Effective Date: June 1, 2023
By providing any of your personal information to JCF, including information obtained by us during your visits to or use of the Site, you hereby agree to all of the terms and conditions of this Policy and consent to the collection, use and disclosure of your personal information as described in this Policy. Please note that except as is set forth in this Policy, we reserve the right to share anonymized and/or aggregated data acquired by us through your provision of your personal information with third parties.
The terms “we”, “us”, and “our” used in the Policy refer, collectively, to JCF and its departments, divisions, and their respective employees, mandataries, agents and other representatives (collectively, “JCF Organization“).
- WHAT IS “PERSONAL INFORMATION”?
- WHAT PERSONAL INFORMATION IS COLLECTED BY JCF?
- HOW IS MY PERSONAL INFORMATION COLLECTED?
- TO WHOM MAY MY PERSONAL INFORMATION BE DISCLOSED?
- PERSONAL INFORMATION OUTSIDE OF CANADA
- THIRD PARTIES & THIRD-PARTY WEBSITES
- HOW DOES JCF OFFER ONLINE ADVERTISING?
- HOW DOES JCF STORE AND SAFEGUARD MY PERSONAL INFORMATION?
- HOW DOES JCF STORE AND SAFEGUARD MY PERSONAL INFORMATION?
- HOW CAN I ACCESS OR CHANGE MY PERSONAL INFORMATION?
- WHAT ARE MY RIGHTS?
- CONTACTING US
WHAT IS “PERSONAL INFORMATION”?
“Personal information” is any information that identifies, directly or indirectly, or could be reasonably associated with, an individual (“individual” or “you“). This may include, for example, your name, contact information, email address, and information relating to your account with us (as the case may be). It may also include other types of information, but only when this information, individually or in combination with other information, can identify you as an individual. In general, personal information does not include business contact information, such as your name, title, or business contact information. Information that is anonymized and cannot be associated with an identifiable individual is not considered to be personal information.
WHAT PERSONAL INFORMATION IS COLLECTED BY JCF?
Personal information we collect may include, but is not limited to, the following:
- Identifiers and contact information, such as your name, email and postal addresses, telephone number, photographs or videos or account information (for example, if you have created an account upon signing up for our service);
- Demographic information and interests, such as your age, gender, occupation, languages, annual household income, types of activities you participate in and other interests;
- Contacts and Connections, such as the names of contacts and their connection to you, and your affiliations with companies, institutions, foundations and other organizations;
- Transactional information, such as bank account information, e-transfer details; payment card details, donation amounts and donation history;
- Browsing activity on our Site, such as pages and events viewed, clickstream data, account login events, preferences, and IP addresses if they can identify you as an individual;
- Geolocation information collected when you use our Site;
- Any other information you provide to us.
In addition to the personal information mentioned above, each time you visit the Site, the following information may automatically be obtained and compiled: your internet protocol (IP) address and the domain name registry information associated with that IP address; identification of your internet browser, operating system and hardware platform you are using; the date and time of your visit; the name and address (URL) of the web page you viewed immediately prior to accessing the Site; your entire query (if any) that was entered into a search engine which led you to the Site; and any other “click stream” data. This information may be stored in our log files.
Additionally, the complete record of your actions at the Site, including all pages visited, the time spent on each page, the information sent or received and the names of all files uploaded or downloaded is collected. This tracking information may be compiled by us in the aggregate and be made available to third parties in order to identify demographic data regarding our users.
The technologies we use may include:
- Cookies, which are small data files that are saved on your computer when you visit a website so that information can be saved between visits, such as your login credentials or language preferences. For example, cookies allow you to log in quickly when you visit our Site. In certain cases, this information is only kept during the session and is deleted when you close your browser. In other cases, the information is stored on your hard drive and, upon your next visit to the Site, the cookies are used to recall such information. Cookies may store a variety of information, including, a unique user ID that can be used to track the pages of the Site you have visited and the number of times that you view a particular page or other item on the Site, login or registration information and your preferences and your transaction history, where available.
- Web beacons and pixels, which are techniques used to track who is visiting a web page or has opened an email. This allows us to understand your online behaviour, monitor our email delivery, and provide you with interest-based advertising. These tools also allow our third-party tracking tools to gather information, such as your IP address, and provide this back to us in an anonymized, aggregate form (i.e., in a manner that prevents us from identifying you personally). Aggregate information refers to personal information compiled and expressed in a summary form where no personal identifiers are included.
