Trans Canada Trail (“the Trail”, “our”, “us” or “we”) follows the highest ethical standards in carrying out its mission and, therefore, protecting your privacy is very important to us. We value the trust of those we deal with and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that is shared with us.
This Privacy Policy (the “Policy”) informs you of our policies and procedures regarding the collection, use and disclosure of Personal Information (as defined below) we receive from users. Such Personal Information can be collected via our websites tctrail.ca and sentier.ca and websites optimized for mobile services (collectively, the “Site”), our Trans Canada Trail mobile applications for mobile devices (the “Trail Apps”), as well as other offline methods, for example if you are participating in any of our in-person activities. The Policy should be read in conjunction with our Terms and Conditions. Unless otherwise defined in this Policy, terms used in this Policy have the same meanings as in our Terms and Conditions.
By accepting the Policy, you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Policy.
Object of the Policy
Our main objectives when we collect Personal Information about you are to provide you with services and functions that meet your needs, to personalize our service to make your experience more secure and friendlier, and to generally better understand how individuals use our resources and can benefit from the Trans Canada Trail. Personal Information collected via the Site and Trail Apps can also be used to improve these resources and understand how the are used by Site/Trail Apps visitors. The information we collect about you is solely information we deem necessary to achieve this objective.
This Policy describes the Personal Information that we collect from you when you interact with us, for example when you use the Site and/or Trail Apps, when you interact with our social media platforms and email advertisement campaigns, or when you attend any of our events across the country, and what may happen to that information. Generally, you can browse and/or use our Site and Trail Apps without revealing your identity. However, if you interact with certain functions of our Site or Trail Apps, for example by signing up for our Trail Talk program or by participating in contests, you will be required to provide Personal Information to us and will no longer be anonymous to us. You can still opt not to provide the requested information by simply not accessing a function or service offered on our Site or Trail Apps.
Personal Information Collection and Use
In order to use certain features we offer, including our Site and Trail Apps, we may request that you provide certain personally identifiable information that can be used to directly or indirectly identify you (“Personal Information”). We only collect Personal Information that is necessary to provide you with our different services. Where possible, we indicate which fields are required and which fields are optional. We may collect this information directly via the Site or Trail Apps, for example by asking you to complete webforms, when you participate in contests or when you fill out surveys to help us improve our services and find out more about what you are interested in. We can also collect Personal Information from you when you participate at in-person events across the country.
- If you decide to make a Donation to us, we will collect your name, email address, phone number and postal address. Any credit card information you provide to make a donation is collected and processed directly by third-party payment processors, and we do not have access to, nor do we store, such payment information. We use this information to record and process your donation in our systems, and to provide you with a tax receipt of your donation.
- If you apply for a position at the Trail with respect to an employment opportunity posted on our Site, we will collect your name, email address and any other information you provide, including employment history and curriculum vitae. We use this information to review and respond to your
- If you participate in a contest on our Site or Trail Apps, we may collect your name, email address and phone We may also collect other types of personal information, such as photographs or otherwise, depending on the exact nature of a given contest.
- If you use the Contact Us feature on our Site or Trail Apps, we may collect your name, email address, object of your communication and your We use this information to respond to your request or comment. If you send us emails or letters, we may collect such information in a file specific to you.
- If you subscribe to our Newsletter, we will collect your name and email address to send you emails about various news, promotions and You may also choose to provide us with your postal address. Even after subscribing to one or more newsletters and/or opting into one or more offers to receive marketing and/or promotional communications from us, you may elect to modify their preferences by following the “Unsubscribe” link provided in an email or communication received.
- When you visit our Site or Trail Apps, we may collect information about your visit through cookies and similar technologies.
- When you participate in any of our in-person events, we may collect personal information including your name, email address, mailing address, phone number and birthday. This information will be used by us to ensure you are properly registered for the event, for promotion on our various platforms, and to reach out to you regarding any future events we think you would be interested in.
While we aim to collect Personal Information from you directly, in some cases we can obtain personal information from partner organizations who adhere to and respect the Canadian Marketing Association Code of Ethics and Standards of Practice. Information collected this way is only used to reach out to you about possible donations, and will be used in accordance with the law. When we contact you, you can rescind your consent to your Personal Information being used for such communications in accordance with applicable laws.
