PRIVACY POLICY

A.    INTRODUCTION 

Soka Gakkai International Association of Canada (“SGI Canada”) is a Canadian registered charity that advances the teachings of Nichiren Buddhism and its associated religious tenets, doctrines, observances and culture.  SGI Canada is associated with the Soka Gakkai and Soka Gakkai International in Japan (collectively referred to as “SGI”), religious organizations that advance Nichiren Buddhism. 

Our Commitment 

SGI Canada takes your privacy seriously and is committed to protecting your personal information.  For these reasons, SGI Canada’s privacy policy (the “Privacy Policy”) incorporates the highest standards as set out in federal and provincial legislation across Canada.  We are accountable and transparent in how we treat your Personal Information. SGI Canada does not sell, rent or trade its mailing lists or other Personal Information. 

What is Personal Information?  

“Personal Information” means information about an identifiable individual, including any information about you or that can be used to identify you. 

Scope of this Privacy Policy 

This Privacy Policy applies to any Personal Information provided to or collected by SGI Canada through our website or online portal (collectively referred to as our “Websites”), by email, facsimile, postal mail, hand delivered, verbally or any other means. 

Purpose of this Privacy Policy 

The purpose of this Privacy Policy is to give you information about what Personal Information SGI Canada collects from you, why we collect it and how we use it, as well as what happens if you choose not to disclose certain Personal Information to us.  This Privacy Policy is based on the principles outlined in the Canadian Standards Association's Model Code for the Protection of Personal Information, set out in Schedule 1 of Canada’s Personal Information Protection and Electronic Documents Act.   These principles are: 

1.       Accountability: SGI Canada is responsible for Personal Information under its control and will designate an individual to be accountable for its compliance with these principles.	6.    Accuracy: We will take reasonable steps to keep your Personal Information as accurate, complete and up-to-date as is necessary for the purpose for which it is used.
2.       Identifying Purposes: SGI Canada will identify the purposes for which Personal Information is collected at or before the time the information is collected.	7.  Safeguards: We will take reasonable steps to keep your Personal Information protected by security safeguards appropriate to the sensitivity of the information.
3.       Consent: The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate.	8.  Openness: SGI Canada will make easily available to individuals’ specific information about its policies and practices relating to the management of Personal Information.
4.       Limiting Collection: The collection of Personal Information will be limited to that which is necessary for the purposes identified by SGI Canada.  Information will be collected by fair and lawful means.	9.  Individual Access: Upon request, an individual will be informed of the existence, use, and disclosure of his or her Personal Information, and will be given access to that information.  An individual will be able to challenge the accuracy and completeness of the information and have it corrected as appropriate.
5.       Limiting Use, Disclosure and Retention: Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law.  Personal Information will be retained only as long as necessary for the fulfillment of those purposes.	10.  Challenging Compliance: An individual will be able to address a challenge about SGI Canada’s compliance with these principles to the designated individual(s) accountable for SGI Canada’s privacy compliance.

 

YOUR USE OF THE WEBSITES SIGNIFIES YOUR AGREEMENT WITH THE TERMS OF THIS PRIVACY POLICY.  IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE WEBSITES OR SUBMIT ANY PERSONAL INFORMATION TO US.  

Please read this document carefully.  

B.    HOW SGI CANADA COLLECTS PERSONAL INFORMATION 

"Personal Information" means information about an identifiable individual. For the purposes of this Privacy Policy, Personal Information means any information provided to or collected by SGI Canada about you or that can be used to identify you, regardless of how the information is collected, whether digitally, by email, facsimile, hard copy, verbally or any other means. 

SGI Canada collects Personal Information in different ways, including: 

• Direct interactions – you may voluntarily provide us with Personal Information by filling out forms, entering personal information into data fields on our Websites, making a donation to SGI Canada, registering to attend a conference, meeting or seminar, participating in one of our initiatives or exhibitions, subscribing for one of our publications, requesting information to be sent to you, purchasing our merchandise or when communicating with us face to face, over the telephone, by mail, by email, by text, through social media or through other means. To protect your privacy, you should not provide SGI Canada with any information that is not specifically requested. 