- Other technologies, such as analytics engines, which pull usage data from multiple sources and help manage and collect this data to use for personalization or customization of content and other methods to gain insights into our customers’ needs and preferences.
For the purpose of this Policy, all of these online technologies, i.e., cookies, web beacons, pixels, and other technologies are collectively referred to as “Cookies”.
HOW IS MY PERSONAL INFORMATION COLLECTED?
Directly From You
We will also collect personal information from you when you provide information to us, such as by making a donation, signing up for an event, completing an entry form, ballot or survey, signing up for our newsletter , by communicating with us by telephone, email or otherwise, by setting up a user account and password, logging in as a registered user of the Site and providing information in your account(s), or by introducing or post any text, image, video, audio, or any information, content or other materials through the Site. We may also maintain a record of your interests and acquire information about you from within the JCF Organization.
With Your Consent
We generally collect your personal information with your consent, unless applicable law provides an exception to this principle (for example, to comply with our legal obligations, where necessary to establish, exercise or defend a legal claim or legal proceeding). By accessing the Site, donating funds, responding to surveys or emails or otherwise providing information to us in connection with our programs, events, services or initiatives via the Site, you are providing your consent to the collection, use and disclosure of personal information as set out in this Policy. In some cases, your consent may be “implied”, i.e., your action or inaction at the point of collection, use or sharing of your personal information is interpreted as evidence of consent.
We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Policy or in the terms and conditions of a specific program, event, donation campaign, service or survey that you applied to, signed up for, or participated in. Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us.
If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, you may not be able to use, obtain or participate in the programs, events, opportunities to donate, services, surveys or information that you requested or that could be offered and provided to you.
Refusal of collection and withdrawal of your consent
In the event that you have already consented to the collection, use and/or disclosure of your personal information, you may subsequently withdraw your consent at any time, subject to legal or regulatory requirements or contractual obligations and reasonable notice, by contacting our privacy officer in the manner described in the section entitled “Contacting us” below. Our privacy officer will also be able to provide you with more information regarding the implications of withdrawing consent.
HOW IS MY PERSONAL INFORMATION USED?
We use your personal information for the following limited and specific purposes (collectively, the “Purposes”):
- Providing Programs and Services
We use your personal information in order to provide programs and services, such as:
- Determining your eligibility for a program, service or event;
- Verifying your identity;
- Enrolling you in an event or providing additional information (updates, changes, related or similar events, etc.), including by email, telephone, text messaging or through social media;
- Donation, including donor engagement;
- Processing your transactions and providing charitable tax receipts;
- Taking or verifying instructions from you;
- Creating, administering, and maintaining your accounts; and
- Fulfilling your requests and responding to your inquiries.
- Managing Our Operations
We use your personal information to manage our operations, for instance:
- Deploying and managing our information technology applications and systems, including managing our Site;
- Notifying you of changes to our services, terms, conditions or policies and to provide you administrative messages, updates, legal notices, technical notices or security alerts;
- Enabling your participation in programs, events or initiatives;
- Maintaining the security of the public, our users and our employees;
- Protecting ourselves and third parties from errors and fraud;
- Maintaining our services;
- Processing your employment application; and
- Meeting our contractual, legal and regulatory obligations.
If you have consented to receive such information, JCF may use your personal information to inform you about news, programs, services, events, donation opportunities, surveys or initiatives (“Messages”) offered by the JCF Organization and other affiliated or unaffiliated organizations within our community that we believe may be of interest to you. We may do this by communicating with you in a variety of ways, such as by email, telephone, direct mail, text message or through social media.
- Conducting Research and Analytics
We may use your personal information in order to conduct research and data analytics by tracking and analyzing current or previously collected information for the following purposes:
- Improving or developing new services;
- Managing and developing our operations;
- Understanding our donors’ interests and priorities and tailoring our activities;
- Measuring the effectiveness of our programs, events, activities, and marketing; and
- Understanding how visitors interact with our Site and ensuring it works correctly.
When possible, we will use your information in an aggregated and anonymized format.
In order to better serve you and the community at large, we may combine information you provide to us either in person, online, by telephone or in writing for any purpose.
- As permitted or required by any applicable legal or regulatory requirements or provision;
- Any other purposes to which you have consented
- Secondary purposes
JCF may also aggregate and anonymize personal information you have provided in order to create statistical data that JCF may use to improve the Site. JCF may also share this information with its partners. Such statistical data does not include personal information.
TO WHOM MAY MY PERSONAL INFORMATION BE DISCLOSED?
