Summary


The notifications provided by this Policy include:

- What personally identifiable information we collect through the Website.
- How we use the information we collect.
- With whom the information may be shared.
- The kind of procedures we employ in an effort to hinder the unauthorized access, use or disclosure of information you give us access to.
- Information related to third party websites.
- The laws that apply to those accessing the Website.
- How you can learn about changes to the Privacy Policy.
- How you can amend the information we collect on you.
- Rights related to the European Union's General Data Protection Regulation.


What Information Do We Collect Through the Website?

Cause Heroes collects both personally identifiable information and non-personally identifiable information through our Website. When we refer simply to the term ''information'' in this Policy we are referring to how Cause Heroes collects, uses, or shares both personally identifiable, and non-personally identifiable information.



Personally identifiable information (the "PII") refers to information that can identify an individual when used alone or with other relevant data. Cause Heroes does not collect any PII unless you provide it voluntarily. If you do not want us to collect PII, you can simply decide not to submit it to us. The PII we collect may include:

Name;
Date of birth;
Contact information, such as name, postal address, email address and telephone number;
other personal information you provide to us on our website and other data collected automatically through the website, as applicable.

We also collect certain non-personal information (the "Non-PII", which is data in a form that does not support direct association with any specific person or individual) by automated means when you visit the Website.

Collection of PII

The circumstances in which you might provide us with PII include, but are not limited to, the following:

Campaigns, contests and promotions information. You can participate in Cause Heroes campaigns, contests, and promotions as long as you meet eligibility requirements and comply with all applicable rules. As part of your participation, you will be required to provide us with PII, including your name, mailing address, email address and other information in order to administer the promotion, notify winners, etc.

Mailing list information. You can opt to be added to the Cause Heroes mailing list. If you do so, you will be asked to provide us with your email address. Subscriptions to the mailing list can be cancelled at any time.

Submitting a request. When you submit a request or comment to our customer service department, you will be asked to provide your email address, and depending upon the nature of your inquiry, you may have to provide us with your PII.


Collection of Non-Personally Identifiable Information

We also collect certain Non-PII when you visit the Website. Much of this Non-PII is collected through the use of third party tracking services, which includes Google Analytics and other means, as further described below.

Google Analytics

Our Website uses Google Analytics (and may use other similar sites or services in the future), a web analytics service provided by Google, Inc. ("Google"), to better assist us in understanding how the Website is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Website, including your computer's IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Website, compiling reports on Website activity for our use, and providing other services relating to Website activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser. Please note that by doing so, you may not be able to use the full functionality of the Website. The use of cookies by Google Analytics is covered by Google's privacy policy. From time to time, we may enter into agreements with other third party providers for web analytics and other similar services. If we enter into such an agreement, we may share your information, including personal information, with the provider, or such provider may have access to and collect your information on our behalf. Your information, including personal information, may be stored with the provider.

Cookies

Cookies are bits of electronic information that a website can transfer to a visitor's hard drive to help tailor and keep records of his or her visit. Cookies allow website operators to better customize visits to the site to the visitor's individual preferences. Many commercial websites use cookies. We may use cookies on our Website to allow us to measure activity, to personalize your experience, and to track your status or progress when requesting information, among other things. If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser's help file directions. However, if your browser is set to reject cookies or if you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Website, or that we may put on our Website in the future.

Web Beacons

Certain pages on the Website contain "web beacons" (also known as Internet tags, pixel tags and clear GIFs). These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information contained in cookies set by the third party. Web beacons also may be used to track whether you have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon that then generates a record showing that the email has been viewed. Web beacons may also recognize when the email was opened, how many times it was forwarded and which URLs (links within the email) were clicked.

IP Addresses

When you visit and interact with the Website, Cause Heroes and third parties with whom we have contracted to provide services for us may collect Internet Protocol addresses (each an "IP Address"), as well as browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and page navigation. An IP Address is a unique identifier number that certain electronic devices use to identify and to communicate with each other on the Internet; your Internet Service Provider automatically assigns an IP Address to the computer that you are using. We gather this information to track website visitor movement in the aggregate, and to gather broad demographic information for aggregate use. Our goal in gathering this information is to learn how our customers and the public are using our service. We may use this information to enhance our Website or for other lawful purposes.