• Automated interactions – when you use our Websites we may automatically collect technical data about your equipment and browsing history using cookies and similar technologies (See D below for more information). 

• Third party interactions – we may collect Personal Information when you interact with our content on third-party sites or platforms, such as Facebook, Instagram or You Tube. This may include data such as comments or feedback, “likes” or shares, profile data or the fact that you viewed or interacted with our content. 

C.    WHAT PERSONAL INFORMATION IS COLLECTED AND RETAINED BY SGI CANADA

The Personal Information we may collect and retain could include:

• Personal identifiers such as your name and gender. 

• Year of birth 

• Contact information such as your mailing address, telephone number and email address. 

• Donor information such as your donation history. 

• Credit card and bank account information, when you make donations to SGI Canada or purchase our merchandise. We collect this information via secure payment processing services as well as through mail, email, fax and telephone. 

• Images, including photographs and videos. 

• Employment history for employees and appointed national leaders and directors, and background checks for employees and volunteers involved with children’s programs, including results of police records checks. 

• Employee records for employees of SGI Canada. 

• SGI Canada Website account information such as your log-in, user name, password information and other security information. 

• Your SGI Canada Website profiles including all photos, posts, videos and other content. 

• Information about your device such as your IP address, location or provider and your usage information and browsing history (See D below for more information). 

• Information about your interactions with SGI Canada content on third-party sites or platforms, such as Facebook and Instagram. 

• Communications such as letters, emails and digital communications that we send to you or that you send to us. 

• Your child's name and age when participating in programs that include children, as required by our Child Protection Policy. 

• Personal Information we may receive from you but that we did not request (such as Personal Information you voluntarily put into an email to us or in a comments box on our Websites). 

D.    IDENTIFYING THE PURPOSES FOR WHICH PERSONAL INFORMATION IS  COLLECTED

SGI Canada identifies the purposes for which Personal Information is collected at or before the time the information is collected.  We use the Personal Information we collect to manage our operations and for various purposes associated with the programs and services we provide.  We collect, use, and disclose Personal Information only for purposes that a reasonable person would consider appropriate in the circumstances.  

The main purposes for which we generally use Personal Information are:

• To manage, oversee and administer our operations, programs, services and activities including, without limitation, coordinating meetings. 

• To establish and maintain records of Personal Information as required to manage, oversee and administer our operations, programs, services and activities, including our SGI Canada centres, district and group activities such as monthly discussion and study meetings, divisional activities for men, women, youth and children, education programs, peace and community activities, and our publications and podcasts. 

• To organize, promote and provide study programs, conferences, workshops and other events that advance the teachings of Nichiren Buddhism. 

• To raise awareness of our programs and services. 

• To monitor the quality of our programs and services. 

• To allow individuals to make donations to SGI Canada, to subscribe to our publications, or to purchase goods or services from SGI Canada. 

• To carry out fundraising activities to meet the needs of SGI Canada. 

• To provide donors and supporters with stewardship and recognition information. 

• To provide donors and potential supporters with information about SGI Canada initiatives. 

• To provide, administer and protect our Websites, including troubleshooting, data analysis, maintenance and network security. 

• To deliver relevant Website content and to provide associated functionality such as technical support and password reminders. 

• To establish, manage or terminate our relationships with our employees, volunteers, consultants and contractors. 

• To perform or carry out the terms of any contract between us. 

• To respond to your inquiries. 

• To send you publications or informational or promotional communications (in compliance with Canada’s Anti-Spam Legislation). 

• To disclose or share your Personal Information when required to comply with legal or regulatory requirements. 

• To prevent and detect fraud and other crimes such as terrorism financing or money laundering. 

• To protect our rights, property or safety or that of our practitioners, leaders, employees, volunteers, contractors, consultants, SGI or any other person. 

• For other purposes that we have told you about and for which you have given us your consent. 

• To fulfill other legitimate purposes permitted or required by law. 

SGI Canada does not collect more Personal Information than we need in order to achieve these purposes.  

