Privacy Policy

This Privacy Policy (“Privacy Policy”) describes how ParticipACTION (“we” or “us”) will collect, access, use and disclose your personal information. It applies to all of our products and services including our website.

Our Commitment to Privacy. The privacy of ParticipACTION’s customers, our employees and visitors to our web sites is of prime importance to us and ParticipACTION is committed to ensuring that your privacy is protected. Our Privacy Policy, developed in accordance with Canada’s Personal Information and Protection and Electronics Document Act (PIPEDA) and other applicable privacy laws, identifies ways in which we ensure that your privacy and the confidentiality of your personal information and opinions are protected within our business. It outlines what personal information ParticipACTION may collect and how we use or restrict the use of your personal information and opinions.

If you do not consent to the collection, use and disclosure of your personal information in accordance with this privacy policy, you must not provide ParticipACTION with any personal information.  It is important to note that some of ParticipACTION’s products and services can only be provided if ParticipACTION receives appropriate and required personal information from you.  Consequently, should you choose not to provide ParticipACTION with the appropriate and required personal information, ParticipACTION may be unable to offer these products and services to you.

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, this 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 and gender, health information, your occupation, your personal financial records or credit information, or any personal identification numbers.

In most circumstances, personal information does not include the business contact information of a representative of an organization, such as the representative’s name, position or title, business address, business telephone number or business fax number. Publicly available information, such as information in a public directory, is not personal information under this privacy policy.

Personal Information of Children.

Important note to children: If you are under the age of 13, you may only use this Site and provide personal information if you have the consent of, and are supervised by, a parent or guardian. Before providing your name, address, email address, or any other personal information to anyone on the Internet, be sure to ask your parents if it is okay.

Important note to parents: We do not knowingly collect the personal information of children who are below 13 years of age. If we believe a child using this Site is under the age of majority in his or her jurisdiction of residence, we will not process any personal information of that child without the consent of the parent or guardian.

Collection and Use of Your Personal Information. ParticipACTION collects your personal information in accordance with this Privacy Policy. We may request that you provide information, some of which may be personal information, when you place an order, join a listserv, provide a submission, register a product, request a service, answer a survey, enter a contest, or correspond with us or engage in certain other activities on our website.

ParticipACTION may collect information including your name, contact information, age, gender, and payment and billing information.  Certain information, including number of steps and move minutes, may be collected if you connect your wearable fitness device to our ParticiPACTION digital products.

ParticipACTION typically collects, uses and discloses your personal information to:

• Provide requested products, resources, services, or website access;
• Monitor and evaluate the quality and outcomes of services, programs and resources for the development, improvement and delivery of our programs, content and, services, business and operations across Canada;
• Establish and maintain communication with you, including responding to your inquiries;
• Process payments and confirm receipt of a product or service;
• Meet and comply with any legal, regulatory, processing or security requirement that requires use or disclosure of your personal information; and
• Inform you about products and services that we offer which we believe may be of interest to you.;
• Provide information to anyone working with or for ParticipACTION as needed for the provision of ParticipACTION’s services;
• Provide billing, accounting and debt collection services relating to ParticipACTION’s products and services;
• Distribute publications, invitations, advertising, and other communications that ParticipACTION believes may be of interest to you;
• Provide for the safety, health, security and emergency preparedness of ParticipACTION’s staff, guests and visitors who are located on ParticipACTION’s premises;
• Respond to your questions and concerns;
• Contact you for survey or client satisfaction purposes, or for the purpose of market or other types of research;
• Detect and protect ParticipACTION and third parties from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with ParticipACTION’s insurers;
• Otherwise communicate with ParticipACTION’s insurers;
• Access third party services’ accounts, including those of third parties that provide services to you;
• Generate analytics;
• Support hosting and backend infrastructures of ParticipACTION or of third parties that assist ParticipACTION;
• Generate location-based interactions;
• Manage contacts and to manage the sending of messages;
• Undertake registration and authentication of you and other users;
• Generate and provide social features;
• Internal, external and regulatory audit purposes
• For any other purpose for which ParticipACTION has your consent.

E-mail, texts and other electronic or hard copy communications you submit to us are saved in accordance with our internal policy and guidelines. If you choose to provide us with personal information in e-mail, text or other electronic communication we use that information to respond to your message and to help us get the information you have requested to you.

E-mail addresses as well as text or other electronic communication contact information are also saved and added to our list server to provide periodic automatic updates and messages about what’s going on at ParticipACTION. If you do not wish to receive these messages, you may unsubscribe at any time.

