Privacy Policy

Effective Date: January 01, 2024

STRATLY Respects Your Right to Privacy

Your privacy and security are important to us. STRATLY respects your right to privacy and is committed to protecting the personal information you provide to us. We use the information collected through our website to facilitate donation collection and processing, provide tax receipts, process online account registrations and to communicate relevant news and updates. STRATLY does not trade, license, rent or sell your personal information in any manner.

Privacy Statement and Summary

This STRATLY Inc. (follows, “STRATLY ”, “we” or “our”) Privacy Statement is to inform you about the personal information STRATLY collects, uses and discloses. It explains why we collect that information, how we use and disclose it, and the choices you have regarding such use and disclosure, including how you may correct and access your personal information. It also describes STRATLY’s information protection policies and practices and how we safeguard your personal information.

STRATLY’s commitment to protecting and safeguarding your personal information is demonstrated through our compliance to Canada’s privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act (PIPEDA). We will treat your personal information in a manner consistent with the version of Privacy Statement under which it was collected and our Privacy Policy, unless we obtain your consent to treat it differently. We work carefully to ensure that your personal information is kept safe and secure during the transaction process and at all times while in our custody and control.

This Privacy Statement applies to any personal information we collect while accessing our website, including when you register for an account, make a donation or submit an information request. We encourage you to carefully read this Privacy Statement before providing us with any information. By providing us with any personal information, you are signifying that you agree with the terms of this Privacy Statement.

General Privacy Practices

STRATLY observes the following privacy practices:

  • STRATLY collects information only for specified purposes.
  • We only require that you provide the necessary amount of personal information to provide you with our services, as required by law or by the Canada Revenue Agency (CRA) and The Internal Revenue Agency (IRS) where applicable.
  • We may ask you for more information about yourself to help us provide you with more personalized information and services, but in such cases, you are not obligated to provide such information.
  • Personal information gathered by STRATLY is held in the strictest confidence and is protected by industry standard best practices.
  • In certain instances, Donors are able to restrict the amount of information shared with the charities they support. In doing so, STRATLY may not be able to provide certain services that require personal information. STRATLY will inform you of the implications of opting out.

Definition of Personal Information

Personal information is defined as any factual or subjective information about an identifiable individual. Your personal information may include but is not limited to your name, mailing address, phone numbers, gender, email address, etc. Personal information does not include any information that is used solely to communicate with you in relation to your employment, business or profession, such as your name, job title, business address or business telephone or fax number, or work email address.

Changes to this Privacy Policy

STRATLY regularly reviews its privacy practices and updates its Privacy Policy as required. We recommend that you check this Privacy Policy periodically so that you are aware of any changes. The Privacy Policy posted at any time or from time to time via this website shall be deemed to be the Privacy Policy then in effect.

Links to Third Party Sites

This website may offer links to other third party websites. You should be aware that operators of linked websites may also collect your personal information (including information generated through the use of cookies) when you link to their websites. STRATLY is not responsible for how such third parties collect, use or disclose your personal information. It is important to familiarize yourself with their privacy policies before providing them with your personal information.

Children

We do not knowingly collect any personal information from children under the age of 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.

Privacy Principles

STRATLY is committed to the following 10 privacy principles under PIPEDA:

  1. Accountability
      • STRATLY is responsible for personal information in our custody or under our control and we have designated a Privacy Official who is accountable for STRATLY’s compliance with PIPEDA. STRATLY provides a variety of convenient methods to allow you to review, communication preferences. You may:
        • Use the Contact Us form on the applicable site
        • Submit an email request to STRATLY ’s Privacy Official at legal@STRATLY .com
        • Call 1-800-857-3102 (Monday to Friday, 9:00 am to 5:00 pm EST)
        • Write us at 260 Queen Street West, Toronto, Ontario M5V 1Z8

    We will make available to you any specific information of yours that we have collected, used or disclosed, upon your request, to the extent permitted by law. We will make such information available to you in a form that is generally understandable.