E.    CONSENT FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION 

We only collect, use and disclose Personal Information with your knowledge and consent. Your consent may be expressed orally, electronically, or may be implied. We are committed to obtaining meaningful consent and use clear explanations and plain language to make sure that our consent processes are understandable and user friendly. 

You have the right at any time to withdraw or cancel your consent to the collection, use or disclosure of your Personal Information by contacting SGI Canada’s Privacy Officer, at privacy@sgicanada.org or at our mailing address: SGI Canada, 2050 Dufferin St., Toronto, ON M6E 3R6.  Withdrawals of consent only take effect from the date of cancellation.  They cannot be retroactive.  We will let you know if your withdrawal could have any consequences, such as SGI Canada being unable to provide you with goods or services.  

F.    LIMITING COLLECTION OF PERSONAL INFORMATION 

SGI Canada will only collect personal information for the purposes identified in this Privacy Policy.  If we want to collect information for a different purpose, we will tell you what that purpose is in writing and obtain your consent.  We collect Personal Information by fair and lawful means. 

We will not collect, use or disclose more Personal Information than is reasonably necessary to meet the identified purposes. We will limit our collection of Personal Information to that which is necessary for the purposes identified by SGI Canada. 

G.    LIMITING USE, DISCLOSURE, AND RETENTION OF PERSONAL INFORMATION 

SGI Canada will only use or disclose Personal Information for the purposes for which it was collected, unless we have your consent to use it for a different purpose or if we are required by law. If we want to use or disclose your Personal Information for a new purpose, we will advise you of this purpose in writing and obtain your consent. 

We keep Personal Information only as long as necessary to achieve the purposes for which it was collected although we may retain certain Personal Information indefinitely if we are required to do so by Canada Revenue Agency or by our insurers.  If you have made a request to access Personal Information, we will keep that Personal Information for as long as is necessary to allow you to fully seek any remedies (exhaust any recourse) that you may have under federal and provincial legislation across Canada. 

We do not disclose or share Personal Information more widely than is necessary to achieve the purposes for which it was collected. 

We may share Personal Information with the parties set out below for the following purposes: 

• Authorized employees and volunteers who have a legitimate purpose and reason for accessing it. 

• External third parties, including:

• Trusted service providers, such as those who provide us with credit card and payment processing, e-commerce, IT and system administration services. 

• Professional advisors, such as lawyers, auditors, bankers and insurers who provide us with legal, accounting, banking and insurance services. 

• Disclosure as may be required or authorized by law including, without limitation, to government, regulatory authorities, law enforcement, dispute resolution bodies, courts and similar entities to comply with any legal or regulatory obligation, to detect and prevent crimes or to assert or defend legal rights and interests. 

• Soka Gakkai and Soka Gakkai International in Japan, for organizational purposes related to the advancement of Nichiren Buddhism. 

• Any persons or entities where we have a legitimate business reason for doing so, such as to manage risk, to process payments, to enable another organization to provide you with services, or to perform or carry out the terms of any contract between us. 

• To anyone we reasonably believe is your authorized representative. 

• To other third parties if we have told you about them and you have given us your consent. 

We require all third parties to respect the security of your Personal Information and to treat it in accordance with all applicable legal requirements.  We require all third party service providers to enter into contractual agreements with us that prevent them from using your Personal Information for their own purposes and require them to use your Personal Information only for specific purposes in accordance with our instructions.    

We keep Personal Information only as long as necessary to achieve those purposes although we may retain certain Personal Information indefinitely if we are required to do so by Canada Revenue Agency or by our insurers.  

If you have made a request to access Personal Information, we will keep that Personal Information for as long as is necessary to allow you to fully seek any remedies (exhaust any recourse) that you may have under federal and provincial legislation across Canada. 

SGI Canada does not sell, rent or trade mailing lists or other Personal Information. 

H.    ENSURING ACCURACY OF PERSONAL INFORMATION 

SGI Canada has adequate processes and safeguards in place to keep Personal Information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.  We will not routinely update Personal Information, unless such a process is necessary to fulfil the purposes for which the Personal Information was collected.  To change or modify any Personal Information previously provided to SGI Canada, contact the Privacy Officer at privacy@sgicanada.org. 

