Last Updated: August 27, 2019
SMF sponsors, works with and supports the SickKids Charitable Giving Fund (“SickKids”) and the Social Impact Fund (“SIF”). If you would like to learn more about the SickKids, please visit its website here:
If you would like to learn more about the Social Impact Fund, please visit its website here:
Personal information is any information about an identifiable individual.
The Personal information that We Collect
We collect and maintain different types of personal information in respect of the individuals with whom we interact. This personal information may include, but is not limited to:
contact and identification information, such as your name, residential address, telephone number and email address; and
payment information, such as your credit card information, debit card information, billing address and other similar banking information required to process transactions, such as donations made on or through our Website.
How we may collect personal information
We, our partners and third-party service providers collect personal information in a variety of ways, including:
Through the Website: We collect personal information when you interact with or provide us with your personal information through the Website.
From the charities to which you donate or contribute through SMF: The charities and organizations that SMF supports share information relating to your donation to these charities. For example, SickKids and SIF will share your name, physical address, email address and the amount you have donated with SMF after you have donated. If you would like to learn more about SickKids or SIF’s personal information handling practices, please visit their respective privacy policies linked above.
From our Third-Parties & Service Providers: From time to time, we may utilize the services of third-parties and may receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us. These third-parties may include, but are not limited to our joint marketing partners, payment processors, social media platforms and analytics providers.
Why we collect personal information
We only collect the necessary information from you to provide you with the services available through our Website, to fulfill SMF’s legitimate business purposes as a charitable enterprise, and which enables SMF to manage, maintain, and develop our operations. For example, we collect and use information in order to:
To deliver our charitable purposes, statutory and financial reporting and other regulatory compliance purposes.To facilitate research, events management, the administration of volunteers, employment and recruitment activities, and carry out the day-to-day operations of SMF.
Fundraising and Campaigning
To administer campaigns, events, initiatives, programs and donations, send marketing materials and sending thank you communications, including preparing and providing tax receipts.
Providing the functionality of the Website and fulfilling your requests.
To verify your identity, establish, maintain, administer and manage our relationship with you so that we may provide you with, facilitate or receive from you, the services, payments, donations or other matters that have been requested.
To enable you to register, access and maintain an account with us.
To respond to your inquiries and fulfill your requests, when you contact us via our Website or otherwise, for example, when you send us questions, or when you request information about our Website, organization or services.
To send you administrative information, including information regarding the Website and changes to our terms, conditions and policies.
To complete and fulfill your donation or purchase, for example, to process your payments and donations, communicate with you regarding your purchase or donations and provide you with related customer service.
Providing you with our communications, newsletter and/or other marketing materials.
To communicate with you about services, offers, promotions, campaigns and events offered by SMF and others.
To send you marketing related push notifications and emails, with information about our services and other news about SMF and its initiatives.
Analysis of personal information for business reporting and providing personalized services.
To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so that we can improve the Website.
To better understand you, so that we can personalize our interactions with you and your experience on the Website, including by presenting information, content, opportunities and offers tailored to your interests.
Allowing you to participate in sweepstakes, contests or other promotions.
We may offer you the opportunity to participate in sweepstakes, contests and other promotions. Some of these activities have additional rules with information about how we use and disclose your personal information.
Aggregating and/or anonymizing personal information.
We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose such aggregated and/or anonymized data for any purpose.
• Accomplishing our business and charitable purposes.
For data analysis, for example, to improve the efficiency of our Website.
For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
For developing new offerings, communications, services, programs, events and initiatives.
For enhancing, improving or modifying our current, offerings, opportunities, services, programs, events and initiatives.
For identifying usage trends, for example, understanding which parts of our Website are of most interest to users.
For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
For operating and expanding our activities, for example, understanding which parts of our Website are of most interest to our users so we can focus our energies on meeting our users’ interests.
Fulfill any other reasonable purpose to which you consent.
By consenting to our collection, use and disclosure of your personal information through the use of our Website you allow us to fulfill the purposes for which we collect your personal information. We will collect your express consent prior to sending you any commercial electronic messages (e.g., marketing emails, news and updates), unless an exception to obtaining your opt-in consent applies under applicable laws. You will have the opportunity to opt-out of receiving commercial electronic messages at any time.
Disclosure of Personal information
We may disclose your personal information to our affiliates and our respective employees, contractors, consultants, service providers, the charitable organizations that SMF supports and other parties who require such information to assist us with managing our relationship with you and operating our organization, including third parties that provide services to us or on our behalf. For example, we disclose personal information:
To the charities and organizations that SMF supports as well as our third-party service providers, to facilitate services they provide to us.
