This Privacy Policy is designed to inform users about the practices of guelpharts.ca / wellingtonarts.ca regarding the collection, use and disclosure of personal information on the site. It is the responsibility of all users to read this Privacy Policy in its entirety before using or submitting information to this site.

NOTE: Because this policy is still under development, users should check back periodically to review any changes that might have been made since they last read it. Whenever changes are made, an announcement will be made in the News section of guelpharts.ca / wellingtonarts.ca.

Introduction

guelpharts.ca / wellingtonarts.ca is committed to following the ten principles outlined in the federal Personal Information Protection and Electronic Documents Act (PIPEDA) which came into force on January 1, 2004. In that legislation, personal information is defined as "information about an identifiable individual." It does not include personal information consisting of name, address and telephone number that appears in a telephone directory that is available to the public, where the subscriber can refuse to have the personal information published in the directory. Business contact information is excluded from this definition.


1. Accountability

guelpharts.ca / wellingtonarts.ca is an arts and heritage website that includes many sub-sites set up by individuals and groups who pay a fee to be contributing members of the site. The site as a whole is overseen and administered by Guelph Arts Council in consultation with an Advisory Committee. Contributing members administer their own sub-sites, and are responsible for adhering to this guelpharts.ca / wellingtonarts.ca Privacy Policy and for developing their own privacy policies. When visiting or contributing to guelpharts.ca / wellingtonarts.ca sub-sites, users are advised to consult their privacy policies.

guelpharts.ca / wellingtonarts.ca has in place several personal information handling policies to ensure protection of the personal information under its control. In cases where personal information is controlled by third-parties – individuals or groups with their own sub-sites – guelpharts.ca / wellingtonarts.ca endeavours by contractual and other means to ensure these third parties have policies and procedures to similarly protect the personal information under their control.

To oversee compliance with personal information policies, guelpharts.ca / wellingtonarts.ca has named the Executive Director of Guelph Arts Council (the not-for-profit, charitable organization serving as administrator of this website) as the site's Privacy Officer. Any questions, comments, requests, or complaints regarding this Privacy Policy should be directed to this individual at contact info@guelpharts.ca or info@wellingtonarts.ca.

2. Identifying Purposes

Active Information Collection
guelpharts.ca / wellingtonarts.ca actively collects information from its visitors by asking them specific questions and by permitting them to communicate directly with guelpharts.ca / wellingtonarts.ca via email and/or feedback forms. In addition, some areas of this site may require individuals to submit information in order for them to benefit from the specified features or to participate in a particular activity (e.g. sign up for email subscription lists or request an event reminder).

In these instances of active information collection, some of the information that individuals provide may be personally identifiable information. Individuals will be informed at each collection point what information is required and what information is optional, and they will be asked for their consent (see also section 3 below). Organizations and individuals who set up their own sub-sites on guelpharts.ca / wellingtonarts.ca are expected to follow the same procedure.

Any personally identifiable information collected by the site will be used only for the purpose for which it was collected, and for which consent was given. Organizations / individuals who are contributing members to the site will have access to personal information only where individuals have given their consent (e.g. email subscription lists). If at any time individuals wish to unsubscribe to email lists or be removed from databases connected to this website, they should contact info@guelpharts.ca or info@wellingtonarts.ca.

guelpharts.ca / wellingtonarts.ca is not responsible for personal information collected, used or disclosed by individual or group members who set up their own sub-sites or for any external website linked from the guelpharts.ca / wellingtonarts.ca site. For their policies and procedures, consult the Privacy Policy posted on each of the sub-sites / external sites.

Passive Information Collection
As users navigate through this web site, certain information can be passively collected (that is, gathered without users' actively providing the information) using various technologies such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection. These data do not collect personally identifiable information; they are aggregate information primarily for producing statistics on how the site is used by visitors; anonymity of the visitors is maintained at all times.

Change in Purpose
If guelpharts.ca / wellingtonarts.ca contemplates any changes in the intended purpose(s) for collecting personal information, explicit permission to use the information for the new purpose(s) will be sought from the individual(s) who provided the information in the first place.


3. Consent

Obtaining Consent
guelpharts.ca / wellingtonarts.ca will obtain consent from individuals to collect, use, and/or disclose their personal information. Consent will be obtained either before or at the time of collection, and in cases where a new purpose(s) has been identified after collection, consent will be obtained for the new purpose prior to use.

guelpharts.ca / wellingtonarts.ca also recognizes that the principle of obtaining consent is dependent on the level of sensitivity of the information and the reasonable expectations of the individual, and will make a reasonable effort to take this principle into consideration whenever appropriate.

Withdrawing Consent
Any time any individuals wish to withdraw consent, they can contact the guelpharts.ca / wellingtonarts.ca Privacy Officer, and the procedures and consequences of withdrawal will be explained. After such discussion and the identity of the individuals and/or groups has been verified, guelpharts.ca / wellingtonarts.ca Privacy Officer will take the necessary and requested actions required to handle withdrawal of consent.


4. Limiting collection

guelpharts.ca / wellingtonarts.ca will collect information only for the purposes stated before or at the time of collection of that information. At that time, the amount and type of information being collected will be specified, and collection will be limited to those specifications.


