- what personal information we collect and why we collect it;
- how we use your personal information;
- who we share your personal information with; and
- the choices you have to access, update, and remove your personal information.
CLEO may gather and use personal information through our Sites, mobile sites, applications, programs, projects, and other content, tools, and services that are linked to our Sites. This Policy applies to CLEO’s collection, use, and disclosure of personal information obtained through the Sites. This personal information may be obtained directly from you or collected from third parties that have the right to disclose this information to us.
Please note that CLEO reserves the right to update or change this Policy at any time. We will notify you of any changes by posting an updated Policy to this current webpage. The most current version of this Policy will govern CLEO’s use of your personal information. By continuing to access the Sites after changes are made to this Policy, you agree to be bound by the revised terms.
1. Consent & Personal Information Collected by CLEO
1.1. CLEO collects, uses, and discloses personal information in accordance with this Policy. We respect your privacy and, except as otherwise set out herein, we will not collect, use, disclose, sell, or rent your personal information to third parties without your prior consent.
1.2. By providing CLEO with your personal information through our Sites or any online fields on our Sites, you consent to CLEO’s collection, use, and disclosure of the following types of personal information, for the purposes set out below:
- (a) Order Publications. The CLEO Site provides legal information resources and publications, which are provided free of charge (“Order Publications”). If you register for an account on the CLEO Site in order to request that certain Order Publications be shipped to you, you will be asked to provide certain basic information, such as your name, the name of your organization (if applicable), address, phone number, email, and password. We will also request information regarding how you will use the Order Publications. This helps keep our Order Publications useful and relevant to our users. We may collect your login credentials for the purpose of the administration of your account. The purpose of CLEO’s collection and processing of this information is to provide you with resources and publications requested by you.
- (b) Letter Writing Tool. The Steps to Justice Site provides information on common legal problems in Ontario and offers practical tools and resources. CLEO offers a “letter writing tool”, which is a guided online letter generator that creates customized letters, as well as a Word template that users can download and complete, to assist users in drafting a formal letter to resolve their legal issues (e.g. a letter that responds to an internal review by the Ontario Disability Support Program). If you use our letter writing tool, you will be asked to provide your name, email address, mailing address, and details regarding your legal issue. The sample letter will be sent to the email that you provide to us. The purpose of CLEO’s collection and processing of this information is to provide you with the sample letter requested by you.
- (c) Live Chat. CLEO offers live chat services on the Steps to Justice Site. If you use our live chat services, you are asked to provide your name and email. We request your email so that we may email you a transcript of the chat. The purpose of CLEO’s collection and processing of this information is to respond to inquiries from you through the live chat services. We also refer to the live chat transcripts for quality control purposes, training, and content development.
- (e) Email Offers, Mailing Lists, and Newsletters. When you consent to receiving email offers, mailing lists, and newsletters from CLEO by subscribing to an email list from CLEO, Steps to Justice, or CLEO Connect, you will need to provide us with your name and an email address. This email address is used to deliver the mailing list messages to you, such as information about CLEO publications, activities, or projects, and Steps to Justice information updates. You can unsubscribe from these communications at any time by following the instructions in any of our communications or by contacting us as set out in Section 10 below. The purposes of CLEO’s collection and processing of this information are: (i) to send you updates about our legal information resources and services that you have requested; (ii) to send you Steps to Justice bookmarks or posters, or other CLEO-related publications that you have ordered or that may be of interest to you, where you have signed up to receive such materials and publications; and/or (iii) to inform you about CLEO news, publications, activities, or projects where you have signed up to receive such emails and newsletter communications.
- (f) Submissions. We ask for and may collect personal information from you when you use interactive features on our Sites or participate in our training events, including participating in surveys. The purposes for CLEO’s collection and processing of this information are: (i) to understand our users; (ii) to research and improve our resources and services, including understanding survey data and user feedback; and (iii) to enhance our Sites, features, tools, and service offerings.