You should be aware that when you voluntarily disclose personal information (e.g., user name, e-mail address, etc.) in an unsecure transmission anywhere on the Internet, including a submission to our web site, that information can be collected and used by others and may result in unsolicited messages from third parties.

We only use your personal information for the purposes stated above and in accordance with this Privacy Policy, and under no circumstances will we sell, trade or rent your personal information to third parties. ParticipACTION’s staff may use your personal information for the purposes identified in this Privacy Policy.

Consent. Privacy legislation requires ParticipACTION to obtain the consent of an individual to the collection, use or disclosure of personal information in many circumstances.

By providing your personal information to ParticipACTION, you agree that ParticipACTION may collect, use and disclose your personal information in accordance with this Privacy Policy and as otherwise permitted or required by law, and that ParticipACTION may access, process and store your personal information in Canada or another jurisdiction. If ParticipACTION transfers your personal information outside of Canada for the purpose of storage, processing and use of your personal information it will be treated in accordance with applicable foreign laws of the jurisdiction to which it is so transferred.

When ParticipACTION receives personal information from you for the purposes of providing you with ParticipACTION’s services or for other uses identified herein or otherwise by ParticipACTION to you, you are providing ParticipACTION with consent as follows:

1. to allow ParticipACTION to deal with that personal information in a reasonable manner;
2. to allow ParticipACTION to use your personal information for all of the purposes listed in the Collection and Use of Your Personal Information section and otherwise in this Privacy Policy or as communicated by ParticipACTION to you;
3. to allow ParticipACTION to provide your personal information to third parties it engages to provide or support ParticipACTION’s website and other products and services;
4. to allow ParticipACTION to use and store your personal information for the purpose of providing you with the products and services you purchase or otherwise obtain from ParticipACTION and to utilize ParticipACTION’s website and
5. to allow ParticipACTION to transfer your personal information outside of Canada (whereby your personal information will be treated in accordance with applicable foreign laws) for the purpose of storage, processing and use of your personal information by ParticipACTION or otherwise in accordance with this Privacy Policy.

If you need to provide ParticipACTION with personal information about other individuals, you represent and warrant to ParticipACTION that, where required by law and prior to your disclosure to ParticipACTION, you will obtain the consent of each individual to the collection, use and disclosure by ParticipACTION for the specific purpose(s) that the disclosure is made by you.

Providing ParticipACTION with your personal information is always your choice. When you request products and/or services from ParticipACTION, utilize ParticipACTION’s services, or register with ParticipACTION’s website.  ParticipACTION asks that you provide information that enables ParticipACTION to respond to your request and/or provide you with ParticipACTION’s services. In doing so, you consent to ParticipACTION’s collection, use and disclosure to appropriate third parties of such personal information for these purposes.

There are legal exceptions where ParticipACTION 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 ParticipACTION must comply with a court order or governmental order.

If ParticipACTION sells its business or merges with another party, your consent will be implied to transfer your information to ParticipACTION’s successor for the same purposes as set out in this Privacy Policy.

Disclosure of Personal Information. ParticipACTION will only disclose your personal information for the purposes set out in this Privacy Policy.

We will not disclose personal information to any external organization without your consent unless we are required or permitted to do so by law, including in the event of an amalgamation, reorganization, change of control or sale of ParticipACTION.

Your personal information may be stored, processed or otherwise used by us, our affiliates or our service providers, both inside and outside of Canada. Whenever we hire other organizations to provide support services, they will be required to conform to our privacy standards and to allow us to audit them for compliance.

Except as set-out in this Privacy Policy, we do not otherwise sell, trade or transfer to third parties your personally identifiable information. We do not and will not share the information tracked on ParticipACTION’s website, in any form, with advertisers or other parties not related to us.

In certain circumstances, ParticipACTION may be required to provide personal information to third parties for legal or regulatory purposes.

Privacy and Our Website, Products and Services. Each time a visitor comes to ParticipACTION’s website, ParticipACTION’s web server may collect and log certain information in access logs. Such access logs may be kept for a reasonable period of time. Such access logs may include, but not be limited to, information such as the following: your machine’s TCP/IP address, files accessed, the date and time of such access, and other information pertaining to your activities on ParticipACTION’s website or social network sites and/or webpages linked thereto. These logs are used solely for performance, site administration and security reviews. They are not sold or shared in any way to third party organizations. ParticipACTION may use this non-personal information to optimize ParticipACTION’s website, or other products and/or services.

