Last updated: [Feb] [2022]
Approved by CRIEC Board of Directors February 24, 2022
1. PRIVACY POLICY
The Calgary Region Immigrant Employment Council (“CRIEC”, “we”, “us”) has a mission to connect newcomer professionals to strategies that will lead to successful employment outcomes. CRIEC respects you and your privacy, and we are committed to protecting the privacy, accuracy and reliability of any personal information that a user chooses to provide through the website, or our business dealings together.
This policy describes:
• How we collect, use, disclose, and protect the personal information of our customers and website users (the “User”, “you”).
• The types of information we may collect from you during our business together, through correspondence with us, or that you may disclose to independent contractors, vendors, volunteers or other organizations whose services have been retained by CRIEC or that you may provide when you visit the website, www.criec.ca (the “CRIEC Website”).
• The information that may be collected, used or disclosed about a User when you interact with our advertising and applications on third-party websites and services if the advertising or applications or include links to this policy.
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use your personal information in accordance with this privacy policy unless otherwise required by applicable law.
The term “personal information” means information about an identifiable individual, including information that can be used on its own or with other information to identify, contact, or locate a single person. The complete definition of personal information can be found in the following legislation: the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5 [PIPEDA].
2. CONSENT
Please read this privacy policy carefully. If you do not agree with our policies and practices, your choice is not to use the CRIEC Website. By accessing or using the CRIEC Website, you acknowledge that you understand, accept, and consent to the practices described in this privacy policy. This privacy policy may change from time to time without notice (see Changes to the privacy Policy). Your continued use of the CRIEC Website after we make changes indicates that you accept and consent to those changes, so please check the privacy policy periodically for updates.
By providing your personal information, through the CRIEC Website or through other interactions with us, you are consenting to the collection, use, storage and where applicable, disclosure of your personal information.
3. INFORMATION COLLECTED
We collect and use several types of information from and about the User, including:
• Personal information that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, email address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, and any other identifier we may use to contact you online or offline.
We provide an opportunity for any user to unsubscribe from or opt-out of contact for marketing purposes on an ongoing basis by using the unsubscribe mechanism at the bottom of our emails.
• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
• Technical information, including browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
4. HOW WE COLLECT INFORMATION ABOUT THE USER
We use different methods to collect your information, including through:
• Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
• Automated technologies or interactions, as you navigate through the CRIEC Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners and various search engines.
5. INFORMATION THE USER PROVIDES
The CRIEC only collects personal information it requires for the purposes of providing programs and services for its Users. Specifically, the information we collect directly from you on or through the CRIEC Website may include:
• Information that you provide by filling in forms on the CRIEC Website. This includes information provided at the time of subscribing to our services (including the email address provided to subscribe to our mailing list), and/or requesting further services or information. We may also ask you for information if you report a problem with the CRIEC Website.
• Records and copies of your correspondence with us (including email addresses).
Please note that through the process of completing an application and/or an assessment online or in-person with CRIEC, you are consenting to the disclosure of that personal information to CRIEC
6. ADDITIONAL INFORMATION COLLECTED
As you navigate through and interact with the CRIEC Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
• Details of your visits to the CRIEC Website, including traffic data, location data, and other communication data and the resources that you access and use on the CRIEC Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• The information we collect automatically is statistical information and may include personal information and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
o Estimate our audience size and usage patterns.
o Store information about your preferences, allowing us to customize our website according to your individual interests.
o Speed up your searches.
o Recognize you when you return to the CRIEC Website.
The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the CRIEC Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the CRIEC Website. For more information on cookies please visit www.allaboutcookies.org.
• Web Beacons. Pages of the CRIEC Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
• This site uses Google Analytics. For any questions or concerns, please review Google’s privacy policy https://policies.google.com/privacyhl=en.
7. HOW INFORMATION IS USED
We use information that we collect about the User, or that the User provides to us, including any personal information, for the following reasons:
• To fulfill the purposes for which the User provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To provide the User with the products and/or services it requests.
• To facilitate the connection between Mentor and Mentee.
• To communicate information regarding CRIEC programming.
• To assist with questions, feedback, complaints or requests.
• To enhance the User’s experience with the Company.
• Present the CRIEC Website and its contents to you.
• To send important notices, such as software updates, service agreements, and changes to the terms of this privacy policy.
• To inform the User about our products, services, projects and activities.
