Effective date: July 1, 2019
Trans World Radio Canada (“TWR Canada”, "us", "we", or "our") operates several websites and mobile apps, including the http://www.twr.ca website and the TWR Canada Speak Hope mobile application, and other locations where this notice is included (together, the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions. Information collected via telephone and mail is subject to the TWR Canada Privacy Policy, available online at https://www.twr.ca/privacy/.
Service
Service means the http://www.twr.ca website, the TWR Canada Speak Hope mobile applications, and other sites and apps created by TWR Canada where this policy is present.
Personal Data
Personal Data means data about a living individual who can be identified from this data (or from this and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is 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).
Cookies
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
We collect several different types of information for various purposes to provide and improve our Service to you.
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 ("Personal Data"). Personally identifiable information may include, but is not limited to:
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 all marketing emails that we send.
Providing us with your Personal Data is always voluntary, but some features of the Service may not work without limited information.
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 ("Usage Data").
This Usage Data may include information such as your computer'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, this Usage Data may include information such as 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 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. Some features may only be available in your location, so disabling location services will prevent you from accessing these features.
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
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 also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we may use:
TWR Canada uses the collected data for various purposes:
If you are from the European Economic Area (EEA), TWR Canada’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
TWR Canada may process your Personal Data because:
TWR Canada 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.
TWR Canada 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.
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada or the US and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
TWR Canada 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.
Under certain circumstances, TWR Canada 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).
TWR Canada may disclose your Personal Data in the good faith belief that such action is necessary to:
TWR Canada works with trusted third-party organizations around the world to make media content available through our Service. Your Personal Data may be shared with these organizations if it was collected as a result of an ongoing partnership with that organization. Such cases are limited but may occur, for example, when you submit comments or feedback about content that organization has made available through our Service.
The security of your 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.
We do not support Do Not Track ("DNT"). Do Not Track is a non-standardized preference you can set in your web browser to inform websites that you do not want to be tracked.
To take advantage of this feature for the sites that do support it, you can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TWR Canada aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you or if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or to 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.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where TWR Canada relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or 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.
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.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
TWR Canada uses advertising and remarketing services to advertise on third party websites to you after you visited our Service, and to attract people to our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
Google AdWords
Google AdWords advertising and remarketing services are provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook advertising and remarketing services are provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services, or allow donations within the Service. In that case, we use third-party 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 third-party 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.
The payment processors we work with are:
Helcim Commerce
Their Privacy Policy can be viewed at https://www.helcim.com/policies/privacy/
Paysafe/Netbanx
Their Privacy Policy can be viewed at https://www.paysafe.com/ca-en/paysafegroup/column3/comprehensive-privacy-policy/
PayPal
Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
We also use other third-party service providers (“Data Processors”) in the delivery of the Service.
Salesforce.com https://www.salesforce.com/ca/company/privacy
Salesforce is used as our primary customer relationship management solution.
MailChimp https://mailchimp.com/legal/
MailChimp provides email newsletter services.
Radiant Webtools https://build.radiantwebtools.com/rwt4/privacy
Amazon AWS: https://aws.amazon.com/privacy/
Radiant Webtools and Amazon Web Services are our website and app solution providers.
Our Service may contain links to other sites 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.
Some of our content is produced for children. We encourage children to use our services under the supervision of a parent or guardian. If you are a parent or guardian and you are aware that your child has provided us with Personal Data and would like this removed, please contact us.
We may update our Privacy Policy at any time. Changes to this Privacy Policy are effective as of the Effective Date at the top of this Privacy Policy. We will notify you of any changes by posting the new Privacy Policy on this page and updating the Effective Date.
You are advised to review this Privacy Policy periodically for any changes.
If you have any questions about this Privacy Policy, please contact us:
