Privacy Policy – MSF Transformational Investment Capacity

Privacy Notice

Summary

Doctors Without Borders / Médecins Sans Frontières (MSF) respects your privacy and takes great care in protecting your personal information.

We understand the responsibility that comes along with collecting, using and sharing personal information, and we are committed to protecting your privacy. The purpose of this notice is to provide you with information about our personal information handling practices so that you can understand the types of information we collect and why as well as how to exercise your privacy rights, and the privacy choices available to you.

Which entities are covered by this privacy notice?

This notice applies to MSF’s Transformational Investment Capacity (TIC).

This notice does not apply to other members of Médecins Sans Frontières (“MSF”), including all worldwide entities licensed to use “MSF”, “Doctors Without Borders”, “Médecins Sans Frontières” or other MSF-related trademarks. This notice does not apply to particular services or products, such as Telemedicine, which have their own privacy policies.

What does this privacy notice include?

In this notice, we explain which personal information we collect, and how we collect, use, share, protect and store your personal information. We also explain your Privacy Choices and how you can exercise those choices.

This notice generally applies to any personal information collected by the TIC, or anyone acting as an agent on our behalf, from or about any individual interacting with us, as further detailed in the “How we Collect Personal Information” section. Please note that additional terms and conditions may apply to how we are collecting and managing your information when you engage with some of our programs or services. Those terms and conditions will apply together with this notice.

What type of personal information do we collect and how?

We collect personal information in a variety of ways, including: directly from you, from third parties, and when you are interacting with us online or through social media. We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected.

How we define personal information

“Personal information” is any information about an identifiable individual, including information that can be used with other available information to identify an individual (e.g., your name, email and phone number, location data). Personal information that is aggregated and/or anonymized so that it cannot be associated with an identifiable individual is not considered to be personal information.

Personal information that we collect may include:

Contact information.We generally collect your name, email address, phone number and address when you contact us for any reason.
Demographic and interest information.When you sign up for a survey or inquire about our activities, we may collect your interests about certain topics or interests in countries we work in, your age bracket and your use of social media.
TIC proposal information.If you submit a Transformational Investment Capacity (TIC) proposal to MSF Canada, we may collect your name, work address, telephone number and email address.

How we collect personal information

We collect personal information in the following ways:

Directly from you

You may collect personal information directly from you when you sign up for one of our events, communicate with us, sign up for email newsletters, leave a comment on our social media accounts or submit a TIC proposal. You may do so in-person, by mail, over the telephone, through our digital properties or in any other direct manner.

From third parties

Occasionally, we may receive personal information about you from third parties. In these cases, we receive your personal information from third parties only if we have obtained your consent to do so, if you provided your consent to the third party, or if the law requires or permits us to do so.

From other entities in MSF

We may receive personal information about you from other entities in MSF.

Through our digital properties

We may collect your personal information electronically through our information technology systems, websites, email, social media properties, or through the use of our or a third party’s technologies, which include cookies, web beacons, and single pixel gifs.

For example:

When you tag us on social media networks;
When you visit our website, we use cookies to help us personalize your experience.

To learn more about these technologies and how we use these technologies, please visit How Do We Use Interest Based Advertising? You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our websites or apps. To learn more about the privacy choices available to you, please visit How Do I Change My Privacy Choices?

Through social media

We may obtain information about you from your social media accounts or services. We can do this if you’ve set your account settings with the services to give us permission. Please check your settings and these services privacy policies for more details.

How do we use personal information?

We use your personal information to help us make informed decisions, to manage our operations, communicate information we think you will be interested in, generally enhance your experience with us, and as permitted or required by law.

Managing our operations and communicating with you

We may use your personal information for the following purposes:

Processing your TIC proposals;
Responding to your inquiries;
Verifying your identity;
Maintaining quality service levels and to assist in training our staff and service providers;
Managing and deploying our web and social media campaigns;
Providing you with information and updates about the TIC’s activities and events, including through our newsletters;
Managing and facilitating the use of our websites, which may include using cookies and other similar technology (see How Do We Use Interest Based Advertising?;
Meeting our legal and regulatory obligations;

If you no longer wish to receive commercial electronic messages from the TIC, please let us know by following the unsubscribe directions provided in every commercial electronic message we send, or you can send an email to privacy@toronto.msf.org. For more information see How Do I Change My Privacy Choices?

