Privacy Policy
Smile Train Canada Foundation
Effective: May 23, 2024
Last Updated: May 23, 2024
Smile Train is a nonprofit, cleft-focused organization, with a model of supporting surgery and other forms of essential care for individuals with cleft conditions. This Privacy Policy is intended to describe how Smile Train Canada Foundation (also referred to as “we” or “us”) collects, uses, and shares information that we collect or obtain through smiletraincanada.org and all subdomains (“Sites”).
1. APPLICABILITY OF THIS PRIVACY POLICY
This Privacy Policy applies only to personal information that you submit or that we collect or receive through our Sites as well as any information that you may provide to us or that we may collect in connection with our provision of the Sites’ services. This Privacy Policy does not apply to other Smile Train websites or applications, or to our Smile Train programs. Our use of patient information that you submit to partners or that we otherwise collect in connection with our partner programs is not subject to this Privacy Policy and is governed by our agreement with the partner organization.
2. INFORMATION WE COLLECT
As described in this Privacy Policy, we may collect certain Personal Information from or about you in connection with your use of, or your submissions to, the Sites and our provision of the services. “Personal Information,” for purposes of this Privacy Policy, generally includes information that may be used to identify you.
The sources and types of Personal Information we collect may vary depending upon our relationship with you. For example, we may collect information from or about the following categories of individuals:
- Individuals who visit or otherwise interact with our Sites or request or sign up to subscribe to receive information or materials from us (“Visitors”).
- Individuals who register for an account (“Users”).
- Individuals who make a donation to us, including directly through the Sites or through a partner organization (“Donors”).
- Individuals who volunteer with our organization (“Volunteers”).
Unless otherwise specified, we refer to these categories of individuals collectively as “you” or “your” in this Privacy Policy. You are not required to provide all Personal Information identified in this Privacy Policy; however, please be advised that if you do not provide the Personal Information requested, we may be unable to provide some or all of the Services.
Categories of Personal Information
We may collect the following categories of Personal Information:
| Categories of Personal Information | Examples |
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| Identifiers, contact, and demographic information | Name; mailing address; email address; telephone number; organization; job title or occupation; device ID; age; username and password. |
| Transaction information | Transaction information associated with donations, such as donation and gift aid details. Please note, when you make a donation through our Sites, we utilize third-party payment processors to manage and administer the payment process (“Payment Processors”). When you make donations to us, the processing of payment information is governed by the respective Payment Processor’s privacy policy. Smile Train does not collect or store your complete bank account number or credit/debit card number; however, we may collect or receive limited information regarding your transaction and payment, such as your payment card type and last four digits of your payment card number. |
| Donation information | Donation history, including recency, frequency, and amount of donations; your connection to the charity; your participation in charity events and campaigns, including giving patterns. |
| Internet or similar network activity | Browsing history; clickstream data; browser and operating system type; navigation paths; data/time stamps; cookie identifiers; domain names; access times and referring website addresses; and other information about device characteristics and how you interact with our Sites or our services. |
| Geolocation data | Geolocation; IP address. |
| Professional or employment-related information | Occupation; job title and description; organization address; and/or other information related to your organization and/or your employment. |
| Inference information | Inferences we may infer from other Personal Information we have collected, which may include preferences and characteristics (for example, about Donors based upon such criteria as timing and history of donations). We do not use information we collect to derive inferences or conclusions about an individual’s mental or physical health. |
Cookies, Device Information, and Similar Technologies. As is common practice with almost all professional websites, we use cookies to enhance your experience. We may collect certain information using cookies and other technologies, such as web beacons, device IDs, HTML5 local storage, and IP addresses. Cookies are pieces of information that some websites transfer to the computer that is browsing that website and are used for record-keeping purposes at many websites. Use of cookies makes web-surfing easier by performing certain functions such as login status, your personal preferences regarding your use of the particular website and to make sure you do not see the same ad repeatedly. Many consider the use of cookies to be an industry standard.
We use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization and performance/analytics. We may also automatically collect certain data about your device, such as information about your web browser, IP address, time zone, mobile device ID, model, manufacturer, operating system, version information, carrier-related information, and IDs related to the cell phone hardware in your phone as well as the network to which the device is connected, mobile phone number, application-specific and instance-specific identifiers, and location information, as further described in this Privacy Policy.
