Interpretation and Definitions

Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions

• My Account means a unique account created for You to access our Service or parts of our Service.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to All Nations International Development Agency (ANIDA), 4401 Steeles Ave. West, Toronto, Ontario, Canada M3N 2S4. For the purpose of the GDPR, the Company is the Data Controller.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Ontario, Canada
• Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the natural or legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For the purpose of this Privacy Policy, we are a Data Controller of Your Personal Data.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information in our possession or likely to come into our possession, that relates to an identified or identifiable living individual.
  For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
• Service refers to the Website http://www.anida.org operated by All Nations International Development Agency (ANIDA)
• Service Provider (or Data Processors) means any natural or legal person who processes the data on behalf of the Company’s Data Controller. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  For the purpose of the GDPR, Service Providers are considered Data Processors. We may use the services of various Service Providers in order to process your data more effectively.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to ANIDA, accessible from http://www.anida.org
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
  Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

The Personal Information Protection and Electronic Documents Act (PIPEDA) Ten (10) Principles
As set out in Schedule 1 of Canada’s Personal Information Protection and Electronic Documents Act, We will comply with the Ten Principles for protecting Personal Data when collecting, using, and disclosing Your information.

• Accountability: We are responsible for Personal Data under our control for our compliance with the following principles.
• Identifying Purposes: The purposes for which Personal Data is collected shall be identified by Us at or before the time the information is collected.
• Consent: Your knowledge and consent are required for the collection, use or disclosure of Personal Data, except where inappropriate.
• Limiting Collection: The collection of Personal Data shall be limited to that which is necessary for the purposes identified by Us. Information shall be collected by fair and lawful means.
• Limiting Use, Disclosure, and Retention: Personal Data shall not be used or disclosed for purposes other than those for which it was collected, except with Your consent or as required by law. Personal Data shall be retained only as long as necessary for the fulfillment of those purposes.
• Accuracy: Personal Data shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Please let Us know of any changes with Your information for Us to update Our files.
• Safeguards: Your Personal Data shall be protected by security safeguards appropriate to the sensitivity of the information.
• Openness: We shall make easily available to Your specific information about Our policies and practices relating to the management of Personal Data.
• Individual Access: Upon request, You shall be informed of the existence, use and disclosure of Your Personal Data and shall be given access to that information. You shall be able to challenge the accuracy and completeness of Your Personal Data and have it amended as appropriate.
• Challenging Compliance: You shall be able to address a challenge concerning compliance with the above principles to Us.

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal Code, City, PO Box
• Bank account information in order to pay for products and/or services within the Service
• Cookies and Usage Data

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

• Date of birth
• Passport or National ID card
• Bank card statement
• Other information linking You to an address

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send.
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Location Data
We may use and store information about Your location if You give Us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time, through Your device settings.

2.2 Tracking Technologies and Cookies

What Are Tracking Technologies?
We use cookies and similar technologies to monitor activity on our Service and store certain information to enhance your user experience.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to Your browser from a website and stored on Your device. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.
Types of Tracking Technologies We Use

1. Session Cookies
   Temporary cookies stored in your browser’s memory while you are visiting a website. These cookies are deleted once you close your browser. They are essential for basic services, such as authenticating users and preventing fraudulent access.
2. Persistent Cookies
   Remain on your device after you close your browser. These help us track and understand usage patterns over time, and remember preferences or login details for future visits. Persistent Cookies may be placed by us or third-party providers (e.g., Google Analytics) and are used to:
   • Analyze web traffic
   • Understand user engagement
   • Test new features and content
3. Preference Cookies
   Remember your settings and choices, like preferred language or region, to provide a more personalized experience.
4. Security Cookies
   Help detect and prevent security risks, such as unauthorized login attempts.
5. Flash Cookies
   Used for content using Adobe Flash to store settings and preferences. These are not managed by typical browser settings.
   To manage or disable Flash Cookies, visit:
   https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html
6. Web Beacons
   Tiny graphic images embedded in emails or web pages. They help track user behavior or confirm if emails have been opened.

