Preamble

Note: the Alberta Kinesiology' Association ("AKA") considers matters relating to the protection of your personal information and your privacy to be extremely important.  In developing this Privacy Policy, AKA wants to assure you that AKA has taken into account the treatment of your personal information and privacy.  

AKA encourages you to review this Privacy Policy. This policy explains when and why we collect personal information about members and users who visit our Platform, how we use it, the conditions under which we may disclose it to others, and how we keep it secure. The AKA is committed to protecting and respecting your privacy.

By providing personal information upon becoming a Member of the AKA, and while using AKA's Website located at www.albertakinesiology.ca (including any related software, apps or websites) or by using or participating in other AKA services (such as, for example, the "Find a Kin" service) (collectively, the "Platform") and generally while dealing with the AKA, with knowledge of this Privacy Policy, we will assume that you have consented to the collection, use and disclosure of your personal information in accordance with the terms set out in this Privacy Policy unless you advise us otherwise. If for some reason you do not agree (consent) with this policy, you are asked to discontinue (cease) your use of the AKA Platform immediately.

If you have questions regarding this Privacy Policy or our privacy practises then please contact us at privacy@albertakinesiology.ca.

General Policies and Principles

“Personal Information” means information about you; it is defined as any factual or subjective personal information, recorded or not, about an identifiable individual. Personal information does not include information that cannot be attributed to you, for example, information of an aggregate or anonymous nature. Except as otherwise provided in this Privacy Policy, AKA will not sell, rent, loan, trade, lease, transfer or otherwise disclose your personal information, including e-mail addresses, to any third party. The AKA is committed to providing high quality service and we respect the privacy of our registered and other users.

Our ability to provide services to members and users requires that we collect personal information during registration and at other times when services are utilized or requested by you. We implement measures to ensure the privacy and confidentiality of the information you provide are maintained. 

Use of the Platform

In order to use some of the features of AKA's Platform, AKA may require that you provide some personal information.  AKA may issue to you a unique "user id" which you will be required to provide each time you use certain features and services.

If you have a user id, then AKA may collect information about your use of the features and services (whether or not you provide your user id each time) and AKA may associate this information with your other personal information.  

Our web servers collect the domain names, IP addresses and the activity of visitors.  This information is aggregated for the purposes of measuring the number of visits, average time spent on the Platform, pages viewed, and other similar purposes.  AKA uses this information to measure the use of the Platform and to improve the content of the Platform.

Cookies

A technology called cookies may be used on certain pages of the Platform.  A cookie is a tiny element of data that a website can send to your browser, which may then be stored on your hard drive.  Cookies allow us to track visitors to the Platform so we will know when they return.  Cookies also allow us to provide the visitor with tailored information and services based on their previous visits.  Cookies do not enable us to identify the visitor unless that visitor has previously provided personal information during a visit.  If your browser permits, you may set your browser to notify you when you receive a cookie or to reject cookies altogether.  (See the documentation provided with your Internet browser for more information on cookies and how to disable them.) – please understand, however, that if cookies are turned off, you may be unable to view certain parts of the website or experience reduced functionality of the website, detracting from your experience. The use of cookies is an industry standard and many websites use them.

Links to Other Websites

Our Platform may contain links to other websites run by other organizations. This privacy policy only applies to our website, we encourage you to read the privacy statements on other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Platform. Furthermore, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend you check the policy of that third-party site.

Accountability

The AKA takes responsibility for personal information in its possession and holds all third parties responsible for personal information that may be transferred to a third party for processing (such as information passed onto the AKA administrative support staff, the CKA approved group insurance provider for member liability insurance).

Choosing to Provide Personal Information

In using the Platform and in dealing with us you will have the ability to control the amount of personal information you are providing and therefore you may restrict the disclosure of your personal information by not providing your personal information to the Platform or us in the first place.  If you choose to limit the personal information you provide, it may limit the manner in which you can make use of the Platform or otherwise interact with AKA or participate in services provided by AKA.

Personal Information Made Anonymous

To the extent that we make any of your personal information anonymous or we aggregate it with the personal information of others, then that information will no longer be considered to be personal information.  Therefore, AKA will be entitled to use and disclose personal information in any manner that it desires provided the personal information has been rendered anonymous or aggregated where that information cannot be attributed to you.