I.    PROTECTION OF PERSONAL INFORMATION 

We will take reasonable steps to keep Personal Information in both paper and electronic format protected against loss, theft, snooping, hacking or people collecting, disclosing, copying, using or changing it without authorization.  We use security safeguards appropriate to the sensitivity of the information. Our methods of protection include: 

• Physical measures - such as areas of restricted access and locked filing cabinets. 

• Organizational measures - such as security policies and procedures, employee and volunteer training on privacy issues, security clearances and limiting access on a “need-to-know” basis. 

• Technological measures - such as passwords, encryption, audits as well as strong data security software and systems to protect Personal Information in SGI Canada’s custody from hackers and malicious intruders. Our software is routinely updated to maximize protection of Personal Information. 

SGI Canada makes all employees and volunteers as well as third party providers aware of the importance of maintaining the privacy and security of Personal Information. All SGI Canada employees must sign a confidentiality agreement.   We require all third parties to enter into contractual agreements with us that require them to respect the security of your Personal Information and to treat it in accordance with all applicable legal requirements. 

We securely destroy Personal information so that reconstruction is not reasonably possible.  This prevents unauthorized parties from gaining access to the Personal Information. 

While we are committed to protecting your Personal Information, our security practices and technology measures do not guarantee absolute security of Personal Information, and we cannot ensure or warrant the security of any information you provide to us.  You can reduce risk to your own Personal Information by using strong passwords, keeping your passwords confidential and following other Personal Information security best practices.

J.    OPENESS, ACCOUNTABILITY AND CHALLENGING COMPLIANCE 

SGI Canada is responsible for Personal Information under our control. We have appointed a Privacy Officer to be accountable for our compliance with these principles and to oversee questions relating to privacy and this Privacy Policy.  We also make this Privacy Policy and other privacy policies and practices easily available by posting them on this Website. 

If you have any questions about this Privacy Policy, including how to exercise your legal rights, if you would like specific information about how we manage Personal Information or if you have any complaints about our privacy practices or procedures, please contact the Privacy Officer at: privacy@sgicanada.org 

SGI Canada Privacy Officer: Glenn Turner – gturner@sgicanada.org  Tel. (613) 232-1100  

If we identify a gap in compliance, we will take appropriate steps to remedy the situation, including changing our policies and practices if necessary. 

K.    ACCESS TO PERSONAL INFORMATION AND CORRECTION OF PERSONAL INFORMATION 

If you make a request to the Privacy Officer, we will inform you of the existence, use, and disclosure of your Personal Information and you will be given access to that Personal Information. 

You can challenge the accuracy and completeness of the Personal Information and have it changed or corrected as appropriate if there is an error or omission by contacting the Privacy Officer. We will respond to your request within the time periods provided for under applicable laws. 

L.    PROTECTING THE PRIVACY OF CHILDREN AND YOUTH

Many of SGI Canada’s activities and programs are designed for children and youth.  This means that the collection of some Personal Information of children and youth is necessary to provide our services. 

We understand that Personal Information relating to children and youth is particularly sensitive, especially the younger they are.  Consistent with the position of the Office of the Privacy Commissioner of Canada, we will not collect Personal Information from children under the age of 18 unless we have the consent of their parents or guardians. We will not knowingly collect Personal Information from children under the age of 18 unless we have the consent of their parents or guardians. 

We collect the minimum amount of Personal Information of children and youth necessary to achieve our purposes.  

If you are a child or youth, you should review this Privacy Policy with your parents or guardians to make sure that you understand and consent to everything in it.  If you are under the age of 18, you should not access our Websites or provide us with any Personal Information unless your parent or guardian has consented.  If we discover that we have collected Personal Information from a child under the age of 18 without parental consent, we will delete that Personal Information.   

M.    INFORMATION COLLECTED THROUGH TECHNOLOGY AND SOCIAL MEDIA

A cookie is a small text file that is placed on your device when you visit a website and can last either for the duration of your visit (a “session cookie”) or for repeat visits (a “persistent cookie”). When you visit our Website we may automatically collect information about you using cookies and other similar mechanisms that work in the same way.  We use the word “cookie” in this Privacy Policy to refer to all files that collect information in this manner.