- (g) Training Events. When you register online for CLEO’s training events, we ask for and collect your personal information, such as your name, email address, and phone number. The purpose of CLEO’s collection and processing of this information is to provide you with access to the training event and any materials or resources from the training event that are requested by you.
- (h) Inquiries and Feedback. When you contact us with feedback or with a comment or question, you may be asked for information that identifies you (such as your name, address, and phone number) along with additional information we need to help us promptly answer your question or respond to your feedback. We may also retain this information to assist you in the future and to improve our information resources and service offerings. The purpose of CLEO’s collection and processing of this information is to respond to any correspondence from you or inquiries you ask us.
1.3. Any personal information provided by you is voluntary. Please note that revoking your consent may result in you not being able to access or utilize certain CLEO information resources, tools, or services. You have the opportunity to withdraw your consent, or to opt-out at any time. If you wish to withdraw your consent or to opt-out at any time, including to remove yourself from our email or mailing list, please contact us as set out in Section 10 below.
2. How We Collect Your Personal Information
You may give us your personal information by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes, but is not limited to, personal information you provide when you: (i) request resources, publications, or services from CLEO, including Order Publications; (ii) use the tools available on our Sites, including the letter writing tool; (iii) use our live chat services; (iv) make a donation to CLEO through the CLEO Site; (v) sign up to receive our email newsletter or other communications; (vi) participate in one of our surveys or online events; (vii) contact us with a question or comment; (viii) react to marketing posts on our social media forums or pages (part 6 of this Policy); or (ix) provide us with feedback.
3. Use and Disclosure of Personal Information
3.1. Legal. CLEO may disclose your personal information to meet its legal obligations, including: (i) to fulfill its regulatory reporting obligations; (ii) in response to a search warrant or other legally valid inquiry or order; (iii) to an investigative body in the case of a breach of an agreement or contravention of law; (iv) where necessary for the establishment, exercise, or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property; or (v) as otherwise required or permitted by applicable Canadian law.
3.2. Sale. We may transfer any information we have about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or substantially all of CLEO’s assets or as part of a corporate reorganization or other change in corporate control.
3.3. Service Provider Suppliers
(a) We may transfer (or otherwise make available) your personal information to third parties who provide services on our behalf, including third party suppliers, contractors, and agents. For example, we may use service providers to host our websites, operate certain features on our websites, send emails or other communications, or process donations. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or other purposes.
(b) To the extent that any personal information is provided to these third party service providers, CLEO requires that the third party service provider be bound by obligations consistent with this Policy and that such providers only collect, use, or disclose users’ personal information for the purposes of providing to CLEO the services described in this Section 3.3. For more information about the way in which our third-party service providers treat your personal information, contact us as set out below in Section 10 below.
(c) Currently, CLEO uses and discloses personal information to the following service providers:
- We use WPForms, a WordPress plug-in, to generate the letter writing tool that creates the sample letters on the Steps to Justice Site.
- We use FullHost to host the Sites.
- We use Drupal, an open-source web content management platform, to store emails that we receive through the CLEO Site.
- We use WordPress, an open-source web content management platform, for the CLEO Connect Site and Steps to Justice Site.
- We use CanadaHelps to process donations made through the CLEO Site and to provide tax receipts directly to our donors.
- We use Mailchimp to manage and create our email newsletters, collect and store email addresses for marketing purposes, and generate automated mailings.
- We use Google Analytics to track website performance. Google Analytics uses persistent cookies to track things like visitor sessions, visitors across multiple sessions, and referral sources to the website. We also track the performance of promotional links to our Sites. The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States. In compliance with the Google Analytics Terms of Service, at no time is personally identifiable information passed to Google Analytics. Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. If you want to opt-out of Google Analytics data collection, you should use the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout. However please note that if you do this, you may not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out in this Section 3.3(c)(vii).
