COMPLEX TRAUMA CANADA PRIVACY POLICY

Last Updated November 1, 2022
INTRODUCTION 

Complex Trauma Canada (Hereinafter referred to as CTC) is committed to protecting your privacy and the confidentiality of any personal information that you provide to us. We value transparency and we want you to be 100% clear on why we ask you for personal information and what we’ll do with it. 

This Policy describes how we collect, use, store and disclose your personal information in connection with our activities. It describes how you can have confidence that we treat your personal information lawfully and respectfully.

By accessing the CTC website or any of the CTC apps (together, “Websites”), or otherwise providing your personal information to Complex Trauma Canada, you indicate your acceptance of this Policy (as amended from time to time).Please note that supplementary rules apply in relation to individuals whose personal information we collect, if you are located in the European Union or European Economic Area. For more information, refer to Appendix A: EU Privacy Notice. 

WHO ARE WE?

CTC is the leading non-profit organization and charity changing the narrative of family mental health and physical health globally. We’re addressing some of the biggest health issues faced by families: non-violent and violent spousal and child abuse, psychological, emotional, and social traumas, financial abuse, sexual abuse, false allegations, social isolation, homelessness, correctional reintegration, mental health and suicide prevention.

We do this via our global fundraising event in the month formerly known as Sober October, and by running awareness campaigns throughout the year. With the money raised by our global community, CTC funds groundbreaking research and innovative health projects across the world that have significant global and local impact.

A reference in this Policy to CTC (or “we” or “us”) is a reference to the CTC Foundation (Canadian Non Profit Business Number 758213342 RC0001), and its subsidiary and affiliated entities (the CTG Global Ltd, the CTF Foundation (US), CTE Europe).

WHAT INFORMATION DO WE COLLECT?

The information we collect about you depends on the nature of your interaction(s) with us. However, we’ll only collect personal information that is reasonably necessary to fulfil the purpose for which it’s being collected (e.g. to process a donation, or to allow you to work for us etc.).
Below are some examples of the information we may collect about you:

PERSONAL INFORMATION
If you are a volunteer or donor we might collect:

• Contact details (e.g. name, image, age, date of birth, address, postal code/Zip Code, phone number, email address)
• Previous donation history or the amount you’ve donated
• Historical member information including any information you have chosen to share on your membership profile
• Information you’ve provided if you’ve contacted us with a question, complaint or enquiry
A visitor to our websites
• Information about the computer equipment and the version of operating system you’re using
• The settings of the device you use to visit our Websites
An employee, contractor or volunteer
• Contact details (e.g. name, image, age, date of birth, address, postal code, Zip Code, mobile number, personal email address)
• Professional details (e.g. previous employer or business name, job title/occupation, previous employment information)
• Family and beneficiary details for insurance and superannuation (e.g. names and dates of birth)
• Financial information (e.g. taxes, bank details and superannuation details)
• Medical history (e.g. your vaccination status or any allergies or other conditions that help us ensure your safety while at work).
A job applicant
• Contact details (e.g. name, age, date of birth, address, postcode, mobile number, work phone number, personal email address, work email address)
• Professional details (e.g. employer or business name, job title/occupation, previous employment information and any other information you provide while applying for an open role at Complex Trauma Canada)
• Educational details (e.g. high school and university attended, degrees undertaken etc).

SENSITIVE INFORMATION

Sensitive information (sometimes referred to as ‘special categories’ of personal information) is data that requires greater security and could be subject to special protections under the laws of your country. Examples of sensitive information include information about a person’s:

• Race
• Ethnic origin
• Health
• Genetics
• Sex life, sexual orientation or practices
• Political views and opinions
• Religious beliefs or affiliations
• Philosophical beliefs
• Membership of a political association, professional or trade association or trade union
• Criminal record
• Biometric information that is to be used for certain purposes (e.g. ID purposes)
• Biometric templates.

