Privacy Statement
Introduction and Scope
CLEO is committed to protecting personal information by following responsible information-handling practices in keeping with the Personal Information Protection and Electronic Documents Act (PIPEDA), and other relevant privacy laws. CLEO uses modern information and communication technology to support our activities.
This Privacy Policy governs our practices with respect to personal information we collect through the Steps to Justice website, a project of CLEO. Personal information is any information recorded in any form that identifies or can identify an individual.
This Privacy Policy is effective as of July 1, 2019.
Accountability
CLEO is responsible for the personal information under our possession and control. We have designated a Privacy Officer to be responsible for our compliance with this Privacy Policy and current privacy legislation.
What Personal Information We Collect
Personal information is any information recorded in any form that identifies or can identify an individual. You can access and browse the Steps to Justice website without disclosing your personal information.
As a general policy, no personal information is collected from our visitors. The only personal information we collect is the information that you volunteer, such as your name, your personal email address, and your home or cell phone number. You may provide us with your personal information:
- when you give us feedback, ask a question, or complete a survey and give us your email address to allow us to send you requested information
- when you sign up to receive an email bulletin
- when you sign up to receive social media updates
- when you use our Live Chat service
How We Use Your Personal Information
CLEO collects personal information for the following purposes:
- to provide services or products to you, such as sending you updates about our legal information resources and services that you have requested, or to send you Steps to Justice bookmarks or posters, or other CLEO-related publications that you have ordered or may be of interest to you
- to respond to any correspondence from you or inquiries you ask us
- to understand, research, and improve our services, including understanding survey data and user feedback
- to satisfy legal, government, and regulatory obligations
- for any other reasonable purposes for which you may have provided your express consent or in which your consent can be reasonably implied
Email mailing list subscriptions
When you subscribe to an email list from CLEO or Steps to Justice, you need to provide your name and an email address. This email address is used to deliver the mailing list messages to you, such as information about CLEO publications, activities or projects, and Steps to Justice information updates. Your email address will not be disclosed to any other mailing list subscriber, organization, website, or government agency. If you do not wish to hear about CLEO publications, activities or projects, you may unsubscribe at any time. For more information on how Mailchimp protects client privacy see: https://mailchimp.com/legal/
Consent
We respect your privacy and, unless otherwise required by law, we will not collect, use, or disclose your personal information without your prior consent. Your consent may be expressed or implied. You may expressly give your consent in writing, verbally, or through any electronic means. In certain circumstances, your consent may be implied by your actions. For example, providing us with your email address to request legal information is implied consent to use your information to send you the requested legal information.
Where appropriate, CLEO will generally seek your consent to use or disclose the information when we collect it. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use. For example, when CLEO wants to use information for a purpose other than those identified above. When getting your consent, CLEO will use reasonable efforts to ensure that you are advised of the identified purposes for which your personal information will be used or disclosed.
The form of consent sought by CLEO may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, CLEO shall take into account the sensitivity of the personal information and the reasonable expectations of visitors to the Steps to Justice website. CLEO will seek your express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw your consent, this will result in our being unable to give you certain services. In order to withdraw consent, you must provide notice to CLEO in writing, including through the unsubscribe link in our emails.
Limiting Use, Disclosure and Retention
We do not share or sell the personal information we collect. We will not disclose your personal information to anyone else without your prior knowledge or consent, except when required by a government body or agency, or as permitted by law. CLEO will not use, disclose, or transfer your personal information for any purpose other than those described above without first obtaining your consent, where such consent is not reasonably implied.
As noted above, CLEO does not disclose your personal information to third parties. However, your personal information may be transferred to third party suppliers, contractors, and agents (“Affiliates”) who are contracted by CLEO to assist it in providing products and services, for example editors and technical support. These Affiliates will only use your personal information for the purposes identified in this Privacy Policy. CLEO takes reasonable contractual or other measures to protect your Personal Information while processed or handled by such Affiliates.
CLEO will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased, or made anonymous according to the guidelines and procedures established by CLEO.
Information We Collect That Does Not Identify You
CLEO also collects information from you that is aggregated and/or anonymized in such a way that it cannot be connected to you or any individual, and therefore is not considered personal information. This includes the following data we collect:
- device and browser type
- operating system
- the pages or features of the website that a visitor browsed
- the time spent on those pages or features
- the frequency with which the website is used by a visitor
- search terms used by a visitor
- the links on the website that the user clicked on or used; and
- other statistics.
This information by itself or together cannot be tracked to a specific individual’s personally identifiable information.
How We Use Aggregated or Anonymized Information
In an ongoing effort to better understand the needs of our visitors so as to improve the Steps to Justice website, we may use aggregated or anonymized information to analyze user demographics and website usage behaviour. This analysis may be used by CLEO and any partners that embed Steps to Justice content for statistical purposes and to develop and enhance CLEO activities and services.
