BLU GENES FOUNDATION’S PRIVACY POLICY

Our Privacy Philosophy

At BLU GENES Foundation (“Blu Genes”, “we” or “us”), we sincerely value the trust that you have placed in our foundation. We have adopted this privacy policy (the “Policy”) to affirm our commitment to maintaining the accuracy, confidentiality, and security of personal information.
This Policy explains how we collect, use, disclose and safeguard the personal information that you or a third party provider. Providing personal information or authorizing a third party to disclose personal information to us signifies your consent to Blu Genes’ collection, use, and disclosure of personal information in accordance with this Policy. If you provide personal information to us about a third party (for example, information with respect to a donation, including the recognition name) or authorize a third party to disclose personal information to us, you agree that you were authorized to do so.
For the purposes of this Policy, “personal information” means information that can identify an individual directly or through other reasonably available means. “Personal information” does not include information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business, or profession. Notwithstanding anything to the contrary herein, the meaning of “personal information” shall be interpreted in a manner that conforms with the minimum requirements of applicable privacy legislation.

Identifying Purposes and Obtaining Your Consent

We identify the purposes for collecting personal information at or before the time it is collected. We will not collect, use or disclose your personal information without your informed consent, unless required or permitted to do so by law.
At Blu Genes, we collect and use personal information so we can:

1. provide, maintain, and improve our services, which includes using the information to contact donors, notify you of upcoming events and opportunities to donate, and otherwise run and manage our foundation in the ordinary course;
2. provide information to our employees, contractors, volunteers, and affiliates to allow them to perform services on our behalf, including the provision of personal information to service providers engaged by Blu Genes to run events to raise funds for the foundation;
3. send you newsletters or other communications to which you have subscribed or may be interested;
4. comply generally with privacy laws and all other applicable regulatory requirements;
5. understand the demographics, interests, usage patterns, and other characteristics of donors and volunteers (and others interested in the foundation) and to track and analyze trends and patterns, including through the aggregation of personal information;
6. administer surveys, contests, draws, and raffles;
7. offer you tailored content, including promotions; and
8. assist you when you contact our support team, including to direct your questions to appropriate individuals, investigate and address any of your concerns, and to improve and monitor our support responses. We may also use your personal information for purposes that are otherwise consistent with the terms of this Policy or that are permitted or required by law, and for purposes for which you have otherwise provided consent.

Should we require your information to fulfill a purpose that is not identified in this Policy, we will obtain your consent before proceeding.

Limiting the Collection, Use and Disclosure of Your Personal Information

1. The information we collect
   The type of personal information that we may ask to collect, including when you make a donation, includes
   1. your name, email address, phone number, address, social media handles, the recognition name, and whether you want the recognition name to appear on the Website; and
   2. other information that you share in your communications with us, our employees, or our contractors, including on or through our website blugenes.org or any other websites operated by us (collectively, the “Website”).

   The choice to provide us with your personal information, either directly or through a third party, is yours. However, your decision to withhold particular information may limit our ability to provide you with some of our services.

2. How your information is collected
   Personal information may be collected in a number of ways, including: in person, over the phone, by mail, by fax, over the Internet (including from our Website and by email), and from third parties whom you have authorized to disclose personal information to us.
   If you have been recognized with respect to a donation, we have obtained personal information, including your name, from the donor.
   We may collect usage information from users of our services, including through the use of cookies, web beacons and tracking pixels, SDKs, and other similar technologies. Cookies are very small text files that are stored on your browser or device. Usage information collected from our Website may include your device type, device identifier, IP address, MAC address, location, browser type, operating system, duration of use, user behavior, length of time spent on the services, and frequency of use. We may use this information for purposes including remembering your preferences and settings, determining the popularity of certain content, authenticating users, determining the effectiveness of any advertising campaigns, and analyzing the behavior and interests of people (including traffic and trends) accessing our Website. We may also allow others to provide analytics services (e.g. Google Analytics) and audience measurement services for us. These third parties may perform such services through the use of cookies, web beacons and tracking pixels, SDKs, and other similar technologies. By modifying your browser settings, you may be able to block cookies or otherwise make adjustments to the use of cookies, although this may the functioning of certain Blu Genes services. You may also visit optout to opt out of certain other cookies.
   If you believe that a third party has inappropriately disclosed your personal information to us, please contact that third party directly. If the third party does not sufficiently respond to your inquiries, please let us know immediately.
   Your personal information will only be used or disclosed in accordance with the purposes for which it was collected unless you have otherwise consented or except where required or permitted by law.
3. We may monitor and record telephone calls
   For the purpose of maintaining quality service, telephone calls to our service lines may be recorded. If your call is subject to a quality assurance program, you will be so advised prior to speaking with a representative.
4. Disclosure to third parties
   We may share your personal information with our service providers in order for them to provide services to or on behalf of Blu Genes. These may include, for example, cloud storage providers, data analytics providers, and third parties that we engage to help us coordinate events. To that end, when you provide personal information to Blu Genes, the information may be stored on servers hosted or owned by a third party.
   If you use a credit or debit card or other methods of payment for your purchase, information with respect to your payment method is required to process your payment. We do not store your payment information. Your payment information will be provided directly to our third party payment provider.
   We may combine personal information with demographic information, publicly available records and other third-party information sources. We may use this information to provide you with a customized experience, to promote and develop services available from Blu Genes, or as otherwise permitted by this Policy.
   If you make post a review, make a comment, or otherwise submit personal information on a public forum such as social media accounts or public forums on our Website, your communications may be viewable by the public.
   We may also disclose personal information in situations where we are legally required or permitted to do so, such as in the course of employing reasonable and legal methods to enforce your rights or to investigate suspicion of unlawful activities. The type of information we are legally required to disclose may relate to criminal investigations or government tax reporting requirements. In some instances, such as a legal proceeding or court order, we may also be required to disclose your personal information to authorities. Only the information specifically requested is disclosed and we take precautions to satisfy ourselves that the authorities that are making the disclosure request have legitimate grounds to do so. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property, and safety of ourselves and others.
   Our successors and assigns may collect, use and disclose your personal information for substantially the same purposes as those set out in this Policy.
5. Keeping your information accurate
   We make reasonable efforts to keep your personal information as accurate, complete and up-to-date as necessary. If desired, you may verify the accuracy and completeness of your personal information in our records.
   
