Privacy Policy

 

Effective Date: November 2021

 

Your privacy is important to Kehilla Montreal Residential Programs(“Kehilla”, “we”, “us” or “our”). This Privacy Policy applies to our activities and describes our practices with respect to the collection, use and disclosure of personal information, as well as any rights you may have with respect to your personal information (as defined in the Definition of “Personal Information” section), in relation to Kehilla (as defined in the Scope and Application section).

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY. WHEN YOU USE SERVICES PROVIDED IN RELATION TO KEHILLA, WE MAY SHARE YOUR PERSONAL INFORMATION WITH ORGANIZATIONS THAT PARTNER WITH KEHILLA IN ORDER TO PROVIDE SERVICES RELATED TO KEHILLA. YOUR PERSONAL INFORMATION MAY ALSO BE SHARED WITH OTHER COMMUNITY ORGANIZATIONS FOR THE PURPOSES OF ASSESSING YOUR ELIGIBILITY FOR ASSISTANCE, COORDINATING SUCH ASSISTANCE WITH THE BENEFITS YOU RECEIVE THROUGH OTHER COMMUNITY PROGRAMS AND DELIVERING SERVICES TO YOU, AND TO ASSIST US IN IMPROVING OUR PROGRAMS. INFORMATION THAT KEHILLA SHARES WITH ALL SUCH ORGANIZATIONS (INCLUDING BUT NOT LIMITED TO FEDERATION CJA, OMETZ) IS NO LONGER IN THE CUSTODY OR UNDER THE CONTROL OF KEHILLA. THOSE ORGANIZATIONS MAY USE THAT INFORMATION TO CONTACT YOU OR FOR OTHER PURPOSES IN ACCORDANCE WITH THEIR OWN PRIVACY POLICIES.

Contents

  1. Scope and Application.
  2. Definition of “Personal Information”
  3. What Personal Information do we Collect?
  4. How we Collect Personal Information
  5. Directly From You
  6. From Organizations
  7. Through Online Technologies
  8. How we Use Personal Information
  9. Providing Services and Information
  10. Managing Our Operations
  11. Conducting Research and Data Analytics
  12. How we Share Personal Information
  13. Organizations
  14. Service Providers
  15. Transfer of Operations or Activities
  16. Other Permitted Reasons
  17. With Your Consent
  18. Third Parties
  19. How we Manage Consent
  20. Your Privacy Choices
  21. When You Apply or by Contacting Us Directly.
  22. Using Third Party Unsubscribe Functionality
  23. How we Store and Safeguard Personal Information
  24. How we Protect Personal Information
  25. How Long we Keep Personal Information
  26. Cross Boarder Transfer of Personal Informal
  27. Accessing and Correcting Your Personal Information
  28. Children
  29. Changes To Our Privacy Policy
  30. Who Can You Contact With Privacy Questions?

1. Scope and Application

ThisPrivacyPolicyrelatestothepersonalinformationcollectedbyKehillainrelationto“Kehilla”.ThisPrivacyPolicy applies whenever you interact with us in relation to Kehilla, including when you visit our website on which this Privacy Policy is posted (the “Website”) or otherwise receive services related to Kehilla(“Services”).

2. Definition of “Personal Information”

“Personal Information” is any information that identifies, or could be reasonably associated with, an individual and their household (collectively, “individual” or “you”). This may include, for example, your name, contact information, email-address, and information relating to your file with us (as the case may be). It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or de-identified and can not be associated with an identifiable individual is not considered to be personal information.

3. What Personal Information do we Collect?

We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected including of assessing your eligibility for assistance, coordinating such assistance with the benefits you receive through other community programs and delivering Services to you, and to assist us in improving our programs. We collect personal information in a variety of ways, including: directly from you, from third parties, and when you are interacting with us through our Website.

