Disclosure Policy

Disclosure Policy

Computers for Success Canada – Ordinateurs pour l’excellence  Canada (“CFSC-OPEC”) is committed to protecting your privacy. The following privacy policy applies to the collection, use, and disclosure (by disclosure we mean who this information could be shared with) by CFSC-OPEC of information regarding identifiable individuals (your Personal Information) from the CFSC-OPEC and “Connecting-Families” –  websites.

For the purposes of this Policy, the term “Personal Information” refers to any information about an identifiable individual or any information that allows an individual to be identified. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

I. Collection of your Personal Information

CFSC-OPEC will  collect the following identifiable data and Personal Information :

1. Contact information: your name, home address, email address, and your phone number (including mobile phone number where provided).
2. Demographic information: demographic information relating to you and other inhabitants of your household, if any (by “demographic”, we mean information such as the age and gender of people who live with you).
3. Supplier data: contact details and other information about you or your company or organization by which you provide services to CFSC-OPEC;
4. Social media: any posts, Likes, tweets and other interactions with our social media presence;
5. Technical information: [when you access this website and our technology services] technical information being Internet Protocol address, browser type and version (e.g. Internet Explorer, Firefox, Safari etc.), language preference, access times, time zone setting, browser plug-in types and versions, operating system you are using (e.g. Vista, Windows XP, MacOS, etc.), device type, hardware model, MAC address, unique identifiers and mobile network information; as well as any other standard information your web browser sends to every website you visit;
6. Online data: [when you access this website and our technology services] information about your visit, including URL clickstream to, through and from our website (including date and time), information about your network as such as information about devices, nodes, configurations, connection speeds and network application performance; pages viewed or searched for, page response times, download errors, length of visits and interaction information (such as scrolling, clicks, mouse-overs) and whether you click on particular links or open our emails.

Our collection of the information set-out in sections “Technical information” and “Online data” hereabove is done anonymously. We cannot connect (a) your Personal Information with (c) what CFSC-OPEC websites you click on, view or consult.

CFSC-OPEC does not collect Personal Information about your online activities across third party websites or online services.

CFSC-OPEC does not knowingly collect information from children or other persons who are under 16 years old. If you are a minor under 16 years old, please do not provide us with any Personal Information without the express consent of a parent or guardian. If you are a parent or guardian and you know that your children have provided us with Personal Information, please contact us. If we learn that we have collected personal information from minor children without verification of parental consent, we will take steps to remove that information from our servers.

II. Use of your Personal Information

CFSC-OPEC uses your Personal Information to identify you so that we can determine if you qualify for programs and initiatives we help deliver. We will not share this Personal Information with any third parties other than those listed below. CFSC-OPEC will only process your Personal Information after you have given us your prior consent or if this is necessary to comply with legal or regulatory obligations.

CFSC-OPEC uses your personal information to contact you regarding your participation in the “Connecting-Families” initiative. We may also use this information to collect anonymous demographic information to help CFSC-OPEC determine whether the programs and initiatives we help deliver are working well according to their design and social objectives. Applicable legal bases under the GDPR: legitimate interests, consent, contract performance and to carry out actions for the conclusion of the contract.

Your email will not be added to a contact or mailing list unless you agree and choose to sign-up – your positive consent would be required.

Our reasons for using special category data

“Special category data”, as said term is used in the European Union and certain other jurisdictions, refers to sensitive data such as your social demographic, racial or ethnic origin, religious beliefs or health data. We will process this data where:

• we have your explicit consent for the particular processing;
• this is necessary for substantial public interest;
• as permitted by applicable law.

III. Disclosure or Transfer of your Personal Information

CFSC-OPEC shares your Personal Information with Partner Organizations* and Service Providers** to the extent that it is required for them to deliver programs and services. We require these organizations to also maintain the confidentiality of your information and respect of your privacy, just as we do. 

* “Partner Organizations” refers to:

• Computers for Schools program affiliates;
• An independent academic research committee;
• Innovation, Science and Economic Development Canada.

** “Service Providers” refers to:

• Internet Service Providers and/or software providers;
• Shipping partners;
• silverorange Inc./Web developer
• Amazon Web Services

CFSC-OPEC will not share, disclose, or otherwise provide the Personal Information supplied by you, the website user, to Partner Organizations and Service Providers for any reason other those stated above.

IV. Security and Storage of your Personal Information

CFSC-OPEC is committed to protecting the security of your Personal Information and to having technical safeguards to protect your confidentiality. All Personal Information is stored in a highly secure data center in Canada. This center uses strong encryption, while in transit and at rest, and employs encryption in transit with Transport Layer Security (TLS) across all services.