   Despite our efforts, errors sometimes do occur. Should you identify any incorrect or out-of-date information in your file, we will remedy any such errors on a timely basis. In the event that inaccurate information is mistakenly sent to a third party, we will communicate relevant changes to the third party where appropriate.

Protecting Your Personal Information

1. Access to your information within Blu Genes
   Access to private, sensitive and confidential information, including your personal information, is restricted to authorized employees, contractors, and volunteers with legitimate reasons. For example, in the course of hosting an event at which you have registered to participate, employees, contractors, and volunteers may have access to your name and email address to confirm your identity.
   Our employees and contractors understand the importance of keeping your information private. All employees and contractors are expected to maintain the confidentiality of personal information at all times and failure to do so will result in appropriate disciplinary measures including dismissal.
2. Disposal and Retention
   Except as otherwise permitted or required by law, your personal information will be retained for so long as is reasonably necessary to fulfill the purposes for which it was collected.
3. Safeguarding your information
   To ensure that your personal information is protected, we utilize security safeguards that are on par with the industry standard. We keep electronic files in a secured environment with restricted access and use.

Addressing Your Inquiries and Concerns

We are happy to provide you with a copy of this Policy and to discuss any of its content with you.
Upon request, we will also inform you of: the type of personal information we have collected, how your personal information has been used, and any third parties to whom your personal information has been disclosed.
Please direct all questions or inquiries about this Policy to:
Privacy Officer, Blu Genes
c/o Nick Torchetti
181 Bay Street, Suite 1800
Toronto, ON, M5J 2T9
Email: info@blugenes.org

Updating this Privacy Policy

Any changes to our privacy standards and information handling practices will be reflected in this Policy in a timely manner. Blu Genes reserves the right to change, modify, add, or remove portions of this Policy at any time. Please check this page periodically for any modifications. To determine when this Policy was last updated, please refer to the modification date at the bottom of this Policy. If Blu Genes make a material change to this Policy, we will post a notice on our Website and highlight the changes. We may also notify you by email. Material changes to this Policy will be binding thirty (30) days after such changes have been introduced and for which notification of such material changes has been made. If at any point you do not agree with the terms of this Policy, you must not use Blu Genes’ services.

Website Governed by this Privacy Policy

Our Website is governed by the provisions and practices stated in this Policy. Our Website may contain links to third party sites or applications that are not governed by this Policy. Although we endeavor to only link to sites or applications that share our commitment to your privacy, please be aware that this Policy will no longer apply once you leave our Website, and that we are not responsible for the privacy practices of third party sites or applications. We, therefore, suggest that you closely examine the respective privacy policies of third-party sites and applications to learn how they collect, use and disclose your personal information.

Governing Law

This Policy and all related matters shall be interpreted and construed in accordance with the laws of the Province of Ontario and the applicable federal laws of Canada.

Personal Information Outside of Canada

Personal information provided to our payment processors and our other service providers may be stored outside of Ontario and outside of Canada. You acknowledge and agree that, as a result, your personal information may be processed, used, stored or accessed in other jurisdictions and may be subject to the laws of those jurisdictions. For example, information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in other countries.

Last revised Tuesday, July 2, 2019