JCF does not rent or sell any of your personal information to third parties, and will not disclose your personal information to any non-affiliated third party without your prior consent, unless required by law or as necessary for the purposes provided below:
- In the course of their work, our employees may need to access your personal information, for example, when you contact us or request technical support. Their access is limited to what is necessary to perform their duties.
- We may disclose your personal information within or among the divisions of the JCF Organization, so that different divisions may communicate with you (whether by email, telephone, post or otherwise) and provide you with promotional materials and additional information about its services, special programs, events and initiatives that may be of interest to you, or collect and use that information subject to and for other purposes contemplated by this Policy.
- We may transfer personal information to non-affiliated third-party service providers for processing on our behalf (such as canvassers who assist us with our donation efforts, fulfillment services, analytics, online payment services, technical support, delivery services and financial institutions). We require these service providers to limit their access to and/or use of personal information to what is required to provide their services and adhere to confidentiality as well as security procedures and protections. Moreover, JCF implements reasonable contractual and technical safeguards to ensure that such third-parties keep all personal information they access and/or use strictly confidential. Please note that these third-parties may be located in locations other than your current location, in which case appropriate measures are taken by JCF, as described below in the section “Personal information outside of Canada”.
- We may decide to transfer all or part of our operations or activities to a third party, to merge with another entity, or to engage in another form of legal transaction (for example, in the event of a merger, acquisition, bankruptcy or sale of assets). In such circumstances, we may also share some or all of your personal information with the relevant third-party (or its advisors) for purposes of a due diligence process. If your personal information is required in connection with any such transactions, we will comply with the legal requirements for the disclosure of personal information and ensure that the handling of your personal information complies with applicable privacy legislation.
- Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., to comply with applicable laws, to comply with an order of a judicial authority of competent jurisdiction, to comply with any legal process served on JCF, to enforce or verify your compliance with agreements with JCF, if any, when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect the property, interests and rights of JCF and any JCF Organization, our employees, donors, or others, or to act in urgent circumstances to protection the personal safety of users of the Site or the general public. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.
Other than as listed above, we may, with your consent, share or disclose your personal information outside of JCF, in accordance with applicable laws.
PERSONAL INFORMATION OUTSIDE OF CANADA
Personal information we collect is hosted in secure systems hosted on servers that may be located outside your province, territory, or country of residence, including in Canada, and the European Union. Your personal information may in some cases be transferred to jurisdictions outside Québec and/or Canada, to service providers or affiliated organizations. As a result, you understand that your personal information will be subject to the laws of other jurisdictions than Canada and may be available to foreign government authorities under lawful orders and laws applicable in such jurisdictions. Regardless of the company or person who processes your information and where it is processed, we will take steps to protect your information in our custody, including personal information entrusted to an agent or service provider, whether they are located in Canada, the European Union, or other jurisdictions or countries in accordance with applicable data protection laws and this Policy. In particular, we strive to limit their access to personal information to that which is necessary to perform their assigned functions. Please be aware that we also strive to put in place contractual arrangements with these agents and service providers to ensure the confidentiality and security of your personal information. This may include implementing robust and effective security measures. If you have additional questions about this, you may contact us.
THIRD PARTIES & THIRD-PARTY WEBSITES
We may include links on the Site to third-party sites or services that we do not control, for example, if you use an integrated feature of Google or social networks (Facebook, Twitter, LinkedIn, Instagram, Tik Tok, YouTube, etc.). Third parties that you connect with directly through hyperlinks or other information provided on our Site may collect, use or disclose your personal information, or link and combine information about you to other personal information they may have collected on you, to achieve their own goals and purposes.
When personal information is collected by any such third parties, JCF does not collect, use or disclose such information, which is subject to the privacy policies of the third-party organization. We do not control the collection, use or disclosure of such personal information and JCF encourages you to review the privacy policies of such third-party organizations.
Strictly necessary Cookies
These Cookies are necessary for the operation of the Site and cannot be disabled in our systems. Strictly necessary Cookies must be present in order for the Site to provide basic functions; they may include logging in, adding items to a shopping cart or electronic billing. They also allow a user to navigate from one page to another without losing previous actions from the same session.
Non essential Cookies
If you have consented to their use, JCF and/or its third-party partners may also use the following nonessential Cookies in connection with the Site and Messages:
Cookies we use
JCF may use different types of Cookies. As indicated below, some Cookies are strictly necessary for the proper functioning of the Site, while others are used with your prior consent for functional or performance purposes:
- Functional cookies. These Cookies are not essential to the provision of our services. They allow us to personalize and improve the user’s experience, and help us perform certain functionalities like sharing the content of the Site on social media platforms, collect feedbacks, and other third-party features. For example, if you have consented to their use, these Cookies will store your communication and language preferences.