We don’t typically collect sensitive information; however, if you’re an employee, volunteer or job applicant we may collect (with your consent) information about your health and/or information that may reveal criminal convictions or offences information about you.
Trauma Drama Queen or Trauma Drama King, Trauma Drama Group you may choose to provide any information you like in your Trauma Drama Network profile. This could include sensitive information. Please be careful about what information you publish in this way.

CREDIT CARD DATA

If you purchase products from us or make a donation to us, you may provide us with credit card details and other information which will allow us to process the transaction. Please note that CTC does not store credit card information.

DIRECT DEBIT DATA

By signing and/or providing us with a valid instruction in respect to your Direct Debit Request, you have understood and agreed to the terms and conditions governing the debit arrangements between you and CTC Foundation as set out in this Request and in your Direct Debit Request Service Agreement. You agree to execute this document by electronic signature and you are aware that by electronically signing this document you are executing a legally binding document.
UNSOLICITED INFORMATION
If you provide us with unsolicited personal information, which means personal information we receive but have not taken active steps to collect from you, we’ll usually destroy or de-identify the information as soon as practicable (where it isn’t otherwise addressed in this Policy, and of course only if it’s lawful and reasonable to do so).

HOW DO WE COLLECT PERSONAL INFORMATION?
BY RECEIVING IT DIRECTLY FROM YOU

Wherever possible, we’ll collect personal information from you directly. This can include, but is not limited to, online registration forms, online donation forms, email correspondence, social media, live chat discussions, job applications, hard-copy forms, and face-to-face meetings. You might provide personal information to CTC for a variety of reasons, including to:
• Receive information about or to participate in Complex Trauma Canada’s Fundraising Network
• Receive information about or become involved with Complex Trauma Canada’s campaigns, projects or activities
• Receive information about the outcomes of the funds we’ve raised
• Purchase CTC products or merchandise
• Donate funds to us (either directly or via a Trauma Queen, Trauma King, or Trauma Team, Trauma Drama Event or Trauma Drama Network Network)
• Provide us with your CTC ‘motivation’ or a personal story
• Host or attend a CTC event
• Apply for a job with or work for us
• Submit an inquiry or chat to us via the live chat function on one of our Websites or social media accounts.

VIA SOCIAL MEDIA 

If you register for or log in using your Facebook account, we’ll collect the personal information from Facebook that we need to complete the registration or login. However, we will only collect the personal information that you’ve permitted Facebook to share with us. That information may include your name and email address and, depending on your privacy settings, additional details about you. Please review the privacy controls you’ve set on your Facebook account, so that you have control over how much information you want shared with us.

VIA COOKIES ON OUR WEBSITES

We may collect, log and process data about your use of our websites. We do this in order to allow our websites to function properly, collect anonymous website traffic data, and to provide you with the best possible user experience (e.g. to keep you logged in if you request this). We use cookies on our websites for the following purposes:

• Analytical purposes
• Usage preferences
• Session management
• Function purposes

To make full use of our websites, your computer or mobile device will need to accept cookies, as our Websites will not function properly without them. If you choose not to accept cookies, you’ll still be able to view our websites, but some interactions may not work normally and will impair the Websites’ functionality. For more information about cookies, please refer to Appendix B.

We use Google Analytics, Google Signals, and other Google web services to monitor and optimise the performance of our digital assets. These services allow us to monitor which areas of our Digital Assets are most frequently visited and to continually improve the online experience we provide to our audiences.

In some cases, we may combine data from one or more of these analytics tools to gain a more thorough understanding of the behaviour and preferences of visitors to our website or apps. The information collected is used to administer and improve the performance of digital assets and to better understand what is of interest to you.

