B.O.L.T. PRIVACY POLICY
1. Introduction
(A) At the B.O.L.T. Charitable Foundation (B.O.L.T.), we recognize the importance of privacy and are committed to maintaining the accuracy, confidentiality and security of your personal information. This privacy policy describes the personal information that B.O.L.T. collects, how we manage that information and the circumstances under which we may disclose that information.
(B) B.O.L.T.’s privacy policy is based upon the Ethical Fundraising and Financial Accountability Code of Imagine Canada (formerly the Canadian Centre for Philanthropy), the Canadian Standards Association’s Model Code, as well as the requirements of applicable privacy legislation.
2. What is personal information?
(A) Personal information is any information about an identifiable individual, other than an individual’s business title or business contact information. Personal information (e.g. name, address, age, credit card information, banking information) does not include information that cannot be associated with or tracked back to a specific individual. Information that is publicly available, such as a telephone book listing, is also not considered to be personal information.
3. What information does B.O.L.T. collect?
(A) B.O.L.T. only collects personally identifying information about donors, clients, volunteers, grant applicants, grant recipients, and event participants for fundraising, public education and advocacy purposes, program and service delivery, as well as to establish, maintain and manage our relationship with you. The personal information collected and maintained is accurate and up-to-date to the best knowledge of B.O.L.T.
(B) Your provision of personal information to B.O.L.T. means that you agree and consent that we may collect, use and disclose your personal information in accordance with this privacy policy. If you do not agree with these terms, please do not provide any personal information to B.O.L.T.
(C) The information B.O.L.T. collects is the minimum amount we need to demonstrate and maintain a service, volunteer, participant, donor or program relationship with you. This includes:
- contact and identification information, such as your name, address, telephone number and e-mail address
- donation information such as date of gift, amount of gift, name of spouse or partner if it was a joint gift
- financial information such as your payment methods and preferences, billing and banking information (credit card number and expiry date or chequing account transit numbers, in order to process your donation); for online financial transactions such as donations and event registrations, we process standard credit card information (card number, card type and expiration date) via a secure, 128-bit encrypted Secure Sockets Layer (SSL) session. SSL is the proven standard for secure web transactions.
- other personal information used for purposes that a reasonable person would consider appropriate in the circumstances (e.g. if you have demonstrated an interest in participating in fundraising events, we may send you information regarding fundraising programs and services)
4. Online third party payment process
(A) B.O.L.T.’s webpages contain online forms that allow visitors to make a donation. The personal and credit card information provided on these forms is used only to process these donations. Online donations to B.O.L.T. may be processed through a third party. B.O.L.T. is not responsible for how such third parties collect, use or disclose your personal information, so individuals should read the privacy policies of such third parties, and make an informed decision whether or not to visit such web sites and/or provide personal information to such third parties based upon their privacy practices and individual discretion.
5. Website generated information: “cookies” on boltonline.org.
(A) In order to improve our site on an ongoing basis, we use cookies to track your visit. B.O.L.T. also uses cookies to provide users with certain features (for example, customized delivery of information) based on your choice of language and your preferred province/territory.
(B) A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the website that gave it to you. It functions as your identification card. It is not a program and cannot be executed as code or deliver viruses. B.O.L.T. does not report on individual user sessions.
(C) Cookies can also customize the site to your particular interests or store your personal information, such as passwords or user IDs. If a site ever greets you with your name, chances are it’s using a cookie to do so.
(D) Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie – this gives you the chance to decide whether to accept it. To learn more about cookies and how to change your settings, please use the help function in your browser. The alerts will be quite frequent, however, and may eventually become annoying. You can use the B.O.L.T. website without cookies, but you may have to re-enter information each time you visit.
6. How does B.O.L.T. collect personal information?
(A) B.O.L.T. generally collects your personal information directly from you and only with your consent. In addition, B.O.L.T. will not collect or use personal information about you from a third party without your express consent. B.O.L.T. will usually obtain your consent at the time that we collect your personal information. If the purpose for using your personal information changes from the time since such consent was obtained, B.O.L.T. will advise you of this purpose before such use or disclosure.
7. How does B.O.L.T. use your personal information?
(A) Some of the information B.O.L.T. collects is needed in order to satisfy the requirements of the Canada Revenue Agency (CRA) (e.g. income tax receipts). There are also circumstances where the use and/or disclosure of personal information is justified or permitted without consent. These circumstances may include:
- where required by law or by order or requirement of a court, administrative agency or other governmental tribunal
- where B.O.L.T. believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group
- where the information is public
(B) As explained above, B.O.L.T. uses your personal information for fundraising, to process donations, to respond to requests for services and information, and to keep you informed about B.O.L.T. activities.
(C) We may also use the information you provide to us in the following ways:
- to assist in the development of new programs, events, and services
- to provide donation recipients with summary or aggregate information about our donations, programs and services
- for internal research purposes
- to develop advertising based on donor preferences
8. When does B.O.L.T. disclose your personal information?
(A) B.O.L.T. shares your personal information only with B.O.L.T.’s Board of Directors and Scholarship/Bursary Selection Committee, as well as employees and/or volunteers, who require such information to establish, manage and maintain our relationship with you. We may also disclose your personal information to third party service providers whom we engage to mail our fundraising material, process your donation, or answer your inquiry. These third party providers only have access to personal information that is needed to perform the related function and may not use it for any other purpose.
9. Accuracy of information
(A) B.O.L.T. aims to ensure that any personal information provided is accurate, complete and current as required for the purposes for which the information is used.
10. Retention of personal information
(A) B.O.L.T. keeps personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the program, service or event and the nature of the information, for example we generally keep financial information for 6 years, in accordance with CRA rules and regulations. The retention period may extend beyond your relationship with us. When your personal information is no longer required for Society purposes, the information is either physically destroyed or deleted.
11. Links to other websites from boltonline.org.
(A) B.O.L.T. provides links to other websites which B.O.L.T. believes may be of interest to you. As B.O.L.T. has no control over the content of any of these websites, these links may be updated or deleted as B.O.L.T. deems appropriate.
(B) Please be aware that B.O.L.T. is not responsible for the privacy practices of other websites that we link to. We encourage you to read the privacy statements of each and every website that requests personal information from you.
12. Inquiries and requests for access
If you have any questions about this privacy policy, or would like to access your personal information, please contact our Privacy Officer. Please note that as we cannot guarantee the security of Internet mail, all formal requests to access personal information should be made in writing.
Privacy Officer
B.O.L.T. Charitable Foundation
4800 Dufferin Street, Suite 200
Toronto, ON M3H 5S9
Telephone: (416) 661-9290; extension 1267
E-mail: privacy@boltonline.org
If you are not happy with the way that B.O.L.T. has handled your inquiry, or have a concern about the B.O.L.T.’s privacy practices that you feel we have not addressed satisfactorily, you can contact the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: (819) 994-6591