Background

At the Canadian Chiropractic Association, we are committed to safeguarding and protecting the privacy of Personal Information (defined below) that is provided to us in the course of the CCA’s operations. This privacy policy (the “Privacy Policy”) applies when you (i) use the CCA’s websites found at www.chiropractic.ca and https://chiropractium.ca/; or (ii) use any other websites, digital properties, audio offerings, mobile applications and/or mobile enabled sites that are owned and/or operated by CCA and that do not have a separate privacy policy (collectively, the “Website”), and when you otherwise engage with us or use our services.

Certain webpages on our Website may contain policies or terms that are specific to their content (e.g. payment terms), and, unless expressly stated otherwise, such policies and/or terms are in addition to and not a substitution for the Privacy Policy.

You acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not use our services or supply your Personal Information to us. By submitting Personal Information to us about another individual, you acknowledge that it is your responsibility to obtain the consent of that individual (or their substitute decision-maker, where applicable) and to inform them of the contents of this Privacy Policy.

Purpose

The purpose of this Privacy Policy is to inform you about the types of Personal Information we collect, use, and disclose when you use our Website or our services. It explains:

• how we collect, use and disclose Personal Information;
• the choices you have regarding the use and disclosure of Personal Information; and
• how you may correct Personal Information.

Amendments to Privacy Policy

From time to time, we may make changes to this Privacy Policy. The Privacy Policy is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information in a manner consistent with the Privacy Policy under which it was collected, unless we have your consent to treat it differently.

The following topics will be covered in this Privacy Policy:

1. What is Personal Information and what Personal Information do we collect?
2. How and when do we collect Personal Information?
3. Where do we store Personal Information?
4. For what purposes do we collect your Personal Information?
5. What safeguards have we implemented to protect the Personal Information that you provide?
6. Who will have access to the Personal Information that you provide?
7. To whom do we disclose Personal Information that you provide?
8. When and how do we obtain your consent?
9. Cookies
10. How long will we use, disclose or retain Personal Information that you provide to us?
11. How can you review your Personal Information that we have collected, used or disclosed?
12. How do you know that the Personal Information we have on you is accurate? What happens if such Personal Information is inaccurate?
13. How do you contact us regarding access to your Personal Information or our privacy practices?
14. Third Party Websites

1. What is Personal Information and what Personal Information do we collect?

“Personal Information” is any information that allows an individual to be identified directly or indirectly. The type of Personal Information that we may collect may include, for example:

• name;
• contact information, such as email address and residential address;
• phone numbers;
• credit card information and bank account information (i.e. where provided to us in the course of paying membership dues);
• social media identifiers (e.g. Twitter handle and Facebook profile, etc.);
• internet protocol (IP) address; and
• other information that falls within the definition of “Personal Information” that we did not request, but that you provide to us.

Personal Information does not include business contact information (such as information regarding where an individual practices their profession and/or the contact information for that practice) and certain publicly available information.

We also collect and use aggregated and anonymized data for various purposes. Aggregated and anonymized data is not considered Personal Information because it cannot be used to identify you.

2. How and when do we collect Personal Information?

We will always collect Personal Information by fair and lawful means. We may collect Personal Information from you directly and/or from third parties, where we (and/or those third parties) have obtained your consent to do so, or as otherwise required or permitted by law. For example, we collect your Personal Information from the provincial chiropractic associations in Canada (e.g. Ontario Chiropractic Association, New Brunswick Chiropractors Association and Association des chiropracticiens du Québec) and the Canadian Chiropractic Protective Association (“CCPA”).

Generally, we collect Personal Information directly from you when you voluntarily provide it in the course of using our Website or services. For example, Personal Information may be collected when:

• you register for an account through the Website;
• you submit a membership application through the Website;
• you pay your annual membership dues through the Website;
• you register to receive our newsletter or any other CCA publications; and
• you communicate with representatives of the CCA, via telephone, email or mail.