Do Not Track Notice

Your browser and other mechanisms may permit you to send do not track signals or other similar signals to express your preferences regarding online tracking. To the extent you employ such browser do not track signals or other similar mechanisms, we will use commercially reasonable efforts to honor such requests received by us to the extent of our capacities and resources to identify and process your request. Due to the potential for rapid and diverse developments of technology in this area, we cannot guarantee that we can process every type of request that exists or may be developed in the future. As noted above, third parties, such as our advertising partners, may collect data that relates to you. We cannot control third parties' responses to do not track signals or other such mechanisms. Third parties' use of data relating to you and responsiveness to do not track signals is governed by their respective privacy policies.

How May We Use This Information?

Our primary purpose in collecting information about you is to provide you with services or information that you request or to process your payments. In addition, we may aggregate the PII that you provide with the PII that other users provide in order to conduct research, analysis, or studies for our own purposes (i.e., not related to providing you with specific services), including improving our services and future campaigns.

We may also use the information that you provide to us to communicate with you about our current activities, future events and campaigns or to notify you about any changes to our services. If you decide that you would no longer like to receive such messages, you can opt out from receiving such emails from Cause Heroes. In order to opt out, you can click on the unsubscribe link provided at the bottom of every commercial email that you receive from Cause Heroes. If you opt out, you will continue to receive communications from us relating to any payments you make or other services you request or purchase. If you decide at a later time that you would like to receive commercial emails from us again, you may be able to re-add yourself to our communication list.

How May We Share Your Information?

We may disclose all of the information (described herein) that we collect, as stated in this Policy in accordance with the terms set forth in this section. Except as stated in this Policy and as detailed below, we do not rent, sell, or share your information with other people or companies. The following describes how we may share your information:

Sharing Your Information with Subcontractors. In our efforts to provide the best quality service and experience for you, we may share information with subcontractors that provide us with services. These services may include, among other things, helping to provide services that you request, helping to create or maintain our databases, helping to research and analyze the people who request services information from us, and/or helping to process payment card information.

Sharing Your Information as Permitted by Law. We may share your information with others as required by or permitted by law. This may include sharing your PII with governmental entities or third parties in response to subpoenas, court orders, other legal processes, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us.

Sharing Your Information with Law Enforcement. We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, we reserve the right to release your information to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies or the release of your information may protect the rights, property or safety of Cause Heroes, you, or another person.

Business Transition. If Cause Heroes becomes involved in a merger, acquisition, or any form of sale or transfer of some or all of its assets, your information will be transferred to the acquiring entity.

Your Comments. If you post a Comment on our Website, the information that you choose to post, including any personal information that you choose to post, may be available to the general public.

Marketing Companies. As a general rule, we only provide limited, Non-PII (e.g., the city or the state in which a device is located or information about your search or posting history), usually in conjunction with a randomly assigned number or a number assigned to your Cause Heroes account and not in conjunction with your name. However, for certain campaigns, we may provide third party advertisers with your email address, which may be used by such companies to provide you with information about other products, services or companies.

Sharing Your Information with Charities and Prize Providers. If you enter a contest, whether by making a donation or by using an alternate method of entry, or make a donation in connection with entering into a contest, you agree that we may share your name and contact information with MakeWay Foundation (''MakeWay''), a Canadian tax-exempt public charity registered under the number 868947797 RR 0001 that is the legal recipient of all net donations made through the Cause Heroes platform, as well as the charity we designate as the benefiting charity for such contest and with any entity providing prizes for that contest, each of which may use your information for marketing purposes. If a designated benefiting charity is ultimately determined to be ineligible to receive a grant from MakeWay, your information will not be sent to such charity.

Contest Winners. As further explained in our Rules, by entering a contest, you give us the right to disclose your name, biographical information, pictures/portraits, video images, likenesses and/or voice to the general public if you are a contest winner.

Credit Card Information. Please note that when you use a credit card to make a donation, you are actually being redirected to our third party provider. WE DO NOT COLLECT, ACCESS, STORE OR PROCESS ANY CREDIT CARD INFORMATION.

How Do We Protect Your Information?

