For the purposes of this Policy, “Personal Information” means any information about an identifiable individual, including any information that directly or indirectly identifies such individual.
Basis for processing Personal Information
The Evolve Program (hereafter, “OPV”) needs to collect and process some of your Personal Information in order for you to use our website and to provide our services.
When we collect your Personal Information, we ensure that we collect only the information necessary to fulfill our purposes, which have been previously disclosed to you, for example, in this Policy. We use Personal Information in accordance with the privacy laws applicable to our organization.
The following is a description of the basis on which OPV collects and processes your Personal Information:
As required by applicable privacy legislation, such as Alberta’s Personal Information Protection Act (PIPA), OPV collects your Personal Information on the basis of your voluntary consent, with some exceptions permitted by law, such as if the collection of the information is clearly in your interests and if your consent cannot be obtained in a timely way. For example, we may need to collect and disclose your personal information to enable a member of a relevant authority to contact you if your state of health so requires.
Collected Personal Information
Depending on the nature of your activity on our website or by voluntarily accessing our services, we may collect your Personal Information, including:
- Information that you voluntarily provide to us that may be used to identify or contact you, such as your first and last name, your e-mail address, your telephone number, your social network account identifier, and other information that you provide.
- Information relating to the use of the Site: for example, date and time of visit, duration of presence on our website, pages clicked and connection IP address).
- Information relating to the use of your mobile devices: for example, the type of mobile device, unique identifier, IP address, operating system and physical location of the device (geolocation, beacon location) as well as mobile identifiers such as Apple IDFA or Google Android AAID, where applicable.
- Information related to your health: Information you disclose about the state of your physical and mental health.
If you choose to provide us with Personal Information through our website, we’ll use that information to respond to your message. Any personal information that you do provide is kept strictly confidential and is not disclosed to anyone except to those OPV staff who need the information for legitimate business purposes (such as responding to your request). There are some limits to confidentiality which are explained in the “Sharing your information without explicit consent” section below. We do not trade or sell information to any second or third party.
Personal Information of minors
In view of the importance of protecting children’s privacy, we do not intend the website for minors. However, the nature of our Site could affect minors. In cases where OPV may collect personal information from minors, we will require the express consent of the parent, guardian or mature minor 16 years of age or older, as applicable. If a parent or guardian discovers that his or her minor child has provided us with personal information without us having obtained the appropriate consent, such parent or guardian has the right, upon request, to inspect the personal information provided by the child and/or to require that it be deleted from our files. In this case, we ask the child’s parent or guardian to contact us at the coordinates indicated in the section “Privacy Officer”.
Purposes of collecting Personal Information
We only collect Personal Information that we consider necessary for the following purposes:
- To offer our services via our website, phone system and in person;
- To answer your questions, queries, comments or complaints;
- To coordinate the provision of services, such as counselling people who want to move away from harmful belief systems;
- For data analysis purposes, including the identification of usage trends, and to determine the effectiveness of our promotional campaigns;
- To send you administrative information, for example, information about our services and changes to our terms, conditions and policies;
- To send you communications that we think may be of interest to you, such as newsletters or direct mailings;
- To send you push notifications on your mobile device or notifications by email and SMS;
- To ensure your safety and the safety of others (please refer to the “Sharing your information without explicit consent” section below).
- For audit, surveillance and fraud prevention purposes;
- To comply with or act under any applicable law or regulation, including but not limited to:
- (i) respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence;
- (ii) to protect our operations and legitimate interests or those of our subsidiaries ;
- (iii) to enable us to pursue available remedies or limit the damages we may suffer, etc.
- To facilitate and improve the use of our website, as long as the Personal Information collected is used proportionally to this Purpose;
- For any other purpose to which you have consented.
In the event that we need to use Personal Information for a purpose not mentioned above, we will ensure that we obtain your consent. We may, however, use or disclose your Personal Information for a purpose not mentioned if it is permitted by law and it would be inappropriate to inform you.