Consent

When we collect, use or disclose your personal information we will generally obtain your consent.  Most of the time, we will obtain your consent before or at the same time we collect your personal information. In some instances, however, we may seek your consent after we have collected your personal information if we wish to make an additional use or disclosure of your personal information where we do not already have your consent for that new use or disclosure.  This additional consent may be obtained through an amendment to this Privacy Policy as provided above.

Depending on the circumstances, your consent may be express or implied.  Express consent would arise if you specifically consented to a particular dealing in your personal information.  Express consent can be given orally, electronically or in writing.  Implied consent can be inferred from the circumstances.  For example, if we indicate that we may send certain correspondence to your home address and then you provide us with your home address in response, we would not normally obtain your explicit consent to use your home address to send you that correspondence, as your consent would be implied in those circumstances.  

We will assume you consent to the collection, use or disclosure of your personal information for a particular purpose if you voluntarily provide the information for that purpose.   

By submitting personal information to the Platform, you accept that the AKA may collect, use, retain, and disclose such personal information as described in and in accordance with this policy and as permitted by law. 

Privacy Policy as a Means of Consent

In addition, certain collection, uses and disclosures that we wish to make of your personal information are specifically set out in this Privacy Policy.  Be sure to review this Privacy Policy since by providing your personal information to us we will assume that you are consenting to the collection, use and disclosure of your personal information in accordance with the terms of this Privacy Policy.  

Changing Consent

You may change or withdraw your consent at any time on reasonable notice, subject to pre-existing legal and contractual obligations, by contacting AKA as set out above.  If you withdraw certain consents, it may limit the manner in which you can make use of the Platform and to otherwise interact with AKA or your ability to continue to participate in programs and services offered by AKA.  For clarity, your ability to change or withdraw consent is not absolute.  AKA reserves the right to continue handling your personal information in those circumstances required or permitted by law despite a change or withdrawal of consent.

Opting In and Opting Out

AKA may, from time to time, provide you with an opportunity to opt out of certain collection, uses and disclosures of your personal information.  At the same time, an implied consent to collect, use or disclose your personal information would arise if you fail to indicate that you wish to opt out of the particular collection, use or disclosure when you are given an opportunity to do so.  

As well, AKA may, from time to time, provide you with an opportunity to opt into certain collection, uses and disclosures of your personal information.  In that case, if you do not opt-in, AKA will assume that you do not consent to your personal information being collected, used or disclosed in that particular manner.

AKA will generally use an opt-out method when the particular use or disclosure is not unusual, the information is not particularly sensitive or when AKA believes that most people would likely consent to the particular use or disclosure.  AKA will generally use the opt-in method in other circumstances.

Collection

Except as otherwise provided in this Privacy Policy, we will obtain your explicit or implied consent to collect your personal information.  When obtaining your consent, we will inform you of the uses and disclosures that we wish to make of your personal information unless those uses and disclosures are readily apparent at the time, we collect the personal information or are set out in this Privacy Policy.  

In some instances, we may collect your personal information directly from a third party.  In that case, we, the AKA, will generally either obtain your consent to do so or we will require that the third party confirm to us that they are entitled to disclose your personal information to us.

Use

When we use your personal information we will ensure that you had previously provided your consent to that use or if you had not previously provided that consent, we will then obtain your consent if that use is not set out in this Privacy Policy or if that use was not readily apparent at the time we collected your  personal information.  

Except as otherwise provided in this Privacy Policy, we will obtain your explicit or implied consent to use your personal information in a particular manner.  Set out below are certain circumstances where we AKA may use your personal information without obtaining your further consent.  By providing your personal information to us, we are assuming that you are consenting to these uses unless you inform us otherwise.  These are:

·       Using identification information and contact information, such as your name and e-mail address to provide information about AKA when you request that information;

·       using identification information and contact information, such as your name and e-mail address so that we can identify you and deliver the products and services, including the Platform, that you request and to communicate with you regarding those products and services;

·       using payment method preferences and related financial information that you provide to us so that we can obtain payment for the products and services that you request;

·       using information relating to your preferences so that we are able to deliver our products and services, including the Platform, to you in accordance with those preferences;

·       using customer relationship information such as your service requests, instructions, comments and feedback to assist us in delivering products and services in accordance with your wishes;

·       using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose.  For example, if you send us an e-mail with a question or comment, AKA will use your e-mail address to respond to you. Further, AKA may store your e-mail and e-mail address and a copy of our response for future reference;

·       using your e-mail address to provide you with information about new features or enhancements to the Platform or new services or programs offered by AKA;

·       analyzing your personal information to assist us in developing and enhancing our products and services and the Platform; and

·       analyzing your personal information to assist us in conducting market analysis and strategic planning.