In any event, we limit our collection of Personal Information to that which is necessary to fulfill the purposes identified in this Privacy Policy, or the purposes that we communicate to you when we collect it.

3. Where do we store Personal Information?

We store your Personal Information on our servers, or those of our service providers, in Canada (in various provinces) and the United States.

As a result, your Personal Information may be transferred to jurisdictions outside of your jurisdiction of residence. While your Personal Information is outside of your jurisdiction of residence, it is subject to the laws of the country or province in which it is located, which may be different than the data protection laws in Canada or your jurisdiction of residence. Those laws may require disclosure of your Personal Information to the governments, courts or law enforcement or regulatory agencies in that country. For more information about our policies and practices regarding storage of Personal Information outside of Canada, please contact us.

4. For what purposes do we collect your Personal Information?

Generally, we identify the purposes for which we use the Personal Information that you provide at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use Personal Information for the following purposes:

• to register and administer your membership with the CCA, including the payment of membership dues;
• to offer and provide membership services to you, which include providing information to you regarding products and services for which the CCA has obtained a preferential benefit (for example, a discount) for its members;
• providing information to you regarding products, services and events (including, for example, those of the Canadian Chiropractic Research Foundation (“CCRF”), the Journal of Canadian Chiropractic Association, the Canadian Chiropractic Guidelines Initiative, and the World Federation of Chiropractic), that the CCA believes may be of interest to you in your capacity as a chiropractic professional;
• to verify your identity and the accuracy of your Personal Information with our records, through using this information to contact you directly for that purpose, or for the purpose of collecting additional personal information;
• to send you information and updates regarding the activities of the CCA;
• to respond to your inquiries, questions, and/or other requests;
• to confirm with the CCPA your eligibility for membership in, and to verify your enrollment with, the CCPA;
• to reconcile member information/status (e.g. full-time, part-time) with the provincial chiropractic associations in Canada;
• for fundraising purposes, but only in respect of fundraising carried out by the CCRF (of which the CCA is a beneficiary);
• to personalize the information and online advertising that we provide to you, so that it matches your interests;
• for such other uses of Personal Information for which you provide your consent from time to time; and
• as otherwise permitted or required by applicable law.

We may anonymize your Personal Information. Anonymization is a data processing technique that removes or modifies personal identifiers and results in data that cannot be used to identify any one individual. We use anonymized data for a variety of purposes, including to contribute to research projects that benefit the profession (with appropriate research ethics board approval) and to better understand how our users use the resources provided on the Website.

5. What safeguards have we implemented to protect the Personal Information that you provide?

We have implemented physical, organizational, contractual and technological security measures in an effort to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. For example, we have implemented the following safeguards:

• premises security;
• security software and firewalls to protect hacking or other unauthorized computer access;
• password protected and encrypted computers; and
• requiring that our service providers also implement safeguards to protect your Personal Information, which reflects industry standards.

Moreover, as noted below, we will only permit our employees and third party service providers to access your Personal Information on a “need-to-know” basis and only after they have agreed to maintain the confidentiality of your Personal Information and keep it secure.

We take reasonable steps to verify your identity before granting you access to your account on the Website. However, you are solely responsible for maintaining the secrecy of your username, password and any other account information. Users should not disclose their username or password.

Despite these measures, we cannot guarantee that our safeguards will always be effective. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately.

6. Who will have access to the Personal Information that you provide?

Your Personal Information will be accessible to our employees and third party service providers on a “need-to-know” basis (i.e. where the employee or service provider requires such information to assist us with fulfilling the purpose for which the Personal Information was collected).

Examples of our third party service providers that will have access to your Personal Information include Moneris (for processing online payments), Wekbraftz (for hosting and managing our Website/Database), Salesforce (for digital marketing and storing Personal Information), and WordPress (for managing the content on our Website).

When we engage these third party service providers to process your Personal Information on our behalf, we require that they comply with applicable privacy laws and only use your Personal Information for the limited purposes for which it is provided.