    • STRATLY has policies and procedures in place to implement and comply with this Privacy Policy, including procedures relating to the collection, handling, disclosure, storage and destruction of personal information.
    • STRATLY is responsible for personal information transferred by us to, or accessed by, third parties, if any, for processing on our behalf. STRATLY uses contractual means to provide an appropriate level of protection for such transferred information. Third parties entering into a business relationship with STRATLY are required to adhere to these privacy principles, this Privacy Policy, PIPEDA and any other applicable law dealing with the protection of personal information.
  2. Identifying Purposes STRATLY  collects and uses personal information for the following purposes:
    • To provide tax receipts when users make an online donation, or use other services such as Fundraising Pages or Gift Cards.
    • To allow users to create or register for a STRATLY account and to manage those accounts.
    • To administer pre-authorized recurring donations.
    • To generate statistics and aggregate reports for internal and external use.
    • To communicate directly with users, including through STRATLY service news and updates, charitable promotions, charitable stories we think will be of interest to you, or other forms of communications.
    • To provide client support and help.
  3. Consent to use your personal information
    • STRATLY collects personal information about you only when you voluntarily provide it or otherwise only with your consent as required by PIPEDA or by other applicable law.
    • By visiting and using this website, the visitor agrees to the Privacy Policy and the terms of use linked to in this Privacy Policy. Terms and Conditions. If you do not agree to the Privacy Policy, do not use this Website or provide personal information to STRATLY.
    • We will not, as a condition of the supply of our service, require you to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information is being provided.
    • A user may withdraw his or her consent to use his or her personal information at any time, subject to any legal or contractual restrictions. If you wish to withdraw your consent, please contact the Privacy Official of STRATLY as described below. We will inform you of the implications of withdrawing consent.
    • If you do not wish to receive marketing communications from us or participate in more personalized information and services, you may unsubscribe by following the directions provided with the communication.
  4. Limiting Collection STRATLY limits the collection of personal information to that which is reasonably necessary for the identified purpose. The types of information STRATLY collects can be summarized as follows:i: Personal Information provided to STRATLY: STRATLY collects certain personal information directly from individuals who interact with our website or otherwise with us, including the following:
    • Contact information (such as name, address, e-mail address and telephone number);
    • Financial and billing information (such as credit card number/expiration date, broker and financial advisor information); and
    • Donation history (such as amount donated and charities donated to);
    • Tax receipt information; and
    • Account username and password information.

    ii: Non-Personal Information: When donors, volunteers, charities and other organizations access the secure section of our website, anonymous, non-personal information about their visit is automatically collected. This information may include:

    • Visitor activity while accessing our secured site, such as how the visitor uses the website, the length of the visit, what pages the visitor viewed, the type of browser and operating system being used, and the name of the visitor’s Internet service provider;
    • Error reports and performance data regarding the performance of our Services while a Visitor is accessing our secured sites. This data may be used by STRATLY to diagnose problems in our Services, to improve our Services and provide solutions;
    • Device data information of those accessing our website, including device identifiers (such as IMEI number for phones, geographic location and regional and language settings.
    • Statistics that describe how Visitors use our site such as the average donation amount, the geographic breakdown of donations by area, what times of the day have the heaviest traffic, and which type of charity receives the most gifts. This information, collected in the aggregate, allows STRATLY to better serve donors and charities. None of these statistics reveal any personally-identifiable or individual information and STRATLY does not use any of this information to identify individuals;
    • Support Data you provide when you engage STRATLY for support. Such information may include authentication data, information about your hardware software and details related to the support incident; and
    • In certain cases, for the purposes of fraud detection and mitigation, IP addresses are collected in order to protect STRATLY against possible illegal activities.

    iii: Cookie-based Information: When our clients, donors, volunteers, and other constituents access the secure section of our website, a small text file called a “cookie” is sent from our web server to their web browser and is stored on their computer. Cookies allow us to recognize users while he or she is logged into the STRATLY website. Cookies expire when the browser window is closed. Session Cookies employed by STRATLY are strictly used to perform the function that the user intended, such as keeping the user logged into the service in a secure fashion and processing transactions and gathering donations into a Gift Basket. Some browsers can be set to reject all cookies. If you choose to modify your browser in this manner, some pages of this website may not function properly.