Personal information we collect may include:

  • Identifiers and contact information, such as your name, email and postal addresses, telephone number;
  • Demographic data, such as whether you are over 13 years of age, your age, occupation, marital status, languages, and your gender;
  • Financial information, such as current information about your financial situation;
  • Browsing activity on our Website, such as pages and events viewed and your IP address, if it can identify you as an individual;
  • Religious or Jewish community identity, such as Conservative, Hasidic, Orthodox (Baal Teshuva), Orthodox (Frum), Reconstructionist, Reform, Culturally Jewish or other Jewish community identity;
  • Any other information you provide to us (as further detailed in the How we Collect Personal Information section).

 

4. How we Collect Personal Information

We collect Personal Information in a variety of ways, including: directly from you, from other organizations, through online technologies (such as when you are interacting with us through our Website) and from third-party social networks.

More specifically, we collect personal information in the following ways:

a. Directly From You

You may provide Personal Infbormation to us by mail, by email, over the telephone, through hour Website or in any other direct manner, for instance when you apply for Kehilla Services, respond to our emails, or call us with respect to a requested service.

b. From Organizations

We may receive Personal Information from other organizations with which you have an existing relationship, including but not limited to organizations that partner with us, in order to ensure eligibility to the program or to facilitate and coordinate the assistance that Kehilla can provide. By applying for Kehilla Services, you are granting your permission for an organization with which you have an existing relationship to release your Personal Information and share it with Kehilla, and other community organizations in order to better determine how to provide Kehilla Services to you, and for Kehilla to obtain such Personal Information from said organization when we facilitate services provided by that organization in relation to or in support of Kehilla or otherwise in conjunction with or at the request of Kehilla. We may also receive your Personal Information from other sources with your consent or when authorized by law.

c. Through Online Technologies

We may collect certain types of information electronically when you interact with our Website, email or social media accounts, either directly or through the use of our or a third party’s technologies, which include cookies, web beacons, pixels or analytics services. This information supports the functioning of our Website, and helps us understand what actions you take on our Website and whether our website is working properly.

You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our Website. To learn more about the privacy choices available to you, please see Your Privacy Choices.

5. How we Use Personal Information

We may use all categories of Personal Information detailed in section 3 to provide you with Kehilla Services or to communicate information we think might interest you, to manage our operations, to generally improve your experience with us and as otherwise permitted or required by law.

Learn more about how we use your Personal Information for: providing services and information, managing our operations and conducting research and data analytics.

We use your Personal Information for the following purposes:

a. Providing Services and Information

We use your Personal Information in order to provide Kehilla Services, for instance:

    • Verifying your identity;
    • Assessing your eligibility for a Service;
    • Responding to your inquiries or otherwise communicating with you;
    • Creating, administering and maintaining your accounts;
    • Fulfilling your requests.

We may use your Personal Information to inform you about Services, both on our own behalf and those of third parties, that we believe may be of interest or assistance to you. We may do this by communicating with you by email, telephone, or direct mail.

If you no longer wish to receive these electronic messages, please let us know by following the unsubscribe directions provided in each such electronic message. For more information on managing your preferences, please see Your  Privacy Choices.

b. Managing Our Operations

We use your Personal Information to manage our operations, for instance:

    • NotifyingyouofchangestoyouraccountorourWebsiteservices,terms,conditionsorpoliciesandtoprovide you administrative messages, updates, legal notices, technical notices or security alerts;
    • Deploying and managing our information technology applications and systems, including managing and facilitating the use of our Website, which may include using cookies and other similar technology (as further detailed in the How we Collect Personal Information section);
    • Enabling your participation in Kehilla Services;
    • Maintaining the security of the public, our users and our employees;
    • Protecting ourselves and third parties from errors and fraud;
    • Monitoring and investigating incidents and managing claims;
    • Maintaining the Kehilla Services; and
    • Meeting our contractual, legal and regulatory obligations.

c. Conducting Research and Data Analytics

We may use your Personal Information in order to conduct research and data analytics by tracking and analyzing current or previously collected information to improve or develop new services, manage and develop our operations, or measure the effectiveness of our website and/or communication efforts. When possible, we will use your information in an aggregated and/or de-identified format.