Some of the cookies we use are necessary to enable you to use our Websites.  Other cookies may not be essential but may make it easier for you to use the Websites (such as by remembering you when you return to the Websites).  Some cookies are used for tracking purposes.

We use cookies for the following purposes:

• to identify you when you visit and navigate the Websites (authentication)
• to determine if you are logged into the Websites (status)
• to keep our Websites operating properly (function)
• to correct errors and optimize our Website for the best possible user experience (performance)
• as a security measure, to prevent fraud and to protect the Websites (security)
• to help us analyze the use and performance of our Websites (analysis)

We collect the following types of information through cookies: 

• your IP address
• your approximate geographic location
• the type of operating system you are using (e.g., Windows or Mac)
• the type of device you are using
• the type of browser you are using
• your domain name
• which pages you visit on our Website
• the date and time of those requests.

We collect this information for the purposes indicated above and to better understand how visitors use our Websites, to improve the content of the Websites and to improve your interaction with the Website by making it easier for you to get back to the pages you have looked at the next time you visit.  

You have choices when it comes to cookies.  All major browsers allow you to disable cookies.  If you do not want information collected through the use of cookies, you can disable it by changing the setting of your Internet browser.  If you disable cookies, you may be unable to access some features on our Website. 

Our Websites may also provide links to third party websites.  Clicking on those links may allow third parties to collect or share information about you.  We cannot control these third party websites and we are not responsible for the actions or policies of such third parties.  You should check the privacy policies of third parties when visiting their websites or when providing any Personal Information to them.  

We may collect Personal Information when you interact with our content on third-party sites or platforms, such as Facebook, Instagram or You Tube. This may include data such as comments or feedback, "likes" or shares, profile data or the fact that you viewed or interacted with our content.  If you voluntarily post or submit any information on these platforms, your Personal Information may be automatically included in the posting and may be collected and used by others. 

N.    COMPLIANCE WITH CANADA'S ANTI-SPAM LEGISLATION 

SGI Canada complies with the requirements of Canada’s Anti-Spam Legislation, as amended from time to time at all times.  SGI Canada does not send commercial electronic messages (“CEMs”) to any person unless it has express or implied consent from the recipient, the CEM includes identification and contact information for the sender and the CEM has an unsubscribe mechanism. Complaints regarding the sending of CEMs and requests to unsubscribe from CEMs should be directed to the Privacy Officer. 

O.    OTHER JURISDICTIONS

SGI Canada is located in Canada and operates programs and activities in many countries.  Depending on the program you applying for or have been accepted to, or the services you are receiving, your Personal Information may be transferred across national boundaries. 

Some or all of the Personal Information we collect may be transferred to third party service providers in the course of our normal operations or activities including, without limitation, being stored on servers in cloud-based environments or transferred through other technological measures to trusted third parties to assist us in serving you. Some of our service providers are located outside of Canada and therefore Personal Information may be stored or processed in jurisdictions outside of Canada.  As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. 

SGI Canada is not established in the European Union (“EU”), does not offer good and services to individuals in the EU and does not knowingly monitor the behaviour of individuals in the EU.  SGI Canada does not knowingly collect or process Personal Information from individuals located in the EU.  Individuals located in the EU should not access our Websites or provide us with any Personal Information.  If you have any questions or concerns about our privacy practices or procedures in relation to other jurisdictions, please contact the Privacy Officer. 

If you have any questions or concerns about our privacy practices or procedures in relation to other jurisdictions, or to exercise any of your rights under the applicable law of other jurisdictions, please contact the Privacy Officer. We will let you know if there are any limitations or exceptions that apply. 

P.    CHANGES TO PRIVACY POLICY

 We may make changes to this Privacy Policy from time to time, such as in response to developments and changes in privacy law.  When we post changes to this Privacy Policy on our Websites, we will change the “last updated” date at the top of this Privacy Policy.  If possible, we will post notices of significant changes before they take place.  We will not reduce your rights under this Privacy Policy without your consent. Your continued use of this Website after any changes are made signifies your agreement with the terms of the revised Privacy Policy