This Privacy Policy governs the manner in which Start Proud collects, uses, maintains and discloses private information collected from users (each a “User” and collectively “Users”) of the www.startproud.ca website (“Site”). This privacy policy applies to the Site, any subdomains, and also to all products, services and activities of Start Proud.

We are committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information (“Personal Information”). As part of this commitment, our privacy policy governs our actions as they relate to the collection, use and disclosure of Personal Information. Our privacy policy is based upon the values set by the Canadian Standards Association’s Model Code for the Protection of Personal Information and Canada’s Personal Information Protection and Electronic Documents Act.

We are responsible for maintaining and protecting the Personal Information under our control. We have designated an individual or individuals who is/are responsible for compliance with our privacy policy.

Personal Identification Information
We may collect personal information from Users in a variety of ways in connection with our activities, services, features or resources, including in connection with the Site. Users may be asked for, as appropriate, name, address, email address, telephone numbers and other personal information. We will collect personal information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal information, understanding that this may prevent them from engaging in certain Site related activities or other activities of Start Proud.

In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address and payment information is provided as part of the order process.

Use of Collected Information
Start Proud collects and uses Users’ personal information for the following purposes:
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1. To personalize user experience: We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.

2. To improve our Site: We continually strive to improve our website offerings based on the information and feedback we receive from Users.

3. To improve customer service: User information helps us to more effectively respond to customer service requests and support needs.

4. To send periodic emails: If a User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time a User would like to unsubscribe from receiving future emails, weinclude detailed unsubscribe instructions at the bottom of each email or a User may contact us via our Site.

Types of Information Collected
Personal information is information about an identifiable individual. The personal information we collect includes:
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1. Identification information: like your name, ID card with or without a photo, date of birth, gender, citizenship status"

2. Contact information: like your phone numbers, personal addresses, email addresses, social media handles

3. Financial information about you: income, employment situation, salary, personal assets and liabilities, financial statements

4. Interactions and preferences information: data which relates to your use of our products and services, data from your interactions with us, our website, our apps

5. ProudConnect activities information: activities when you are logged in to your Proud Connect space

Non-personal Identification Information
We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and other technical information about Users’ means of connection to our Site, such as the operating system and the Internet service providers utilized, and other similar information.

Consent
Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law. Providing us with your Personal Information is voluntary. However, your decision not to provide certain information may limit our ability to provide you with our products or services.

We will not require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except as required to be able to supply the product or service.

If you withdraw your consent to receive information regarding certain products, publications, services or events being offered by us, you may not be made aware of the same.

Where is it reasonable to do so, or permitted by law, we may rely on implied consent.

From time to time, service updates are emailed to users. If you do not wish to receive such mailings, you may request to be removed from this electronic mailing list at any time. You should understand, however, that if you are removed from the mailing list you may not be made aware of the status or availability of certain Start Proud Website services.

Storage of Information
Your personal or business information can be stored outside Canada because we use third-party service providers to store and process your personal or business information.

We take stringent measures to ensure that your personal and business information is protected and handled properly. We do not store your personal or business information forever. Hence, we will destroy, erase or dispose of your Personal Information in accordance with Start Proud’s retention period.

Limiting Collection
The Personal Information collected will be limited to those details necessary for the purposes identified by us. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, or the Internet.

Limiting Use, Disclosure and Retention
Personal Information may only be used or disclosed for the purpose for which it was collected unless you have otherwise consented or when it is required or permitted by law. Personal Information will only be retained for the period of time required to fulfill the purpose for which we collected it or as may be required by law.

Accuracy
Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

Safeguarding Customer Information
We are accountable for all personal information in our possession or control. This includes any personal information that we have collected about members, candidates, customers, and past members. We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

In order to protect personal information in our possession or control, we have:

- established and put into effect policies and procedures aimed at properly protecting personal information;

- educated staff and volunteers regarding such policies and procedures and their roles and responsibilities in protecting personal information;

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and other data stored on our Site.

Sensitive and private data exchange between the Site and its Users happens over secured communication channel and is encrypted and protected with digital signatures.You can visit our Start Proud website(s) without telling us who you are or revealing any information about yourself, including your email address. However, our web server may collect the IP address and domain you used to access our website(s), the type and version of web browser and operating system you are using, the number, duration and frequency of visits to our website(s) and the website you came from and visited next. This anonymous information cannot be traced to a specific individual User– it is used by us simply for the purposes of analytics– for example, to measure the number of visits, average time spent, page views, most popular preferences and other statistics about visitors to the website(s) and to determine the characteristics in which users use our website(s) and services. We may use this data to monitor website performance for systems administration purposes, to make our website easier and more convenient to use, to improve our services and to track information in aggregate form. This helps us better understand our traffic, visitor behavior, and the impact of campaigns, content and email-driven traffic. By having access to such deeper data insights, we are able to measure, re-evaluate content offerings, map customer buying journeys and provide you with a more personalized visitor site experience, enabling demographic and interest reporting.

Sharing Your Personal Information
We do not sell, trade, or rent Users’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and Users with our partners, trusted affiliates and advertisers for the purposes outlined above.

Openness
We will make information available to you about our policies and practices with respect to the management of your Personal Information.

Customer Access
Upon request, you will be informed of the existence, use and disclosure of your Personal Information and will be given access to it. You may verify the accuracy and completeness of your Personal Information and may request that it be amended if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.

Cookies
A cookie is a small computer file or piece of information that may be stored in your computer’s hard drive when you visit our websites. We may use cookies to improve our website’s functionality and, in some cases, to provide visitors with a customized online experience.

Cookies are widely used, and most web browsers are configured initially to accept cookies automatically. You may change your Internet browser settings to prevent your computer from accepting cookies or to notify you when you receive a cookie so that you may decline itsacceptance. Please note, however, if you disable cookies, you may not experience optimal performance of our website.


Third-Party Websites Users may find advertising or other content on our Site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on those sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, those sites or services, including their content and links, may be constantly changing. Those sites and services may have their own privacy policies and customer service policies.
Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Acceptance of Terms
By using this Site, you signify your acceptance of this policy as a User. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting Us
If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this Site, please contact us at:

info@startproud.org

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