How to Manage Cookies
You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. Disabling cookies may cause parts of our Service to become inaccessible or function improperly.
Resources to manage cookies on popular browsers:

• Google Chrome (https://support.google.com/chrome/answer/95647)
• Mozilla Firefox (https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences)
• Safari (https://support.apple.com/en-ca/guide/safari/sfri11471/mac)
• Microsoft Edge (https://support.microsoft.com/en-us/help/4027947/microsoft-edge-delete-cookies)

2.3 Use of Your Personal Data

ANIDA may use Personal Data for the following purposes:

1. Service Delivery and Account Management
   To provide and maintain our Service, manage your account, and enable access to features.
2. Contract Fulfillment
   To process donations or deliver products/services you’ve requested.
3. Communications
   To contact you about updates, service announcements, security notifications, or promotional materials (unless you opt out).
4. Support
   To respond to inquiries and support requests, and manage interactions.
5. Improvement and Analysis
   To gather feedback and analyze usage trends to enhance your experience.
6. Legal and Security Purposes
   To detect and prevent security issues or fulfill legal obligations.
7. Marketing and Promotions
   To inform you of related goods, services, or events unless you’ve opted out.
8. Other Purposes
   To assess the effectiveness of our outreach and to anonymize data for research or reporting.

We may share Your Personal Data in the following situations:

• With Service Providers for analytics, email marketing, and payment processing
• With Affiliates bound by this Privacy Policy.
• With Other Users if you publicly share content or use social media integrations.
• With Your Consent for any additional specified purposes.

Retention of Your Personal Data
ANIDA will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. When removed from Our Service, your Personal Data is securely erased, destroyed, or appropriately anonymized.
ANIDA will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at Our operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your region, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
If You are located outside Canada and choose to provide information to Us, please note that We transfer the data, including Personal Data, to Canada and process it there.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
ANIDA will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

2.4 Disclosure of Your Personal Data

Business Transactions
If ANIDA is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, We may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
ANIDA may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of ANIDA
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security Safeguards of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security
For example, We use password protocols and encryption software in protecting Your Personal Data and other information We receive when a donation is made and/, or a product is purchased on-line. Our software is routinely updated to maximize the protection of such information.
Personal Data gathered by Us is kept in strict confidence. Your Personal Data can only be accessed by Our authorized staff based only on their need to deal with it for the reason(s) for which it was obtained. Security Safeguards are in place to ensure that Personal Data is not disclosed or shared more widely than is necessary to achieve the purposes described above.

2.5 Detailed Information on the Processing of Your Personal Data

We may employ third-party companies and individuals to facilitate our Service (or Service Providers) to perform their tasks on Our behalf, to assist Us in analyzing how our Service is used.
These third-parties have access to Your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.

• Google Analytics
  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
  You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
  For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

Email Marketing
ANIDA may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.

• Mailchimp
  Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
  For more information on the privacy practices of Mailchimp, please visit their Privacy policy: https://mailchimp.com/legal/privacy/

Payments
ANIDA may provide paid products and/or services within the Service. In that case, We may use thirdparty services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our thirdparty payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

• Stripe
  Their Privacy Policy can be viewed at https://stripe.com/us/privacy
• Elavon
  Their Privacy Policy can be viewed at https://www.elavon.com/privacy-pledge.html
  When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

Usage, Performance and Miscellaneous
ANIDA may use third-party Service Providers to provide better improvement of our Service.

• Invisible reCAPTCHA
  We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google. The reCAPTCHA service may collect information from You and from Your Device for security purposes. The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

GDPR Privacy
Legal Basis for Processing Personal Data under General Data Protection Regulation (GDPR)
If You are from the European Economic Area (EEA), ANIDA legal basis for collecting and using the Personal Data described in this Privacy Policy depends on the Personal Data We collect and the specific context in which We collect it.
ANIDA may process Personal Data under the following conditions:

• You have given Us Your consent for processing Personal Data for one or more specific purposes.
• We need to perform a contract with You for the Provision of Personal Data. This is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• The Processing Personal Data is in Our legitimate interests and it’s not overridden by Your rights. Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company
• Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, ANIDA will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
ANIDA undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the European Economic Area (EEA), to:

• Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
• Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Please note that We may ask You to verify Your identity before responding to such requests.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

3. Supplementary Provisions

Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Canada’s Anti-Spam Legislation Compliance
ANIDA complies with the requirements of Canada’s Anti-Spam Legislation, as amended from time to time at all times, including when:

• Sending emails from My Account.
• Email address or domain name.
• Obtaining consent from recipients to send emails.
• Managing and responding to requests to unsubscribe and documenting and retaining records of consent.

The Company 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.
Children’s Privacy
Our Service does not address anyone under the age of 18 (or Children).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from children without verification of parental consent, We take steps to remove that information from Our servers.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.