Room 217 Privacy Policy

This Privacy Policy explains how the Room 217 Foundation™ (“Room 217”), will process personal information relating to you that we may collect when you register and use the MUSIC CARE CONNECT™  mobile application (“the APP”) and online services on our Website (“the Website“).

This privacy policy applies only to the actions of Room 217 and any third party who accesses the App or our Website and is not either (i) employed by the Room 217 Foundation and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Room 217 and accessing the App or Website in connection with the provision of such services (“the Users”).

At Room 217, we are committed to protecting and respecting your privacy.

1. INTRODUCTION AND GENERAL TERMS

The App is operated by the Room 217 Foundation (“we”, “us”, “our” or “Room 217”), a company incorporated in Canada as well as a registered Canadian charity number 857285092RR0001 whose registered office is at 970 Scugog Line 8, Port Perry, ON L9L 1B2.

Where we decide the purpose and means for the processing of personal data relating to you, we are the “controller”. As controller, we will comply with all applicable data protection laws, applying to PIPEDA.

Room 217 has a Privacy Officer who is accountable for the Foundation’s overall compliance with its Privacy Policy and acts as the primary contact person on information privacy and security matters. The Privacy Officer can be reached at: Bev Foster, 905.852.2499, or bfoster@room217.ca. The Privacy Officer conducts privacy audits and privacy training on a regular basis to ensure that practices conform to the Foundation’s Privacy Policy.

If you have any questions or comments about this Privacy Policy, please contact us at: Email: info@musiccare.org.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information Room 217 may collect about you or receive from others;
• How and why Room 217 will use that information;
• Whether Room 217 will disclose information about you to anyone else; and
• Your choices and rights regarding the personal information we hold about you.

This Privacy Policy should be read in conjunction with our other policies and procedures, Website terms and conditions, notices, or agreements with you, as may be relevant.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal information:

• Customer Services (including visiting our App and Website)
• Type of information

We may ask you for, or you may submit, personal and non-personal information to us when contacting us through the App or our Website in relation to the products and services that we offer. Personal data that we may obtain includes: your first and last name, email and/or postal address phone number(s) your username (typically your email address) and password any other personal information you voluntarily provide.

Identifying Purposes and Consent

We only collect, use and disclose personal information with your knowledge and consent. Your consent may be expressed orally, electronically or in writing or it may be implied. , We collect, use and disclose personal information for the following purposes: to provide you with information about the products and services that we offer, including news about Room 217 that may be of interest to you; to set up and administer your user account; to enter into and perform our contract for sales of our products and services; to respond to your enquires when you contact us through the App or our Website, by telephone, post or email to resolve issues or fix problems in relation to the App. You have the right at any time to withdraw or cancel your consent to the collection, use or disclosure of your personal information by contacting our Privacy Officer at bfoster@room217.ca. Withdrawals of consent only take effect from the date of cancellation. They cannot be retroactive. We will let you know if your withdrawal could have any consequences, such as our being unable to provide you with goods or services. We will only collect personal information for the purposes identified in this Privacy Policy. If we want to collect information for a different purpose, we will tell you what that purpose is in writing and obtain your consent. 

Limiting Collection

We will not collect, use or disclose more personal information than is reasonably necessary to meet the identified purposes. We will limit our collection of personal information to that which is necessary for the purposes identified in this Privacy Policy. We collect personal information only by fair and lawful means.

Limiting Use and Disclosure

We will only use or disclose personal information for the purposes for which it was collected, unless we have your consent to use it for a different purpose or if we are required by law. If we want to use or disclose your personal information for a new purpose, we will advise you of this purpose in writing and obtain your consent.

Who is this information shared with?

We keep your information confidential. We will not sell your information. We may disclose your information to our personnel and to third party suppliers or subcontractors (including our employees, independent agents and/or professional advisors and third-party payment providers who process payments made via the App or on our Website to support payment and enquiries). In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email, account message and/or a prominent notice on our Website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements between us, to investigate potential breaches, or to protect the rights, property or safety of the companies forming part of Room 217, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

If we do share your information, we will only do so insofar as it is reasonable or necessary for the operation of our business, including for the purposes set out in this Privacy Policy, and subject to contractual agreements with us that prevent third parties from using your personal information for their own purposes and require them to use your personal information only for specific purposes in accordance with our instructions and all applicable legal requirements. In some instances, this data sharing may involve the transfer of information outside Canada. Please see our section on International Data Transfers below.

Setting Up Your Account

Type of information

When you set up your user account, we will ask you to provide us with personal information, which may include the following: full name, date of birth, postal address (including country of residence) information about your preferences and interests, and the operating system you are using (which is automatically collected).

Marketing and Advertising

Type of information

Our App and Website may from time to time contain third party advertising and links to other Websites. These third-party Websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible. Clicking on those links may allow third parties to collect or share information about you. These third-party Websites operate independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Website is not an endorsement. Should you use any of these Websites, such use is at your own risk. You should check the privacy policies of third parties when visiting their websites or when providing any personal information to them. 

