RAISERS HUB LIMITED PARTNERSHIP: PRIVACY POLICY CANADA

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At Raisers Hub Limited Partnership (“Raisers Hub”, “we”, “our” or “us”), we are committed to protecting the privacy and the confidentiality of personal information in our possession or control.
In this Privacy Policy:

“Applicable Privacy Law” means the federal Personal Information Protection and Electronic

Documents Act and any substantially similar provincial legislation that is applicable to Raisers Hub and information in its possession or control, as well as any applicable payment card industry standards and other standards binding on Raisers Hub;

“Charity” means any charitable organization registered as a charity under the Income Tax Act (Canada) from whom Raisers Hub collects Personal Information, and whose Personal Information may be used or disclosed in connection with procuring a donation or potential donation from a Supporter or the provision of services to the Charity;

“Employee” means any full-time or part-time staff member or employee of Raisers Hub from whom Raisers Hub collects Personal Information, and whose Personal Information may be used or disclosed in connection with that individual’s employment with, or his or her provision of services to Raisers Hub;

“Personal Information” means information in the possession or control of Raisers Hub and which is defined as personal information in Applicable Privacy Law.

“Supporter” means an individual from whom Raisers Hub collects Personal Information, and whose Personal Information may be used or disclosed in connection with either a donation or potential donation or the provision of services to the individual;

“Third Party” means any agent or independent contractor retained by Raisers Hub from whom Raisers Hub collects Personal Information, and whose Personal Information may be used or disclosed in connection with that person’s provision of services to Raisers Hub;

(Charity, Employee, Supporter and Third Party hereinafter collectively, a “Party” or “Parties“)

Personal information we collect

The types of Personal Information Raisers Hub collects, uses and discloses may include, without limitation, a Party’s name, age, gender, mailing address, phone numbers or email addresses, and/or financial, credit and banking information, as applicable.

Identifying the purposes and Use of Personal Information

Before collecting any Personal Information, Raisers Hub will identify to the Party why the Personal Information is required and how it will be used. The Personal Information for all Parties except for Supporters is documented and kept on file at Raisers Hub’s offices. In the case of a Supporter, his or her Personal Information is documented and kept on file only at the offices of the Charity to whom such Supporter has made a donation. Raisers Hub will obtain the Party’s consent before using or disclosing Personal Information for purposes other than the original purposes intended.
Raisers Hub collects and uses Personal Information for the following purposes:

    1. Recording and using Personal Information relevant to the performance of the services rendered to, for or by a Party, as applicable;
    2. In the case of a Supporter, providing access to that Supporter’s Personal Information to the Charity to which that Supporter wishes to donate funds;
    3. Recording and determining the services received by a Charity during its relationship with us;
    4. Protecting against fraud and error;
    5. Offering a Charity additional services which may be of interest to such Charity;
    6. Communicating with a Charity generally or to ensure Charity satisfaction;
    7. Improving the services offered to Charities in the future;
    8. Communicating Personal Information to an agent, intermediary or other third party during the course of a contract or mandate for the performance of any of the purposes listed in this Privacy Policy;
    9. Complying with all applicable laws and regulations; and
    10. Such other specific purposes which are communicated to the Party by Raisers Hub and its representatives at or before the time of collection of the Personal Information.

We may disclose a Party’s Personal Information to our affiliates, associates, agents, suppliers and such other third parties as Raisers Hub, acting reasonably, may deem necessary for the fulfilment of the purposes noted above or otherwise as permitted by Applicable Privacy Law. In the unlikely event that Raisers Hub or substantially all of its assets are acquired by a third party, a Party’s Personal Information may be one of the assets transferred to such third party.

Consent

Except in certain extraordinary circumstances, Raisers Hub does not collect, use or disclose a Party’s Personal Information without the knowledge and consent of that Party. Such extraordinary circumstances may include, without limitation, when legal or security reasons make it impossible or impractical to obtain consent or where consent is not required under Applicable Privacy Law.

A Party’s consent will be obtained at the time of collection of his, her or its Personal Information, or when a new use for that Party’s Personal Information is identified. The Party may withdraw his, her or its consent at any time, subject to any legal or contractual restrictions and on the provision of reasonable notice to Raisers Hub. If a Party chooses to withdraw his, her or its consent, he, she or it is required to do so in writing to the Chief Compliance Officer (please see Section VII of this Privacy Policy). Any implications to withdrawing consent will be explained to the Party at the time written notice of such withdrawal is received by Raisers Hub. Such implications may include, but are not limited to, a breakdown, interruption or cessation of Raisers Hub’s relationship with the Party.

By contracting with Raisers Hub, Parties have consented to the disclosure of their Personal Information to a third party in the circumstances, or for the purposes, set out in this Privacy Policy.

Limiting collection

Raisers Hub limits the collection of a Party’s Personal Information to information which is reasonably necessary for the purposes identified in this Privacy Policy, or for any additional purpose identified to the Party before collection of the Personal Information.

Limiting use, disclosure and retention

Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the Party, or as permitted by Applicable Privacy Law. Personal Information is only retained as long as may be necessary for the fulfilment of

these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous.