Internet browsers normally accept cookies by default. However, most browsers let you turn off either all or third-party cookies. If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. The option to do this is usually found in the options, settings or preferences menus of your browser or mobile device. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features that they add to this site. You may choose not to disable cookies if you are not sure whether you need them or not in case they are used to provide a service that you use. If you choose to have your browser refuse cookies, it is possible that your ability to use our Site will be limited or that some areas of our Sites will not function properly when you view them.
You may opt-out of Google’s analytics cookies by visiting Google’s opt-out page: https://tools.google.com/dlpage/gaoptout. Click on the following links to find out how to change your cookie settings in: Internet Explorer; Firefox; Chrome; Safari; Opera; iPhone and iPad; Samsung. For more information about the use of cookies see: www.allaboutcookies.org. Check out allaboutcookies for instructions and advice.
Aggregated or Anonymous Data. We may anonymize Personal Information to create anonymous or aggregated information, in accordance with applicable law to understand how to improve or enhance our services. Such anonymization process will be completed in accordance with applicable law and current industry standards.
3. SOURCES OF INFORMATION AND PURPOSES OF COLLECT AND PROCESSING
The following is intended to describe the various sources through which we may collect Personal Information and the purposes for which we collect and process it. As noted above, the sources and types of Personal Information and our purposes may vary depending upon our relationship with you:
| Sources of Personal Information | Categories of Personal Information from Source | Purposes of Collection and Use |
|---|---|---|
| Communications and Interactions with Us and Participation in our Events and Programs We may collect Personal Information from you when you interact with the Sites or services, register for an account, sign up for or participate in our events, conferences, or programs, submit inquiries or request information from us, complete quizzes or surveys, contact our support hotlines, or otherwise contact or communicate with us. |
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| Agreements, Forms, and Applications We may collect Personal Information from you or your authorized representatives in connection with entering into an agreement with you or through other forms or agreements. We may also collect Personal Information when you submit applications to us, such as for our scholarship, schools, and partner programs. |
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| Requests Regarding Our Partner Programs We may collect Personal Information from you when you submit inquiries or request information regarding our partner programs. The information we collect in connection with those inquiries is subject to and treated in accordance with this Privacy Policy. As noted above, the information we may collect once you become a cleft patient or otherwise participate in our partner programs is not subject to this Privacy Policy and is governed by our agreement with the partner organization. |
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| Account Administration and Transactions We may collect Personal Information from you and from records we create in connection with administering your account or when you complete transactions. |
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| Social Media, Online Forums, and Advertisements We may collect Personal Information from third-party social media platforms and sites, when you engage with our social media pages, online communities and forums, and when you mention us on your own or other social media pages, online communities, or forums, or when you interact with advertisements related to our services. Please note that online forums may be publicly accessible and other users may view information you post in the forums. We encourage you to exercise care in deciding what information and content you wish to disclose on the areas of the Sites that are accessible to the general public. |
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| From Partner Organizations and Service Providers We may collect Personal Information from our partner organizations and service providers, or other third parties who are authorized to act on our behalf. |
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| When You Make a Donation We may collect Personal Information from Donors when you make a donation or you otherwise contact or communicate with us in connection with our donation program. |
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| Publicly available Sources We may collect Personal Information from publicly available sources. |
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4. HOW WE MAY DISCLOSE INFORMATION
We may disclose personal information as described in this Privacy Policy, including with the following categories of third parties:
| Categories of Third Parties with Whom We May Share Personal Information | Categories of Personal Information We May Share |
|---|---|
| Affiliates We may share Personal Information with our Affiliates for the purposes of our operations and administration. Where we share personal information with our Affiliates, we will require our Affiliates to honor this Privacy Policy. |
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| Technical and Operational Service Providers and Partner Organizations We may engage third parties to perform certain functions on our behalf. To do so, we may disclose Personal Information to our third-party partners and service providers in order to maintain and operate the Sites and to provide, improve, and personalize the services, including to fulfill requests for the services, process donations and payment transactions, to administer your account, and for other technical and processing functions, such as sending e-mails on our behalf, administering transactions, and technical support. We may also share Personal Information with service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process. |
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| Marketing, Advertising, and Analytics Providers for Our Direct Marketing Purposes We may share Personal Information with third-party providers, including social media providers, for marketing, advertising, and analytics purposes. For additional information regarding our advertising practices, please see the Advertising and Social Media section. |
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| Government Entities and Legal Compliance We may share Personal Information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with any court order, law, or legal process or to respond to a subpoena, search warrant, or government or regulatory request; for fraud- or crime-prevention purposes; to enforce agreements and to assert and defend against legal claims; and to establish, protect, and/or defend the rights of our organization or the rights or safety of third parties. |
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| Professional Service Firms We may share Personal Information with professional service firms in connection with our legal and regulatory obligations and to establish or exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants. |
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| Corporate Transactions Subject to applicable law, we reserve the right to transfer some or all Personal Information in our possession to a successor organization in the event of a merger, acquisition, bankruptcy, re-organization, or other sale or transfer of all or a portion of our assets, or in contemplation of any such proposed transaction, including for the purpose of permitting the due diligence required to decide whether to proceed with such a transaction. If any such transaction occurs, the purchaser will be entitled to use and disclose the Personal Information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding Personal Information as described in this Privacy Policy. |
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5. ADVERTISING AND SOCIAL MEDIA
Interest-Based Advertising
Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads. Depending on from where you access the Sites, you may also be asked to consent to our use of cookies, including advertising cookies.