We employ reasonable physical and administrative safeguards to protect your personal information. While we will use such efforts, we cannot and will not ensure the security of your information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third party access or other acts of third parties, or acts or omissions beyond our reasonable control.

Third Party Websites; Advertisements

Our Website or our emails may link to a variety of third party social media sites and/or websites – such as YouTube, Twitter, Facebook and others - as a service to you, and in order to provide you with additional information and/or content related to the work that we do, or additional venues in which you can learn about and discuss the activities of Cause Heroes. We may also allow third parties to place advertisements on the Website. Please note that we have no affiliation with any of these other parties and/or websites, and cannot control and are not responsible for the information collection, use, and disclosure practices of such third parties; we encourage you to review and understand their privacy practices and policies, if any, before providing any personally identifying information to them or initiating any financial transactions. We are not responsible for the content or information on these websites, or any other use of the linked website.

In regard to the advertisements that may appear on the Website, you have a right to opt out of such personalized targeted ads. Our advertising partners are members of the Network Advertising Initiative; to opt out of targeted ads served by our advertising partners, or any or all Network Advertising Initiative members, contact us. Please note that when you opt out using this method, the Network Advertising Initiative will place an opt out cookie on your computer. If you delete, block, or restrict cookies in any other way, you may need to renew your opt out choice. Once you have opted out, our advertising partners will no longer use information they have collected to help deliver targeted advertisements.

Children's Privacy

We do not knowingly collect, use, or disclose personally identifiable information about visitors younger than 13 years of age. If you are under the age of 13, you are expressly prohibited from accessing/viewing the Website. If you are the parent or guardian of a child under 13 years of age and believe that they have disclosed personally identifiable information to us, please contact us so that we may delete your child's information.

What if I Provide Information from Outside Canada?

Our Website is hosted in Canada and is governed by Canadian law, and each contest drawing takes place within Canada. Accordingly, by submitting any personal information to Cause Heroes or enter a contest, you are transferring your personal information to Canada and you consent to such transfer. We do not represent or warrant that the Website, or any part thereof, is appropriate or available for use in any particular geographic location. If you choose to access our Website, you do so on your own initiative and at your own risk, and are responsible for complying with all local laws, rules, and regulations applicable in your jurisdiction. If you are visiting the Website from outside Canada, please be aware that your information will be transferred to, stored and processed in Canada where our servers are located and our central database is operated. The data protection and other laws of Canada and other countries might not be as comprehensive as those in your country. By using the Website, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.

Notice To European Union Area, Switzerland & United Kingdom Residents

This Policy is intended to provide adequate and consistent safeguards for the handling of personal information in accordance with Directive 95/46/EC of the European Parliament and of the Council of October 24th 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("the Directive") and all the relevant transposing legislation of the Directive in the European Union/European Economic Area, the Swiss Federal Data Protection Act, as such laws may from time to time be amended and valid during the application of this Policy, and any other privacy laws, regulations and principles concerning the collection, storage, use, transfer and other processing of personal data transferred from users in the European Economic Area, the United Kingdom or Switzerland (the "EU Users") to the United States including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27th 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the "General Data Protection Regulation" or "GDPR") as of its entry into force on May 25th 2018. Cause Heroes has developed this GDPR Privacy Notice to provide additional information about how we handle the PII collected via our Website that is subject to GDPR when we are the controller of that information. The following provisions apply only to EU Users.

Purpose of this GDPR Privacy Notice

This GDPR Privacy Notice explains how we process PII that is subject to GDPR, and also sets out individuals' rights related to our processing of such PII.

Purpose and Legal Bases For Our Use Of Your PII
Our processing of PII is justified by a "legal basis", that is, a specific condition. We may use PII for the following purposes, in each case as justified by a legal basis:

Website administration

We may use your PII for the effective administration of the Website, to fulfill and/or address your requests, or to provide the functionalities and features as further described herein.


This processing is necessary to establish, exercise or defend our legal claims and rights. It is in our legitimate interest or in a third party's legitimate interest to use your PII in such a way to ensure that we provide the very best customer service we can to you or others and comply with our professional and ethical duties as attorneys, consistent with applicable law. In some cases, this processing is necessary to perform a contract to which you are a party.

