FEDERAL INDIAN DAY SCHOOL CLASS ACTION PRIVACY POLICY
1. INTRODUCTION
Gowling WLG (Canada) LLP (“Gowling WLG”, “we”, “our” or “us”) is committed to protecting your privacy and the confidentiality of your Personal Information (as defined in Section 2 below). This privacy policy (the “Privacy Policy”) describes how we treat the information we collect when you use our website, https://indiandayschools.com/ (the “Website”).
This Privacy Policy describes:
- how we may collect, use, disclose, and protect the Personal Information of users of the Website;
- the types of information we may collect from you or that you may provide when you visit the Website; and
- our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Privacy Policy, together with the Website terms of use, available at: https://indiandayschools.com/en/website-terms-of-use/ (the “Terms of Use”), set forth the general rules and policies governing your use of the Website.
We will only use your Personal Information in accordance with this Privacy Policy unless otherwise required by applicable law.
This Privacy Policy does not apply to information that:
- we collect offline or through any other means, including on any other website; or
- you provide to, or is collected by, any third party, through any application or content (including advertising) that may link to, or be accessible from or on, the Website.
Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information. By using the Website, you are agreeing to this Privacy Policy, as it may be amended by us from time to time, and to our collection and use of your Personal Information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy or to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy, please do not use the Website or otherwise provide us with your Personal Information.
2. PERSONAL INFORMATION
In this Privacy Policy, “Personal information” means any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate an individual. Personal Information can be recorded in any format, and includes an individual’s name, date of birth, age, address, city, province, country, and postal code. Personal Information does not include information from which an individual cannot be identified, either alone or in combination with other information.
3. INFORMATION WE COLLECT ABOUT YOU
We take steps to ensure that the Personal Information that we collect about you is adequate, relevant, and not excessive. The information that we collect may vary depending on how you interact with us and/or the Website. The information we may collect includes:
- Personal Informationthat we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, and Internet protocol (IP) address used to connect your computer to the Internet.
- Non-personal informationthat does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Non-personal statistical or aggregated data is information that does not directly identify a specific person, but may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users accessing a specific Website feature.
- Technical information, including your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your Internet connection, the equipment you use to access the Website, and your usage details.
- Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from the Website (including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call the Claims Administrator, Class Counsel and Hope for Wellness service numbers.
- Any other information which is necessary or required for us to collect as part of our statutory or regulatory compliance requirements.
4. EXTERNAL LINKS
The Website may include links to third party websites, plug-ins, services, social media platforms, and other applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. Other websites and plug-ins are governed by privacy policies and practices that may differ significantly from those of Gowling WLG. We strongly recommend that you review the privacy policies and practices applicable to Personal Information collection of a linked website before submitting any Personal Information to linked websites. We do not accept any responsibility or liability for the content or the privacy practices of other websites, whether or not linked to the Website.
5. HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your Personal Information, including through:
- Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, e-mail, or otherwise.
- Automated technologies or interactions, as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons and similar technologies.
Information You Provide to Us
The Personal Information we collect directly from you on or through the Website may include:
- information that you provide by filling in webinar registration forms on the Website, including information provided at the time of registering for a claims assistance session and/or requesting further support. We may also ask you for information when you report a problem with the Website;
- records and copies of your correspondence (including e-mail addresses), if you contact us; and
- your search queries on the Website.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with the Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- details of your visits to the Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website; and
- information about your computer and Internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical data and may include Personal Information, and we may maintain and/or associate it with Personal Information we collect in other ways, that you otherwise provide to us, or that we receive from third parties. Such information helps us improve the Website and deliver a better and more personalized service, including by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize the Website according to your individual interests;
- speed up your searches; and
- recognize you when you return to the Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies).A cookie is a small file placed on the hard drive of your computer. Cookies are widely used, and most web browsers are configured to accept cookies automatically. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
- Flash Cookies.Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website are maintained by third parties, including possible advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your Personal Information and/or your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada and/or an opt-out tool created by the Network Advertising Initiative. You can also access these organizations’ websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising, but it does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
6. HOW WE USE YOUR INFORMATION
We may use information that we collect about you or that you provide to us, including any Personal Information:
- to present the Website and its contents to you;
- to provide you with information or services that you request from us;
- to fulfill the purposes for which you provided the information or that were described when it was collected;
- to notify you about changes to the Website or any services we offer or provide though the Website;
- to improve our Website, services, marketing, or customer relationships and experiences;
- to enable you to personalize your experience with the Website;
- to meet our professional standards, and obtain and maintain certifications and accreditations which may involve audits of our internal processes;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
7. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about users of the Website, and information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect, or you provide, as described in this Privacy Policy:
- to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and process it with the same standards as are set out in this Privacy Policy;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
We may also disclose your Personal Information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable laws;
- to enforce or apply the Terms of Use and other agreements; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Gowling WLG or others.
8. TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer Personal Information that we collect or that you provide as described in this Privacy Policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and process it with the same standards set out in this Privacy Policy.
We may process, store, and transfer your Personal Information in and to a foreign country with different privacy laws, that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, and/or regulatory agencies of that foreign country may be able to obtain access to your Personal Information through its laws. By submitting your Personal Information or engaging with the Website, you consent to this transfer, storage, and/or processing.
9. DATA SECURITY
The security of your Personal Information is very important to us. We use physical, electronic, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Website. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.
10. DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as it is necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances, we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without requiring further notice to you or your consent.
11. CHILDREN UNDER THE AGE OF 13
The Website is not intended for children under 13 years of age. No one under the age 13 may provide any Personal Information to or on the Website without parental consent. We do not knowingly collect Personal Information from children under the age of 13. If you are under 13 years of age, do not use or provide any information on the Website or on or through any of its features, or provide any information about yourself to us, including your name, address, telephone number, or e-mail address. If we learn that we have collected or received Personal Information from a child under 13 years of age without verification of parental consent, we will delete that information.
12. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law, you have the right to request access to and to correct the Personal Information that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of your Personal Information, you may send us an e-mail (using the e-mail address set out in Section 15) to request access to, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change your information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access and be provided with the Personal Information that we hold about you, or for us to make your requested changes. We may refuse to provide you with access to some or all of the Personal Information that we hold about you if we are permitted or required to do so by applicable laws or if we have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you are concerned about our response or would like to correct the information provided, you may contact our privacy officer using the contact information set out in Section 15.
13. WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the contact information set out in Section 15. Please note that if you withdraw your consent, we may not be able to provide you with certain information or services. We will explain the impact of withdrawing your consent at the time of such a withdraw request to help you with your decision.
14. CHANGES TO OUR PRIVACY POLICY
We reserve the right to make changes to this Privacy Policy at any time. It is our policy to post any changes we make to the Privacy Policy on this page and will include the date the Privacy Policy was last revised at the top of this page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on the Website home page.
You are responsible for periodically visiting the Website and reviewing this Privacy Policy to check for any changes. Any changes to this Privacy Policy will be effective immediately upon being posted to the Website and your continued access to and use of the Website constitutes your acceptance of this Privacy Policy, as amended.
15. CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact Gowling WLG at:
Gowling WLG (Canada) LLP
Suite 2600, 160 Elgin Street
Ottawa, Ontario, Canada K1P 1C3
Attention: Cam Cameron
Email: cam.cameron@gowlingwlg.com
Phone: 1-844-539-3815
We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information, and our compliance with this Privacy Policy and applicable privacy laws. To discuss our compliance with this Privacy Policy, please contact our privacy officer, Cam Cameron, using the contact information listed above.