4. Aggregated or Anonymized Information
4.1. Device Information. CLEO also collects information from you that is aggregated and/or anonymized in such a way that it cannot be connected to you or any individual, and therefore is not considered personal information. Specifically, when you visit the Sites, we automatically collect certain information about your device, including information about your device and browser type, operating system, the pages or features of the website that a visitor browsed, the time spent on those pages or features, the frequency with which the website is used by a visitor, search terms used by a visitor, the links on the website that the user clicked on or used; and other statistics. Additionally, as you browse the Sites, we collect information regarding your web browser, IP address, time zone, and some of the cookies that are installed on your device.
4.2. How We Use Aggregated or Anonymized Information. In an ongoing effort to better understand the needs of our users in order to improve our Sites, we may use aggregated or anonymized information to analyze user demographics and website usage behaviour. This analysis may be used by CLEO and any of CLEO’s partners that embed content on our Sites for statistical purposes and to develop and enhance CLEO activities, programs, projects, and services.
6. Social Media
6.1. We may offer you the opportunity to engage with our content on or through third-party social networking websites, plug-ins, and applications. When you engage with our content on or through third-party social networking websites, plug-ins, and applications, you may allow us to have access to certain information associated with your social media account (e.g. name, username, email address, profile picture, gender). When you provide information from your social media account, we may use this information to personalize your experience on our Sites and on the third party social networking websites, plug-ins, and applications.
6.2. If you voluntarily submit or post any information, photographs, or other content to any CLEO social media forums or other social networking pages/sites, certain elements of your personal information may be automatically included in the posting, including your user name and email address, and this information may be collected and used by others. CLEO has no control over, and is not liable for, the collection, use, or disclosure of any posted user content by users of such forums and social media networking pages. For further clarity, any personal information posted, used, or disclosed via such social media sites is not subject to this Policy.
7. Third Party Links
8. Security, Confidentiality, and Breach
8.1. Security. CLEO has employed reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control. It is important to remember that no method of transmitting or storing data is completely secure. Mail and data transmissions over the Internet are all susceptible to possible loss, misrouting, interception, and misuse of the information being communicated or transmitted.
8.2. Confidentiality. Personal information submitted to CLEO, including through CLEO’s Sites or a prescribed online form, is kept confidential unless disclosed in accordance with your express consent or legal requirements. Only CLEO staff, volunteers, or third party suppliers, contractors, or agents with a business need to know, or whose duties reasonably so require, are granted access to personal information about our users. All such staff and volunteers will be required as a condition of employment to contractually respect the confidentiality of your personal information and handle it responsibly.
8.3. Breach. CLEO shall comply with, and provide CLEO users with reasonable assistance in complying with, applicable laws with respect to any unauthorized use, access, or disclosure of personal information.
9. Data Retention and Deletion
9.1. CLEO only retains personal information for as long as it is necessary for the purposes for which it was collected, or as required by applicable law. When personal information is no longer required for these purposes, it is securely destroyed or deleted according to the internal guidelines and procedures established by CLEO. For further details on our data retention periods, please contact us.
9.2. Specifically, CLEO retains the following types of information for the data retention periods set out below:
- (a) Letter Writing Tool. CLEO will retain records of the sample letter generated through the Steps to Justice Site, along with the associated emails, for three (3) years after the date that the sample letter was generated.
- (b) Emails. Where you have emailed CLEO with any questions or inquiries, the emails will be collected and stored in an offline environment and maintained for three (3) years after the date that the email was sent to CLEO.
- (c) Email Offers, Mailing Lists, and Newsletters. Where you have consented for us to use your details for direct marketing, we will keep this data until you notify us or otherwise withdraw your consent.
If you have a question about CLEO’s information-handling practices, we encourage you to let us know. Any inquiries involving CLEO’s handling of personal information or compliance with this Policy should be directed to CLEO’s Privacy Officer:
Executive Director, CLEO (Community Legal Education Ontario / Éducation juridique communautaire Ontario)
180 Dundas St. West, Suite 506, Toronto, ON M5G 1Z8