Privacy Policy

1. Introduction

This website, https://ifex.org (the “Site”) is operated by IFEX (“We” or “Us”).

In this policy, “IFEX” refers to IFEX staff, council members, contractors, interns, volunteers, and consultants, all of whom are bound by Canadian law or contract to keep information they receive as part of their assistance to IFEX confidential.

We are committed to protecting the privacy of visitors to our Site. We strive to minimise the amount of information we collect or allow to be collected by third parties on our Site. We have established this Privacy Policy to explain what information we collect through our Site and how it is used, as well as the protections we have in place for your personal information.

As an organization, we are strongly committed to data security, including working with security experts to ensure our own channels of communication are safe and secure. Our staff members use PGP to encrypt emails. Please request further information from dataofficer@ifex.org if you want to sign or encrypt emails with PGP so we can exchange keys.

2. Collecting personal information

  • We use third party processors to deliver services on our Site — such as newsletter subscriptions — at your direction. For more information contact dataofficer@ifex.org
  • We may collect, store and use the following kinds of personal information:
    • Information about your computer and your visits to and use of this website including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, and website navigation paths.
    • Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletter including your name and email address.
    • Information contained in or relating to any communication that you send to us or send through our website including the communication’s content and metadata associated with it.
    • When visitors complete surveys on the site we collect the data shown in the survey form, and also the visitor’s IP address and browser user agent string to help spam detection.
    • Any other personal information that you choose to send to us. Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.

3. Using personal information

  • Personal information submitted to us through our website will be used for the purposes specified in this policy. Your information will not be published without your explicit permission. We may use your personal information to:
    • Send you newsletters and other updates, where you have specifically agreed to this. You can inform us at any time if you no longer want to receive email from IFEX by clicking the unsubscribe link at the bottom of all our email communications.
    • Deal with enquiries and complaints made by you relating to our website.
  • If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
  • We may run surveys, contests, or similar activities through this Site. Any information you provide relating to such activities will be used only for the purposes for which it was collected.
  • We will not supply your personal information to any third party for the purpose of direct marketing.
  • The lawful basis for the processing of your data is:
    • Your prior consent, which you can withdraw at any time, for dealing with enquiries, sending you newsletters, managing participation surveys and similar activities.
    • The fulfilment of the contractual relationship, for the management of job applications, IFEX membership applications, and the possible publication of stories you share.

4. Disclosing personal information

  • Except as provided in this policy, we will not provide your personal information to third parties.
  • We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy. We may also disclose your personal information to third parties who process personal data on our behalf.
  • While we endeavour to provide the highest level of protection for your information, we may disclose personally identifiable information about you to third parties in limited circumstances, including: (1) with your consent; and (2) when we have a good faith belief it is required by Canadian law, such as pursuant to a subpoena or other judicial or administrative order.
  • If we are required by Canadian law to disclose the information that you have submitted, we will attempt to provide you with prior notice (unless we are prohibited or it would be futile) that a request for your information has been made in order to give you an opportunity to object to the disclosure. We will attempt to provide this notice by email, if you have given us an email address, or by postal mail if you have entered a postal address. If you do not challenge the disclosure request, we may be legally required to turn over your information.
  • We do not sell or rent member, donor, or website visitor information under any circumstances.

5. International data transfers

  • IFEX’s office is located in Toronto, Canada. Information that we collect may be stored and processed in, or transferred between, any country where our staff, contractors, or service providers are located in order to enable us to use the information in accordance with this policy.
  • International data transfers may be performed to countries outside of Canada, to which the EU General Data Protection Regulation (“GDPR”) applies. These transfers are regulated in accordance with the applicable data protection law. If you need more information regarding the appropriate safeguards implemented for such transfers of data, you can request it by contacting our Data Privacy Officer.
  • Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

6. Retaining personal information

  • This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
  • Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. For example, processing activities based on the fulfilment of a contractual relationship will continue for as long as the contractual relationship, and any legal obligations relating to it, are in force.
  • Notwithstanding the other provisions of this section, we will retain documents (including electronic documents) containing personal data:
    • To the extent that we are required to do so by Canadian law;
    • If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
    • In order to establish, exercise, or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

7. Security of personal information

  • We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
  • We have dedicated personnel assigned to the task of guaranteeing the security of your personal information.
  • We use a variety of technical means to protect your data, including encryption, security measures and robust intrusion defences.
  • We will carry out periodic audits of our information handling procedures and adjust accordingly.
  • The transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8. Updating of personal information

  • Please let us know if the personal information that we hold about you needs to be corrected, updated or removed. You can do this by contacting dataofficer@ifex.org.

9. Children

  • We do not solicit personally identifying information from children. Visitors who are under 13 years of age should ask their parent or legal guardian for assistance when using the Site and should not submit any personally identifying information to the Site.