Sharing your information with our Trusted Partner
Data that does not contain any personal identifying information about you, such as your deidentified Usage, Communications and Technical data will be shared with our Trusted Partner Moonshot CVE Ltd (hereinafter “Moonshot” or “Trusted Partner”), a company based in London, UK, and subject to the General Data Protection Regulation (EU) 2016/69 (GDPR) and to the UK Data Protection Act (2019) (UK GDPR) and other European privacy and data protection laws when processing personal data. Moonshot will use this data to help us provide services, customize the website and its contents, and to communicate with you. Additional Volunteered Data that you share with us will not be shared with Moonshot or other third parties, except where that data has been aggregated, anonymized, and it is necessary to share this data to provide our services.
Sharing your information without explicit consent
In certain cases, we may disclose categories of personal data listed above in order to prevent an act of violence. Acts of violence include suicide, and occasions where there is reasonable cause to believe that there is a serious risk of death or serious bodily injury threatening a person or an identifiable group of persons, and where the nature of the threat generates a sense of urgency. We may also report any situation of probable child abuse or neglect to children. Where we process your personal data for this purpose, our legal basis for processing will be the vital interests basis. We may report this data to relevant municipal, provincial or federal law enforcement agencies, and/or applicable health and/or social service authorities..
Sharing and disclosing of your personal information
In the course of our activities, we may need to disclose and share your personal information with various stakeholders. We will only disclose and share your personal information as described below:
- Our Employees: In the course of their work, our employees may need to access your personal information, for example, when you call us, or chat with us. Their access is limited to what is necessary to perform their duties.
- Third Parties and Service Providers: From time to time, we may need to share your personal information with third parties or service providers to assist us in making available all of the features of our website (maintenance, analysis, legal requirements, fraud detection, marketing and development). Please note that these service providers may be located in Canada or in other jurisdictions or countries. They will only have access to personal information that is necessary to perform these functions on our behalf and are required not to disclose or use it for any other purpose. Please be aware that we have contractual agreements with these vendors to ensure the security of your data.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
- When required by law, to enforce compliance or to protect the property or safety of our rights or those of others: By way of example, we may disclose personal information to legal or regulatory authorities in the event that we suspect criminal activity, to detect and prevent fraud, or to comply with legal or regulatory requirements of governmental bodies, regulatory agencies or other self-regulatory organizations. We may also need to disclose personal information to comply with a legal obligation (e.g., court order) or to protect our assets (e.g., to collect overdue accounts).
Your choices regarding our use and disclosure of Personal Information
If you give us your email address and opt in to join our mailing list, we’ll send you updates and other communications related to the purposes outlined in the contact form. We comply with Canadian Anti-spam Legislation (CASL), and our email marketing provider, MailChimp, is CASL-compliant as well. If you no longer want to receive updates and other communications, you can click the “Unsubscribe” link at the bottom of our emails. Doing so will immediately remove you from our mailing list. Please note that you might still receive personal, non-marketing emails from a staff member. We do use third-party services for distributing newsletters. However, we’ll only share your information with these third-party services and send you the appropriate content if you’ve given your consent.
Embedded content from other websites
Google Ads and Google Remarketing
We use the Google Ads online advertising program and Google Remarketing technology, both operated by Google Inc. (“Google”). For measuring conversion with Google Ads, a conversion tracking cookie is placed when a user clicks on an OPV advertisement delivered by Google. Conversion tracking cookies expire after 30 days and are not used for personal identification. Google uses a different cookie for each Google AdWords customer, and there is no consolidation of the cookie data with other data. If you click one of our Ads and proceed to a page equipped with a conversion tag where the cookie has not yet expired, the conversion is documented. With the help of the conversion tracking cookie, we see the total number of conversions and can review the performance of our Ads. You can find more information about Google Ads here. When you click on one of our Ads, a Google Remarketing cookie is placed. This cookie helps to serve our Ads to you when you browse the Google content network pages. Remarketing cookies expire after 30 days and are not used for personal identification. For more information on Google Remarketing, please see here. To opt out of Google personalized ad serving, refer to the Opting Out section of this policy.