Business administration and legal compliance

We use PII for the following business administration and legal compliance purposes:

To perform and maintain information for the purposes of performing conflicts of interest searches.
To comply with our legal obligations (including Know Your Client, Anti-Money Laundering, Anti-Bribery, conflicts or similar obligations including, but not limited to, maintaining regulatory insurance).
To enforce our legal rights. To investigate and/or settle inquiries or disputes.
To comply with any applicable law, court order, other judicial process, law enforcement requests or the requirements of a regulator.
To enforce our agreements with you.
To protect the rights, property or safety of us or third parties, including our other clients and users of the Website and Services.
To maintain our records.
To process business transaction data, such as in connection with a merger, or a restructuring, or sale.
To use as otherwise required or permitted by law, consistent with these purposes.

Purpose and legal bases for our use of your PII

It is necessary to enforce, establish or defend our legal rights, or to protect the rights of third parties. This processing is necessary to comply with the EEA legal obligations imposed upon us. It is in our legitimate interest or a third party's legitimate interest to use your PII to comply with other legal obligations. In some cases, this processing will be necessary to perform a contract to which you are a party.

Marketing and promotions

It is in our legitimate interest to use your PII for marketing purposes in order to develop and grow our business and services and to promote the reputation of our firm. We will, where required by applicable law, obtain your consent to send such communications.

We may use PII for marketing and promotional purposes, such as to send you news and newsletters, or to otherwise contact you about products or information we think may interest you, by email and direct (postal) mail. We may also use it to develop new services and determine how to market our services.

Clients insight and analytics

We use PII to better understand how you and others use our services or our Website, so that we can improve our Website and services, develop new features, tools, offerings, services and the like, and for other research and analytical purposes. We also use the information we collect to measure the effectiveness of our online content and how visitors use our Website and our services. We may use this information and the insights we have derived for marketing purposes or to make decisions about events, news and information that may be of interest to clients, prospective clients, Website users and others.


Prevent misconduct, abuse and misuse

Subject to our professional and ethical duties, we use PII where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use. We also use PII to protect and secure the Website and our information systems and networks.

This processing is necessary to comply with EEA legal obligations imposed upon us. It is necessary to enforce, establish or defend our legal rights, or to protect the rights of third parties. It is in our legitimate interest or a third party's legitimate interest to use your PII to comply with other legal obligations. In some cases, this processing will be necessary to perform a contract to which you are a party.

Retention of Personal Data

In general, we will retain relevant PII of Website visitors for at least 2 years from the date of our last interaction with them and in compliance with our obligations under applicable laws, or for longer if we are required to do so according to our regulatory obligations or when we believe necessary to establish, defend, or protect our legal rights and interests or those of others.

Third Party Contractors and Other Data Processors

We may appoint subcontractor data processors as required to deliver the services, such as, without limitation, IT systems or software providers, IT Support service providers, and document and information storage providers, who will process PII on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process PII appropriately and according to our legal and regulatory obligations.

Your Information and Your Choices; Withdrawal of Consent

GDPR provides EU Users with additional rights in respect to the PII we hold about you, including the following rights:

- Your right of access

If you ask us, we will confirm whether we are processing your PII and, if necessary, provide you with a copy of that PII (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

- Your right to correction (rectification)

If the PII we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If you are entitled to have information corrected and if we have shared your PII with others, we will let them know about the rectification where possible. If you ask us, we will also tell you, where possible and lawful to do so, with whom we have shared your PII so that you can contact them directly.

- Your right to erasure

You can ask us to delete or remove your PII in some circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we have shared your PII with others, we will let them know about the erasure where possible. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your PII with so that you can contact them directly.

- Your right to restrict (block) processing

You can ask us to restrict the processing of your PII in certain circumstances, such as where you contest the accuracy of that PII or you object to us. If you are entitled to restriction and if we have shared your PII with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, we will also tell you, where it is possible and lawful for us to do so, with whom we have shared your PII so that you can contact them directly.

- Your right to data portability

You have the right, in certain circumstances, to receive a copy of the PII we've obtain from you in a structured, commonly used and machine readable format, and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

- Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it's based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

- Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your PII, you have the right to withdraw that consent at any time.

- Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we've handled your PII, you can report it to the relevant supervisory authority.

