Effective Date: February 20, 2022
1. Commitment to privacy
This website – https://reelshorts.ca (the “Site”) – is owned and provided by the Reel Shorts Film Society (“Society”, “we”, “us” or “our”), a non-profit society registered in Alberta, Canada. We are committed to maintaining the security and privacy of your personal information. This Policy has been developed in compliance with the Alberta Freedom of Information and Protection of Privacy (FOIP) Act.
This Policy describes how we collect, use and disclose personal information when you use our Site, products, and services, and the rights you have associated with such information.
We are accountable and responsible for personal information under our control. We have designated a Privacy Officer who is accountable for our compliance with this Policy. If you have any questions about this Policy, please contact our Privacy Officer using the details set out at the end of this Policy.
2. Scope of Policy
This Policy addresses personal information about individuals which includes any information about an individual from which the personal can be identified. Personal information does not include information where the identity of the individual has been removed (anonymous data), information concerning corporate or commercial entities, or information that is publicly available.
3. Collection of information
This Site collects and uses personal information as part of operations and in the provision of our products and services.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser type, Internet Protocol (“IP”) address, device type, operating system, and cookies that are installed on your device (collectively, “Device Information”). Additionally, as you browse the Site, we collect information about the individual web pages that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site (collectively, “Usage Information”).
We collect Device Information and Usage Information using cookies and other technologies. Please refer to the section entitled “Cookies Usage” for more information on the technologies that we use to collect Device Information and Usage Information.
Additionally, when you sign up for a membership, subscribe to our newsletters, make a purchase or attempt to make a purchase through the Site, we collect certain information directly from you, including your name, billing address, payment information (including credit card numbers), email address, and phone number (collectively, “Order Information”).
We will not collect personal information indiscriminately and will limit the collection of your personal information to what is reasonably necessary to provide our products and services and which is reasonably necessary for the purposes consented to by you.
We collect your personal information for the following purposes:
- to provide and administer products and services requested by you and to use and disclose the information for purposes related to providing the requested products and services such as to facilitate payment processing for the requested products and services;
- to protect the Society, yourself and others from fraud and error and to safeguard the financial interests of the Society;
- to authenticate your identity;
- to communicate with you including but not limited to responding to your questions or concerns, sending notifications and emails to you about our products and services, soliciting feedback from you about our products and services, sending you administrative information such as updates to this Policy, and sending you news, special offers and general information about our other products, services and events that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
- to enable you to participate in interactive features of the Site when you choose to do so;
- to improve our Site, monitor the usage of our Site, detect, prevent and address technical issues related to our Site;
- to collect debts owed to the Society; and
- to comply with legal and regulatory requirements.
The purposes listed above are a reasonably necessary part of your relationship with us.
When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by FOIP or other laws and regulations (for example, the European Union General Data Protection Regulation or GDPR).
5. Your reviews and comments
We may select and post customer testimonials, reviews and/or comments on our Site, which may contain personal information such as your name and/or the city, province or country in which you live. When submitting your testimonials, reviews or comments on questionnaires, you have the opt-in option of giving us permission to post them on the Site and they will be available to other users of the Site. Your posting may also become public and we cannot prevent such information from being used in a manner that may violate this Policy or the law. If you would like us to remove your name, testimonial, review or comment from our Site, you may contact our Privacy Officer using the information provided in this Policy. Note that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of our Site for a period of time.
6. Cookies Usage
Cookies are files with a 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. Our Site uses the following types of cookies:
- Necessary Cookies. These cookies are necessary for the proper function of a website, they enable basic functions like page navigation and access to secure areas of the website;
- Preference Cookies. These cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in;
- Statistics Cookies. These cookies help us to understand how visitors interact with the Site by collecting and reporting information anonymously; and
- Social Media Buttons. Our Site includes social media buttons to promote our social media channels such as our Twitter, Facebook, and Instagram channels. These buttons work through pieces of code that come from the social media service providers. Cookies are placed using these codes which we have no influence on. To understand how these social media service providers collect, use and otherwise process your personal information via these cookies, please review their privacy policies at:
- Facebook: https://www.facebook.com/policy.php
- Twitter: https://twitter.com/en/privacy
- Instagram: https://help.instagram.com/519522125107875
We also use Google Analytics to monitor and analyze the use of our Site. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Such data are shared with other Google services. You can learn how to opt-out of Google Analytics by downloading the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout. For more information on Google’s privacy practices, please see Google Privacy & Terms at https://www.google.com/intl/en/policies/privacy/.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, this may prevent you from taking full advantage of our Site. For more information about cookies and how to disable them, please visit http://www.allaboutcookies.org.
7. Consent and disclosure
We will seek your consent to collect, use or disclose personal information except where we are authorized or required by FOIP or other laws and regulations to do so without consent.
Your consent may be express or implied, or given through your authorized representative.
Consent may be provided orally, in writing, electronically, or otherwise. For example, oral consent could be expressed over the telephone at the time information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application form.
You may withdraw your consent at any time, subject to legal or contractual restrictions, provided reasonable written notice of withdrawal of consent is given by you to us. Upon receipt of your written notice, we will inform you of the likely consequences of the withdrawal, which may include our inability to provide certain products or services for which the delivery of that information is a prerequisite.
Your credit card information collected through our Site is encrypted through the Payment Card Industry Data Security Standard (“PCI-DSS”). All our payment processors adhere to the PCI-DSS as managed by the Payment Card Industry 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 credit card information by our Site and our service providers. We do not currently retain credit card numbers internally.
