OUR COMMITMENT

YW Kitchener-Waterloo (YWKW, we, us or our) respects the privacy of our program participants, families, donors, volunteers, employees, members, website visitors and community partners. We are committed to handling personal information responsibly and explaining how we collect, use, disclose and protect it.

This policy covers personal information under our control through our website, programs, services, fundraising, employment and other activities. Our practices are guided by the ten fair information principles in the Personal Information Protection and Electronic Documents Act (PIPEDA). We comply with privacy laws where they apply to our activities. Additional program or employment notices may explain specific requirements; applicable law takes priority if a requirement differs from this policy.

Personal Information we collect:

Personal information is information about an identifiable individual. Depending on your relationship with YWKW, we may collect:

• Contact and communication information, such as your name, address, email address, telephone number, correspondence and communication preferences.
• Program and service information needed to assess eligibility, register participants and deliver services. Depending on the program, this may include age, emergency contacts, family circumstances, housing needs or relevant health and accessibility information.
• Donation and event information, such as gift amounts, transaction dates, receipt details, registration information and recognition preferences.
• Employment and volunteer information needed for recruitment and administration, such as qualifications, references and other information relevant to the role.
• Website information, such as an IP address, browser and device details, pages visited and interactions, to the extent collected by the tools described under Website cookies and tracking.
• We limit collection to information needed for identified purposes. We generally collect it directly from you or an authorized representative. Where information comes from another source, such as a referral partner or reference, we obtain consent unless the law permits or requires otherwise. Information does not automatically lose privacy protection because it is publicly available.

How we use personal information

We identify the purposes for collecting personal information at or before collection. Depending on your interaction with us, we use it to:

• Respond to inquiries and deliver, administer and evaluate programs and services.
• Process donations and event registrations, issue applicable receipts and maintain financial records.
• Manage employment, volunteer and membership relationships.
• Send requested or consented-to newsletters, fundraising communications, event information and organizational updates.
• Operate, maintain and protect our website and systems, and understand website use through the technologies disclosed below.
• Meet legal, regulatory and contractual obligations that apply to our activities.

Consent and your choices

We do not use personal information for a new purpose without consent unless the law permits or requires it. Any optional use, including marketing tracking, is subject to the choices explained in this policy and the notice provided when information is collected.

We explain what information we need, why we need it and any relevant disclosures so that you can make an informed choice. The form of consent depends on the information, the circumstances and applicable law. We seek express consent for sensitive information where required. A visit to our website does not by itself constitute consent to optional tracking.

You may withdraw consent for optional uses by contacting our Privacy Officer. Withdrawal is subject to applicable legal and contractual limits and does not affect processing already lawfully completed. We will explain if withdrawal prevents us from providing a particular service. Access to a service is not conditional on consent to unrelated collection, use or disclosure.

You can unsubscribe from marketing emails using the link provided in the message or by contacting us. Necessary service communications, transaction confirmations and legally required notices may still be sent.

Children and youth privacy

YWKW provides programs and services for children, youth and families. We collect, use and disclose children’s and youths’ personal information only for identified, appropriate purposes, such as program registration, service delivery and safety.

Where consent is required, we consider the young person’s capacity and applicable law. For children under 13, we generally obtain consent from a parent or legal guardian. For older youth, consent depends on their ability to understand the nature and consequences of the proposed collection, use or disclosure. Where needed, we obtain consent from a legally authorized representative. These practices are subject to applicable legal permissions and requirements.

Children, youth and their authorized representatives may contact our Privacy Officer to request access, correction or a review of whether information can be deleted. We verify identity and legal authority and consider applicable confidentiality and record-retention requirements.

If you believe a child has submitted personal information through our website without necessary consent, contact our Privacy Officer. We will review the circumstances and take appropriate steps, including deletion where appropriate and legally permitted.

Website cookies and tracking

Cookies are small files stored on your device. Pixels and similar technologies can communicate information about your visit to another provider. These technologies may support website functions, measure use or support marketing. Information collected through tracking can be personal information even when it does not include your name.

