RESOLUTE CENTER PRIVACY POLICY
The purpose of this Privacy Policy is to inform you about the types of Personal Information the Resolute Center (as follows, “RC”, “we” or “us”) collects about you or members of your family in the process of conducting the principal activities for the specific products and services you receive from us. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information. The majority of the collection, use, and disclosure of personal information by RC Canada is for the purposes of membership, and therefore for non-commercial purposes.
This Privacy Policy sets out a summary of the principles and procedures that Resolute Center follows in meeting its privacy commitments and, as applicable in light of the foregoing, complying with the requirements of the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act. From time to time, we may make changes to this Privacy Policy. The Privacy Policy is current as of the “last revised” date which appears at the bottom of this page. We will treat Personal Information in a manner consistent with the Privacy Policy under which it was collected unless we have your consent to treat it differently. This Privacy Policy applies to any information we collect or receive about you, from any source.
GUIDING RULE 1 — RESOLUTE CENTER IS ACCOUNTABLE FOR YOUR PERSONAL INFORMATION IN ITS POSSESSION OR CONTROL.
Resolute Center is making every reasonable effort to keep the personal information it collects safely. This includes any personal information that was collected about members, students, candidates, customers, and past members.
Resolute Center has established and put into effect policies and procedures aimed at properly protecting personal information;
Resolute Center has educated its staff and volunteers regarding such policies and procedures and their roles and responsibilities in protecting personal information;
GUIDING RULE 2 — RESOLUTE CENTER IDENTIFIES THE PURPOSES FOR WHICH IT COLLECTS PERSONAL INFORMATION FROM YOU BEFORE IT IS COLLECTED.
We generally identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use.
Some of the primary purposes for which we collect and use your Personal Information include:
- to provide services to you or members of your family;
- to complete a transaction with you when you purchase or use a product or service offered by us;
- to advise you of Resolute Center products or services that may be of interest to you;
- to send you electronic Resolute Center newsletters that may be of interest to you or to which you have subscribed, and to better understand which articles are of interest to you;
- to have access to an emergency contact number you provided in a case of emergency; and
- to respond to inquiries you submit.
We may also use your Personal Information as otherwise permitted or required by law.
GUIDING RULE 3 — RESOLUTE CENTER OBTAINS YOUR CONSENT BEFORE COLLECTING PERSONAL INFORMATION FROM YOU.
We explain your options and obtain your implicit or explicit consent at the time of or prior to collecting, using or disclosing your Personal Information. We will always collect your Personal Information by fair and lawful means (for example, when you complete an application form or purchase a product or service from us). We also collect your Personal Information where we have obtained your consent to do so or as otherwise permitted or required by law.
Where is it reasonable to do so or permitted by law, we may rely on implied consent.
Except as required to process a transaction, to maintain records of Resolute Center or as required or permitted by applicable law, providing us with your personal information is voluntary. You may withdraw or modify your consent at any time, subject to legal and contractual restrictions, provided that reasonable notice is given to us. 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.
Personal Information is any information that is identifiable to you. This information may include but is not limited to, your name, mailing address, phone numbers, email address, identification numbers, credit card numbers, and banking information.
GUIDING RULE 4 — RESOLUTE CENTER DISCLOSES YOUR PERSONAL INFORMATION ONLY FOR PURPOSES FOR WHICH IT HAS CONSENT, OR AS PERMITTED OR REQUIRED BY LAW.
RESOLUTE CENTER RETAINS PERSONAL INFORMATION ONLY AS LONG AS NECESSARY TO FULFIL THOSE PURPOSES.
We identify to whom, and for what purposes, we disclose your Personal Information, at the time of or prior to collecting such information from you and obtain your consent to such disclosure. For example, we may:
- transfer/disclose your Personal Information to Center Ontario in order to arrange participation in the group insurance policy;
- transfer your Personal Information to our volunteers, for the purposes of the volunteers performing volunteer functions;
- transfer your Personal Information to third-party service providers with whom we have a contracted agreement that includes appropriate privacy standards, such as service providers that provide communication services support or data storage or processing – for the purpose of, for example, providing member benefits or facilitating commercial transactions with us;
- disclose your Personal Information to such persons and for such purposes for which you provide your consent; and
- disclose your Personal Information as otherwise permitted or required by law.
