PRIVACY POLICY

Project Orbis International Inc. (""Orbis Canada"; “Orbis”) wants you to know how we use and protect the important information you provide to us through our websites, technology, applications, content, products, and services (our “Platforms”). This information summarizes our policy, procedures and practices.

Please read this Privacy Policy carefully prior to joining our mailing list, or accessing or using the Website.

  • We collect information as a way to further our vision of transforming lives through the prevention and treatment of blindness. The information you provide allows us to help you on a more personal level. We can better respond to your requests, understand your needs, and provide you the information and resources you need. We can also compare your information with the information of others we connect with to identify important trends.
  • Sharing personal information with Orbis is voluntary. Orbis may collect personally identifiable information that you voluntarily give us when choosing to participate in various activities related to the Orbis, such as your name and email address or creating an account on the Website.
  • Unless you tell us otherwise, when you provide your information we assume you are agreeing to allow us to use and disclose it as allowed by law and Orbis policies with and in furtherance of our mission.
  • We will comply with all Canadian and Ontario laws and the laws of countries in which Orbis has a programmatic and development presence.
  • When we ask for certain types of sensitive information, we will tell you how we intend to use and disclose that information.
  • We will require our data management vendors use reasonable and appropriate security practices to safeguard your information.
  • If you change your mind about allowing us to use your information or have questions about our privacy practices, please let us know.

1. INFORMATION WE COLLECT

We may collect the following kinds of information:

A. INFORMATION YOU PROVIDE

Orbis collects information from you when you provide it to us. This happens when you register for our website, use the Platforms, or communicate with us, such as through our website, email, over the telephone or in person. The information you provide us may include information that personally identifies you ("Personal Information" or "PII"), such as name, email address, phone number or your mailing address. We also may collect your credit card or bank information in order to process payments. You should also know that Orbis automatically stores information about your usage of our website or applications, which we may use for marketing purposes.


B. INFORMATION FROM COOKIES AND SIMILAR DEVICES

Orbis uses cookies, web beacons, embedded scripts and similar methods to collect information about how users use and interact with our services through our website and applications. Cookies can also be used to remember you and your preferences. "Cookies" are alphanumeric identifiers in the form of text files that are inserted and stored by your web browser on your hard drive. Most large websites or Internet service providers enable cookies in order to improve their user experience. Cookies are used to collect information about your use of a website or application during your current session and over time, your operating system, your Internet service provider, and your domain name and IP address. Cookies allow websites to remember users, either for a single visit or for repeated visits. Cookies allow websites to store settings, such as language, font size, and other viewing preferences for your computer or mobile device. This means that user preferences will not need to be re-configured upon each visit to the website. If a website does not use cookies, users are treated as new visitors each time they open a new page. For more information, see www.allaboutcookies.org. You can manage, remove or reject cookies, but be aware that such action could affect the availability and functionality of the Website or third-party website(s) and application(s). You may set your browser to block all cookies, including cookies associated with the Website, or indicate when a cookie is being set by us. You can clear all cookies stored on your device and most web browsers can be configured to block cookies. Some web browsers may let you enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. However, a “do not track” feature is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies. It is important to remember that the Application may not function properly if your cookies are disabled.


C. INFORMATION FROM MOBILE DEVICES

If you are interacting with our website or applications on a mobile device, your mobile carrier may automatically send us your device and hardware ID, device type, carrier, carrier user ID, the content of your request and basic usage statistics about your device. This information is stored automatically, but Orbis will not use it for any purpose. If you provide it to us or send us a message from your mobile device, we may also collect your phone number. Your device may also store information about your usage of our website and applications. Please consult your device documentation on how to manage local storage.


D. INFORMATION BASED ON STANDARD WEB PROTOCOLS

When you access our website through a browser, application or other client, like other web providers, our servers automatically record certain information. This data is recorded in server logs and may include information such as your web request, your interaction with the website, the website that you were visiting when you came to our website, your Internet Protocol (IP) address, your browser type and language, the date and time of your request, and your cookie data.