- Performance cookies: These Cookies are used to understand and analyze the key performance indexes of the Site which helps in delivering a better user experience for the users.
- Advertisement cookies: These Cookies are used to provide visitors with relevant ads and marketing campaigns. These Cookies track visitors across websites and collect information to provide customized ads. If you have consented to their use, we use these Cookies to collect information about your devices in order to display ads based on relevant topics that may be of interest to you. Advertisement Cookies are not essential to the navigation of the Site, but they allow you to receive a more relevant advertising offer, adapted to your centers of interest, on the Site, but also on other sites on which you could navigate. As such, advertisement Cookies allow, for example, the display of the advertisement, the capping of the display (consisting in not presenting to a user the same advertisement in a too repetitive way), the fight against click fraud, the invoicing of the display service, the measurement of the targets’ appetite to the advertisement to better understand the target audience. Our partners may use these Cookies to determine whether our advertisements were displayed to you and whether you interacted with them. In this case, our partners share data with us, including statistics about the performance of our ads. Personalization of advertising content may also be achieved, using our partners’ technology, by associating your browsing information on the Site with the data you provided to us when you registered. The deposit or reading of such Cookies is made subject to obtaining your prior consent. The refusal of these advertisement Cookies has no impact on the use of the Site nor will it stop the advertising on the Website. However, we may not be able to provide you with advertisements that take your interests into account. If you would like more information on how to manage and/or disable advertisement Cookies, visit http://www.youronlinechoices.com/. You may also opt out of the use of these Cookies by following the instructions listed below.
- Analytical Cookies. We may use analytical Cookies to better understand traffic patterns on the Site (for example, Google Analytics), to help us measure and improve the effectiveness of the Site and the Messages, and to determine whether those Messages have been opened and the links contained therein have been clicked. These Cookies are used to understand how visitors interact with the Site. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc. for statistical purposes only. All information that these Cookies collect is aggregated. To refuse to be tracked by Google Analytics, please consult this module: https://tools.google.com/dlpage/gaoptout?hl=en. You can also refuse the use of analytics Cookies by following the instructions below.
How to Manage Cookies
With the exception of strictly necessary Cookies, we will only place Cookies on your devices with your consent, and these Cookies will be retained for a maximum period of thirteen (13) months from the time they are placed on your devices. At the end of this period, your consent will again be required.
You may delete or disable certain of these Cookies via your browser’s Cookies settings. Please refer to your browser instructions or help screen to learn more about how to block, delete and manage Cookies on your computer or mobile device. We may also use third parties (e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behaviour as you visit our Site. For details on how to configure browsers, please consult the help centre for Chrome, Safari, Firefox, Internet Explorer, Edge or Opera. You can manage your privacy preferences with respect to certain third parties by using the functionality within their platforms. Social network Cookies (“plug-ins”) can also be managed by consulting the policies of the following networks (to the extent applicable):
- Facebook: https://www.facebook.com/policies/cookies/
- LinkedIn: https://www.linkedin.com/legal/cookie-policy
- Twitter: https://help.twitter.com/fr/safety-and-security/twitter-do-not-track
- Instagram: https://help.instagram.com/1896641480634370?cms_id=1896641480634370&maybe_redirect_pol=true
- YouTube: https://policies.google.com/technologies/cookies?hl=en
- Tik Tok: https://www.tiktok.com/legal/page/global/cookie-policy/en
Please note that disabling, blocking or deleting some of these technologies, such as Cookies, may cause you to lose the functionality of certain features on our Site. Therefore, if you reject Cookies, you may not be able to use all the features of the Site and Messages. If you would like more information on how to manage and/or disable non essential Cookies, please visit https://allaboutcookies.org/ and https://optout.aboutads.info/?c=3&lang=en.
HOW DOES JCF OFFER ONLINE ADVERTISING?
Through Cookies or mobile advertising identifiers
Based on your preferences on your mobile devices, JCF and its advertising partners may also use your mobile advertising ID to target and measure the effectiveness of their advertising campaigns. In iOS, this identifier is called “IDFA” (ID for Advertising); in Android (Google Play), this identifier is called “AAID” (Android Advertising ID). You can access and reset your mobile advertising ID or limit its use through the operating system settings of your mobile devices.