More generally, we can also use your personal information for the following purposes that are not related specifically to the Site or Trail Apps:
- To provide you with information about our work or our activities;
- To fundraise in accordance with our internal policies and procedures;
- To organize events that you have registered for, and to provide you with information, and other materials relating to the event;
- To process donations and generate tax receipts;
- To provide our newsletters and publications;
- To respond to your questions and provide related services; and
- To contact contest winners and award prizing
We can also use your Personal Information to personalize and improve our services, content and advertisements; to prevent, detect and, eventually, investigate fraud and security breaches, activities that may prove to be prohibited or illegal, enforce our Terms and Conditions, and meet legal, regulatory, insurance and processing requirements, and otherwise with your consent, or as permitted or required by law.
Information Sharing and Disclosure
We will only disclose your Personal Information with your consent or if we have legal authority to do so, whether as a result of the law or otherwise, such as in the following contexts:
- Service We may employ third party companies and individuals to facilitate, perform or provide services related to the Site and/or Trail Apps (including, without limitation, maintenance services, database management, data processing and hosting, payment processing, web analytics and improvement of the Site and Trail Apps’ features) or to assist us in analyzing how our Site and Trail Apps are used. We may also use such third parties to assist us with organizing our in-person activities, or for other purposes, independently from the Site and/or Trail Apps. These third parties only have access to the Personal Information needed to perform the tasks on our behalf and are contractually required not to disclose or use it for any other purpose.
- Legal We may be asked to disclose your Personal Information to meet certain legal, regulatory, insurance and audit requirements, enforce our Terms and Conditions, respond to claims to the effect that some content breaches the law or the rights of a third person, including intellectual property rights or ensure everyone’s safety and security, and as otherwise with your consent, or as permitted or required by law (including as required by Canadian and foreign laws applicable to us or our service providers). In particular, without the need for a subpoena, we are entitled to disclose your Personal Information, including your family name, first name, postal code, email address, telephone number (if available), your browsing history of our Site or usage history of our Trail Apps, your IP address, and any other information that might seem relevant, in response to a formal request from a regulatory body in connection with a criminal investigation or allegedly illegal activities or any other activity that might expose us to legal liability.
- Philanthropic With your consent or as otherwise permitted by applicable laws, we may also share your name, phone number and email address with partner philanthropic organizations who adhere to and respect the Canadian Marketing Association Code of Ethics and Standards of Practice, so that they can then contact you about other projects and/or causes you may be interested in donating to.
Security
Trans Canada Trail is very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” to you via email or conspicuous posting on the Site or via the Application in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
International Storing and Transfer of Personal Information
In order for us to offer our products and services, we may collect, use, disclose, store or process Personal Information on servers located in other jurisdictions, including the United States, for the purposes described within this Policy. Please note that the privacy laws in such jurisdictions may differ from Quebec and Canada privacy laws. Reasonable measures we may take to protect your Personal Information while processed or handled by these service providers, contractual or otherwise, are subject to applicable foreign legal requirements, including lawful requirements to disclose Personal Information to government authorities and law enforcement in certain circumstances. By submitting your Personal Information or engaging with the Site and Trail Apps, you consent to such transfer and storage of your Personal Information outside your jurisdiction of residence.
Cookies and Other Tracking Technologies
When you browse our Site, use our Trail Apps or otherwise benefit from our services, we automatically collect information that is sent to us via your computer, your mobile device or, more generally, whatever device you use. The information thus collected may, in particular, include your IP address, as well as anonymous information collected as a result of our cookies and our web trackers such as the date and time of your visit, the pages you visit, the features you use, the referring URL you came from and which one you go to after, clickstream behaviour (i.e., the pages you view, the links you click, and other actions you take in connection with our Site and/or Trail Apps), your browser type and selected language.