E. INFORMATION FROM SOCIAL MEDIA

Information from social networking sites (such as Facebook and Twitter). We collect information from social media activity, including likes, shares and tweets about our content on social networking sites.


2. HOW WE USE THE INFORMATION WE COLLECT

Information we collect is used to provide, maintain and improve the services offered by Orbis. We may combine information we collect from various sources to improve the efficacy of our service offerings. We may perform statistical, demographic and marketing analyses, including to determine how users interact with the Platforms, the level of interest in the Platforms, and to customize products and services for you. We may use information to contact you about the services, and send you information that you have requested.


A. FINANCIAL INFORMATION

Orbis will use financial information to facilitate a donation or other transaction. Orbis may collect credit or debit card information. Personal financial information in the form of a credit card number and expiration date are only collected if a user wishes to make a donation through Orbis online. This information is not stored or maintained by Orbis when entered online. All online transactions are protected and securely transmitted using algorithms such as TLS/SSL and the most current encryption protocols.


B. TRANSACTIONAL INFORMATION

Orbis may use transactional information for marketing and management purposes to provide or improve any products or services that Orbis may offer. In addition, Orbis may also share such transactional data on an aggregated basis (which will not identify any particular user) with third parties, such as vendors, advertisers, or business partners.


C. TECHNICAL INFORMATION

Orbis may use technical information, such as your IP address or browser type, to help diagnose problems with Orbis’s servers, analyze Platforms usage trends, track user movements on the Platforms, and to otherwise improve, manage and monitor the Platforms.


D. GEOLOCATION DATA

Orbis may use geolocation data to personalize your Platform experience on the Platforms, e.g., to show local contacts and information relevant to your location.


E. BUSINESS TRANSACTIONS

In the event that Orbis goes through a business transaction such as a bankruptcy event, merger, investment transaction, or acquisition by another entity involving the sale of all or a portion of its assets, the Personal Information collected by Orbis may be among the assets reviewed.


F. LEGAL ACTION

Orbis may disclose Personal Information when legally required to do so. Orbis may also disclose Personal Information to protect against misuse or unauthorized use of the Platforms or to limit legal liability or to protect Orbis’s interests or those of others.

3. HOW WE SHARE THE INFORMATION WE COLLECT

Orbis will not sell, rent or lease its customer lists to third parties unless we have your express consent, or unless we are required to do so by applicable law. However, we may share the information we collect from and about you within our organization and with certain third parties. For example, we may share your information with:

  • Credit card processing companies, to process your payments and donations;
  • Other organizations we work with to provide services, research, products or programs;
  • Other similar charities; and
  • Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.

In the event that Orbis is acquired by or merged with a third party entity, or sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information and content we have received and collected from the Orbis’s subscribers as part of such merger, acquisition, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

4. SECURITY

We recognize that security is important and take reasonable measures to protect your Personal Information from loss, misuse or unauthorized access, disclosure, alteration or destruction. We regularly review our physical and digital security, storage, and processing to ensure adherence to industry best practices.

If you believe that the Personal Information you have provided us has been compromised, or if you become aware of a potential security vulnerability in our Platforms, please contact us at privacycanada@orbis.org.

5. THIRD-PARTY WEBSITES

There may be places on our website where you may click on a link to access other websites that do not operate under this Privacy Policy. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. Before visiting and providing any information to any third-party websites, we encourage you to review the privacy statements of websites you choose to link to from Orbis so that you can understand how those websites collect, use and share your information.

6. CHILDREN'S ONLINE PRIVACY PROTECTION ACT

This website is intended for use by persons over the age of 18. Orbis does not seek to collect information about children under the age of 18. No information should be submitted to or posted on this website by users under 18 years of age. If you believe that we might have any information from a child under age 18, please contact us at [email protected].