As explained above, when you donate through our Website it is processed by SickKids or SIF, depending on your jurisdiction of residence.
To third parties, to permit them to send marketing communications to you, consistent with your choices.
To third-parties that sponsor contests, sweepstakes and similar promotions.
In connection with a sale or business transaction involving SMF.
To enforce our terms and conditions and to protect our rights, safety, property and/or that of our affiliates, partners, you or others.
In addition, your personal information may be disclosed:
As permitted or to comply with applicable law and regulations in cooperation with foreign or domestic government authorities or law enforcement.
This can include laws outside your country of residence.
To cooperate with law enforcement.
For example, when we respond to valid legal processes such as search warrants, subpoenas or court orders or other similar law enforcement requests. This can include laws outside your country of residence.
As part of SMF’s regular reporting activities under applicable laws.
The Consequences of Disclosing Your Personal Information
Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, social insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Website or otherwise to us.
“Other Information” is information that does not reveal your specific identity or does not directly relate to an identifiable individual. We and our third-party service providers may collect Other Information, such as:
Browser and Device Information: Browser and device information, such as your IP address, device domain used to access our Website, the operating system on your device, your device settings, application IDs, the type and version of your browser, serve log files, crash data, and other unique device identifiers.
Cookies and Other Tracking Technologies: This information includes, but is not limited to, information that is collected through cookies, pixel tags and other technologies, such as web beacons.
Information about how you use the Website: This information includes, but is not limited to, the website you came from to access our Website, the page of our Website you entered and exited at, any page within our Website that is viewed by your IP address.
How We Collect Other Information
We and our service providers collect Other Information in a variety of ways, including:
Through your browser or your device: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Windows or Mac), screen resolution, operating system version, Internet browser type and version and the type and version of a Website that you are using. We use this information to ensure that the Website functions properly.
Through server log files: An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing a Website by your Internet Service Provider and is identified and logged automatically in our server log files whenever you visit the Website, along with the time of the visit and the activity on the Website. We and our service providers use IP addresses for purposes such as calculating Website usage levels, helping diagnose server problems, administering the Website and determining your approximate geographic location.
Information about how you interact on the Website: We may collect information about how you interact on the Website. For example, some Website may utilize analytic tools to help us better serve you through improved services and revisions to the Website. This information may let us know which services and features you are using the most within the Website, as well as device type and hardware features, country and language of download, etc.
Collection, Uses and Disclosures of Other Information
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Team using the contact information set out in the “Contact Us” section below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Team. If you withdraw or vary your consent, we may not be able to provide you with the communications and/or services you request through our Website. For example, if you would like to receive our newsletter, but are not willing to provide your email address, we will not be able to fulfill your request.
We seek to use reasonable physical, technical and administrative measures to protect personal information under our control. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, no data transmission over the Internet or data security system can be guaranteed to be 100% secure.
The security of your personal information is important to us. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
The Website is not directed to children and we do not knowingly collect, use or disclose personal information from children through the Website, except where in compliance with applicable laws.
Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Website, you understand that you are transferring your information to countries outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security agencies in those other countries may be entitled to access your personal information.
If you have any questions regarding the storage of your personal information, please contact our Privacy Team using the information included in the “Contact Us” section below.
You can ask to access the personal information that we have received from or possess about you. If you want to review, verify or correct your personal information, please contact our Privacy Team. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Team.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
We give you choices regarding our use and disclosure of your personal information for marketing purposes. If required under the laws for your jurisdiction, you will be provided with an opportunity to opt-in to receiving news, updates, marketing and promotional communications from SMF and its partners. You may opt of receiving news, updates, marketing and promotional communications from us and/or our partners at any time.
You may also opt-out from:
Receiving push notifications from us – if you do not want to receive push notifications from us, you may opt out using your device settings.
Our sharing of your personal information with third parties for their marketing purposes – if you prefer that we not share your personal information on a going-forward basis with third parties for their marketing purposes, you may opt-out from such sharing by emailing us at email@example.com.
We will try to comply with your request(s) as soon as reasonably practicable, and in all cases, within the time period prescribed under applicable laws. Please note that, if you opt-out from receiving marketing-related messages from us, we may still send administrative messages to you.
How you can access, change or delete your Personal information
If you would like to request to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us, object to the collection, use, disclosure or other processing of your personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact our Privacy Team using the information included in the “Contact Us” section below. We will respond to your request consistent with applicable laws.