• To resolve disputes, investigate any complaints, claims or disputes, or any actual or possible illegal conduct.
• To conduct internal audit, data analysis and research of the Company.
• To comply with laws and regulations and with the requirements of regulatory agencies.
• To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
• To fulfill our obligations and terms of contract with the User and our partner financial institutions, or any contractual obligations related to payments and payment processing.
• To verify eligibility status with our funder (see federal website for their privacy policy)
• To improve the CRIEC Website, products or services, marketing, or customer relationships and experiences.
• To allow you to participate in interactive features, social media, or similar features on the CRIEC Website.
• To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• Other reasonable purposes related to the foregoing.
• In any other way we may describe when you provide the information, or any other purpose with your consent.
8. DISCLOSURE AND TRANSFER OF INFORMATION
We may disclose personal information that we collect, or that you provide, as described in this privacy policy:
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• We may also disclose your personal information:
o To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
o If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
o We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
9. THIRD-PARTY WEBSITES
Our Website may contain links to other websites which are provided as a convenience only. Users are advised that other third-party websites may have different privacy policies and practices than CRIEC, and CRIEC has no responsibility for such third-party websites.
This privacy policy DOES NOT apply to information collected by third parties on their own websites, even if those websites may be linked from the CRIEC Website. We are not responsible for the actions or privacy policies of any third-party.
We do not control third parties’ collection or use of your information to serve interest- based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
10. DATA STORAGE AND TRANSFER
CRIEC uses third party data storage. The company we have our agreement with operates and utilizes data centres worldwide but, they have advised that all data will be stored in Canada. By consenting to the terms of this privacy policy you are acknowledging and accepting our use of service providers.
Where applicable, the relevant party will seek additional consent if data will be stored outside of this jurisdiction.
11. DATA SECURITY
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the CRIEC Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the CRIEC Website.
By submitting your personal information or engaging with the CRIEC Website, you consent to this transfer, storage, or processing.
12. DATA BREACH NOTIFICATION
In the unlikely event of a data security breach the Company will comply with the notification and reporting requirements as set out in the Personal Information Protection and Electronic Documents Act. This includes, in a situation where there exists a real risk of significant harm to the User, notifying the affected individuals as soon as feasible after the organization has determined that the breach has occurred.
13. DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such
anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
14. USER RIGHT
TO WITHDRAW CONSENT
Where the User has provided consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at [privacy@criec.ca] Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.
TO ACCESS, CORRECT AND OBJECT
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. You have the right to request access to and to correct the personal information that we hold about you. If you want to review, verify, correct, or withdraw consent to the use of your personal information, please contact us at: [privacy@criec.ca]. Any such communication must be in writing and must contain sufficient detail to enable to organization to identify any record in their custody or control.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
15. PROTECTION OF MINORS
We do not knowingly collect, store, or share personal information about any child under the age of 13. If the User believes a child under the age of 13 has provided us with personal information, we request that the User contact our customer support at: privacy@criec.ca
16. PERSONAL EMPLOYEE INFORMATION
Personal employee information is defined as personal information about an employee or volunteer which is collected for the purpose of establishing, maintaining and terminating an employment or volunteer-work relationship. CRIEC can collect, use and disclose your personal employee information for the purposes listed above, in accordance with applicable employment standards and applicable privacy legislation.
17. CHANGES TO THE PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our User’s personal information, we will notify you through a notice on the Website home page. We include the date the privacy policy was
last revised at the top of the page. You are responsible for ensuring we have an up-to- date, active, and deliverable email address for yourself, and for periodically visiting our Website and this privacy policy to check for any changes.
18. PRIVACY OFFICER
We have appointed a Privacy Officer to oversee compliance with this privacy policy. If you have any questions about this privacy policy, how we handle your personal information or would like to request access to your personal information, please contact the Privacy Officer at:
Email: privacy@criec.ca
The Calgary Region Immigrant Employment Council #900, 105 – 12th Avenue SE
Calgary, AB, T2G 1A1
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above.
19. OTHER
The User must fully understand and comply with all relevant laws, rules and regulations in its jurisdiction which govern the use of the CRIEC Website.
This privacy policy is governed and shall be interpreted and construed in accordance with the laws of the Province of Alberta. Any disputes related to this agreement shall be heard in the courts of the City of Calgary, Province of Alberta, Canada.