We take all reasonable steps to protect the security and confidentiality of your personal information. We protect the personal information within our custody or control with appropriate organizational, technological and physical safeguards.

ParticipACTION may, from time to time, use “cookies” for security and authentication purposes, and to identify unique visitors to our sites and track general user trends and patterns. Cookies are small pieces of data which are stored on your computer or smart device to allow your Internet browser to remember something about a website and/or services.  Cookies help you access pages faster and allow our server to recognize you as you move from page to page. A cookie is retrieved automatically whenever you return to ParticipACTION’s website and some of its contents are stored in log files that are then used to generate periodic statistical reports for ParticipACTION. These reports help us to evaluate and improve our website, programs, resources, products and services by tracking global indicators such as the total number of visitors, total pages viewed, most popular documents retrieved, etc. If you choose not to accept cookies, all or some sections of our website or our products and/or services may not be available to you.

At your option, you may turn off ParticipACTION’s “cookies” using the applicable features contained in your Internet browser; however, doing so may prevent you from accessing all or part of ParticipACTION’s website, and other products and/or services.  To readjust your Internet browser’s cookies options, refer to the applicable instruction documentation for your particular Internet browser.

ParticipACTION may, from time to time, engage third parties to assist with this Website, and such third parties may track your usage, locate your geographic position, collect personal information, send messages to you on behalf of ParticipACTION, push notifications to you, and use “cookies”, as discussed herein.

By accessing and browsing ParticipACTION’s website or other products and/or service(s), you agree that ParticipACTION, or any third party it engages or that assists ParticipACTION, may collect, use and disclose any information collected about you through ParticipACTION’s website or other products and/or services or that you provide to ParticipACTION through ParticipACTION’s website or other products and/or services as described in this Privacy Policy.

ParticipACTION’s website, or other products and/or service(s) may contain links to other sites and may provide forms on behalf of other organizations.  Please be aware that we do not control these linked sites, and that this Privacy Policy does not apply to those sites. This Privacy Policy only applies to personal information that we collect, use and disclose.  ParticipACTION is not responsible or liable for the privacy practices of third parties, including any organizations on the behalf of which ParticipACTION provides forms, and ParticipACTION strongly recommends that you review a third party’s privacy policy before disclosing any personal information to the third party.

Public Forums. We may provide bulletin boards, blogs, chat rooms, or other areas where users can post information or content for public viewing, on our website. Any personal information or other content you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. Such information and content are not subject to this Privacy Policy; rather, such information and content is subject to our Terms of Use. We are not responsible for the personal information you choose to submit in these forums. You should be aware that such content and information may be made broadly available to the public.

Retention and Destruction of Personal Information. The amount of time ParticipACTION will retain personal information varies, depending on the products and services ParticipACTION has provided and the nature of the personal information that ParticipACTION holds.  ParticipACTION retains personal information for such period of time as is necessary for ParticipACTION to maintain sufficient information so ParticipACTION may respond to any issues that arise at a later date or as is required by law.

Legal requirements, however, may require us to retain some or all of the personal information we hold for a particular period of time.

When personal information is no longer required by ParticipACTION or by law, ParticipACTION will either convert it into an aggregated non-identifying form or ParticipACTION will appropriately destroy or erase the personal information in a manner that is in accordance with ParticipACTION’s current policies and procedures.

Safeguarding Personal Information. ParticipACTION employs reasonable physical, electronic and procedural safeguards that are designed to protect ParticipACTION’s systems and personal information under ParticipACTION’s control against unauthorized access and use. In accordance with appropriate industry standards in Canada, all safety and security measures are appropriate to the sensitivity level of the information collected.

ParticipACTION may engage third party external servers as well as other external services, including cloud services and cloud compatible servers, to store and protect personal information and ParticipACTION does not have any control over such external servers or services.

Electronic Communications. Email is frequently ParticipACTION’s preferred method of communicating with you and others, and, unless you object, ParticipACTION may use unencrypted plain text or html-based emails or messages when communicating with you.  These emails or messages, and other electronic means by which ParticipACTION may communicate with you, may contain information that is confidential. ParticipACTION will send such information unless you instruct us not to send such information electronically. ParticipACTION may communicate with you through any electronic means, in accordance with the contact information you provide to ParticipACTION.