We may keep a record of your Personal Information, correspondence or comments in a file specific to you. We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law.
GUIDING RULE 5 — RESOLUTE CENTER ENDEAVOURS TO KEEP ACCURATE, COMPLETE, AND UP-TO-DATE, PERSONAL INFORMATION IN ITS POSSESSION OR CONTROL, TO THE EXTENT REQUIRED TO MEET THE PURPOSES FOR WHICH IT WAS COLLECTED.
We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible based on information provided to us by you or members of your family. We expect you, from time to time, to supply us with written updates to your Personal Information, if applicable. In the case of Resolute Center members, Personal Information may be updated by accessing My Account.
GUIDING RULE 6 — RESOLUTE CENTER PROTECTS THE PRIVACY OF PERSONAL INFORMATION IN ITS POSSESSION OR CONTROL BY USING SECURITY SAFEGUARDS APPROPRIATE TO THE SENSITIVITY OF THE INFORMATION.
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.
You can visit our Web Site 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 Web Site, the type, and version of web browser and operating system you are using, the number, duration, and frequency of visits to our Web Site 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 Web Site and to determine the characteristics in which users use our Web Site and services. We may use this data to monitor Web Site performance for systems administration purposes, to make our Web Site easier and more convenient to use, to improve our services and to track information in aggregate form (e.g. how many visitors use the Web Site). This helps us better understand our Web Site traffic, visitor behaviour 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.
We make use of Google Analytics. A description of how Google Analytics collects and processes data is set out in “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).
Please note that we have also implemented the following specific Google Analytics Advertising Features:
Remarketing with Google Analytics
Google Display Network Impression Reporting
Google Analytics Demographics and Interest Reporting
Integrated services that require Google Analytics to collect data via advertising cookies and identifiers.
We use cookies, that is, small files that your Web browser places on your computer’s hard drive, to remember a User’s code, and preferences while the User is using our Web Site, to facilitate navigating different pages on the Web Site, to personalize the users experience when returning to our Web Site, to monitor progression through our Web Site, to identify opportunities to improve the user experience, and to customize ads you see when visiting the Web Site, and third-party sites. Also, as a result of us enabling the Advertising Reporting Features, in addition to collecting the information it normally does, Google Analytics collects information via its Google advertising cookies: see https://support.google.com/analytics/answer/2444872#web.
Should you wish to opt out of the Google Analytics advertising features, you may do so at https://tools.google.com/dlpage/gaoptout/.
Our website contains security mechanisms that protect against the loss, the misuse and the modification of information under our control.
Our website provides links to third-party websites. Our Privacy Policy does not extend to these third-party websites and it is recommended that Users read the privacy policies of these websites. We are not responsible for the content of, or the privacy practices employed by third-party websites.
GUIDING RULE 7 — RESOLUTE CENTER IS OPEN ABOUT THE PROCEDURES IT USES TO MANAGE PERSONAL INFORMATION.
Up-to-date information on Resolute Center privacy policies can be obtained from a knowledgeable member of our staff (see contact information under GUIDING RULE 8).
GUIDING RULE 8 — RESOLUTE CENTER RESPONDS ON A TIMELY BASIS TO REQUESTS FROM MEMBERS ABOUT THEIR PERSONAL INFORMATION WHICH RESOLUTE CENTER POSSESSES OR CONTROLS.
We will generally make available to you any Personal Information that we have collected about you, utilized or disclosed, upon your written request, to the extent permitted or required by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes. Personal Information of Resolute Center members may be reviewed and updated by accessing My Account.
You can at any time, challenge the accuracy or completeness of the Personal Information we have which is related to you. Where we validate your identity, and you successfully demonstrate the inaccuracy or incompleteness of your Personal Information, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. You have the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.
We will not assess any costs to you for access to your Personal Information or to our Privacy Policies or Practices without first providing you with an estimate of the approximate costs if any. We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such information shall be used only for this purpose.
All comments, questions, concerns or complaints regarding your Personal Information or our Privacy Policy and Practices, should be forwarded to our Chief Privacy Officer as follows.
By mail:
Attn: Chief Privacy Officer
Resolute Center,
150 Katimavik Road, Kanata, ON, K2S 1E1
We will inform you of the relevant procedures when you make an inquiry or lodge a challenge or complaint.
Last revised: September 28, 2019