Privacy Policy

1. Personal Information We Collect

The personal information we collect depends on how you interact with FEJ Canada.

We may collect the following types of information:

Contact and identification information, including:

• First and last name
• Email address
• Telephone number
• Mailing address
• City, province and postal code
• Other identifying information you voluntarily provide

Donation information, including:

• Donation amount
• Date of donation
• Donation history
• Designation or purpose of a donation
• Information required to acknowledge a donation or issue a receipt, where applicable
• Communication preferences
• Information included with a donation or donor message

Raffle and ticket information, including:

• Purchaser’s name
• Email address
• Telephone number
• Mailing or residential address, where required
• Number and type of tickets purchased
• Transaction amount
• Ticket or entry number
• Information necessary to verify eligibility
• Information required to contact and verify a potential winner

Website and technical information, which may include:

• IP address
• Browser type
• Device type
• Operating system
• Approximate geographic location
• Date and time of visits
• Pages viewed
• Referring website
• Website interactions
• Cookie and similar technology identifiers

Information submitted directly to us, including information provided through:

• Contact forms
• Registration forms
• Donation forms
• Newsletter subscriptions
• Event registrations
• Surveys
• Volunteer inquiries
• Program inquiries
• Email
• Telephone
• Other communications with FEJ Canada

We seek to collect only personal information that is reasonably necessary for the purposes for which it is collected.

2. How We Collect Personal Information

We may collect information:

• Directly from you;
• Through forms on our website;
• When you make a donation;
• When you purchase a raffle ticket;
• When you register for an event, activity or program;
• When you subscribe to our communications;
• When you communicate with us by email, telephone or other means;
• Automatically through cookies, analytics technologies and server logs; and
• Through service providers acting on our behalf, including our payment processor.

Where required, we will explain the purposes of the collection and obtain appropriate consent.

3. Why We Collect and Use Personal Information

FEJ Canada may use personal information to:

• Process and administer donations;
• Maintain donor records;
• Provide donation acknowledgements or receipts, where applicable;
• Process raffle-ticket purchases;
• Administer raffles and draws;
• Verify raffle eligibility;
• Contact raffle winners;
• Respond to questions and requests;
• Administer programs, events and activities;
• Manage registrations;
• Communicate with donors, supporters and participants;
• Send newsletters, fundraising information and other communications where permitted;
• Maintain and improve our website;
• Understand how visitors use our website;
• Detect and prevent fraud or misuse;
• Maintain appropriate financial and administrative records;
• Meet regulatory, accounting, taxation and legal obligations;
• Protect FEJ Canada, its users and the public; and
• Carry out other purposes disclosed to you when the information is collected.

We will not use personal information for a substantially different purpose without obtaining additional consent where required by law.

4. Donations and Payments Through Square

FEJ Canada uses Square to process certain online payments, including donations and/or raffle-ticket purchases.

When a payment is made using Square, payment information is transmitted to and processed by Square in accordance with Square’s own terms and privacy practices.

FEJ Canada does not intend to collect or store complete credit or debit card numbers or card security codes on its own website or systems when payments are processed through Square.

Square may receive information associated with a transaction, including transaction details, contact information, device information and payment information. Square’s current Canadian consumer privacy notice confirms that it may process transaction information, contact information, IP addresses and related information when consumers make payments using its services.

Square’s processing of information is governed by Square’s applicable privacy notices and terms.

5. Google Analytics and Cookies

FEJ Canada uses Google Analytics to understand how visitors interact with our website and to help us improve its performance, content and usability.

Depending on our Google Analytics configuration and your privacy choices, Google Analytics may collect information such as:

• Pages viewed;
• Session information;
• Browser and device information;
• Approximate geographic location;
• Website interactions; and
• A device or browser identifier.

Google states that its standard Analytics implementation collects user and session statistics, approximate geolocation and browser/device information and may use a first-party _ga cookie to distinguish users and sessions.

Cookie Choices

Where required, non-essential cookies and technologies that identify, locate or profile visitors will not be activated until the visitor has been provided with an appropriate choice.

You may be able to:

• Accept all cookies;
• Reject non-essential cookies;
• Select categories of cookies you wish to permit; or
• Change your preferences through our cookie settings.

Disabling certain cookies may affect some website functionality.

Important implementation point: FEJ Canada’s cookie banner should be configured to prevent non-essential analytics/profiling functions from activating automatically. The Quebec privacy regulator’s guidance specifically discusses allowing users to activate these functions rather than enabling them by default.

6. Communications and Mailing Lists

If you subscribe to FEJ Canada communications or otherwise provide appropriate consent, we may send you:

• News and organizational updates;
• Information about programs and events;
• Fundraising campaigns;
• Raffle announcements; and
• Other information relating to FEJ Canada’s activities.

You may unsubscribe from electronic marketing communications using the unsubscribe mechanism included in those communications or by contacting us.

Administrative communications relating to an existing donation, transaction, raffle entry, registration or request may still be sent where necessary.

7. Who May Access Your Information

Access to personal information within FEJ Canada is limited to individuals who reasonably require it to carry out their duties.

Depending on the information and purpose, this may include:

• Authorized employees;
• Officers and directors;
• Authorized volunteers;
• Fundraising or administrative personnel;
• Individuals responsible for accounting and financial administration; and
• Individuals responsible for administering programs, events or raffles.

We expect individuals with access to personal information to protect its confidentiality.

8. Service Providers and Disclosure of Information

FEJ Canada may provide personal information to service providers where necessary for them to perform services on our behalf.

These may include:

• Square and other payment-processing providers;
• Website hosting providers;
• Website and IT service providers;
• Email and communications platforms;
• Google Analytics and related technology providers;
• Database and cloud-storage providers;
• Accounting or bookkeeping providers;
• Professional advisers;
• Raffle-management or electronic raffle providers, where applicable; and
• Other suppliers required to operate our organization or website.