Where applicable, we will seek your express consent to contact you, including by way of commercial electronic messages. You can unsubscribe at any time from receiving commercial electronic messages by following the instructions such in messages. Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes in accordance with applicable laws. For example, we may contact you to provide communications you have consented to receive, regarding the products or services we provide to you, or if you contact us with an inquiry.

While ParticipACTION makes every effort to secure all electronic communications within ParticipACTION’s control, there are inherent risks involved with exchanging information electronically.  For example, such information may be accidentally or deliberately intercepted by third parties.  ParticipACTION is unable to accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange of such information.

ParticipACTION will endeavour to be compliant with Canada’s anti-spam laws (“CASL”) in ParticipACTION’s commercial electronic communication with you. Should you fail to provide ParticipACTION with the requisite consent to send you commercial electronic messages, or withdraw such consent, ParticipACTION may be unable to provide, or continue to provide, to you access to ParticipACTION’s website or some of ParticipACTION’s products and/or services that can only be provided if ParticipACTION receives appropriate and required personal information. CASL consent can be provided or withdrawn by contacting: info@participaction.com

Keeping Information Accurate / Access and Correction. It is important to ParticipACTION that your personal information held by ParticipACTION is accurate and complete. Having accurate information about you enables ParticipACTION to give you better service. You can help ParticipACTION keep personal information up to date by keeping ParticipACTION informed of any changes, such as a change of address, telephone number or any other circumstances.

With some exceptions, ParticipACTION has the right to access, verify and amend the information ParticipACTION has about you after ParticipACTION has received your written request and authenticated your identity.

ParticipACTION may charge a reasonable fee for providing information in response to an access request, and, upon request, ParticipACTION will provide an estimate of any such fee upon receiving a request to access information. ParticipACTION may require a deposit for all or part of the fee.

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

Despite ParticipACTION’s efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect or incomplete, let ParticipACTION know and ParticipACTION will make the corrections promptly.

Withdrawal of Consent / Deletion of Data. You may, at any time, withdraw your consent to ParticipACTION’s collection, use and disclosure of your personal information, subject to reasonable notice and any legal and/or contractual restrictions.

Should you choose to withdraw your consent, ParticipACTION may be unable to provide, or continue to provide, this website or some of ParticipACTION’s, products and/or services that can only be provided if ParticipACTION receives appropriate and required personal information.  Consequently, should you choose not to provide ParticipACTION with the required personal information, ParticipACTION may be unable to offer this website and such  products and/or services to you.

You may, at any time, ask ParticipACTION not to send you further marketing materials about ParticipACTION’s products or services or if you do not wish to receive further invitations, you may unsubscribe or ask ParticipACTION not to contact you for these purposes at: info@participaction.com

You may, at any time, request that ParticipACTION deleteall your data held by ParticipACTION.  Unless ParticipACTION is required by law to keep certain information, ParticipACTION will delete it upon your request.  To request deletion of your data, please e-mail:   info@participaction.com with the subject line “Data Deletion”.

Privacy Concerns. ParticipACTION will respond to questions and concerns relating to ParticipACTION’s personal information handling practices and this Privacy Policy directed to: info@participaction.com

Contact Information. Please contact ParticipACTION to obtain further information about ParticipACTION’s policies and procedures, to seek access to personal information ParticipACTION may have about you, or if you have any unresolved inquiries or concerns. ParticipACTION can be contacted at: info@participaction.com Your privacy is important to us. We welcome comments and questions about our Privacy Policy. You or a person authorized on your behalf has the right to request to see and obtain a copy of your personal information and to request changes or corrections to inaccurate or incomplete information as set out in this Privacy Policy. ParticipACTION will respond to you and do ParticipACTION’s utmost to resolve concerns you direct to us.  ParticipACTION may need to ask you for personal information to verify your identity.

Changes to this Privacy Policy. This privacy policy is effective as of the Last Updated date above. ParticipACTION reserves the right to change this Privacy Policy, and any of ParticipACTION’s policies and procedures concerning ParticipACTION’s practices for handling personal information, at any time and without any prior notice.  If ParticipACTION has modified or amended our Privacy Policy, ParticipACTION will post the most current version on ParticipACTION’s website.  Any changes that are made to this privacy policy will apply to both any personal information that ParticipACTION holds prior to the effective date of the amended privacy policy and any personal information that ParticipACTION collects on or after such effective date.

Successors and Assigns: ParticipACTION’s successors and assigns may collect, use and disclose your personal information for substantially similar purposes as described in this Privacy Policy.

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