookies from our Site, please leave the Site immediately and then delete and block all cookies from the Site. 

Individuals Located Outside Canada 

Your Personal Information will be processed in accordance with this policy and in compliance with Canadian federal and provincial privacy law. 

Retention of Personal Information 

Starling Community Services retains Personal Information provided by you  so long as we have an ongoing legitimate business need to do so (for example, to provide you with the service and information, to comply with applicable legal requirements, dispute resolution, or as otherwise permitted or required under applicable law).We will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. 

When Personal Information is no longer required by us or by law, we will either convert it into an aggregated non-identifying form or we will appropriately destroy or erase the Personal Information in a manner that is in accordance with our current policies and procedures. 

Information Accuracy 

While we collect the Personal Information that you supply, we do so with the understanding that any such information is accurate. It is important to us that your Personal Information held by us is accurate and complete. Having accurate information about you enables us to provide you with services in a manner whereby they function as intended. We will bear no responsibility for any action or omission as a result of our lack of accurate contact information for you, including any inaccuracy, malfunction or other deficiency of the Site. 

Access and Correction 

We recognize that you may have the right to access your Personal Information. Any access request must be made in writing to: Privacy Officer, Rory Goodman rgoodman@lutherwood.ca. Where applicable or permitted, we will make the information available within 30 days or provide written notice when we require additional time to respond to a request for access to information. 

In some situations, we may not be able to provide access to certain Personal Information as the right to access Personal Information is not absolute. If we do not provide you with the requested information, we will notify you in writing and explain our reason(s) for not fulfilling your request. 

Anti-Spam 

Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages, which may include email or SMS text messages. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions in the message or by contacting us at admin@lutherwood.ca. 

Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry. 

Withdrawal of Consent 

You may, at any time, withdraw your consent to our collection, use and disclosure of your Personal Information, subject to reasonable notice and any legal or contractual restrictions. Should you choose to withdraw your consent, we may be unable to provide, or continue to provide, the services that can only be provided if we receive appropriate and required Personal Information. 

Changes to our Privacy Policy 

This Privacy Policy is effective as of the date indicated herein. We reserve the right to change this Privacy Policy, and any of our policies and procedures concerning our practices for handling Personal Information, at any time and without any prior notice. Any changes that are made to this Privacy Policy will apply to both any Personal Information that we hold prior to the effective date of the amended Privacy Policy and any Personal Information that we collect on or after such effective date. 

If we decide to change our Privacy Policy, we will post a notice of the changes on the Site and update the Privacy Policy modification date below. The modifications become effective immediately. You should review this Privacy Policy and all policies regularly to make sure that you are aware of any changes. Your access to use of the Site, our products and services on and after the date on which we post the revised terms constitutes your acceptance of the Privacy Policy as revised as well as of any revised policies. 

Governing Law 

All matters relating to your access or use of the Site shall be governed by the laws of the Province of Ontario and the laws of Canada applicable therein, without regard to principles of conflicts of law. You agree and hereby submit to the exclusive jurisdiction of the courts of Toronto, Ontario with respect to all matters relating to your access and use of the Site, as well as any dispute that may arise therefrom. 

Successors and Assigns 

Our successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this Privacy Policy. 

Contacting Us 

If there are any questions regarding this privacy policy you may contact our Privacy Officer by emailing rgoodman@lutherwood.ca.