At Kehillat Shaarei Torah ("KST"), we are committed to protecting the privacy and confidentiality of the personal information of our members. In order to comply with applicable privacy legislation and to instil confidence in our members and potential members that the Personal Information they entrust to us is safe, we have developed this Privacy Policy. We want our members to know why we ask for their personal information, how we use it, what safeguards we employ, and how to contact us with privacy-related questions. In this Privacy Policy, "Personal Information" means information that specifically identifies a member as an individual and is provided to, or collected by, KST and its staff. We may collect Personal Information directly from a member upon applying for membership wish KST, or during the term of membership. We may on occasion obtain information about a member from other sources, such as other family members or members of KST. Personal Information does not include the name, title, business address or telephone number of any employee of any organization. I IDENTIFYING THE PURPOSES AND USE OF PERSONAL INFORMATION KST collects and uses a member's Personal Information for the following purposes:
KST is a vibrant and caring "Kehilla" which is dedicated to our community and supportive of its members. As such, certain information or news about our members and their life cycle events will be shared with the community unless we are notified that it is not to be. II CONSENT KST will not collect, use or disclose a member's Personal Information without the member's requisite consent, except in certain extraordinary circumstances. Such extraordinary circumstances shall include without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent or where it is otherwise in the best interests of the member. Consent for the collection, use and/or disclosure of Personal Information may be obtained orally or in writing and may be expressly given or implied. We may occasionally ask a member to give written consent to the use and disclosure of specific Personal Information. In determining how we obtain consent, we will take into account the sensitivity of the Personal Information that we are collecting, using and/or disclosing. We will use and disclose Personal Information only in accordance with this Privacy Policy. By becoming a member or renewing a membership in KST, a member consents to the terms of this Privacy Policy, including the disclosure of Personal Information to a third party in the circumstances or for the purposes set out in this Privacy Policy. Our members may withdraw their consent by written notice to us at any time, subject to any legal or contractual restrictions and reasonable notice. A member's refusal to provide, or subsequent withdrawal of, his or her consent may affect our ability to provide the member with our services. We will inform the member of the implications of such withdrawal. To withdraw consent, a member should contact KST's Chief Privacy Officer, who is KST's Vice-President from time to time, in writing at: Kehillat Shaarei Torah III LIMITING COLLECTION KST limits the collection of a member's Personal Information to that which is necessary for the purposes identified in this Privacy Policy, or for any additional purpose identified to the member before collection of the Personal Information. IV LIMITING USE, DISCLOSURE AND RETENTION Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the member, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous. KST is guided by and adheres to the standards of Halacha, and, as such, selected items of Personal Information may be retained indefinitely. Under certain circumstances KST may disclose a member's Personal Information:
We never make our membership list available to third parties in any form, except as set out in this section or unless we have consent from our members. Our membership list will be made available to members upon request. If a member does not wish to be included on this list, please contact the Chief Privacy Officer. V ACCURACY KST strives to ensure that a member's Personal Information is as accurate, complete and up to date as necessary for the purposes for which it is used. If a member's Personal Information changes or if a member becomes aware that the Personal Information which we have is incorrect, please inform us so that we can make the necessary changes. VI SAFEGUARDS KST endeavours to maintain adequate safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of members' Personal Information in the care of the KST, including restricted access to Personal Information, locked cabinets and offices and computer passwords. As KST is responsible for any Personal Information under its control, including Personal Information that KST may transfer to a third party for processing, we will use contractual or other means to ensure that the third party will have a level of privacy protection comparable to the internal privacy protection maintained at KST. VII ACCOUNTABILITY, OPENNESS AND MEMBER ACCESS KST is responsible for the Personal Information under its control and has appointed a Chief Privacy Officer to oversee our efforts to comply in all material respects with applicable privacy legislation and the terms of this Privacy Policy. The Chief Privacy Officer and those designated by the Chief Privacy Officer (the "Privacy Team") address and investigate questions or concerns regarding a member's Personal Information. To reach the Chief Privacy Officer or a member the Privacy Team, please call 416-229-2600 or email: cpo@shaareitorah.com. A copy of this Privacy Policy and any future updates or amendments is available at www.shaareitorah.com. KST will provide a member access to their Personal Information upon written request. Detailed requests that require archive, retrieval or copying costs may be subject to reasonable reimbursement for our actual costs. The member may correct or amend any inaccuracies in the member's Personal Information. KST has the right to refuse a request for access to Personal Information if:
If we deny a request for access, or refuse a request to correct information, we will provide a written explanation. VIII CHALLENGING COMPLIANCE Members are encouraged to discuss any privacy issues with the Chief Privacy Officer or a member of the Privacy Team. IX WEBSITE Our Web site (www.shaareitorah.com) may contain links to other sites, which are not governed by this Privacy Policy. On our Web site, like most other commercial Web sites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information. X COMMUNICATING WITH US Email is not a 100% secure medium and members should be aware of this when contacting us to send personal or confidential information. XI CHANGES TO THIS PRIVACY POLICY KST will from time to time review and revisit privacy practices and this Privacy Policy. In the event of any material amendment, an appropriate notice will be posted on KST's Web site. All members are encouraged to contact KST to establish if any updates have been made to this Privacy Policy, which can be ascertained by the date listed at the top of this Privacy Policy. All updates and amendments to this Privacy Policy can be found at www.shaareitorah.com. |
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