We use the following technologies, grouped by category:

• Essential (always on, needed for the website to work)
• Fastly (Fastly, Inc.) helps our website load quickly and securely.
• Analytics (only with your consent)
• Google Analytics (Google LLC) helps us understand how visitors use our website, such as which pages are visited and how long visitors stay.
• Marketing (only with your consent)
• Facebook Pixel and Facebook conversion tracking (Meta Platforms, Inc.) help us measure the results of our advertising on Facebook and Instagram.

We ask for your consent before activating optional analytics or marketing technologies. You can accept optional technologies, reject them or choose by category. You can change or withdraw your choice at any time through Cookie Settings.

Browser settings can also help you block or delete cookies. Blocking essential cookies may affect some website functions. Browser controls may not stop every type of tracking and are not a substitute for our website consent controls.

When we share personal information

We limit disclosure to what is needed for an identified purpose. Personal information may be shared:

• With authorized staff and volunteers who need it to carry out their responsibilities.
• With service providers that support functions such as hosting, information technology, payment processing, donor administration or email delivery, subject to appropriate privacy and security arrangements.
• With referral or program partners when necessary to provide an identified service and with consent, unless disclosure is otherwise permitted or required by law.
• With authorities or other recipients where required or permitted by law, including applicable reporting obligations, or with your consent for a specific disclosure.
• We remain accountable for personal information transferred to providers for processing on our behalf. We use contractual or other appropriate measures to limit their use and protect that information. A provider acting independently, such as an external donation platform, may also collect information under its own privacy policy.

YWKW does not sell, rent or trade donor, participant or mailing lists.

Where information is processed

Our service providers may store or process personal information outside Ontario or Canada. When that occurs, the information may be subject to the laws of the relevant country, including lawful access by its authorities. We remain responsible for the protection of information processed on our behalf. You can contact our Privacy Officer for information about these arrangements.

Safeguards and privacy incidents

We use administrative, physical and technical safeguards appropriate to the sensitivity and amount of personal information and the risks involved. Access is limited to authorized people who need it for their work. Our measures include access controls, password protection and encryption where appropriate. No online transmission or storage system can be guaranteed completely secure.

If a privacy incident occurs, we will take steps to contain it, assess its effects and reduce the risk of further harm. We will keep incident records and notify affected individuals, regulators or other parties as required by applicable law. Please contact our Privacy Officer promptly if you suspect that personal information entrusted to YWKW has been compromised.

Retention and disposal

We retain personal information only as long as needed for its identified purposes and applicable legal or contractual requirements. Retention depends on the record, including program, employment, donation, accounting and incident records. When information is no longer needed, we securely destroy it, erase it or de-identify it as appropriate. You may ask our Privacy Officer about the retention period relevant to your information.

Access correction and privacy concerns

You may request access to personal information under our control, information about its use and disclosure, and correction of inaccurate or incomplete information. Send a written request to our Privacy Officer using the contact information below. We may need to verify your identity or an authorized representative’s authority, using only information reasonably necessary for that purpose.

We respond to written access requests within 30 days, subject to any extension or different requirement permitted by applicable law. If an extension is needed, or access is limited or refused, we will explain the reason and available complaint options as required. Contact us if you need assistance making a request or require an accessible format.

You may also ask us to review whether information can be deleted. Some records must be retained to meet legal requirements or other justified retention needs. You may raise a concern or complaint with our Privacy Officer about our handling of personal information. We will review the concern and explain our response.

External websites and platforms

Our website may link to third-party websites, donation services or social media platforms. Their own collection and use of information is governed by their privacy policies. Please review those policies before submitting information. This does not remove YWKW’s responsibility for information processed on our behalf or disclosed through tools we choose to use.

Changes to this policy

We may update this policy to reflect changes in our practices or applicable requirements. The current version will be posted on our website with its updated date. Where a change requires notice or new consent, we will provide that notice or obtain consent before applying the change. Posting an update does not by itself authorize a new use of personal information.

Contact Information

Question, concerns or complaints relating to the YWKW’s privacy policy on the treatment of personal information should be e-mailed to general@ywkw.ca or the Privacy Officer at 153 Frederick Street, Main Floor, Kitchener, Ontario, N2H 2M2.

Information about Canadian privacy rights and complaint routes is available from the Office of the Privacy Commissioner of Canada at https://www.priv.gc.ca/. Depending on the activity and law involved, another regulator may be responsible.