Please note that some of these rights may be limited where we have an overriding legitimate interest or legal obligation to continue to process the PII, or where the PII may be exempt from disclosure due to applicable law, the applicable rules of professional conduct, attorney-client privilege, legal professional privilege, other applicable privileges or protections, or professional secrecy obligations. Additionally, there may be circumstances in which we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided in data protection legislation in general, and GDPR in particular. Finally, please note that we are not responsible for removing or deleting information from the databases of third parties (such as service providers) with whom we have shared information about you, but we will make the request on your behalf for such removal/deletion.

Where We Transfer Your Personal Information

Cause Heroes is located in Canada; when you submit personal information to us, or when others provide personal information to us, we will receive it and process it in Canada.

Children's Privacy/Note To Parents Of Children Residing in The EEA, Switzerland And UK

Except as may be provided by a parent or guardian, we do not knowingly collect, use, or disclose PII about visitors of our Website that are less than 16 years of age; please note that if you are a parent or guardian we ask that you do not provide confidential or sensitive information – including any medical or health related information - to us directly through this Website, or by email to any of the contact email addresses listed on this Website. If a child under the age of 16 submits information to us through any part of the Website and we becomes aware that the user submitting the information is under the age of 16, the information provided will be deleted as soon as it is discovered and not used for any purpose. If you are the parent or guardian of a child under 16 years of age and believe that they have disclosed PII to us, please contact us and be sure to include in your message the same username and password and/or email address that you believe your child submitted, if applicable.

Canada's Anti-Spam Legislation "CASL"POLICY

We are committed to compliance with the law known as Canada's Anti-Spam Legislation ("CASL"). Any electronic communication sent by us to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message we send (a "CEM"), which is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.

In addition to adopting this Policy, and to provide transparency about our compliance, we have undertaken various initiatives in order to ensure we are compliant with CASL in various respects:
Consent—We do not send CEMs without your consent. This consent typically must be "expressed" (or expressly acknowledged by you), but in certain circumstances consent can be "implied" and in others, messages are specifically exempt from consent requirements. We have modified or adopted our sign-up, registration and consent forms in order to ensure that the express consent obtained from you is in compliance with CASL. When we are collecting your electronic contact information, you will know what purposes we want to use it for.
Content—We have adopted processes to ensure that our CEMs contain the prescribed content of CASL. On any CEM from us (usually in the footer), we will clearly:

Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
Provide you with contact information where you can readily contact us; and
Set out a clear, working unsubscribe mechanism (or preference centre) that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).

Clarity—We have ensured that each constituent element of a CEM (including its header, its content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.

If you have received a CEM from us, and you believe that you should not have or you do not wish to receive them (even if we are allowed to send them), we will endeavour to respect your inbox preferences. Without limiting our legal rights or obligations, we try to ensure that our messages all contain useful identity information and unsubscribe or preferences link in our messages—if you check the CEM itself, you will find clear instructions on how to stop receiving CEMs from us or manage your mail preferences. When you unsubscribe, it should happen very quickly – but as required by CASL, we will make sure it occurs within 10 business days. If you have any questions or concerns about our unsubscribe methods, you may contact us at the address indicated below.

Changes to This GDPR Privacy Notice

We may make changes to this GDPR Privacy Notice from time to time, to reflect changes in our practices. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where we materially change this Privacy Notice, we will take steps to notify you (such as by posting a notice on the Website or via email), and where required by applicable law to obtain your consent.

How and When is the Policy Updated? How are You Notified of these Changes?

We reserve the right to modify or amend this Policy at any time by posting the revised Policy on our Website. If there are changes or additions to this Policy, we will post those changes here or in other formats for you to review. Each version of this Policy will be identified at the end of this document by its effective date. Your continued use of the Website after the effective date of any modification to the Policy will be deemed to be your agreement to any changed terms.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your PII, your choices and rights regarding such use, please do not hesitate to contact us at:

Phone: +1 (902) 800-4606
Email: hello@causeheroes.com
Postal: The Cause Heroes Corporation of Canada Inc. Attn: Privacy 1701 Hollis St Suite 800, Halifax, NS B3J 3M8

This Policy is effective as of March 2020.