5. Limiting use, disclosure and retention of personal information

Use and Disclosure
guelpharts.ca / wellingtonarts.ca will use and disclose personal information only for the purposes stated before or at the time of collection of that information. At that time, the amount and type of information being collected will be specified, and use and disclosure will be limited to those specifications. At no time will information be sold or traded to any individual, organization or business.

Retention
guelpharts.ca / wellingtonarts.ca will retain personal information about site visitors only if and when they sign up and give consent related to any of the site's special features. In such cases, personal information will be retained only as long as those visitors wish to avail themselves of these special features. If and when visitors indicate that they wish to cancel use of or participation in any of these special features, their personal information will immediately be erased.

guelpharts.ca / wellingtonarts.ca will retain personal information about site members as long as they are contributing, paid-up members of the site. For any members who let their memberships lapse through choice, non-fulfillment of obligations or non-payment of fees, their information will be retained in hard copy by the site administrator for one year from the date of their membership lapsing, after which any personally identifiable information will be destroyed, erased or made anonymous.

Legal Disclaimer
Though guelpharts.ca / wellingtonarts.ca makes every effort to preserve user privacy, we may need to disclose personal information when required by law when we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order, or legal process served on guelphrts.ca / wellingtonarts.ca or Guelph Arts Council.

Organizational Change
In the event that Guelph Arts Council should merge with or transfer its assets or turn over responsibility for the administration of guelpharts.ca / wellingtonarts.ca to another organization or entity, users' information will, in most instances, be part of the assets and/or responsibility transferred.


6. Accuracy

Main site
guelpharts.ca / wellingtonarts.ca will endeavour to keep information as accurate, complete and up-to-date as is necessary for the puposes(s) for which it was collected, used and/or disclosed. However, it is also incumbent upon all individuals and groups who are members of the site to inform the site administrator of any changes they wish to make in personal information. Similarly, users of the site -- such as subscribers who use any of the site's email subscription lists or who request reminders about specific events -- should also inform the site administrator of relevant changes (e.g. email addresses).

For any such changes to guelpharts.ca / wellingtonarts.ca, members or users should contact the site administrator at info@guelpharts.ca or info@wellingtonarts.ca, and provide both old and new information and indicate when the change is to take effect.

Sub-sites
guelpharts.ca / wellingtonarts.ca is not responsible for the accuracy, completeness or currency of information that is submitted online by individuals (e.g. Artist Directory) or by members setting up and maintaining their own sub-sites. These individuals and members are responsible for maintaining and updating their own sub-sites, including all personal information.

For changes to information on any member sub-sites of guelpharts.ca / wellingtonarts.ca, users should review the privacy policies posted on these sub-sites and/or contact the site administrators of the appropriate sites.

Links
guelpharts.ca/wellingtonarts.ca is not responsible for the accuracy, completeness or currency of any of the personal information on pages linked to or referenced from this site. Users should consult the privacy policies posted on any linked sites.


7. Safeguards

guelpharts.ca / wellingtonarts.ca employs physical, technical and organizational safeguards to protect personal information against loss, theft, unauthorized access, disclosure, copying, use or modification. However, it is the responsibility of users and members to put in place their own safeguards to protect their passwords or ID numbers, or any other special access features related to the guelphrts.ca / wellingtonarts.ca website.


8. Openness

Policy and Procedure Details
guelpharts.ca / wellingtonarts.ca undertakes to make readily available any details of policies and practices related to the management of personal information. Comments, questions and requests should be addressed to the guelpharts.ca / wellingtonarts.ca Privacy Officer at info@guelpharts.ca or info@wellingtonarts.ca.

Changes
If and when guelpharts.ca / wellingtonarts.ca makes any changes to its policies or procedures related to the management of personal information, it will this post information as a news item on the guelpharts.ca / wellingtonarts.ca website, and in any other location (digital or print) deemed appropriate.


9. Individual Access

guelpharts.ca / wellingtonarts.ca undertakes to provide any individual access to any personal information held about that individual, including how the information was collected and how it is being used. The only exceptions to such access would be if the personal information also contains information about another individual(s) or that it cannot be disclosed for legal, security or other reasons. Requests should be made in writing to the Privacy Officer (info@guelpharts.ca or info@wellingtonarts.ca or 147 Wyndham Street North - Suite 404, Guelph, ON N1H 4E9) who will handle them as quickly as possible or within 30 days.


10. Challenging Compliance

Challenges to any aspect of guelpharts.ca / wellingtonarts.ca privacy policies or procedures or its compliance with PIPEDA should be directed to the Privacy Officer who will investigate and respond to all complaints. If an objection is justified, guelpharts.ca / wellingtonarts.ca will take steps to change policies and procedures and to notify all relevant parties of such changes.


This Privacy Policy Last Updated: February 14, 2004



Information
Any users or members who have questions, comments or concerns about this Privacy Policy or the information practices of this website should address these to the Privacy Officer at info@guelpharts.ca or info@wellingtonarts.ca.

Also, please consult the guelpharts.ca / wellingtonarts.ca Legal Notice page on this site.