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PRIVACY POLICY

This Privacy Policy was last updated November 18, 2010.

The textED.ca website (the “Website”) is owned and operated by the Canadian Centre for Child Protection Inc. (the “Centre”) which operates out of Winnipeg, Manitoba, Canada. The Centre is a not-for-profit, charitable organization dedicated to the personal safety of all children. The goal of the Centre is to reduce child victimization by providing programs and services to the Canadian public.

Intended Audience and Purpose of Website

This website is intended for use by Canadian students in Grade 7 or higher, and their teachers. The purpose of this site is to provide users with information and resources designed to increase textual awareness and safety. Games and other interactive content are provided to enhance the site and encourage learning, and any personal information collection, use and disclosure that occurs through interactive activities is incidental to the operation of the games and interactive content.

The provisions of federal privacy legislation in Canada (the Personal Information Protection and Electronic Documents Act (PIPEDA)) applies to personal information that is collected, used and disclosed in the course of commercial activities. This Website is not operated in the course of commercial activities, nor is it operated for commercial purposes. Although the Centre does not consider the collection, use and disclosure of personal information obtained through the site to be a commercial activity, the Centre nonetheless believes that maintaining the privacy of your personal information is of the utmost importance and accordingly it adheres to the spirit of PIPEDA in its operation of this Website.

This online Privacy Policy describes how personal information obtained through this Website is collected, used and disclosed by the Centre. This Policy applies to users of the textED.ca website only, and it reflects the spirit of PIPEDA. We encourage you to read this Privacy Policy to gain a better understanding of how your personal information will be treated when you visit and use the textED.ca website.

Definition of Personal Information:

Personal information is any identifiable information about an individual, including: name, e-mail address, mailing address, and telephone/fax number. Personal information does not include aggregated information that cannot be associated with a specific individual.

Privacy Policy Applicable to the textED.ca Website

We respect your privacy. We developed this privacy policy in order to ensure our users are confident that their personal information will be handled in a reasonable manner. We feel it is important for users of this Website to understand what information we collect, why we collect it, how we will use and disclose it, and how they can contact us with privacy-related questions. Whether you are visiting the Website to obtain access to resources and information or to complete a report form, we are committed to respecting your privacy and personal information.

In order to observe the spirit of PIPEDA, the Centre has adopted the 10 Privacy Principles contained within the Canadian Standards Association Model Code for the Protection of Personal Information. A summary of the principles is set out below, and following is a brief explanation of how the principles are applied with respect to the information received through the Website.

Summary of Privacy Principles

The following is a summary of the privacy principles we adhere to. Further explanation of each principle follows:

  1. Our responsibility to protect your personal information
    The Canadian Centre for Child Protection Inc. is responsible for personal information under its control, and as such has designated an individual who is accountable for compliance with the following principles. See principle 10 for contact information.
  2. Our obligation to identify the purpose for collecting personal information
    The Centre will identify the purposes for which personal information is collected at or before the time of collection. On this Website, see below for the purposes for collection.
  3. The requirement for knowledge and consent
    The individual's knowledge and consent are required for the collection, use, or disclosure of personal information, except where inappropriate. In determining the appropriate form of consent, the Centre shall take into account the sensitivity of the information and the reasonable expectation of the user. When you use this Website, it is implied that you have consented to the use of your information for the purposes identified.

    Note: In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example:
    1. the Centre may collect, use or disclose personal information if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated
    2. the Centre may collect, use or disclose personal information if seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or a contravention of federal or provincial law
    3. the Centre may use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened
    4. the Centre may disclose personal information without knowledge or consent to a lawyer representing the Centre, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.
  4. Limiting information collection
    The collection of personal information will be limited to that which is necessary for the purposes identified by Canadian Centre for Child Protection Inc. Information will be collected by fair and lawful means.
  5. Limiting Use, Disclosure, and Retention of your personal information
    Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual, to comply with a government request, to protect the operations of the Centre, or as required by law. In certain circumstances such as where we consider an individual to be potentially at risk of exploitation, based on the information provided by that individual, we may use or disclose personal information where we consider such use and disclosure to be in the best interest of the individual. Personal information will be retained only as long as necessary for the fulfillment of those purposes. Only those employees of the Centre who require access to personal information for business reasons, or whose duties reasonably so require, are granted access to personal information.
  6. Accuracy of your personal information
    Personal information will be as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.
  7. Our responsibility to safeguard your personal information
    The Canadian Centre for Child Protection Inc. has security safeguards in place designed to protect personal information against loss, theft, unauthorized access, disclosure, use or modification. Such safeguarding measures may include but are not limited to alarm systems, locked cabinets, computer passwords, firewalls and encryption.
  8. Our obligation to be open about our Privacy Policy and practices
    If additional specific information about our policies and practices of personal information management are required, such information will be provided to individuals upon receiving a written request.
  9. Your right to access your personal information
    Upon request, an individual will be informed of the existence and use of his or her personal information, and will be given access to that information. An individual will be able to challenge the accuracy and completeness of their information and have it amended accordingly.
  10. Your right to challenge the compliance of our Privacy Policy
    If for any reason, you have questions or concerns about this Privacy Policy, please contact our Privacy Officer by mailing a letter outlining your concerns to:

    Privacy Officer
    Canadian Centre for Child Protection Inc.
    615 Academy Road, Winnipeg, Manitoba R3G 0N4

Application of the above principles to Information provided by the users of textED.ca

What Information Do We Collect from Visitors to the Site:

From all Users:

All information provided by your computer during your visit is collected. Session cookies are used to gather some of the information below, and some of the information is delivered automatically by your computer. This information is aggregated and non-personally identifying. It includes:

  • Your IP address
  • The search terms you used
  • The pages you accessed on our site and the links you clicked on
  • The date and time you visited the site
  • The referring site (if any) through which you clicked through to this site
  • Your operating system (e.g. Windows XP, Mac OSX)
  • The type of web browser you use (e.g. Internet Explorer, Mozilla Firefox) and
  • Other incidental matters such as screen resolution, the release of your installed Flash version and the language setting of your browser.