However, prior to gaining access to your Personal Information, we require all of our employees and third party service providers to enter into agreements with us under which they are bound to abide by applicable law (including privacy laws), this Privacy Policy and our other related policies and procedures.

7. To whom do we disclose Personal Information that you provide?

We generally identify to whom, and for what purposes, we may disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. For example, we may disclose your Personal Information to:

• the CCPA, for the purpose of confirming your eligibility for membership in and verifying your enrollment (including your enrollment status) with CCPA;
• the CCRF, in connection with potential or actual donations made to the CCRF;
• to our third-party partners, such as Perkopolis, so that they can provide you with their products and services for which the CCA has obtained a preferential benefit (for example, a discount) for its members;
• provincial chiropractic associations in Canada in order to reconcile membership information/status (e.g. full-time, part-time); and
• such other persons for which you provide your consent.

In the event that we are required by applicable law to disclose your Personal Information without your consent, we will aim to disclose only the specific information that is required in the circumstances and, if possible, inform you about the disclosure.

8. When and how do we obtain your consent to collect, use and disclose Personal Information?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing any Personal Information you provide to us for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances. If we need to use your Personal Information for a purpose not previously identified to you at the time of collection, we will seek your consent prior to our use of such information for that new purpose.

You may provide your consent to us either orally, electronically or in writing.

We also require users who are submitting Personal Information to us that is about another individual, to only do so if they have the consent of that individual (or their substitute decision-maker, if applicable).

You may withdraw your consent to our use or disclosure of your Personal Information at any time by contacting us using the contact information below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

9. Cookies

The Website also uses “cookies” to help personalize and maximize your online experience. See our Cookie Policy for information about how we use cookies and how you can manage your cookie preferences.

10. How long will we retain Personal Information that you provide to us?

We will retain Personal Information that you provide to us for as long as necessary to fulfill the purpose(s) for which that Personal Information was collected, and as permitted or required by applicable law, or until you exercise your right to withdraw your consent to our use of the Personal Information provided.

Once Personal Information is no longer necessary to fulfill the purposes for which it was collected, we either securely destroy the information or anonymize it.

11. How can you review your Personal Information that we have collected, used or disclosed?

If you make a written request to review any Personal Information about you that we have collected, used or disclosed, we will provide you with any such Personal Information to the extent required by applicable law. Upon request, we will also provide you with details about the Personal Information that we have collected from you, the categories of persons who have access to the information within the CCA, and the duration of time the Personal Information will be retained. We will provide such information to you in clear and simple language and explain any abbreviations or codes. Where computerized Personal Information is concerned, we will provide it to you in a structured, commonly used technological format. We will explain any abbreviations or codes.

We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

12. How do you know that the Personal Information we have on you is accurate? What happens if such Personal Information is inaccurate?

We will attempt to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you to supply us with updates to your Personal Information, as required, using the functionality of the Website (or by other means, where appropriate).

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate, incomplete or equivocal, or that the collection, disclosure or retention of your Personal Information is not authorized by law, we will amend or delete the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

13. How do you contact us regarding access to your Personal Information or our privacy practices?

All comments, questions, concerns or complaints regarding your Personal Information, this Privacy Policy or our privacy practices, as well as any written request to access or correct your Personal Information, should be forwarded as follows:

By mail: Privacy Officer, Canadian Chiropractic Association 200-184 Front St. East. Toronto, ON, M5A 4N3

E-mail: [email protected]

14. Third Party Websites

The Website contains links to third party websites (“Third Party Websites”). Please be aware that the CCA is not responsible for the privacy practices of the Third Party Websites. This Privacy Policy applies solely to information collected by the Website, such that this Privacy Policy does not extend to Third Party Websites. We encourage our users to be aware when they leave our site that they are doing so and to read the privacy statements of each Third Party Website that collects personal information.