VIA THIRD PARTIES

In limited circumstances we may collect information about you from third parties, for example:
If you are a Trauma Queen, a Trauma King or a donorwe might collect information from third parties in these ways:

If you donate to CTC via our Website using either PayPal or MasterPass, depending on where you live, these organisations may provide us with your address.
They will only do this if you have not entered your address onto the donation form yourself, and if you have set up your address as part of your PayPal or MasterPass account.
Alternatively, if you donate to us via a Facebook Fundraiser, your name and the amount of your donation will be shared with us. When you make your donation, you'll also have the option to share your email address with us to receive newsletters and updates. For more information on donating via a Facebook Fundraiser, visit the Facebook website.
If you chat to us via the live chat function on our website, some of your personal information will be shared with us, including your name, email address and location (if you allow this to be shared via your web browser).
A job applicant
We may obtain your personal information if you apply for a job at CTC via a third party such as a recruitment agency or LinkedIn.

USING DATA AVAILABLE FROM PUBLIC SOURCES

As a fundraising organisation, we undertake in-house research and may from time to time engage specialist agencies to gather information about you from publicly available sources, for example, Companies House, the Electoral Register, company websites, ‘rich lists’, social networks such as LinkedIn, political and property registers, and news archives.
We also may carry out wealth screening to fast track the research using our trusted third-party partners. You will always have the right to opt out of this processing. We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause with whom we are not already in touch. This may include people connected to key supporters and lead volunteers. We also use publicly available sources to carry out due diligence activities, in line with guidance issued by the Chartered institute of Fundraising on major donor fundraising and gift acceptance.
This research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you. If you would prefer us not to use your data in this way please email us at privacy@ComplexTraumaCanada.com.

HOW MUCH INFORMATION DO YOU NEED TO PROVIDE?

How much information you provide to CTC is up to you; however, if you want to use our Websites, donate to us, receive information from us, participate in our campaigns, programs and events etc., we require certain information from you.
Most of the time you’ll be able to interact with us anonymously if you choose; in specific circumstances where that’s not possible, we’ll let you know.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We make every effort to tell you what we’ll do with the personal information you provide us, at the time you provide it.

For general information, here’s a list of common ways we may use your personal information:
If you are a Trauma Queen, Trauma King or donorwe might use your personal information in these ways:

• To provide you with products or merchandise you’ve requested
• To provide you with information or other communications about CTC or any of Complex Trauma Canada’s initiatives
• To market CTC and/or our campaigns and events
• To involve you in promotions, future campaigns and other initiatives undertaken by Complex Trauma Canada
• To include your image, name and details on our Websites if you register as a Trauma Queen, Trauma King, as part of a Trauma team, or if you register to Host a CTC event (these details will appear in public search results unless you change the default setting)
• Target ads to you via third party platforms, such as Facebook
• To include your name, comments and amount of donation on our Websites if you make a donation to a Trauma Queen, Trauma King, Trauma Team or Trauma Drama Event (unless you choose a private or anonymous donation)
• To enter you into automatic prize draws if you’re a registered Trauma Queen, Trauma King, and meet the relevant prize draw criteria
• To provide you with details of how we spend the funds raised by Complex Trauma Canada
• To analyse statistics in relation to the CTC community
• To involve you in health initiatives
• To acknowledge or reward you for your participation in CTC or any of Complex Trauma Canada’s other initiatives.
An employee, contractor, or volunteer
If you’re employed or volunteer with us we’ll use the personal information you’ve provided us to manage your employment and our responsibilities to you.
A job applicant
If you apply for a job with us, we’ll use the personal information you’ve provided us for the purposes of assessing your job application.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

CTC takes reasonable steps to ensure the security of all information we collect, including that the information is protected from misuse and loss, and from unauthorised access, modification or disclosure. We make use of:
• Password protection;
• Secure cloud-based servers; and
• Multi-factor authentication.
Some of these services are hosted by third parties located in Canada and the United States. However, as no data transmission over the internet or information stored on servers accessible through the internet can be guaranteed to be fully protected from being accessed, tampered with or used in an unauthorised manner by third parties.