Last Updated June 26, 2017.
- This Privacy Statement applies to any individual who accesses a website owned or operated by CARP (each a “Site”), including without limitation the websites located at carp.ca, my.carp.ca, secure.carp.ca.
- “CARP” means, collectively, the not-for-profit corporation CARP, formerly Canadian Association for Retired Persons.
- The term “personal information” has the meaning attributed to it under Part I of the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”). Where a province or territory has enacted legislation that is substantially similar to Part I of PIPEDA, such as Alberta’s Personal Information Protection Act, British Columbia’s Personal Information Protection Act, or Quebec’s Act respecting the protection of personal information in the private sector, and that statute has application to your personal information that CARP collects, stores, uses or discloses, then the term “personal information” has the meaning attributed to it in that legislation.
- This Privacy Statement applies to any individual who corresponds with CARP, enters into a contest sponsored by CARP, or uses any products or services offered by CARP. It explains how personal information about you may be collected, used, or disclosed by CARP as a consequence of your activities on this website and as a consequence of the operation by CARP of its various commercial activities.
Protection of Personal Information
- Canadian law governs the collection, use and disclosure of personal information in a manner that recognizes individuals’ right of privacy with respect to their personal information. CARP is committed to protecting your privacy and safeguarding the personal information provided to us in relation to our Sites. We protect and use your information by observing the principles and guidelines in PIPEDA and Canada’s Anti-Spam Law (“CASL”).
- The type of personal information that is protected includes almost any information about an identifiable individual, such as the individual’s name, address, telephone number, age, sex, marital status and nationality. Personal information may not, however, include certain types of business or employment related information. It may not, for example, include the name, title, business address or telephone number of an employee of an organization.
- Certain fundamental principles apply to the collection, use and disclosure of your personal information. One of the most significant, is that your personal information generally cannot be collected, used or disclosed without your consent. It also allows you to find out why your personal information is being collected, how it is being used, where it’s being stored and to whom it’s disclosed. It requires the use of appropriate safeguards to secure your personal information. It also grants you access to your personal information and provides mechanisms for ensuring compliance.
- CARP does not collect, use or disclose your personal information without your consent except where required or allowed by law.
What Information Does CARP Collect?
- Although CARP sometimes offers products or services jointly with CARP vendors, advertisers and other business partners, or informs you of products or services that third parties offer and that CARP feels may be of interest to you, these third parties never have access to the personal information that is collected from you unless it is made clear at the time that the information is collected (e.g. the sponsor of a contest administered by or co-branded with CARP may contact you regarding its products or services, where it is made clear that the sponsor might contact you directly if you enter the contest). If you prefer not to learn about such products or services, and you no longer wish to receive these types of communications from CARP, you always have the option to request that CARP exclude you from such further communication.
- CARP may, from time to time, ask you to provide general information about yourself to assist in meeting your needs or to better understand the requirements, profiles and experience of Site visitors. This information includes information that is collected if you choose to participate in a survey, if you ask to receive newsletters or ask to be kept updated about new developments or services offered by CARP or its partners, or if you contact CARP.
- You can visit this Site without telling CARP who you are and without providing CARP with any information about yourself. However, certain anonymous information (“Anonymous Information”) may be collected by CARP automatically. For example, CARP’s Web servers may collect the IP address and the name of the Internet service provider (“ISP”) associated with the computer from which you accessed a Site, the type and version of Web browser and operating system that you are using, and the address of the Web site that you visited prior to the CARP Site. If your Web browser is configured to accept cookies, CARP may place either temporary cookies (only until you exit your current browser window) or permanent cookies (until you manually disable or delete the cookie using your browser software) on your computer. A “cookie” is a small piece of information that a CARP Web server automatically sends to your browser for storage on your computer, which then permits a CARP Web server to recall information about your preferences as a part of the Anonymous Information. Please note that portions of the CARP Sites may not function if you do not accept cookies.
- With the exception of the Anonymous Information described above, you will always know when CARP is collecting information from you and therefore have the opportunity not to provide the information.
- CARP does not knowingly solicit information from children and does not knowingly market its products and services to minors.
Use of Information by CARP
- Personal information collected by CARP is primarily used for the purpose of:
(a) identifying you as a user of one or more of the CARP Sites;
(b) updating you about the Sites and other products and services of CARP and its partners, and otherwise developing, marketing, recommending or providing products or services, including by administering surveys and contests;
(c) understanding the ways in which CARP can improve its products and services;
(d) answering your questions and providing you with products and services that you have requested;
(e) determining appropriate new features, content or services for the Sites as well as other products and services of CARP, including through the use of market research and surveys;
(f) processing payments where applicable;
(g) occasionally providing advertisers and business partners with aggregate but not personally identifiable information about our customers and their preferences, including statistical information about the use of CARP products and services;
(h) meeting any legal, regulatory, processing or security requirements that involve use or disclosure of your personal information; and
(i) such other purposes as are disclosed to you at the time that personal information is collected from you.
- Anonymous Information may be used to serve you with targeted advertising on the Sites.
- CARP Sites may contain links to other sites, including those of CARP’s vendors, advertisers and other business partners, that are not governed by this Privacy Statement. CARP is not responsible for the content of, or the privacy practices employed by, other Web sites.
- You should be aware that when you voluntarily disclose personal information by posting any information on a Site, including on any blogs, chat areas or bulletin boards, such information can be collected and used by others and may result in unsolicited messages from third parties.
- If you contact CARP, a record may be kept of the correspondence but CARP will not make any use of the email address or other contact information, other than to respond to the communication, unless consent has separately been obtained for such other use.
