Pathways
WWW.PATHWAYS TO EDUCATION.CA
legal & privacy

LEGAL:
The intellectual property shared here as well as the approach, methodology and delivery of the program is the trademarked and copy written property of The Regent Park Community Health Centre and cannot be reproduced without the expressed written consent of these parties.

PRIVACY:
PATHWAYS TO EDUCATION CANADA (“Pathways”) recognizes that the privacy of your personal information is essential.  Our privacy policy (the “Privacy Policy”) confirms our commitment to the protection of personal information and to the collection, use and disclosure of personal information only in accordance with the spirit and letter of Canadian privacy laws.

Our Privacy Policy applies to all personal information that we collect, use or disclose about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization or information that is publicly available.

Collection of Personal Information:

Information collected by Pathways Canada includes:  name, address, telephone number, e-mail address, gift amount, credit card and expiry date if donation made through credit card.   If a donation is made in honour of someone, their name and address is required.

1.1     We collect personal information:

         To administer the Pathways Program;

         To establish and maintain our donor lists;

         For such other uses for which you may consent from time to time; and

         As otherwise permitted or required by law.

1.2     When we collect personal information, we limit the information we collect to that which
          is necessary to fulfill the purposes outlined above.

1.3     We will not use previously collected personal information for a new purpose without
          first identifying the new purpose and obtaining your consent for the new use, unless
          otherwise permitted or required by law.

Obtaining Consent:

2.1     In obtaining your consent for the collection, use and disclosure of your personal
          information, we make a reasonable effort to ensure that you are advised of the
          purposes for which the information is collected and will be used or disclosed.

2.2     We will not, as a condition to supplying a product or service, require you to consent to
          the collection, use or disclosure of personal information beyond that required to provide
          the product or service.

2.3     You may withdraw your consent at any time, subject to legal or contractual restrictions
          and reasonable notice, by contacting our Chief Privacy Officer.  Please note that the
          withdrawal of your consent may impact on our ability to serve you, may limit your ability
          to participate in Pathways’ products and services and/or our ability to maintain our
          relationship with you.

2.4     In certain circumstances personal information may be collected, used or disclosed
          without your knowledge and consent.  For example, legal, medical or security reasons
          may make it impossible or impractical to seek consent.  When information is being
          collected for the detection and prevention of fraud or for law enforcement, seeking
          consent might defeat the purpose of collecting the information.  Seeking consent may be
          impossible or inappropriate if you were a minor, seriously ill, or mentally incapacitated. 

2.5     We may also collect information without your consent if the collection is reasonable for
          the purposes of establishing, managing or terminating an employment or volunteer
          relationship. 

2.6     Personal information may also be disclosed when required or permitted to do so by law
          or legal process, or in connection with a sale, transfer or reorganization of Pathways’
          business, in which case Pathways will require that any personal information will
          continue to be treated in accordance with this Policy.

Use and Disclosure of Personal Information:

3.1     Pathways does not use or disclose personal information for purposes other than those
          for which it was originally collected, except with your consent or as otherwise
          permitted by law.

3.2     We may also disclose personal information to another organization without your consent
          if you had consented to the use of the personal information by us, and we are
          disclosing the personal information to the other organization solely for the purposes for
          which the information was previously collected and to assist the other organization to
          carry out work on our behalf. 

3.3     We remain responsible for personal information in our possession or custody, including
          information that we transfer to a third party for processing.  We enter into confidentiality
          or contractual agreements with third parties which are engaged to perform services on
          our behalf and to whom we transfer personal information for processing requiring them
          to provide a level of security comparable to that provided under our Privacy Policy.

Protection of Personal Information:

4.1     Pathways is committed to protecting your personal information by security safeguards
          appropriate to the sensitivity of the information.  These security measures include both
          physical and technical security measures, such as locked filing cabinets and restricted
          access to areas where personal information is stored, passwords and encryption
          technology as appropriate as well as organizational security measures, such as
          security clearances and limiting access on a “need-to-know” basis. 

4.2     When disposing of or destroying personal information which is no longer needed, we
          ensure that appropriate measures are taken regarding the disposal or destruction so as
          to prevent unauthorized parties from gaining access to the personal information.

Retention of Personal Information:

5.1     We retain your personal information only as long as necessary for the fulfillment of the
          general purposes outlined above or for the fulfillment of legal or business purposes. 

Access To and Correction of Personal Information:

6.1     Upon receipt of a written request, Pathways will inform you of the existence, use and
          disclosure of your personal information and will give you access to that information. 
          You will be able to challenge the accuracy and completeness of the information and
          have it amended as appropriate following procedures that have been established by
          Pathways.

6.2     We do not routinely update personal information, unless such a process is necessary to
          fulfill the purposes for which the information was collected or we receive notification
          from you to do so.  If you are aware of updates changes to the personal information
          you have given us, simply write our Chief Privacy Officer and we will update our
          records accordingly.

Compliance:

7.1     Should you have any questions or comments about our Privacy Policy or the collection,
          use or disclosure of your personal information, please contact our Chief Privacy Officer
          by mail at: 

          ATTENTION:  Chief Privacy Officer
          Pathways To Education Canada
          6 Adelaide St. East, 8th Floor
          Toronto, Ontario
          M5C 1H6

            Or by e-mail at: info@pathwayscanada.ca

7.2     A challenge concerning compliance with privacy laws can be addressed to our Chief
          Privacy Officer.

7.3     We have procedures in place to receive and respond to complaints or inquiries about
          our policies and practices relating to the handling of personal information.

Internet Usage:

8.1     When you visit Pathways’ website at www.pathwayscanada.ca, please rest assured
          that we do not collect identifying information about you unless you specifically provide
          it.  The only information we collect is non-identifying information (such as the ISP,
          the type of Internet browser used, the referring web site, the pages requested and the
          date and time of those requests) to create aggregate data in order to determine the level
          of interest in the information provided on the website and to improve the content of the
          website.

8.2     We collect this non-identifying information through the use of cookies and server log
          files, including IP Addresses. Our website does not link IP Addresses to any personally
          identifiable information.  Cookies identify which areas of our website you have visited or
          customized, and make these pages readily accessible the next time you visit.  If you do
          not want non-identifying information collected through the use of cookies, you can
          disable it by changing the setting of your Internet browser.

8.3     In addition, we may provide links to other websites managed by
          third parties/may permit third parties to offer users subscriptions/registration-based
          services through its website.  As we cannot control or be responsible for the actions or
          policies of such third parties, you should check the applicable privacy policy of such
          third parties when visiting their websites or when providing any personal information to
          them.  Please also note that we cannot control or prevent the use of cookies or any
          information obtained through cookies by such third parties.  

8.4     Finally, please be advised that information voluntarily disclosed online in discussion
          areas/other public areas of our website can be collected, used and disclosed by third
          parties.  Any submissions made to discussion areas/other public areas on our website
          are done at the user’s risk and on the understanding that such information may be
          accessible to third parties.  We cannot control and will not be liable for any damages
          that may arise from such user activity.

Changes to Privacy Policy:

9.1     Pathways reserves the right to modify our Privacy Policy at our sole discretion.  In
          particular, the Chief Privacy Officer will periodically review and modify our Privacy
          Policy in response to developments and changes in privacy law.  Any modifications
          shall be effective immediately upon its publication by any means, including posting on
          this website.

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