8. CHANGES TO THIS PRIVACY POLICY

We will occasionally update this Privacy Policy. When we post changes to this Privacy Policy, we will revise the 'last updated' date at the end of this Privacy Policy. We recommend that you check our website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies

GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of Canada and the province of Ontario. If you are located outside of Canada when you use the Platforms, any information you submit thereto will be transferred to Canada. Accordingly, by using the Platforms and submitting Personal Information thereto, you authorize the transfer of your Personal Information to Canada. If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision or part will be deemed suspended and a valid, enforceable provision that most closely matches the intent of the original provision or part and the remainder of this Privacy Policy shall continue in full force and effect.

APPENDIX: DISCLOSURES ON PERSONAL DATA PROCESSING

Pursuant to Article 13 and 14 EU General Data Protection Regulation (GDPR)

The EU’s GDPR requires that personal data from the EU/EEA must be especially protected. In addition, all EU-based individuals, irrespective of their nationality (“data subjects”) have certain individual rights under the GDPR, such as:

1. The right to be informed about the collection and use of their personal data.

2. The right of access to find out that is stored about them.

3. The right to rectification of their personal data if it is inaccurate or incomplete.

4. The right to erasure to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing.

5. The right to restrict processing to ‘block’ or suppress processing of personal data.

6. The right to data portability allowing individuals to obtain and reuse their personal data for their own purposes across different services.

7. The right to object to the processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing and/or for purposes of scientific/historical research and statistics.

8. Various rights in relation to automated decision making (making a decision solely by automated means without any human involvement) and profiling (automated processing of personal data to evaluate certain things about an individual).

Orbis will abide by the GDPR and provide at least the same level of data protection for personal data received from the EU/EEA and processed as the privacy protections set forth in Orbis’s Privacy Policy. Orbis has implemented appropriate technical and organizational measures that include internal data protection policies, relevant documentation on processing activities and where appropriate appointing a data protection officer. In order to enable data subjects to exert their rights under the GDPR, Orbis makes the following disclosures under Art. 13 GDPR for personal data directly received from a data subject and under Art. 14 GDPR for personal data received from a third party:

(a) The identity and the contact details of the controller Orbis Canada, 340 College St. Suite 375, Toronto, ON M5T 3A9 +1.416.413.7925
(b) Contact details of the data protection officer Data Protection Officer email: [email protected]
(c) Purposes of the processing for which the personal data are intended Responding to your requests, to market Orbis’s products and services, obtaining donations, recruiting volunteers, for developing new products, to notify you of changes to service, fraud prevention.
(d) The recipients or categories of recipients of the personal data Employees and volunteers of Orbis who respond to the inquires as well as external service providers, such as credit card companies for processing your donations, who need to know the data for purposes of providing services
(e) Storage Limitations The personal data will be stored by Orbis for a period necessary for the purposes listed under (c) above, which is usually 10 years unless applicable law (bookkeeping, tax etc.) allows for a longer storage.
(f) Access/Rectification/ Erasure Requests The data subject has the right at any time to request access to and rectification or erasure of personal data held by Orbis or restriction of processing concerning the individual or to object to processing as well as the right to data portability. In these cases, please send an email request to Orbis’s Data Protection Officer listed under (b).
(g) Withdrawal of Consent The data subject has right to withdraw his/her consent at any time, without affecting the lawfulness of processing based on consent before the withdrawal, by sending an email to the Data Protection Officer listed under (b).
(h) Complaints with the Supervisory Authorities The data subject has the right to lodge a complaint with his/her data protection authority against the data processing.
(i) Legal Basis for the processing The data subject is obliged to provide his/her personal data to Orbis (such as name and contact information) so that Orbis can process the payment or respond to the inquiry.
(j) No automated decision making or profiling Orbis will not use the personal data of the data subject for automated decision-making, including profiling.
(k) Further processing In the event Orbis intends to further process the personal data for a purpose other than that for which the personal data was collected, Orbis will provide the data subject, prior to that further processing, with information on that other purpose and any further relevant information, insofar as the data subject does not already possess such information.

Last updated: 29 April 2020