Opt-outs for interest-based advertising require that strictly necessary cookies are not blocked by the settings in your web browser. To learn more about this type of advertising and how to opt-out of this form of advertising, you may either visit optout.aboutads.info to opt-out of sites and services participating in the Digital Advertising Alliance (“DAA”) self-regulatory program, or visit optout.networkadvertising.org to opt-out of this form of advertising by members of the Network Advertising Initiative (“NAI”). You can visit Your Ad Choices (Canada) to opt-out of interest-based advertising with participating entities for each region. These websites also provide detailed information about how interest-based advertising works.
Opting out does not mean that you will no longer receive advertising from us, or when you use the Internet. It just means that the data collected from our Sites will not be used for interest-based advertising and that the advertising you see displayed on websites will not be customized to your interests. Note that electing to opt-out will not stop advertising from appearing in your browser or applications, although it may make the ads you see less relevant to your interests.
Your choice to opt out on a particular browser or mobile device will apply only to the collection and use of information from that particular browser or mobile device. Opting out on a particular device will not opt you out of information collection on other devices (including mobile devices), nor will it limit cross-device sharing on those other devices. Similarly, opting out on a particular browser will not opt you out of information collection on other browsers. (This opt-out works through cookies set on a particular browser, so if you delete cookies from a web browser, or use a different browser, you will need to opt out again.) If you use different browsers on a device or multiple mobile devices, for each browser and device you wish to opt out, please opt out each device and browser separately at optout.aboutad.info and at optout.networkadvertising.org.
Profiling and Donor Prospect Research
We may analyze your Personal Information and create a profile of your interests and preferences as part of our fundraising activities. This allows us to ensure communications are relevant and timely, and provide an improved experience for our supporters. It also helps us, for example, understand the background of our supporters and prospective supporters so that we can make appropriate requests to those who may be willing and able to give more than they already do, enabling us to raise funds sooner and more cost-effectively.
When building such a profile, we may make use of additional information about you, including geo-demographic information. This information may be collected from third parties or publicly-available sources, for example from public registers, such as listed Directorships and trusteeships on the Companies House and Charity Commission registers, typical earnings and house prices in a geographical area, information from the electoral roll, press reports, and social media posts. The type of information we collect may include a career overview, gift capacity, and measures of affluence, areas of interest, and history of giving to charities/public information on any philanthropic activities.
We may also engage specialist prospect research and wealth-screening agencies to assist with our profiling activities. This includes screening our supporter database against the agency’s demographic database in order to assess (based on estimated levels of wealth), whether our existing supporters may have the capacity and propensity to provide greater financial or other support to our organization. This activity enables us, for example, to better communicate and engage with supporters.
Social Media Tools
We may use Personal Information to participate in Facebook’s Custom Audience and Lookalike Audience programs, which enable us to display advertisements to both existing and potential supporters when they visit Facebook (and/or Instagram, which is also operated by Facebook). We choose to use Facebook Audience tools as a means to reach our current supporters and new supporters in order to pursue fundraising in a more cost-effective way. We may provide your Personal Information, including (currently) your email address, name, phone number and postal address to Facebook so that it can determine whether you are a registered account holder with them. Our advertisements may then appear when you access their platforms.
