Privacy Policy Update

Last updated September 01, 2023

 

This privacy notice for Congregation Shaar Hashomayim (‘we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you interact with us such as when you:

• Apply for Shul membership, marriage, conversion, bar/bat mitzvah, baby naming, study group, or daycare
• Register for an event
• Begin employment with us

 

1. WHAT INFORMATION DO WE COLLECT?

 

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our services, when you participate in our activities, or otherwise contact us.

 

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• mailing addresses
• job titles
• debit/credit card numbers
• social insurance numbers
• date of birth

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• health data
• financial data
• information revealing religious or philosophical beliefs

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

2. HOW DO WE PROCESS YOUR INFORMATION?

 

• We process your personal information for a variety of reasons, depending on how you interact with us, including:
• To evaluate your membership application.
• To send administrative information to you.
• To send you marketing and promotional communications about our events.
• To determine the effectiveness of our marketing and promotional campaigns.
• To send you notices regarding life events in the community
• To provide any other service you request

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

 

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

 

• In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the information is publicly available
• For internal research and analytics (when anonymized)

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

 

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. These parties may be located outside the province of Quebec. The third parties we may share personal information with are as follows:

• Cloud Services: ShulCloud, Dropbox, Google and Microsoft
• Communications: MailChimp, SurveyMonkey and Constant Contact
• Invoice and Billing: PayPal and Elavon

 

5. HOW LONG DO WE KEEP YOUR INFORMATION?

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 7 years if required by law, or as long as you are a member of our Shul.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information. If your information is archived for legal purposes then

we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

 

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. Access controls are in place to limit exposure of your information to employees who need it for the purposes listed above.

 

7. DO WE COLLECT INFORMATION FROM MINORS?

 

We collect information from minors when it is provided to us by a parent or legal guardian. This information is collected when you wish to mark significant life events at the Shul such as a baby naming or Bar/Bat Mitzvah.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

 

Under Quebec law, you have the following rights with respect to your personal information:

• Right of access: You have the right to access any personal information we have concerning you (unless restricted by law) in a common, readable format.
• Right of rectification: If your information has changed, or if you discover an error with regards to your information, you have the right to request that it be modified.
• Right to withdraw consent: We will always ask for your consent prior to collecting your information. You will be fully informed of what data we are collecting, the purposes for which it is collected, and rights granted to you. The information will only be used for the purpose described. Your consent can be withdrawn freely at any time, without consequence
• Right of erasure: You have the right to request that we delete your personal information, if we do not have a legal or business obligation to retain it.

To exercise any of these rights, please see ‘HOW CAN YOU CONTACT US ABOUT THIS NOTICE?’ below. We will consider and act upon any request in accordance with applicable data protection laws.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you for non-marketing purposes if you are a member of the Shul.

 

If you have questions or comments about your privacy rights, you may email us at privacy@theshaar.org.

 

 

9. DO WE MAKE UPDATES TO THIS NOTICE?

 

We may periodically update our privacy policy. The ‘Revised’ date above will indicate the date that the latest version comes into effect.

 

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may contact our Privacy Officer (PO) by email at privacy@theshaar.org, or contact us by post at:

 

Congregation Shaar Hashomayim

450 Av. Kensington

Westmount, Quebec H3Y 3A2

Canada