Except as otherwise provided in this Privacy Policy, AKA will not use your personal information for any other purpose.

Disclosure

When we disclose your personal information we will ensure that you had previously provided your consent to that disclosure or if you had not previously provided that consent, we will then obtain your consent if that disclosure is not set out in this Privacy Policy or if that disclosure was not readily apparent at the time we collected the personal information.  

Except as otherwise provided in this Privacy Policy, we will obtain your explicit or implied consent prior to disclosing your personal information to a third party.  Set out below are certain circumstances where we may disclose your personal information without obtaining your further consent.  By providing your personal information to us, we are assuming that you are consenting to these disclosures unless you inform us otherwise.  These are:

·       Your personal information that you supply to the Platform will be disclosed in accordance with the description of disclosures as set out in the related documentation for the Platform or as may be readily apparent through the general operation of the Platform;

·       In the event AKA transfers or is considering transferring control of any or all of its operations or services to another organization, AKA reserves the right to transfer and disclose your personal information to that organization.  However, AKA will require that the organization agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose your personal information as AKA is similarly entitled under this Privacy Policy;

·       In the event AKA amalgamates with another organisation, AKA reserves the right to permit that amalgamated organisation to continue to use and disclose your personal information.  However, AKA will require that the amalgamated organisation agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose your personal information as AKA is similarly entitled under this Privacy Policy;

·       AKA may engage certain product and service providers.  Those providers may provide products and services to AKA to assist AKA in its activities.  Other providers may provide products and services directly to you at the request of AKA.  As such, it may be necessary for AKA to disclose your personal information to these providers.  However, AKA will take steps to ensure that these providers will only use and disclose your personal information as necessary to provide the products and services and that they will adhere to the terms of this Privacy Policy or their own similar privacy policy;

·       AKA may disclose your personal information to third -parties for the purpose of confirming your membership status; and,

·       AKA may work with other organisations towards some common purpose consistent with the objectives of AKA.  In that case, it may be necessary for AKA to disclose your personal information to these organisations.  However, AKA will require that these organisations agree that they will only use and disclose your personal information as necessary for the common purpose and that they will adhere to the terms of this Privacy Policy.

Other Collection, Use and Disclosure

AKA may monitor your use of the Platform to ensure the proper use and operation of the Platform and your compliance with the terms of use.

As well, the law permits or requires the collection, use and disclosure of personal information without the knowledge or consent of the individual in a number of circumstances.  We reserve the right to collect, use and disclose your personal information in these circumstances without your knowledge or consent as the law may permit or require.

Limiting Collection, Use, and Disclosure

Personal information will not be collected indiscriminately. The AKA will limit the collection of personal information to that which is necessary to fulfill the purposes for which it is collected. The principle of identifying the purposes for which personal information is collected is associated with limiting the collection to that which is necessary. The extent and type of personal information will vary depending on the type of service being requested. 

If the AKA is compelled by law, court order, or other judicial process to disclose any of your personal information to a court, administrative platform, government agency, or other third party, the AKA will attempt to provide you with prior notice using any contact information you may have provided. 

Retention and Destruction

For legal and business purposes we may retain your personal information for as long as it is reasonably needed.  Upon expiry of the appropriate retention period, bearing in mind our reasonable legal and business requirements, your personal information will either be destroyed in a secure manner or made anonymous.  You should be aware that there are legally required minimum retention periods, which AKA must and does observe.

Accuracy and Completeness

When we, the AKA, collects, uses, or discloses personal information, we, the AKA, will make a reasonable effort to ensure that it is accurate, up- to- date and complete.   To do so, we AKA may need to request additional information from you or have you verified your information.  If your personal information does change, we would appreciate it if you could inform us of those changes in order that your personal information in our possession remains accurate.