Our Site and Trail Apps can use “cookies” to collect information, which can be placed either by us or by our service providers. A cookie is a small data file that we transfer to your computer’s hard disk for record- keeping purposes. We use cookies to enable certain features of the Site and Trail Apps, to better understand how you interact with the Site and Trail Apps and to monitor aggregate usage by users and web traffic routing on the Site and Trail Apps. The cookies placed by our server are readable only by us and/or our service providers, as the case may be, and cookies cannot access, read or modify any other data on a computer. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site and Trail Apps or all functionality of the Service.
We also use Google Analytics and Google Tag Manager to better understand who is using our Site and/or Trail Apps, and how people are using it. Google Analytics uses cookies to collect information such as pages visited, places where users click, time spent on each page, Internet Protocol address, type of operating system used, and location. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information. Google may track your activity over time and across websites. Once again, such information is used to target advertisements and content that may be of interest to you, and also to provide statistical insight through features such as Google Analytics and Google Ads. We can also use these services to track how you interact between our Site or Trail Apps and external websites hosted by partners. This information is used to review and analyze user tendencies to improve our services and offering.
In some instances, tracking tools used by third-party service providers may be disabled. For example, Google allows you to deactivate cookies designed to target ads by accessing the Opt-Out page of its main website. Google Analytics may also be deactivated once you download the browser add-on available for that purpose. You may also decline the use of cookies by other third-party vendors by logging on to the Network Advertising Initiative consumer deactivation page.
Finally, when you download or use our Trail Apps , or you access one of our mobile-optimized sites, we might receive data on your location and on your mobile device, including a unique identifier of your device. We can then use this information to provide you with services, such as advertisement, research results and other personalized content, taking your location into account. You can use the adjustment menus on most mobile devices to activate or deactivate the location services at your convenience.
Links to Other Sites or Applications
Our Site and Trail Apps may contain links to other websites or applications. If you click on another third party link, you will be directed to that third party’s website or application. The fact that we link to a website or application is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites or applications. These other websites or applications may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other websites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit, and will not be responsible for any processing of your Personal Information that may happen on third-party websites.
Data Retention and Anonymization
Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. Under some circumstances we may anonymize your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous data for any legitimate business purpose without further notice to you or your consent. Furthermore, we do not sell your information to third parties.
Accessing, Correcting, Withdrawing Consent and Deleting Personal Information
It is important that the Personal Information we hold about you is accurate and up to date. Please keep us informed if your Personal Information changes. By law, you have the right to request access to and/or correction of the Personal Information we hold about you.
If you wish to review, verify, correct or withdraw your consent to the use of your Personal Information, you may also send us an email at privacy@tctrail.ca to request access, correction, or deletion of any Personal Information you have provided to us. We may not accept a request to change information if we believe that the change would violate a law or legal requirement or result in incorrect information.
Before providing you with access to your information, we may ask you for specific information to help us confirm your identity and right of access, and to provide you with the Personal Information we hold about you, or to make the requested changes. In some cases, applicable law requires us to refuse to provide you with access to some or all of the Personal Information we hold about you, or that we may have destroyed, erased or made anonymous in accordance with our legal record-keeping obligations and privacy best practices.
Please note that if you request deletion of certain information or withdrawal of your consent, we may not be able to provide you with certain services. We will explain the consequences of deletion or withdrawal at that time to assist you in your decision.
If we are unable to provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Such restrictions may include, for example, information about another individual that would reveal their Personal Information or confidential business information, or would be prohibitively costly to provide.
Changes to this Policy
This Policy applies to any Personal Information collected by Trans Canada Trail, whether using our Site or Trail Apps or using other methods. If we intend to use or disclose Personal Information for purposes materially different than those described in this Policy, we will make reasonable efforts to notify you of this. This Policy is effective as of the last updated date above and may be updated from time to time. We will notify you of any material changes by posting the new Policy on the Site or via the Trail Apps, or using any other method we deem appropriate. You are advised to consult this policy regularly for any changes. Your continued provision of Personal Information or use of our Site or Trail Apps following any changes to this Policy constitutes your acceptance of any such changes.
Contacting Us
We welcome your questions and comments about security and privacy. Please send any questions, comments or complaints via email to privacy@tctrail.ca.
Approved by the TCT Board of Directors – October 14, 2023