Use of cookies
A cookie is a small text file containing a unique identification number that is transferred from any website you are on to the hard drive of your computer so that the website may identify separate visitors to the site and track users’ activities on the website. A cookie will not give a website any personally identifiable information about you, such as your name and address.
CLEO uses cookies only to keep track of how many people visit the Steps to Justice website and how frequently each page is visited. Specifically, cookies are used to:
- preserve and expire visitor sessions on the site (keeping visitors signed in after authenticating or saving data; and ending the session after a period of inactivity)
- store font size preferences on the site
- enable web analytic tools
Individual movements of users cannot be tracked while on the Steps to Justice website. CLEO uses cookies to track page popularity only to be able to improve the quality of the site and meet your needs. We collect information about you only if you volunteer it.
Visitors who wish to opt out of cookies should review the help documentation for their browser software to decline or selectively decline cookies. Visitors can also regularly delete their browser and cookie history. Note that declining cookies may adversely impact site performance for you.
You can find more information about how to do manage cookies for all the commonly used internet browsers by visiting www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device.
Google Analytics
The Steps to Justice website uses Google Analytics to track website performance. Google Analytics uses persistent cookies to track things like visitor sessions, visitors across multiple sessions, and referral sources to the website. We also track the performance of promotional links to our website.
The information generated by the cookie about your use of the Steps to Justice website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In compliance with the Google Analytics Terms of Service, at no time is personally identifiable information passed to Google Analytics.
Google will use this information for the purpose of evaluating your use of the Steps to Justice website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet 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. Google will not associate your IP address with any other data held by Google.
If you want to opt out of Google Analytics data collection, you should use the Google Analytics Opt-out Browser Add-on. However please note that if you do this you may not be able to use the full functionality of the Steps to Justice website. By using the website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Zendesk
The Steps to Justice website uses Zendesk, an online customer service application, to operate the Live Chat functions on the site. Information submitted through the live chat interface is stored by Zendesk.com. For more information on how this information is stored and kept private see: https://www.zendesk.com/company/customers-partners/eu-data-protection/
AddThis
AddThis tools provide website owners with the capability to enable users to instantly share webpages, blogs, news, photos, videos, and other content to the most popular social networks and other destinations via a browser plug-in or website plug-in. We use services provided by AddThis to help visitors share content that they find useful on our website across multiple social networks and platforms. AddThis uses cookies to collect data on how our content is shared. You can learn how to opt-out of AddThis as well as find further information on AddThis terms and conditions of use and data privacy at: http://www.addthis.com/privacy/privacy-policy(link is external).
Third Party Ad Networks
The Steps to Justice website is promoted on third party ad networks such as Google Adwords which may collect “click stream” data prior to your visit. In some cases, this site may use cookies, web beacons, or pixels in order to determine which advertisements are successful in directing visitors to this site. Please review the following related privacy pages:
Google Advertising FAQ: https://ads.google.com/intl/en_ca/home/faq/
Opting out of Google Advertising: https://support.google.com/ads/answer/2662922?hl=en (link is external)
Links On Our Website
The Steps to Justice website provides links to other websites. CLEO is not responsible for the privacy policy of these websites or how personally identifiable information is collected, stored, and used. We encourage visitors to review each website’s privacy policy before disclosing any personally identifiable information.
Confidentiality and Security
CLEO maintains physical, electronic, and administrative safeguards that are appropriate to the type of personal information we obtain from you. Only CLEO staff, volunteers, or third party suppliers, contractors, or agents with a business need to know, or whose duties reasonably so require, are granted access to personal information about our website visitors. All such staff and volunteers will be required as a condition of employment to contractually respect the confidentiality of your personal information and handle it responsibly.
How to Access Your Personal Information
Upon request, CLEO will provide information to any person about whether we have their personal information, and what we have disclosed and used it for. CLEO will respond to an application for individual access to personal information within a reasonable time and at minimal or no cost to the individual. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, CLEO may not be able to provide access to all the personal information it holds about a person. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. CLEO will provide the reasons for denying access upon request.
Privacy Questions
If you have a complaint or concern about CLEO’s information-handling practices, we encourage you to let us know. Any inquiries or complaints involving CLEO’s handling of personal information or compliance with this policy or with PIPEDA should be directed to CLEO’s Privacy Officer:
Julie Mathews, Executive Director, CLEO (Community Legal Education Ontario / Éducation juridique communautaire Ontario)
180 Dundas St. West, Suite 506, Toronto, ON M5G 1Z8
or by email at info@cleo.on.ca.
CLEO will maintain procedures for addressing and responding to all inquiries or complaints from individuals about CLEO’s handling of personal information. CLEO will investigate all complaints.
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If CLEO finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
General
CLEO reserves the right to modify and amend this privacy policy from time to time in its sole discretion without prior notice. Any amendment(s) will be posted on the Steps to Justice website and will be effective as of the date of posting.