6. How we Share Personal Information

We may share your Personal Information with third party organizations that have partnered with Kehilla in order to provide Services related to Kehilla. Your Personal information may also be shared with other community organizations for the purposes of assessing your eligibility for assistance, coordinating such assistance with the benefits you receive through other community programs and delivering Services to you, and to assist us in improving our programs. We do not sell your Personal Information to any organization or person; the only exception to this would be if we transfer any part of our operations to another organization. We will not share your Personal Information with any non-affiliated third party without your prior consent, other than as provided in this Privacy Policy or as otherwise authorized by applicable law.

Learn more about how we may share Personal Information: with third party organizations, with third party service providers, in the course of a transfer of operations or activities, for other permitted reasons, and with your consent.

a. Organizations

We may share your Personal Information with third party organizations that have partnered with FCJA for Kehilla. Your Personal information may also be shared with other community organizations for the purposes of assessing your eligibility for assistance, coordinating such assistance with the benefits you receive through other community programs and delivering Services to you, and to assist us in improving our programs. Although we only share the Personal Information needed by such organizations to provide you with access to the Kehilla Services, once Kehilla shares such information with such organizations, it is no longer in the custody or under the control of Kehilla. Those organizations may use that information to contact you or for other purposes in accordance with their own privacy policies. FCJA encourages you to review the privacy policies of the relevant organizations.

b. Service Providers

In the course of providing our Services we may share all categories of Personal Information detailed in the section What Personal Information do we Collect? with third party service providers, such as organizations that we have selected in order to provide or otherwise assist with one or more of the Kehilla Services or who perform other services on our behalf. These service providers help us operate and manage our technology systems and applications, internal procedures, infrastructure and marketing. They provide services to us, such as reviewing and processing applications, sending emails and postal mail, data hosting and analytics services. We require these service providers to limit their access to and/or use of Personal Information to what is required to provide their services and adhere to confidentiality as well as security procedures and protections.

c. Transfer of Operations or Activities

We may decide to transfer all or part of our operations, assets or activities to a third party, to merge with another entity, or to engage in another form of transaction. If your Personal Information is required in connection with any such events, we will comply with the legal requirements for the disclosure of Personal  Information and ensure that the handling of your Personal Information complies with applicable privacy legislation in Canada.

d. Other Permitted Reasons

Applicable laws may permit or require the use, sharing, or disclosure of Personal Information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect FCJA, our employees, those receiving our assistance, or others. If this happens, we will not share more Personal Information than is reasonably required to fulfill that particular purpose.

e. With Your Consent

Other than the purposes listed above, we may, with your implied or express consent, share or disclose your Personal Information outside of FCJA, in accordance with applicable laws.

7. Third Parties

Third parties that you connect with directly through hyperlinks or other information provided on our Website, such as organizations that have partnered with us to provide Kehilla Services, may link and combine information about you to other Personal Information they may have collected on you, to achieve their own goals and purposes. We do not collect, use or disclose such information, which is subject to the privacy policies of the third party organization. FCJA encourages you to review the privacy policies of such organizations as well.

8. How we Manage Consent

By applying for Kehilla, responding to emails or otherwise submitting information to us in connection with using the Kehilla Services, you are providing your consent to the collection, use and disclosure of Personal Information as set out in this Privacy Policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your Personal Information.

We will generally obtain consent when we want to use Personal Information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy or in the terms and conditions of a specific Service. Your consent can be withdrawn at anytime, except in limited circumstances, including legal or regulatory  requirements or as a result of your contractual obligations with us. For information on how to manage your privacy preferences, please see Your Privacy Choices.

If you choose not to provide us with certain Personal Information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you Kehilla Services that you applied for or that could be offered to you.

9. Your Privacy Choices

We want you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences, including, for example: managing your preferences within your account when applicable, contacting us directly, changing your browser settings on your device, and/or, where available, using third party unsubscribe functionality.