Under no circumstances will JCF allow advertising to children when it has actual knowledge that the user is under 13 years of age. To learn more about JCF’s advertising practices, please contact JCF as indicated in the “Contacting us” section.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative (“NAI“) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. In addition, you can opt out of some of these services by visiting the Digital Advertising Alliance’s Opt-Out Portal at http://optout.aboutads.info/.
HOW DOES JCF STORE AND SAFEGUARD MY PERSONAL INFORMATION?
With necessary and appropriate security measures
We strive to apply the necessary and appropriate security measures to ensure the confidentiality of personal information in our possession. In doing so, we follow generally accepted industry standards. Personal information in our possession is therefore only accessible to those individuals who have the authority to access it and who only consult it when necessary for the performance of their duties. We have adopted physical, technological and organizational processes and procedures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These measures include, for example, privacy impact assessments, contractual obligations, restricted access to the physical office and personal information. If you believe your personal information has been compromised, we invite you to contact us.
We will store your personal information for as long as necessary to fulfill the purposes for which it was collected, or to comply with applicable legal, tax or regulatory requirements, and in accordance with JCF’s automatic computer back-up procedures and document retention policies, except where otherwise required or permitted by law. At the end of this period, we will endeavor to destroy or anonymize such information.
In determining the appropriate retention period for your personal information, we consider the amount, nature and sensitivity of personal information involved, the potential risk of harm from unauthorized use or disclosure of your personal information, the Purposes for which we process your personal information and the possibility of achieving those Purposes by other means, as well as any applicable legal, tax or regulatory requirements. If you would like more information on this subject, please contact us.
At any time, you may request deletion of your account by contacting us.
What is “Phishing”?
“Phishing” is a scam designed to obtain personal information. If you receive an email which appears to be from JCF requesting any personal information, please do not respond. We do not request any personal information by email. Note that for certain programs, you may receive an email inviting you to provide certain information through an online platform. Please ensure that the address is legitimate and not a “Phishing” scam. If you are uncertain, please contact our privacy officer.
In light of the importance of protecting children’s privacy, we do not intend the Site for child audiences, and we do not seek to purposely collect, process or use on the Site any information relating to an individual whom we know to be under thirteen (13) years old without the prior, verifiable consent of his or her parent or other legal representative. If a parent or guardian discovers that his or her child has provided us with personal information, such parent or guardian has the right, upon request, to view the information provided by the child and/or to require that it be deleted from our records. In such a case, we ask that the parent or guardian of the child contact us at the contact information provided in the “Contacting Us” section below for such purpose.
HOW CAN I ACCESS OR CHANGE MY PERSONAL INFORMATION?
You are entitled to request access to, and, if necessary, correct your personal information collected by us. In order to make such a request, please contact our privacy officer in writing (see “Contacting us” section below). It is your responsibility to provide accurate, correct and complete information. You can also contact our privacy officer for any questions about or to make any complaint in relation to this Policy, as well as JCF’s privacy practices in general (see the “Contacting Us” section below).
WHAT ARE MY RIGHTS?
In addition to your right to access and correct your personal information collected by us, and depending on applicable law, you may have certain rights in relation to your Personal Information such as the right to portability and de-indexation of your personal information, the right to withdraw your consent (if any), the right to request deletion of your personal information, and the right to demand for the removal of your email address from our newsletter mailing list by sending your request by email to [email protected].
You also have the right to make a complaint to the appropriate authority at any time if you believe that JCF is not processing your personal information in accordance with this Policy or applicable law.
Please see the “Contacting Us” section for any such request. For more information about exercising your rights in Québec, you may also consult the following website Commission d’accès à l’information du Québec.
JCF has established procedures for receiving complaints and inquiries about its policies and practices relating to the management of personal information, including the retention and destruction of personal information, the roles and responsibilities of JCF employees and members and the handling of privacy complaints. We will notice individuals who make inquiries or lodge complaints of the existence of the relevant procedures. JCF will investigate all complaints. If a complaint is found to be justified, we will take appropriate action, including, if necessary, amending our policies and practices. If you have any questions about how we handle your personal information, please contact us as indicated below. If you are participating in a program, event, service, initiative, competition or survey that is offered by us via the Site, jointly with a third party, the third party may hold your personal information. If you have any questions or concerns, you can contact our privacy office at the following address:
Jewish Community Foundation of Montreal
BY POST MAIL
510-5151, ch. de la Côte-Sainte-Catherine
Montréal (Québec) H3W 1M6