CFSC-OPEC will protect Personal Information through appropriate security measures against risks such as loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction.

CFSC-OPEC will protect Personal Information disclosed to Partner Organizations and Service Partners. All parties involved agree to sign a non-disclosure agreement (NDA). Parties agree that all Personal Information (as defined in the NDA) they have access to, will be treated as confidential and only used for the primary purpose intended – delivering programs and initiatives relative to those outlined on our websites.

To the extent CFSC-OPEC employs third-party Service Providers to store, handle or process Personal Information on its behalf (e.g., data storage and processing, cloud computing, application hosting or office services), CFSC-OPEC uses contractual and other means to provide a comparable level of protection while the information is being stored, handled or processed by those Service Providers.

CFSC-OPEC’s Service Providers are committed by contractual agreements to protect your Personal Information from unauthorized access, collection, use or disclosure. CFSC-OPEC’s Service Providers are not permitted to disclose your information to others.

Some of CFSC-OPEC’s Service Providers may store your Personal Information in countries other than Canada. If it is required by law or court order, your Personal Information could be made accessible to legal authorities, including law enforcement and national security authorities of those countries.

If you have questions about the collection, use, disclosure or storage of your Personal Information by CFSC-OPEC’s Service Providers outside of Canada, or if you would like to obtain more information about our policies and practices with respect to Service Providers outside of Canada, please contact one of our Privacy Officers listed below.

V. Use of Cookies and Web Beacons

Cookies are small text files stored on your device (such as your computer or smartphone) that are uniquely assigned to you which collect standard Internet log information and visitor behavior information. For example, cookies can be used to remember information about you, your preferences (such as your language of choice) or your device information, when you return to a specific website. Similar technologies falling under the generic term “cookies” also include local objects (sometimes called flash cookies), web beacons, pixels, browser fingerprinting technologies or any technology that stores or accesses information on the user’s device. This information does not usually allow us to identify you, but it can offer you a better user experience when visiting websites (including ours).

Although most web browsers automatically accept cookies, you have the ability to accept or decline them by modifying your browser settings.

CFSC-OPEC uses cookies to measure how users interact with our websites and to gather statistics that distinguish unique users. CFSC-OPEC also monitors website statistics for the number and time of previous visits, the start and end of a user session and to remember the traffic source information. Traffic source information tells us how people access our website, for instance through a search engine or a link they clicked on. As for many other websites, CFSC-OPEC uses this data to remember your settings and to help improve your experience on our website.

CFSC-OPEC also uses web beacons to provide statistical information about visitors to our websites. This sends small amounts of data to an analytics server with information about your IP Address, browser URL, and other browsing data.

This website uses Google Analytics, which uses cookies and transmits data to Google’s servers. Google Analytics does not identify individual users or associate your IP address to any other data held by Google. We use Google Analytics’ reports to help us understand user behaviours on our website in order to help us serve a better web experience.

CFSC-OPEC uses Google Adwords to advertise. Google uses cookies to deliver ads on websites across the internet based on your browsing history. You can opt out of third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

VI. What cookies do we use?

Strictly necessary cookies

These are cookies that are required for the operation of our websites and use of its features, and therefore cannot be switched off in our systems. The information collected relates to the operation of our website (e.g. website scripting language and security tokens) and enables us to provide you with the service you have requested. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personal data. These cookies are: used solely for the purpose of carrying out or facilitating the transmission of a communication over an electronic communications network; and strictly necessary to provide you with the information society service you have expressly requested (i.e. if these cookies are disabled, We will not be able to provide you with the service you have expressly requested). The use of these cookies for the purposes described above is based on our legitimate interest to ensure the proper technical functioning of, access to and use of our websites or apps and to provide you with the service(s) you have expressly requested.

Functional cookies

These cookies are optional and are used to remember the choices you have made, for example the country you visit our website from, your language and any changes you have made to text size and other parts of the web pages that you can customise to improve your user experience and to make your visits more tailored and enjoyable. If you do not allow these cookies then some or all of these services may not function properly.

Analytical / performance cookies

These cookies are optional and are used to collect information on how visitors use our website, for example which pages they visit most often, whether they receive any error messages and how they arrived at our website. Information collected by these cookies is used only to improve the use of our website by our visitors. These cookies are sometimes placed by third party providers of web traffic and analysis services. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when people have visited our site and will not be able to monitor its performance.