The above information is used to help us better understand our audience and how our site is being used so we can improve it for subsequent users and deliver content in the appropriate format during your visit. It is also provided to gather broad, aggregated demographic information (such as geographical, domain and ISP information) and, compile statistical information about the use of the Website.

From participants in the Rock Paper Scissors game:

If you choose to play the Rock Paper Scissors game, your cell phone number and username will be collected, used and disclosed for the purpose of facilitating your playing the game. For the cell phone number, a third party is involved in processing and delivering the text messages and that party is contractually bound to use the cell phone number for the sole purpose of administering the game. Your cell phone service provider is also involved. Your username is included in the text message delivered as part of the game. No other information is shared with the aggregator and service provider. Internally, your cell phone number is linked to your user name and your game results may be posted with your username on the Website from time to time. We may also use your cell phone number to let you know what username you have been assigned, in cases where the username you have chosen has not yet been approved or is not accepted.

When you submit information through “Contact Us”:

If you submit a question or comment through the “Contact Us” section, we collect the text of your message (which may contain personal information depending on what you entered). We use the text for the purpose of responding to your message. We will also collect your email address, if provided.

When you click the “Need Help Now”:

If you choose the “Need Help Now” section of the website, we collect the text of your message (which may contain personal information depending on what you entered), and your email address. We use the text and email address for the purpose of responding to your message.

From Teachers:

If a teacher chooses to register their class, we collect the name of the teacher, the name of the school they are with, the address of the school, and an email and phone number. We use this information to verify that the teacher is at a school in Canada and to provide the teacher with a login and password to access the teachers’ only page, and to communicate with the teacher about changes and enhancements to the Website or to obtain feedback on various features of the Website.

Participants in Projects or Contests:

If you participate in a project or contest and submit personal information with your project or contest entry, we collect, use and disclose the information solely for the purpose of evaluating the submission or processing the contest entry.

Contact Information:

In cases where contact information is included in a submission to the Website (whether through “Contact Us”, “Need Help Now”, or a general posting/submission), we generally collect, use and disclose that information for the purpose of responding. With a general posting/submission that is accepted for posting, only the username associated with the posting will appear on the Website, however we may use the contact information you provided to communicate additional and other information to you.

Why We Collect Information:

On this Website, we collect, use and disclose personal information for the following purposes, or other purposes that may be identified to you at the time of collection:

  1. To educate Canadian youth (grade 7 and older) and their educators about how to use cell phone technology respectfully;
  2. To provide Canadian youth (grade 7 and older) and their educators with accessible information and resources on issues surrounding cell phone technology, privacy, and safe texting practices;
  3. To provide a positive user experience;
  4. To understand user requirements and make information available to users;
  5. To further our mandate of protecting children from sexual abuse and exploitation; and
  6. To meet legal and regulatory requirements.

How We Use What We Collect:

All personal information we receive from you is used for the purpose of operating and administering the Website, responding to you, and facilitating your use of games or other features on the site, and as described in the “What Information Do We Collect from Visitors to the Site” section above. We will not use your personal information for other purposes except with your consent, or where we have reason to suspect that: you or someone you know is or may be at risk or in need of protection; you are or may be a risk to a child or children; you are involved in unlawful activities; or our site has been compromised or misused.

We also use information provided through the use of the Website to generate statistical reports to enable us to improve the user experience, identify trends, and help us to more effectively target communication and awareness activities.

Who Do We Share Information With

With the exception of the Rock Paper Scissors game, which necessitates the disclosure of your cell phone number to an aggregator and to the service providers involved with the process, we do not disclose your personal information to others. An exception would be where we have reason to suspect our Website has been compromised or misused; that you are involved in unlawful activities; or that you are or may be a risk to a child or children, in which case we may disclose information we have about you to law enforcement and/or child welfare, as appropriate.

Where we believe you are a child, and something that you have posted or submitted to us gives us reason to suspect that you or someone you know may be at risk or in need of protection, we consider ourselves obligated to report that information. In such cases, any contact information that may have been included in the posting or submission, together with any other information collected during the use of the Website or the features of the Website that can be associated with the user, may be shared with law enforcement agencies and/or child welfare agencies as appropriate. We may also share information with emergency services in emergency situations, and we share information as required by statute or court order.

How We Protect Information

All transmitted information is protected using measures that are reasonable given the sensitivity of the information. Physical and technical security measure including firewalls and access lists are employed to protect the computer servers and databases within which information is stored. Physical or digital access to report information is restricted to those within the organization who have a need to know. However, users should be aware that the internet is a public network, and as such cannot be considered 100% secure.

Questions and Concerns

If you have any questions or concerns about our privacy practices, please send a letter outlining your concerns to:

Privacy Officer
Canadian Centre for Child Protection Inc.
615 Academy Road, Winnipeg, Manitoba R3G 0N4

You may also submit your question by contacting us through the Contact Us page accessible from https://www.protectchildren.ca/app/en/privacy_contact.

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