Accuracy

Raisers Hub takes commercially reasonable steps to ensure that a Party’s Personal Information is as accurate, complete and up to date as necessary for the purposes for which it is used. Information is updated only when necessary to fulfil specified purposes. Parties should provide Raisers Hub with any updates to their Personal Information on a timely basis.

Safeguards

Raisers Hub employs commercially reasonable security safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of Personal Information while in the possession or control of Raisers Hub. The nature of the safeguards depends on the sensitivity, format, location and storage of the Personal Information. These security measures may from time to time include locked cabinets, computer passwords, software firewalls on all computers with access to Raisers Hub’s network to stop hackers and external untrusted networks, current anti-virus software, routine testing of all security software and firewalls, employee training, restricting access to Personal Information to only those employees or representatives who have a need to know and, if deemed necessary by Raisers Hub in its sole discretion, confidentiality covenants from third parties to whom Personal Information has been disclosed. In addition to the foregoing, encryption software is used as a security measure in the case of Supporters’ Personal Information. Any employee’s misuse of Personal Information is

considered a serious offence for which disciplinary sanctions will be imposed.

Supporters’ Personal Information will be stored on our secure and encrypted file transfer protocol servers located in Australia while in the custody of Raisers Hub. All other Personal Information will be stored on our secure file servers located either in Australia or Canada. We treat your Personal Information as an asset that must be protected and use the several security measures outlined above to protect your Personal Information against unauthorized access and disclosure.

Web Site Information

Raisers Hub may collect user information from www.raisershub.com (the “Site”) (for example, via cookies which are alphanumeric identifiers transmitted from a website to a visitor’s browser and IP address). The information that is collected is generally not Personal Information as it does not allow us to identify you. This information is used solely for enabling us to provide you with a customized online experience and to find ways to improve our website. Although cookies are widely used, it may be possible to disable cookies via your browser settings. However, in so doing, some websites may not function properly or optimally.

The Site may contain links to other third party sites that are not governed by this Privacy Policy. Although we endeavour to link only to sites with high privacy standards, this Privacy Policy will no longer apply once you leave the Site. We are not responsible for privacy policies employed by other third parties. Any sites operated from outside of Canada, including those of our foreign affiliates, may be governed by privacy legislation applicable in their country of residence. We suggest, therefore, that you examine the privacy statements of those sites to learn how personal information may be collected, used and/or disclosed.

Processing Outside Of Canada

Raisers Hub and/or its affiliates and service providers may store Personal Information in, or access Personal Information from, locations outside of Canada, and those locations may have privacy and other laws that are different from Applicable Privacy Law. In particular, Raisers Hub and/or its affiliates and service providers may be subject to legal requirements to disclose Personal Information to local law enforcement and regulatory bodies and may be prevented from notifying you of such disclosure.

Accountability and Openness

Raisers Hub is responsible for the Personal Information under its control and has appointed a Chief Compliance Officer to ensure that we comply with all applicable privacy legislation and the terms of this Privacy Policy. Personal Information provided to third party service providers with whom Raisers Hub has a contractual agreement will have levels of protection comparable to the internal protection of Personal Information maintained at Raisers Hub.

The Chief Compliance Officer addresses and investigates questions or concerns regarding a Supporter’s Personal Information. The Chief Compliance Officer may be reached by mail at Raisers Hub Limited Partnership, c/o Raisers Hub Pty. Ltd., 14A Mentmore Ave, Rosebery NSW Australia 2018, Attention: Chief Compliance Officer, or by email at compliance.officer@raisershub.com. A copy of this Privacy Policy, and any future updates or amendments hereto, is available at www.raisershub.com and upon request from Raisers Hub.

Access by a party other than a supporter

Upon written request of a Party other than a Supporter (in this section, the “Requesting Party”), Raisers Hub will provide the Requesting Party with access to his, her or its Personal Information.

Raisers Hub will correct or amend any inaccuracies in the Personal Information of the Requesting Party, and such amended information will be forwarded to any third parties who require access to the information. Raisers Hub may refuse a request for access to Personal Information if Applicable Privacy Law does not require that access be provided.

If the request of a Requesting Party for his, her or its Personal Information is denied, that party will be informed in writing of the reasons for the denial, as well as any recourse available to such party.
Access to the Personal Information of a Requesting Party will be at no cost to such party. Minimal charges may apply, however, for the transcription, reproduction or transmission of documents containing Personal Information.

Access by a Supporter

A Supporter wishing to access his or her Personal Information must make a request directly to the Charity to whom he or she has donated money. Such request shall be governed by that Charity’s applicable privacy policy.

Challenging compliance

Any complaint regarding Raiser Hub’s handling of Personal Information should be directed to the Chief Compliance Officer at the contact points set out in Section X above.

Currency of this Privacy Policy

Raisers Hub reserves the right to change this Privacy Policy at any time and from time to time. Any changes or additions to Section I of this Privacy Policy regarding those situations where Raisers Hub will collect, use or disclose Personal Information will not apply to a Party without the prior consent of such Party. Parties are encouraged to contact Raisers Hub to determine if any updates have been made to this Privacy Policy.