Targeting cookies

These cookies record your visit to our website, the pages you have visited and the links you have followed. We may use this information to make our website and the information (including marketing information) displayed on it more relevant to your interests and to measure the effectiveness of and marketing or information initiatives. We may also share this information with third parties for this purpose. They remember the other websites you visit and this information is shared with third party organizations as described below. These are also optional cookies. If you do not allow these cookies, you will experience less targeted advertising.

VI. Statistics and sharing, Links

CFSC-OPEC’s websites, newsletters, email updates and other communications, may from time to time contain links to and from other websites not owned or operated by CFSC-OPEC. CFSC-OPEC does not claim responsibility for the privacy practices of these websites. When leaving a CFSC-OPEC website, we encourage users to review the separate privacy policies of every website they visit.

The privacy policy reflected on this website applies to Personal Information collected by CFSC-OPEC websites only.

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites. The personal data that you provide through these websites is not subject to this Privacy Policy and the treatment of your personal data by such websites is not CFSC-OPEC’s responsibility.

VII. Changes to Policy

Privacy laws are rapidly evolving and, as a result, this Policy may be changed by CFSC-OPEC from time to time in CFSC-OPEC’s full discretion without any prior notice or liability to you or any other person. The collection, use and disclosure of your personal information by CFSC-OPEC will be governed by the version of this Policy in effect at that time.

CFSC-OPEC encourages users to review any updates or changes since their previous visit.

VIII. Consent

At CFSC-OPEC, it is important that we only collect, use or disclose your Personal Information where we have your positive consent to do so.

CFSC-OPEC will ensure that users of our websites understand how their Personal Information is being used. CFSC-OPEC will typically ask for a user’s consent when collecting Personal Information.

CFSC-OPEC may disclose a user’s Personal Information where legally required to do so.

IX. What are your data protection rights?

CFSC-OPEC would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access– You are entitled to ask CFSC-OPEC if we are processing your data and, if so, you can request access to your Personal Information. This enables you to receive a copy of the data we hold regarding your Personal Information.
• The right to rectification– You are entitled to request that any incomplete or inaccurate Personal Information about you held by CFSC-OPEC is corrected. You are equally entitled to request CFSC-OPEC to complete the Personal Information about you held by CFSC-OPEC you believe is incomplete.
• The right to erasure– You are entitled to request that CFSC-OPEC delete or remove any Personal Information about you held by CFSC-OPEC, under certain conditions. There are also certain exceptions where CFSC-OPEC may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
• The right to restrict processing– You are entitled to request that CFSC-OPEC restrict or suspend the processing of your Personal Information, under certain conditions, notably if you want CFSC-OPEC to establish its accuracy or CFSC-OPEC’s reason for processing said Personal Information.
• The right to object to processing– You are entitled to object to CFSC-OPEC’s processing of your Personal Information, under certain conditions, where we are processing your personal data based on legitimate interests of CFSC-OPEC (or those of a third party).
• The right to data portability– You are entitled to request that CFSC-OPEC transfer the data that it has collected to another organization or party, or directly to you, under certain conditions.

If you want to exercise any of these rights, please contact one of the  Data Privacy contacts set out in this Policy below, in writing at the relevant email or mailing address.

You also have a right to lodge a complaint with a data protection supervisory authority, in particular in the Province of Canada (provincial and/or federal level), country, or Member State in the European Union, where you are habitually resident, where CFSC-OPEC is based or where an alleged infringement of any relevant Data Protection law has taken place.

X. Contact our Privacy Officers

For any questions, concerns or comments about CFSC-OPEC’s Privacy Policy or If you wish to access information, modification or deletion regarding your Personal Information Personal Information, to exercise any applicable rights, to make a complaint, or to obtain information about our policies and practices with respect to any service providers outside Canada, our Privacy Officer can be reached by email at info@cfsc-opec.org or by mail using the following contact information:

Computers for Success – Canada Incorporated

Attn: Michel Langelier

Privacy Officer

405 Av. Ogilvy #101,

Montreal, Quebec H3N 1M3

Subject to certain exceptions prescribed by law, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of that information and, to the extent that you have proven such inaccuracy or incompleteness, have it amended as appropriate. Examples of such exceptions include information that contains references to other individuals, and information that cannot be disclosed for legal, security or commercial proprietary reasons.

You can help CFSC-OPEC maintain the accuracy of your information by notifying CFSC-OPEC of any changes to your Personal Information.

If you have any inquiry or complaint that relates to CFSC-OPEC’s policies or procedures relating to the handling of personal information, we invite you to communicate with our Privacy Officer.