- CARP does not collect, use or disclose your personal information without your consent except where required or permitted by law. CARP will not require you to consent to the collection, use or disclosure of personal information as a condition to the supply of any products or services, except to the extent reasonably required to fulfill the purposes identified in this Privacy Statement or otherwise identified at the time that CARP collects your personal information.
- The way in which CARP obtains your consent depends on the circumstances and the type of information collected. Express consent is generally obtained when the personal information is likely to be considered sensitive. Consent may also be implied by the circumstances. For example, when CARP receives personal information from you that enables CARP to provide you with a requested product or service, your consent to allow CARP to deal with that personal information in a reasonable manner would be implied.
- If you provide personal information about other individuals, such as, for example, personal information about employees or dependants, you must first obtain their consent for these purposes prior to your disclosure of the information to CARP.
- CARP may collect, use or disclose personal information without your knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
- CARP may also disclose personal information without knowledge or consent to a lawyer or other advisor representing CARP, to collect a debt, to comply with a subpoena, warrant or other court order or rules, if required for the investigation or enforcement of laws, or as may otherwise be required or authorized by law. Where a request for personal information is made by an organization claiming lawful authority for the request, CARP will take reasonable steps to ensure that the requesting party properly identifies its legal authority.
- CARP will generally obtain your consent electronically on the applicable Site. However, it may also be obtained in writing or verbally. In determining the appropriate form of consent, CARP will consider the sensitivity of and reasonable expectations regarding the personal information.
- You may withdraw your consent to the continued collection, use or disclosure of your personal information by CARP at any time by emailing [email protected], but such a request would be subject to legal or contractual restrictions. CARP would also require reasonable advance notice to effect any requested changes. A request that CARP no longer collect or use your personal information may mean that CARP will no longer have practical means to provide you with certain services or products. You may no longer be able to log in to a Site or may lose certain functionality when visiting a Site, including functionality that depends on Anonymous Information such as the placement of cookies.
- If you withdraw your consent to the disclosure of personal information that you have previously authorized CARP to share with others, you should know that others may already have retained a copy of your personal information in their own systems and databases.
Retention of Information
- CARP maintains record retention practices and policies which apply to personal information that is no longer necessary or relevant for the identified purposes, or that is no longer required or permitted by law to be retained.
- Your consent to CARP’s collection, storage, use or disclosure of your personal information remains valid even after the termination of CARP’s relationship with you, unless you provide CARP with written notice that such consent is withdrawn.
- All personal information destroyed or erased from our records is done so securely with due regard to the sensitivity of the information.
Disclosure of Information
- CARP will not sell, trade, rent or license personal information that you provide.
- In providing its services, CARP may need to disclose your personal information to affiliates, subsidiaries or successors, or to service providers or agents who perform various functions for CARP.
- CARP will not otherwise disclose your personal information to third parties except to the extent reasonably required to fulfill the purposes clearly identified at the time that CARP collects the personal information. For example, during the administration of a contest, CARP may share certain personal information that CARP collects from you with a party sponsoring the contest, but this will be clearly set out as a part of the contest description or rules.
- CARP may from time to time use third party service providers to process certain data, such as mailing lists or credit card transactions. Third party service providers are required to comply with privacy laws and principles comparable to CARP’s. All credit card transactions are completed using secure electronic encryption. Credit card and other personal information may be transmitted to third party data processing companies or servers located in the United States and are subject to United States laws regarding disclosure.
- CARP may disclose your personal information to third parties who acquire all or a substantial part of the CARP business, including by merger, amalgamation, a sale of our assets or in the unlikely event of bankruptcy. CARP may disclose your personal information to third parties during the due diligence process preceding such a transaction, provided that the other party is bound by an appropriate confidentiality agreement. Subject to a court order, at the time of such merger, amalgamation, sale or bankruptcy, CARP would contractually require any resulting entity that obtains your personal information to comply with its obligations regarding your personal information, including the applicable terms and conditions of this Privacy Statement.
Access and Accuracy and Update of Personal Information
- You are responsible for advising CARP of any inaccuracies or changes to your personal information.
- Upon request made in writing, CARP will inform you of the existence, use and disclosure of your personal information, at minimal or no cost to you, in accordance with processes and procedures that CARP has put in place for such requests. If you are unsure whether CARP has a record containing your personal information and would like to confirm what personal information CARP has, please send your request to [email protected]. If there is a cost involved, CARP will inform you at that time.
- CARP may require additional information from you in order to verify your identity following an access request. Such personal information will only be used for the purpose of identity verification and will itself be subject to protection under the terms of this Privacy Statement.
- In some circumstances, CARP may not be able to provide access to all of the personal information that CARP holds about you. CARP may not provide access to information if doing so would likely reveal personal information about a third party, could be expected to threaten the life or security of an individual, reveal confidential commercial information, if the information is protected by a legally recognized privilege, if it was created as part of a settlement or dispute resolution process, or if it was collected in relation to the investigation of a breach of an agreement or a contravention of law. CARP will provide reasons to you if it refuses an access request.
- Where CARP considers it appropriate, having due regard to the sensitivity of the particular information that CARP collects, uses or discloses, CARP uses encryption or authentication tools, among other methods, practices and procedures, to protect certain your personal information irrespective of which format it is stored in.
- CARP’s service providers and agents are required to maintain client confidentiality and may not use or disclose any information provided to them by CARP for any unauthorized purpose.
Changes To Our Privacy Statement
- CARP will make information about its policies and practices relating to management of personal information readily available. Please direct any questions about CARP privacy policies and procedures, any requests for access to records of your personal information and any other privacy related concerns or complaints to [email protected]. If you contact CARP by telephone, please note that telephone calls may be recorded for training or quality assurance purposes.