It’s important that you can control the collection of personal data relating to your use of our website, so we’ve provided links to help you opt out of personal data collection using cookies or other technologies as set out below.
Use your browser settings or preferences to see and control the cookies set on your computer or mobile device. Visit http://www.aboutcookies.org to find out how.
To opt-out of analysis by Google Analytics, please visit http://tools.google.com/dlpage/gaoptout.
To opt-out of personalized ad delivery on the Google content network, please visit Google’s Ads Preferences Manager. If you wish to opt-out permanently, you can install their plugin here.
To opt out of interest-based ads on mobile devices: For android devices, open the Google Settings app and select “ads” to control the settings. Use Apple’s advertising identifier on iOS devices (with iOS 6 and above). Visit the settings menu on your device and select “Privacy,” then select “Advertising” to learn more about limiting ad tracking using this identifier.
Keeping your Personal Information secure
The security of your Personal Information is a priority for us.
Our employees and Trusted Partners are informed of the confidential nature of the personal information collected and are made aware of the appropriate security measures to prevent unauthorized access to your personal information.
In addition, our service providers and partners undertake to use reasonable security measures to preserve the integrity and confidentiality of your personal information. We maintain our services and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorized access, destruction, misuse, alteration and improper disclosure of your personal information. These safeguards vary according to the sensitivity of the data in our possession and are based on the best industry standards.
Access to your personal information is limited to people who have a genuine need to know it. Any use of your personal information will only be done by an authorized person who is subject to a duty of confidentiality.
If you have any questions about the security of your interaction with us (if, for example, you feel that the security of any account you may have with us has been compromised), you can contact our Privacy Officer.
Retention of your Personal Information
OPV will retain your Personal Information only for as long as is necessary to fulfill the purposes for which it was collected, in accordance with our internal document retention policies, to comply with legal, tax or regulatory requirements applicable to us or until you request us to destroy it. After such period, any personal information concerned and held by OPV will be destroyed, deleted or anonymized.
Depending on applicable laws, where you live and how you interact with the site or our services, you may be granted certain rights with respect to the personal information we hold about you.
For example, you may be entitled to:
- Obtain access to the personal information we hold about you;
- To correct personal information we hold that is inaccurate, misleading or incomplete;
- Request the deletion of your personal information;
- To obtain additional information, for example on the categories of third parties to whom we communicate your personal information;
- To request the portability of your personal information in a structured, commonly used and machine-readable format;
- To withdraw your consent at any time if we have collected and processed your personal information with your consent. Withdrawal of your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, nor the processing of your personal information carried out on the basis of legitimate processing grounds other than consent.
- To refuse promotional communications sent by OPV;
- File a complaint with our Privacy Officer or with a privacy control authority, such as the Privacy Commissioner of Alberta or with the Privacy Commissioner of Canada.
We will provide you with such information or make the corrections promptly where personal information is inaccurate and no later than 30 days from the date when we receive the written request. A reasonable fee may also be charged to process your request.
In some situations, it may not be possible for us to disclose all of the personal information we hold about you. Exceptions to the access requirements are limited and specific. The reasons for denying access are provided upon request.
These exceptions include information that is prohibitively costly to provide, information that contains details about other individuals, the existence of legal, security or business reasons that prevent the provision of the information and the fact that the information is protected by solicitor-client or litigation privilege.
If you would like to exercise any of your other rights or ask any questions, please contact email@example.com.
Links to other websites
It is important to understand that this Policy does not apply to other third-party websites that may be accessed through links on our site. We are not responsible for those third-party sites, their content or access. Therefore, any personal information you transmit through these sites is subject to the privacy policies of those sites. It is your responsibility to review their privacy policies to ensure the protection of your personal information.
Contact information and challenging compliance
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 our Privacy Officer using the contact information listed above.