We may collect personal information when you interact with our content on third-party sites or platforms, such as Facebook, Instagram or You Tube. This may include data such as comments or feedback, "likes" or shares, profile data or the fact that you viewed or interacted with our content. If you voluntarily post or submit any information on these platforms, your personal information may be automatically included in the posting and may be collected and used by others.

If we do receive any personal information about you from these third-party social media sites, we will not process your information for the purposes of direct marketing unless you have provided your consent, or it is otherwise lawful for us to do so. We may use this information to find out more about our digital community so that we can better understand and serve our customers and Website visitors (for example, to create customized content by analyzing general interests). Where we provide you with information about our products, services or offers (such as via our email updates), we will comply with the requirements of Canada’s Anti-Spam Legislation (“CASL”), as amended from time to time at all times, including when: sending emails or texts from a music care account, email address or domain name, obtaining consent from recipients to send emails or texts, managing and responding to requests to unsubscribe and documenting and retaining records of consent. We do not send commercial electronic messages (“CEMs”) to any person unless it has express or implied consent from the recipient, the CEM includes identification and contact information for the sender and the CEM has an unsubscribe mechanism. To ensure compliance with CASL, we have written policies and procedures, updates its volunteers and staff regarding CASL requirements and keeps records of consents and requests to unsubscribe. Complaints regarding the sending of CEMs and requests to unsubscribe from CEMs should be directed to the Privacy Officer at info@musiccare.org.

Data Analytics and Cookies

We may use cookies to understand how users interact with our App and Website. As you interact with our App and Website, we may automatically collect data about your browsing activities. We use cookies to collect and log analytical information such as the date, times, and frequency with which you access the App and Website. This processing is necessary for us to pursue our legitimate interest in improving the App and Website and providing a more relevant service to our customers. This information is not used to develop a personal profile of you. If you do not want information collected through the use of cookies, you can disable cookies by changing the setting of your Internet browser. If you disable cookies, you may be unable to use or access some features on our Website.

Your Rights In Relation To Personal Information

Individual Access

If you make a request to the Privacy Officer, we will inform you of the existence, use, and disclosure of your personal information and we will give you access to your personal information. We will respond to your request within the time periods provided for under applicable laws.

Challenging Compliance

You can challenge the accuracy and completeness of the personal information and have it changed or corrected as appropriate if there is an error or omission by contacting the Privacy Officer. We will respond to your request within the time periods provided for under applicable laws. If we identify a gap in compliance, we will take appropriate steps to remedy the situation, including changing our policies and practices if necessary.

Limiting Retention

We keep personal information only as long as necessary to achieve the purposes for which it was collected although we may retain certain Personal Information indefinitely if we are required to do so by Canada Revenue Agency or by our insurers. If you have made a request to access personal information, we will keep that personal information for as long as is necessary to allow you to fully seek any remedies (exhaust any recourse) that you may have under federal and provincial legislation across Canada.

If you would like us to stop using your personal information, please email our Privacy Officer at bfoster@room217.ca.

Data Relating to Children

We do not knowingly use the Website to solicit data from or market or sell to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us or otherwise interacting with us without consent of a parent or guardian, we ask that this be brought to our immediate attention. We will make it our priority to address this situation and delete information relating to a child as soon as practicable. In such an event, please contact us at info@musiccare.org.

Security of Data

We protect personal information using security safeguards appropriate to the sensitivity of the information. The security safeguards protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. We protect personal information regardless of the format in which it is held. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. More sensitive information will be safeguarded by a higher level of protection. The methods of protection include (a) physical measures, for example, locked filing cabinets and restricted access to offices; (b) organizational measures, for example, security clearances and limiting access on a “need-to-know” basis; and(c) technological measures, for example, the use of passwords and encryption.

In particular, access to your User account is controlled by a password and a username that is unique to you.

Please be aware that, while we make the security of our App and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. We cannot ensure or warrant the security of any information you provide to us. You can reduce risk to your own personal information by using strong passwords, keeping your passwords confidential and following other security best practices. 

International Data Transfers

Some or all of the personal information we collect may be transferred to third-party service providers in the course of our normal operations or activities including, without limitation, being stored on servers in cloud-based environments or transferred through other technological measures to trusted third parties to assist us in serving you. Some of our service providers are located outside of Canada and therefore personal information may be stored or processed in jurisdictions outside of Canada. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

In addition to the rights listed in this Privacy Policy, other jurisdictions, such as the European Union (“EU”) grant other rights with respect to Personal Information. If you reside in the EU, these rights include the rights to access your Personal Information; to have us erase it;

 to obtain and reuse it for your own purposes and to restrict its processing. Certain limitations on or exceptions to these rights may apply. If you are an EU resident, we may have to process or store your Personal Information outside of the EU. We use contracts with third party service providers and other mechanisms to protect your Personal Information in accordance with this Privacy Policy and applicable law.

3. CHANGES TO THIS POLICY

This Privacy Policy may be updated from time to time. We will notify you of any changes to this policy by posting the new version of the Privacy Policy on our Website. You are advised to consult this Privacy Policy webpage regularly for any changes.

4. CONTACT US

Questions, comments, and requests in relation to this Privacy Policy are welcome and should be addressed to info@musiccare.org.