In your request, please make clear what personal information you would like to have changed or removed, or whether you would like to have your personal information suppressed from our database. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include, but are not limited to: (1) the length of time we have an ongoing relationship with you and provide the Website to you (for example, for as long as you have an account with us or keep using the Website, as applicable); and (2) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them).
INTERPRETATION OF THIS POLICY
CALIFORNIA PRIVACY RIGHTS
Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer’s personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please send us an email to: firstname.lastname@example.org or write us at: 63 Roebling St, New York, NY, ATTN: Privacy Team. We will be happy to honor your request.
California Privacy Rights for Minor Users
Since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or delete personal information provided by you or publicly posted by you, by sending us an email asking us to delete certain posted content at email@example.com or write us at: 63 Roebling St, New York, NY, ATTN: Privacy Team.
We will be happy to review, update or remove Information and/or content as appropriate. Residual copies of Information and/or content that have been removed from your account and/or the Website may remain in our backup systems for approximately one month. We may still retain your Information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose.
This Website is intended to comply with the United States Children’s Online Privacy Protection Act (“COPPA”). If you reside in the United States, we encourage you to visit http://www.ftc.gov/bcp/edu/pubs/consumer/tech/tec08.shtm for more information about COPPA and children’s privacy. In the event that we become aware that we have collected COPPA-restricted personal information from any child other than as permitted under that law, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information (as defined by COPPA) without COPPA-required consent, please write to: firstname.lastname@example.org, or write us
at: 63 Roebling Street, New York, NY ATTN: Privacy Team.
Do Not Track
If you would like to find out more about Do Not Track, you may find the following link useful: http://www.allaboutdnt.com/.
ADDITIONAL INFORMATION REGARDING THE EUROPEAN ECONOMIC AREA (“EEA”)
You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available https://edpb.europa.eu/about-edpb/board/members_en.
Our Legal basis for Using Data: Data controllers need a lawful basis to collect and use your personal data under EU data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Three of these are relevant to the types of processing that the SMF carries out. This includes information that is processed on the basis of:
A person’s consent;
Processing that is necessary for compliance with a legal obligation, such as processing a donation; and
SMF’s legitimate interests.
Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, as long as that interest is not overridden by the privacy rights of the individual whose data is being used. SMF’s legitimate interests include the legitimate interests that are outlined in the section entitled “Why We Collect Personal information” above.
If you would like to change our use of your personal data in this manner, please get in touch with us using the details in the “Contact Us” section below.
How Long We Retain Data: We will keep your personal data for no longer than is necessary for the purposes for which it is processed, in accordance with our internal policies. The length of time that data will be kept may depend on the reasons for which we are processing the data and on the applicable laws or regulations that the information falls under such as financial regulations, statutory limitation periods or any contractual obligation we might have.
If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.
Transfers Outside of the EEA As SMF is based in Canada any personal data that you provide to us via the Website will be transferred to and held in Canada. Data transfers that are made from the EEA to SMF in Canada will be conducted securely and in accordance with applicable laws.
Your Rights: You have a number of rights under EU data protection legislation. These include:
Right of Access: You have the right know what information we hold about you and to ask, in writing, to see your records. We will supply any information you ask for that we hold about you as soon as possible, but this may take up to 30 days. We will not charge you for this. You will be asked for proof of identity as the person dealing with your request may not be the staff member you have met before. We need to be sure we are only releasing your personal data to you. This is called a data subject access and can be done by writing to us using the “Contact Us” details.
Right to be Informed: You have the right to be informed how your personal data will be used. This policy as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.
Right to Withdraw Consent: Where we process your data on the basis of your consent (for example, to send you marketing emails) you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the “Contact Us” section below.
Right to Object: You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us using the details in the “Contact Us” section below.
Right to Restrict Processing: In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
Right of Erasure: In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials we will need to keep some limited information in order to ensure that you are not contacted in the future.
Right of Rectification: If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated. To update your records please get in touch with us using the details in the “Contact Us” section below.
Right to Data Portability: Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.
Rights Related to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (a) is necessary to enter into/perform a contract between you and us/another organisation, (b) is authorised by EU or Member State law to which the SMF is subject (as long as that law offers you sufficient protection); or (c) is based on your explicit consent.
If you would like to exercise any of these rights, please get in touch with us using the details in the “Contact Us” section below. If you are unhappy with the way in which we have handled your personal data, please contact us using the details below. You are also entitled to make a complaint to the data protection regulator within your EU member state, for example, the Information Commissioner’s Office in the UK.