Learn more about how to change your privacy choices when you apply or by contacting us directly and by using third party unsubscribe functionality.

a. When You Apply or by Contacting Us Directly

You may opt in to receiving email or other electronic communications at the time that you apply for Kehilla, or any time thereafter through your online account. We may also have your implied consent to send you such electronic communications under applicable laws.

You may opt out of receiving email promotional communications by clicking “unsubscribe” with in any promotional email you receive or through your online account (if you have create done).

Please note the following regarding withdrawal of consent or changes in your privacy preferences:

    • Even if you have opted out of receiving promotional communications from us, we may still contact you for purposes relating to services provided, incompliance with applicable laws (e.g., to convey information about  Kehilla Services that you are receiving from us). We may also need to contact you with questions or information regarding your inquiries; and
    • It may take some time for all of our records to reflect changes in your preferences (e.g., if you request that you not receive promotional communications from FCJA, your preference may not be captured for a promotion already in progress).

b. Using Third Party Unsubscribe Functionality

We may use third parties(e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behavior as you visit our Website. You can manage your privacy preferences with respect to certain third parties, such as Google, by using the unsubscribe or do-not-track functionality with in their platforms, or by disabling cookies when you visit our Website. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our Website.

10. How we Store and Safeguard Personal Information

We take the security of your Personal Information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safe guards. Your Personal Information may be stored in foreign jurisdictions, in which case it will be subject to foreign laws. We store your Personal Information for as long as it is necessary to provide you with our Services and for a reasonable time there after, or as permitted or required by law.

We are based in the Canada. The Services are controlled and operated by us from Canada and are not intended to subject us to the laws or jurisdiction of any state, country or territory. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Learn more about how we protect Personal Information,where we keep Personal Information and cross-border transfers and how long we keep Personal Information.

a. How we Protect Personal Information

We employ organizational, physical and technological measures to protect the confidentiality of Personal Information and to safe guard Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your Personal Information.

b. How Long we Keep Personal Information

We will store your Personal Information for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your Personal Information will be securely destroyed or anonymized (so the information no longer identifies you).

c. Cross Boarder Transfer of Personal Informal

While we endeavor to keep your Personal Information within Canada, we may access, store or process your Personal Information outside of Canada. Some of our service providers may also access, process or store your Personal Information outside of Canada. We use reasonable safeguards to ensure that our service providers protect your Personal Information wherever it is used or stored.

As a result, when your Personal Information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the Personal Information to the government, government agencies, courts and law enforcement in that jurisdiction.

11. Accessing and Correcting Your Personal Information

You may have the right to access and rectify the Personal Information we hold about you under the law applicable in the jurisdiction where you reside. In this case, upon request, we will provide you with access to your Personal Information with in a reasonable time frame, incompliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.

You can request access or rectification by contacting the applicable Privacy Office as described in the “Who Can You Contact With Privacy Questions?” section.

12. Children

We do not knowingly request or collect Personal Information regarding children under 13 years of age without prior verifiable consent of his or her parent or legal guardian and complying with any other legal requirements. If we become aware that we have unknowingly collected Personal Information about a child without verifiable parental or legal guardian consent, we will delete this information from our records or take reasonable available steps to de-identify the information.

13. Changes To Our Privacy Policy

We may make changes to this Privacy Policy from time to time. Any changes we make will become effective when we post a modified version of the policy on our Website. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. By continuing to use our Services after the modified version of the Privacy Policy has been posted or you have been informed of such update, you are accepting the changes to the Privacy Policy. If you do not agree to the changes in our Privacy Policy, it is your responsibility to stop using our Services. It is your obligation to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective Date” at the top of the Privacy Policy indicates when it was last updated.

14. Who Can You Contact With Privacy Questions?

If you have any questions about how we handle your Personal Information, please contact us as indicated below. If you are participating in a program, event, promotion, contest or survey that is offered by us jointly with a third party, the third party may hold your Personal Information. If you have any questions or concerns, we will direct you to the appropriate party so that you may make enquiries as to that party’s privacy policies and practices.

 

Phone number: 514-343-8708

Email address: privacy@federationcja.org