Do-Not-Track
Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. Please note that the Sites do not alter its behavior or use practices when we receive a Do Not Track signal from your browser.
6. INFORMATION ABOUT CHILDREN
Due to the nature of our Services, we may collect or receive Personal Information about children in order to provide the services. We do not knowingly collect information directly from children under 14 years old without the consent of the minor’s parent, legal guardian, or authorize representative, except as permitted or required by law or for safety and security purposes. If you become aware that a child under 14 years old has provided us with Personal Information without appropriate consent, please contact us using the information in the “How to Contact Us” section. If we become aware that a child under 14 years old has provided us with Personal Information without appropriate consent, we will take steps to remove the data as permitted by law.
7. ACCESS AND CORRECTION OF PERSONAL INFORMATION
- Request access to or correction of your Personal Information. You may request access to, modification of, or correction of your Personal Information. If you believe our records are inaccurate, you may ask for those records concerning you to be updated. If you have registered for an account, you can also make changes to your Personal Information within your account settings.
- Withdrawing consent. In certain circumstances, you may have the right to request that we stop processing your Personal Information, such as a request to stop sending you direct marketing communications. Where we have collected, used or disclosed your Personal Information on the basis of your consent you can withdraw that consent at any time. For more information on withdrawing consent and opting-out of direct marketing communications, please see the instructions in the “Updating Your Communications Preferences and Withdrawing Consent” section of this Privacy Policy. For more information regarding opting out of certain profiling and advertising practices, please see the “Advertising and Social Media” section of this Privacy Policy.
Please contact us at the email or telephone number in the “How to Contact Us” section of this Privacy Policy. If you have registered for an account, you can also access and update certain Personal Information within your account. You may also authorize someone to exercise the above rights on your behalf.
As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. We will respond to authorized and verified requests as soon as practicable and as required by law. To protect your privacy and security, we may take steps to verify your identity in order to respond to your request. The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. These rights are also subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.
8. UPDATING YOUR COMMUNICATIONS PREFERENCES
Opting-Out of Direct Marketing Communications
If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications, or you may contact us at the information in the “How to Contact Us” section to opt-out of direct marketing. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices and communications in connection with administering donations.
9. LINKS TO OTHER SITES
Our Sites may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). For example, our Sites may offer links to various resources to support individuals with cleft conditions and their family members. Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites. We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.
10. DATA RETENTION
We will retain your Personal Information for as long as is necessary to fulfill the purposes for which we obtained the Personal Information, including to provide the services, or for such longer period as may be required or permitted by applicable law, in accordance with our internal data retention policy. The length of time that Personal Information will be kept may depend on the reasons for which we are processing the information and on the law or regulations that the information falls under, such as financial regulations, statute of limitations, health and safety regulation, or any contractual obligation we might have (for example, under grant funding agreements).
Subject to the above, we will typically retain Personal Information relating to Donors for six (6) years from the end of the last tax year of their last donation or interaction with us, or as otherwise required by law, after which time it will either be deleted, archived, de-identified, or anonymized. Please note if you request to receive no further contact from us, we may need to retain certain basic information about you in order to avoid sending you unwanted materials in the future or to comply with our legal obligations.
11. DATA SECURITY
We implement technical and organizational security measures designed to secure and protect Personal Information. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of Personal Information.
12. TRANSFER OF DATA
The Personal Information we collect from you may be transferred to and processed and/or stored at a destination outside of Canada, including in the U.S. and India. While located in a foreign jurisdiction your Personal Information may be subject to local law, including access by local law enforcement.
We use service providers located outside of Canada for services such as hosting donor information and processing donations. We maintain contractual safeguards with such providers regarding protecting personal information in accordance with this privacy policy.
If you have any questions about our use of foreign service providers, please contact us (see contact information below).
13. UPDATES TO THIS POLICY
We may update this Privacy Policy from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. We encourage you to review this Privacy Policy often to stay informed of how we may process your information.
14. HOW TO CONTACT US
If you have questions about this Privacy Policy or our privacy practices, please contact the Director, Development, Canada, by e-mail at info@smiletraincanada.org or by phone or mail using the details provided below:
Smile Train Canada Foundation
174 Spadina Avenue, Suite 404
Toronto, ON M5T 2C2
+1.226.765.3706