We may also disclose information where required or authorized by law, including to regulators, law-enforcement authorities, courts or government bodies.

FEJ Canada does not sell donor personal information or donor lists.

9. Information Outside Quebec

Some of FEJ Canada’s service providers may store or process information outside Quebec or Canada.

This may include providers of:

• Payment processing;
• Cloud hosting;
• Analytics;
• Email;
• Website services; and
• Other technology infrastructure.

Where applicable, personal information processed outside Quebec may be subject to the laws of the jurisdiction in which it is processed.

Quebec law requires an organization to conduct a privacy impact assessment before communicating personal information outside Quebec or entrusting an organization outside Quebec to collect, use, disclose or retain it on its behalf.

FEJ Canada will take reasonable measures to ensure that service providers handling personal information provide an appropriate level of protection.

10. Raffles

FEJ Canada may conduct fundraising raffles from time to time in accordance with applicable laws and licences.

When you purchase a raffle ticket, we may collect information necessary to:

• Complete the transaction;
• Verify eligibility;
• Create and maintain an entry;
• Administer the draw;
• Select and verify a winner;
• Contact a winner;
• Award a prize;
• Maintain records required by regulatory authorities; and
• Comply with applicable lottery and gaming requirements.

Each raffle may be governed by separate Official Raffle Rules containing additional information about eligibility, ticket purchases, prizes, draws and winner verification.

Personal information collected for a raffle will not automatically be used for unrelated marketing purposes unless permitted by law or you provide the required consent.

11. Donor Privacy

FEJ Canada respects the privacy of its donors.

We will not publicly identify an individual donor solely because they made a donation unless:

• The donor has consented to recognition;
• Recognition was clearly disclosed as part of a fundraising initiative; or
• Disclosure is otherwise authorized or required by law.

Donors may request anonymity in public donor-recognition materials where FEJ Canada offers such recognition.

12. Retention of Personal Information

We retain personal information only for as long as reasonably necessary to:

• Fulfil the purposes for which it was collected;
• Administer our relationship with the individual;
• Maintain required accounting, taxation and organizational records;
• Satisfy raffle and regulatory recordkeeping requirements;
• Resolve disputes; and
• Meet legal obligations.

Different categories of information may have different retention periods.

When personal information is no longer required, it will be securely destroyed or anonymized where permitted by law.

FEJ Canada should maintain a separate internal retention and destruction schedule identifying the retention period applicable to donor records, raffle records, website submissions, analytics information, accounting records and other categories of personal information.

13. Security

FEJ Canada uses reasonable administrative, organizational and technical safeguards appropriate to the sensitivity of the information under our control.

Measures may include:

• Restricted access to systems and records;
• Password and account controls;
• Secure hosting;
• Encryption where appropriate;
• Secure payment processing;
• Software and security updates;
• Access controls;
• Backups;
• Staff and volunteer confidentiality practices; and
• Secure destruction of records.

No website, electronic transmission or storage system can be guaranteed to be completely secure.

Quebec organizations are required to implement safeguards appropriate to the information they hold and to respond to confidentiality incidents.

14. Privacy Incidents

If FEJ Canada becomes aware of a privacy or confidentiality incident, we will assess the incident and take reasonable measures to reduce the risk of harm and prevent similar incidents.

Where an incident presents a risk of serious harm, FEJ Canada will make notifications required by applicable law.

FEJ Canada will also maintain records of confidentiality incidents where required.

15. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Ask whether FEJ Canada holds personal information about you;
• Request access to your personal information;
• Request correction of inaccurate or incomplete information;
• Request that certain information be updated;
• Withdraw consent to certain uses or disclosures;
• Ask questions about how information is collected, used or disclosed;
• Request information concerning the persons or categories of persons who have access to your information;
• Request information concerning the period for which information is retained;
• Submit a privacy complaint; and
• Exercise other rights provided by applicable privacy legislation.

Quebec law expressly provides rights of access and rectification and requires organizations to inform people about their ability to withdraw consent to certain uses or disclosures.

Some rights are subject to legal exceptions.

We may need to verify your identity before responding to a privacy request.

16. Withdrawing Consent

Where FEJ Canada relies on your consent, you may withdraw that consent, subject to legal or contractual restrictions and reasonable notice.

Withdrawal of consent may prevent us from providing certain services. For example, we may require certain identifying information to administer a donation, issue an applicable receipt, register a raffle entry or award a prize.

Withdrawal of consent does not affect uses or disclosures that were lawful before consent was withdrawn.

17. Children and Minors

Our website is not intended to collect personal information unnecessarily from children.

Quebec law contains additional consent requirements concerning personal information collected from minors under 14 years of age.

Raffle participation is additionally subject to the age and eligibility requirements established in the Official Rules for the applicable raffle.

18. Third-Party Websites

Our website may contain links to third-party websites or services.

FEJ Canada is not responsible for the privacy practices of independent third parties. We recommend reviewing the privacy policies of those websites before providing personal information.

19. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to:

• Our activities;
• Our website;
• Our service providers;
• Our information-handling practices; or
• Applicable legal requirements.

The current version will be posted on our website with the date of the most recent update.

Where required by law, we will provide appropriate notice of material changes.

20. Privacy Officer and Contact Information

The person with the highest authority within an organization is responsible for the protection of personal information under Quebec law unless that function has been delegated in writing.

Questions, requests or complaints concerning this Privacy Policy or FEJ Canada’s handling of personal information may be directed to:

Privacy Officer
FEJ Canada
Gina Ferrus
5050 chemin de la Côte-Saint-Luc
Montréal, Quebec H3W 2H1
Email: info@fej-canada.ca
Telephone: [PHONE]