We reserve the right to change this policy from time to time as industry practice, the law, and our procedures in this area may change from time to time. We will post the current version of this policy at: https://iad.inuitartfoundation.org/privacy-policy
WHAT IS PERSONAL INFORMATION?
If the policies and procedures outlined in this document do not address a specific situation, individuals are advised to contact the Foundation's Privacy Officer for guidance or clarification.
WHAT PERSONAL INFORMATION DO WE COLLECT?
When you visit our websites, we will not collect your personal information unless you choose to enroll in one of our programs or receive online products and services that require it. For transactions with the Foundation involving credit cards, we use up-to-date security protocols to ensure the integrity and confidentiality of information and systems.
When you make a contribution to any Foundation site, including on our artist database or copyright clearance pages, you are creating a permanent record of every piece of content added, removed, or altered by you. For public information, the database audit log will show when your contribution or deletion was made, as well as your username. We may use your public contributions, either aggregated with the public contributions of others or individually, to create new features or data-related products for you or to learn more about how the databases are used.
The Foundation collects and uses only the personal information that we need for providing services and operating our business. Generally, the Foundation collects the following personal information from individuals for the various purposes set out below:
- name, address, email address (home and work), phone number
- age, date of birth
- payment history
- financial information
- employment, income, salary
- credit card numbers
The Foundation collects, uses and discloses personal information for the following purposes:
NOTE: The IAF will not use your information for a new purpose without expressed consent.
- to process payment arrangements
- to manage the Foundation's business and operations, including customer relationships and matters
- to meet legal and regulatory requirements
- deliver, develop, enhance or improve products and services
- evaluate suitability of employment candidates
- verify access rights to our website
- contact individuals about appointments and meetings
- meet regulatory requirements
- conduct market research
- to enforce our legal relationship with you
- as is necessary in contemplation of a business transaction
We normally collect information directly from individuals and from third parties that utilize our services. We may collect your information from other persons with your consent or as authorized by law. Before or at the time of collecting personal information, we identify the purposes for which we are collecting the information. We do not provide this notification when personal information is volunteered for an obvious purpose. If we wish to use or disclose your information for a new purpose not included in this policy, we will notify you and seek your consent.
In addition, we also receive and send data from our servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our site, if any. We may use tracking technologies in a variety of ways, including the following: keeping count of return visits to our site; accumulating and reporting anonymous, aggregate (data collected in mass), statistical information on website usage; and determining which features users like best. We also incorporate geo targeting into our design to help service users in lower bandwidth areas to ensure access and efficiency.
The Foundation’s computer systems use hardware and software to anonymously monitor unauthorized attempts to upload or change information on our websites, disrupt service, or otherwise cause damage. As a general practice, we make no attempt to link this information with the identity of individuals visiting our sites. If an attempt to damage our site has been detected, we can take further actions.
Cookies used by the Foundation, do not give us access to anything on your hard drive and cannot do anything to your computer. Cookies used by the Foundation are encrypted for security purposes to make any information in the cookie unreadable to anyone except the government organization with which you are dealing. We use two types of cookies: session cookies (temporary) or persistent cookies (longer-term continuing use).
- Session cookies may be used to support on-line feedback/discussion, forms and registration and 'e-commerce/shopping cart' transactions - they are used only during your online session and expire when you close your browser. Without session cookies, moving around our web sites could be much slower
- Persistent cookies are different from session cookies because they are stored on your computer's hard drive for some length of time - they are usually used if you want us to remember information about your web preferences (e.g. large font) and passwords for automatic log-in purposes
Ordinarily we ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.
You may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our reasonable business or legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
COLLECTION OF PERSONAL INFORMATION
The purpose for collecting personal information is set out in this policy. Any necessary consents shall be obtained before personal information is collected, used or disclosed.
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask individuals to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button).
In cases that do not involve sensitive personal information, we may rely on “opt-out” consent.
The amount and type of personal information collected by the Foundation shall be limited to what is necessary to fulfill the identified purpose. Personal information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law.
Personal information collected by the Foundation or on behalf of the Foundation will be sent to the Foundation’s head office in Toronto and will be subject to the laws of Canada.
Please note that we use cloud-based services to store information. Where personal information is stored or processed outside of Canada, it is subject to the laws of that foreign jurisdiction, and may be accessible to that jurisdiction’s governments, courts or law enforcement or regulatory agencies.
Our hosting service provider is in the U.S. and is utilized for the purpose of data storage and accessibility.
OBTAINING ACCESS TO PERSONAL INFORMATION
Upon request received by the Foundation in writing, individuals shall be informed of the existence, use, and disclosure of their personal information records and shall be given access to that information. Requests to access personal information held by the Foundation should be directed to the Foundation's Privacy Officer.
Requests must be made in writing or by e-mail. Individuals may be required to verify their identity in order to access their personal information. Any such documentation provided shall be used for verification purposes only.
The Foundation responds to requests for access to personal information within thirty (30) days of receipt of the request, or as may be permitted in accordance with applicable privacy legislation.
A fee for reasonable costs incurred may be charged when responding to more complex requests. The individual will be informed of the applicable fee.
Requested information will be provided in a form that is generally understandable.
The Foundation will be as specific as possible when describing third parties to whom it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information, the Foundation will provide a list of organizations to which it is likely to have disclosed information.
Individuals are permitted either to view the original record, or to request a copy, subject to limitations as permitted or required by law. To preserve the integrity of the record and ensure that documents are not removed from the Foundation, individuals wishing to view an original record will do so at the Foundation's head office and under the supervision of designated the Foundation personnel.
LIMITATION TO ACCESS
The Foundation will only refuse access to information about you in those circumstances permitted or required by applicable privacy legislation.
In the event that the Foundation refuses to provide access to information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to or opinions of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. The Foundation will respond to your requests for access in accordance with applicable privacy legislation.
MAINTENANCE OF PERSONAL INFORMATION
Personal information shall be kept as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.
Individuals have the right to challenge the accuracy and completeness of the personal information that is maintained by the Foundation and have it amended as appropriate.
Individuals seeking a correction or amendment to their personal information should direct their requests in writing to the Foundation's Privacy Officer.
All formal requests to amend personal information must be accompanied by appropriate supporting documentation. The Foundation’s Privacy Officer will manage any exceptions. The amended information will be transmitted to third parties, as appropriate.
If the individual is not satisfied with the results of the request, the Foundation shall internally document the issue, and provide a response. The existence of the unresolved challenge will be transmitted to third parties, as appropriate.
SECURITY OF PERSONAL INFORMATION
Personal information will be retained only as long as necessary and will be disposed of in a manner that is appropriate to the sensitivity of the information. We render individual personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying individual personal information, including shredding paper records and permanently deleting electronic records.
Personal information will be protected by security safeguards, appropriate to the sensitivity of the personal information.
Where required by law we will notify the applicable provincial or federal Privacy Commissioner, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.
If you are not satisfied with the response from our Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the Federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.
QUESTIONS AND COMPLAINTS
If you have a question or concern about any collection, use or disclosure of personal information by the Foundation, or would like to request access to your own personal information, please contact:
215 Spadina Ave #400
Toronto, ON M5T 2C7