Personal information accessible through the website will be maintained in a form that is accurate, complete, and up-to-date as necessary for the purposes for which it was obtained. A notice for the updated information will be made annually for members at the time of membership renewal, other users are responsible for maintaining up-to-date personal and/or applicable business information. Updating personal information is the responsibility of the member or registered user. 

Security of Personal Information

AKA recognizes its obligation to protect personal information in its possession and will make reasonable arrangements to secure that personal information against unauthorized access.  These measures will be reasonable in the circumstance and may include providing access to only those individuals with a need to know the information, locked doors and/or filing cabinets and other physical and electronic security measures as well as contractual measures, such as non-disclosure or confidentiality agreements.  

Requests for Access to Personal Information

On your written request we will provide you with:

·       Access to your personal information (if any) under our custody or control;

·       Information about the purposes for which your personal information under our custody or control has been and is being used by us; and

·       The names of persons to whom, and the circumstances in which, your personal information has been and is being disclosed by us.  

All requests may be subject to reasonable fees and disbursements.  Where appropriate to do so, we may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.

The AKA requires that all requests for access be in writing and be signed and dated by the requestor. AKA requires sufficient information and detail from the requestor in order to verify their identity, properly locate the information and respond to the request.  

Limits on Individual Rights to Information

An individual's ability to access his or her personal information under our control is not absolute.  AKA reserves all rights to not disclose personal information in certain circumstances.  For example, we may not disclose personal information where:

·       The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual;

·       The disclosure would reveal personal information about another individual;

·       The disclosure of the information would reveal confidential commercial information; or,

·       The personal information was collected by us for an investigation or legal proceeding.

Requests for Correction of Personal Information

On request by you, we will correct errors or omissions in your personal information where that information is in our custody or control.   We AKA requires that all such requests be in writing and signed and dated by you.  We AKA may require sufficient information and detail from the individual in question in order to verify their identity, properly locate the information and respond.  

If you make such a request, we will either:

·       Correct the personal information and, if reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect information; or,

·       Decide not to correct the personal information but we will annotate the personal information that a correction was requested but not made.

Corrections or amendments will rarely, if ever, be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.

Limited Nature of this Privacy Policy

Nothing contained in this Privacy Policy is intended to create a contract or agreement between AKA and you and you may not rely on it as such.

Amendments to this Privacy Policy

 AKA may amend at its sole and absolute discretion this Privacy Policy at any time. In such cases the AKA may choose, at its sole and absolute discretion, to publish on its Website a new privacy policy in place of this one.  These amendments may include, without limitation, adding to, deleting from or modifying any of the provisions in this Privacy Policy.  AKA will post notice(s) that the Privacy Policy has been amended on the association homepage located at www.albertakinesiology.ca for 30 days.  The amended privacy policy shall automatically be effective when posted. Your continued use of the Platform following the publishing of the amended privacy policy and the posting of such notice shall mean that you accept the terms of this Privacy Policy as amended.  If you do not agree with any of the terms or conditions in the amended Privacy Policy then you agree to immediately cease all use of the Platform, which shall be your sole recourse and remedy in the event you are dissatisfied with the amended Privacy Policy. This Privacy Policy may not otherwise be amended.  

The first paragraph of this Privacy Policy indicates when the Privacy Policy was last amended.  You are strongly encouraged to check back regularly for changes.  

Contact Information

If you:

·       Have any questions with respect to our privacy policies or practises;

·       Have any questions with respect to our handling of your personal information;

·       If you wish to request access to, or correction of, your personal information under our care or control; or,

·       If you are dissatisfied with our handling of your personal information,

please contact the AKA’s Chief Privacy Officer.

AKA Chief Privacy Officer

Sheena Warsi

Email: privacy@albertakinesiology.ca

Mailing Address: P.O. Box 4358, Edmonton, AB, T6E 4T3

Additional Contact Information:

Office of the Information and Privacy Commissioner (OIPC) of Alberta

In Edmonton: (780) 422-6860

In Calgary: (403) 297-2728

Elsewhere in Alberta (Toll-Free): 1-888-878-4044

Website: www.opic.ab.ca

Email: info@oipc.ab.ca

Updated January 12, 2020