  5. Limiting Use, Disclosure and Retention
    • STRATLY does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as permitted or required by law.
    • STRATLY does not disclose credit card account information provided by users except to the appropriate banking institutions or payment processing provider in order to process a credit or debit authorization for payment, or to resolve a dispute.
    • STRATLY may have to disclose personal information to satisfy a law, regulation or government request, or to satisfy a subpoena, search warrant or legitimate court order.
    • STRATLY may share personal information with third parties engaged to assist us in providing our services. Such third parties are contractually bound to protect your personal information as explained above under “Accountability”.
    • STRATLY reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of STRATLY in order for you to continue to receive the same services from the third party.
    • STRATLY retains personal information only as long as is necessary for the fulfillment of those purposes for which it was collected or as required by law, and your consent to such purposes(s) remains valid after termination of our relationship with you
  6. Accuracy STRATLY takes reasonable effort to keep personal information accurate, complete and as up to date as is necessary for the purposes that is being used. Individuals are permitted to check on the accuracy of their personal information and may make, or request, modifications or corrections, if necessary. STRATLY depends on individuals and organizations to help it in maintaining the completeness, accuracy, and timeliness of the information collected. You must log-in to your STRATLY online account to update, modify, correct or delete your personal information.
  7. Safeguards
    • STRATLY makes commercially reasonable efforts to protect personal information from loss, theft, unauthorized access, copying, use, modification, disclosure and destruction by establishing and maintaining appropriate security safeguards appropriate to the sensitivity level of the information.
    • ll STRATLY staff members are made aware of the need to maintain strict confidentiality of all personal information.
    • With respect to the handling of credit card information, Credit card numbers are not stored by STRATLY, but instead each credit card is tokenized by the gateway and the token is stored. This ensures credit card numbers cannot be exposed via security intrusions or accidental data exposure.
    • STRATLY uses Secure Sockets Layer (SSL) technology to help ensure the safety and security of online donations. SSL technology enables encryption (scrambling) of sensitive information, including passwords and credit card numbers, during your online transactions.
    • STRATLY has thorough security standards to protect our systems and your personal information against unauthorized access and use. This includes the security protections required by PCI compliance as well as specific procedures to keep your donation information secure, private and in Canada.
  8. Openness STRATLY makes information about our policies and practices related to the management of personal information readily available to users of our service and the general public. Our Privacy Policy, which informs users of the type of information we collect, what it is used for, and to whom the information may be disclosed, is posted on our website. Additional information about our privacy policies and practices can be obtained from our Privacy Official as described below.
  9. Individual AccessUpon request STRATLY will:
    1. Inform users of the existence and use of their personal information.
    2. Inform users whether their personal information has been disclosed to any authorized third parties.
    3. Provide users with access to their personal information in our custody or under our control subject to legal restrictions.

    Requests are to be directed by email to legal@STRATLY .com STRATLY will make every effort to respond to requests for access to personal information in a reasonable and timely manner.

  10. Challenging ComplianceAny question, request, or concerns regarding STRATLY ’ compliance with respect to the Privacy Policy or about our privacy practices may be directed to the Privacy Official as described above.
  11. Canada’s Anti-Spam Legislation (CASL)Where CASL applies to STRATLY ’ communications with users, donors or volunteers, STRATLY is committed to complying with CASL and in particular the provisions setting out the requirements for sending commercial electronic messages.
  12. Governing LawThis Privacy Statement is governed by, and interpreted and enforced in accordance with the federal laws of Canada, the Province of Ontario, and where applicable, the privacy laws of the United States of America, excluding any conflict of laws, rule or principle which might refer such interpretation to the laws of another jurisdiction.
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