You hereby also consent to us disclosing your personal information to public bodies as required in order to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
8. Legal basis for processing (for EU residents only)
For individuals in the European Union, our processing of personal information is justified on the following legal bases:
- Performance of Contract: the processing is necessary to perform a contract with you or take steps to enter into a contract at your request;
- Our Legitimate Interests: the processing is in our legitimate interests, namely, in using applicable information to conduct and develop our non-profit activities, such as developing and maintaining relationships with our customers, to understand how our customers use our products and services, and to operate and grow our operations (the majority of the processing covered by this Policy is legitimate interest based), subject to your interests and fundamental rights;
- Defend Our Rights: where the processing is necessary to the establishment, exercise or defence of legal claims; or
- With Your Consent: you have consented to the processing (for example, when you consented to receiving our newsletters).
9. Retention of information
Your personal information will only be used or disclosed for the purposes set out above and as authorized by FOIP and other laws and regulations.
We will keep personal information for no longer than is necessary for the purposes for which the information was required, to comply with any of our legal obligations, to resolve disputes, or to enforce our contractual agreements.
Usage Data will be retained for internal analysis purposes, to strengthen security, and to improve the functionality of our Site. This information will be destroyed once it is no longer necessary for these purposes.
We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
We will take due care when destroying personal information so as to prevent unauthorized access to such information.
10. Safeguarding and third-party sites
We protect the personal information under our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
You should be aware that confidentiality and security are not assured when information is transmitted through email or wireless communication. We will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when information is transmitted by email or wireless communication.
We will take all reasonable steps to ensure that personal information is handled securely and in accordance with this Policy.
11. Your rights
You have the following rights regarding your personal information that is under our control:
- Right to Access: You may request access to your personal information held by us. Upon written request and authentication of identity, we will provide you with your personal information under our control, information about the ways in which that information is being used, sources that the information was collected from, and/or a description of the individuals and organizations to whom such information has been disclosed. We may charge a reasonable fee for providing the information in response to your request to cover our administrative costs and will provide an estimate of any such fee upon receiving a your written access request. We will make the information requested available within 30 days or provide written notice where additional time is required to fulfill the request. In some situations, we may not be able to provide access to certain personal information. We may also be prevented by law from providing access to certain personal information. Where an access request is refused in whole or in part, we will notify you in writing within 30 days of request, giving the reason for refusal and outlining further steps which are available to you.
- Right of Correction: We will comply with your request to correct incomplete or inaccurate parts of your personal information, although we may need to verify the accuracy of the new information you provide us. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.
If you are a resident of the European Union, you will also have the following rights regarding your personal information under our control:
- Right to be Forgotten: Upon your request to erase your personal information under our control, we will do so promptly if the personal information is no longer necessary in relation to the purposes for which it was collected, you withdraw the consent which formed the basis of your personal information processing, you object to the processing of your personal information, the personal information was processed illegally, or if the personal information must be deleted for us to comply with our legal obligations. When a request has been made and the personal information has been shared with third parties, we will take reasonable steps to inform third parties that are processing the information that you have requested it to be erased. We may decline your request for deleting if the processing of your personal information is necessary to comply with our legal obligations, in pursuit of a legal action, or for the performance of a task in the public interest.
- Right to Stop Direct Marketing: At your request, we will stop using your personal information for the purpose of direct marketing. If you want to stop us from calling or emailing you in connection with marketing communications, please contact our Privacy Officer using the details set out at the end of this Policy. Please note that even if we stop all marketing communications, you may still receive administrative communications from us.
- Right to Restrict Processing: At your request, we will limit the processing of your personal information if the accuracy of the information is contested, the information was processed unlawfully but you oppose the erasure of your personal information, we no longer need your personal information but you require retention of the personal information in connection with a legal claim, or you object to the processing of your personal information pending verification of whether overriding legitimate grounds for such processing exist. We will make reasonable effort to inform third parties with whom your personal information has been shared of your request to restrict processing.
- Right to Data Portability: At your request, we will provide you free of charge with your personal information in our control in a structured, commonly used and machine readable format, if you provided us with the personal information, the processing of your personal information is based on your consent or required for the performance of a contract, or if the process is carried out by automated means.
12. International transfer
The Site, and the features and functionality of the Site, may be provided using resources and servers located in Canada, the United States and other countries. Therefore, your personal information may be transferred, processed and stored outside the country where you access the Site. We will protect the privacy and security of personal information we collect in accordance with this Policy, regardless of where it is processed or stored. Such transfer is necessary for the purposes set out in this Policy. By allowing us to collect your personal information, you consent to such transfer and the processing thereof. While your personal information is located outside your home jurisdiction, it may be subject to the laws of the jurisdiction in which it is retained.
We contractually require agents, service providers, and affiliates who may process personal information related to the Site to provide the same level of protections for personal information as required under the Policy. We currently do not transfer personal information to a third party for the third party’s own use, but only for the purposes as outlined in this Policy.
13. Child Privacy
Our Site is not directed to, and we do not knowingly collect personal information from, persons under the age of majority. If you are under the age of majority in your home country, please do not use our Site. If we are made aware that we have collected any personal information from a minor without parental consent, and are asked to erase such information from our database, we will do so without undue delay.
14. Automated decision making
Automated decision making takes place when our electronic systems process your personal information to make a decision about you without human intervention.
You will not be subject to decisions that will have a legal or significant impact on you based solely on automated processing, unless we have a lawful basis for doing so and we have notified you.
15. Do not track
We do not support Do Not Track (“DNT”). DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.
16. Changes to policy
To keep pace with economic and technological changes, we may revise this Policy from time to time. We will inform you of any material changes via email and/or a prominent notice on our Site prior to the change coming into effect. The “Effective Date” at the top of this Policy will be updated with each amendment. We advise you to review this Policy from time to time for any changes.
Any inquiry, complaint or question regarding this Policy must be directed in writing to our Privacy Officer.
Privacy Officer – Terry Scerbak
Reel Shorts Film Society