10. Your rights

  • You may instruct us to provide you with any personal information we hold about you by contacting dataofficer@ifex.org. Provision of such information will be subject to the supply of appropriate evidence of your identity. We will usually accept a photocopy of your passport certified by a lawyer, solicitor, or bank plus an original copy of a utility bill showing your current address.
  • Please note that there may be instances where access to your personal information may be restricted as permitted or required by Canadian law. We will advise you of the reasons for restricting access subject to any legal or regulatory limitations.
  • You may request that we delete any personal information we hold about you.
  • You may object to the processing of your personal data. Also, if the processing of your data falls within the GDPR’s scope, you may exercise your right to restriction, objection and data portability of your personal data.
  • You may instruct us at any time not to process your personal information for marketing purposes.
  • In practice, you will expressly agree in advance to our use of your personal information for communications from IFEX through a double opt-in process.
  • If the processing of your data falls within the scope of the GDPR and you consider that IFEX has infringed, or may have infringed, your rights under the applicable data protection regulation, you may submit a complaint to the applicable data protection authority.

11. Third party websites and content

  • We may provide links to third party websites, and other websites may provide links to our Site. Third party websites operate according to their own terms of use and privacy policies. We have no control over such third party websites, and by using this Site, you acknowledge and agree that IFEX is not responsible for the availability of such third party sites, and does not endorse and is not responsible or liable for any content, advertising, products or other materials on or available from such sites. You further acknowledge and agree that IFEX will not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, advertising, products, or other materials on or available from such sites.
  • Articles on this Site may include embedded content. Examples may include videos (YouTube Privacy Policy), images (Flickr Privacy Policy), and maps (Google Privacy Policy). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
  • This Site uses third-party plugins to provide services for your use, including, but not limited to, social media sharing and forms that allow you to contact us.
  • We have no control over, and are not responsible for, the privacy policies and practices of third parties.

12. Data breaches

  • In the event of a data breach we will comply with all data notification requirements required by applicable law.

13. Newsletter subscribers

  • If you choose to subscribe to any of our electronic newsletter offerings, we collect your name and email address and, if you choose to provide it, your country and professional affiliation.
  • We only email people who have provided us with their freely given, specific, informed and unambiguous consent. Subscribers can change their subscription preferences or unsubscribe at any time. We make unsubscribing from our communications swift and easy by including a clear unsubscribe link at the bottom of every email.
  • We will not share, disclose or otherwise provide the data of our newsletter subscribers to any unaffiliated group or organisation.
  • We may share some of our subscribers’ personal information with Third Party Administrators, such as companies we engage to facilitate large-scale distribution of emails. The content of these emails will be from IFEX and these third parties do not have direct access to your personally identifiable information.

14. Cookies

  • By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
  • A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  • Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie will expire at the end of the user session, when the web browser is closed.
  • Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
  • Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
  • We use both persistent and session cookies on our website to be sure promotions are not re-displayed to users who have already seen them. We also use cookies set by a third party analytics service to measure traffic and collect statistics about users’ devices and browsers.
  • Third parties may use cookies to track users on our website when they interact with specific site functions such as social media sharing buttons or embedded video.

15. Google Analytics

  • This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
  • Google will use this information for the purpose of evaluating your use of the 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. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Site. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

16. Blocking cookies

  • Most browsers allow you to refuse to accept cookies; for example (accurate as of July 2019):
    • In Internet Explorer you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”.
    • In Firefox you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the dropdown menu, and unticking “Accept cookies from sites”.
    • In Chrome, you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
    • In Safari, choose Safari > Preferences, click “Privacy”, then select “Block all cookies”.
  • Blocking all cookies could have a negative impact upon the usability of many websites.
  • If you block cookies, you may not be able to use all the features on our website.

17. Deleting cookies

  • You can delete cookies already stored on your computer; for example:
    • In Internet Explorer, you can manually delete cookie files. You can find instructions for doing so here.
    • In Firefox you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”.
    • In Chrome, you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
    • In Safari, choose Safari > Preferences, click “Privacy” then click “Manage Website Data”. Select “Remove All” to delete all cookies.
  • Deleting cookies may have a negative impact on the usability of websites.

18. Amendments

  • We may update this policy from time to time by publishing a new version on our website.
  • If we make any substantive changes in the way we collect or use personally identifying information provided by users, we will post a prominent announcement on our website home page and post the changes on this page.
  • We will never change our policies and practices to make them less protective of user information collected prior to the effective date of any changes without the consent of affected users.
  • You should check this page occasionally to ensure you are happy with any changes to this policy.
  • We may notify you of changes to this policy by email.

19. How to contact our regulator

  • If our processing of your personal data is covered by European Union law, you may also wish to contact the relevant data protection supervisory authority for your country of residence.

20. How to contact us

  • If you have any questions about this privacy policy, your personal information, or the practices of this Site, you can write to our office at 555 Richmond Street West, Suite 1101, P.O. Box 407, Toronto, ON, Canada, M5V 3B1.