B.Conducting data analytics

We may use your personal information in a de-identified form (personal identifiers are removed) in order to conduct data analytics for purposes, such as:

Managing and developing our business and operations;
Improving our programs and services (e.g. improving the navigation or content of our website);

What are our legal basis for processing personal information?

If you are located in the European Economic Area (EEA) or Switzerland, we will only process your personal information for the above purposes when we have a valid legal ground for the processing.

Our valid legal grounds for processing include:

You consented to the use of your personal information. For example, to send you newsletters or to process personal information deemed sensitive under applicable law;
We need your personal information to respond to your inquiries or to process an application (e.g. a proposal application);
The processing is necessary for compliance with a legal obligation or other regulatory obligations;
We have a legitimate interest in using your personal information, such as- Charity Governance, including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes;
– Administration and operational management, including responding to solicited enquires, providing information and services, research, events management

How do we use interest-based advertising?

In order to deliver interest-based advertisements to you on our websites and other third party websites such as social media platforms, we and third party advertising companies that we engage may use cookies, pixel tags, web beacons and other technologies to collect information about your visits to our websites and other websites. The information we collect includes any interaction you had with our websites, including the pages you visited and information you scrolled over or clicked on or viewed.

Find out more on the cookies we are using by reading our Cookies Notice.

How do we share personal information?

We may share your personal information within MSF or with our service providers for the purposes described in this notice and in accordance with applicable law. We do not sell your personal information to any other organization or person.

We will not share your personal information outside of MSF, except for the following purposes, or as permitted or required by law:

Service Providers

In the course of our activities, we may use service providers who may require access to systems or applications which contain personal information. These service providers help us operate our activities. For instance, they may help us process donations, manage email lists, host our website, assist us in organizing events, or provide business analytics services. We require these service providers to limit their access to and use of personal information to that required to provide their services and to otherwise comply with our privacy requirements.

Transfer of activities

We may decide to transfer all or part of our activities to a member of MSF or to a third party, to merge with another entity, or to engage in another form of corporate transaction. If your personal information is required in connection with any such transactions, we will comply with the legal requirements for the disclosure of personal information and ensure that the handling of your personal information complies with applicable privacy legislation.

Other permitted reasons

We may be permitted or required by applicable law to share or disclose personal information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government enforcement agencies). These circumstances may include situations when necessary to protect the TIC, MSF, or employees and volunteers of MSF. If this happens, we will not share more personal information than is reasonably required to fulfill that particular legal purpose.

With your consent

Besides for the purposes listed above, we may, with your implied or express consent as applicable, share or disclose your personal information outside of MSF, in accordance with applicable law.

How do I change my privacy choices?

Understanding your choices and helping you make informed decisions about your privacy options is important to us. There are several options available for you to manage your privacy preferences, including, for example: contacting us directly, changing your browser settings on your device, and/or, where available, leveraging third party unsubscribe functionality. Please remember that changing your privacy preferences may impact your experience or limit our ability to communicate with you.

Contacting us directly

You may opt-in to:

Receiving email newsletters at the time that you consult our website

You may opt-out of:

Receiving email newsletter from us, by clicking “unsubscribe” within such newsletter email or by contacting us at privacy@toronto.msf.or
Interest-based ads being displayed on our or third-party websites, your social media accounts, and/or mobile apps, by leveraging third party unsubscribe functionality or, if available, through AdChoices.

Should you have any questions on how to update your preferences, or how to opt-in or out of our communications and ads, please contact us at privacy@toronto.msf.org.

Changing your browser settings on your device

We use technologies to enhance your customer experience and present offers to you, including interest-based ads. For example, technologies such as cookies allow us to recognize when you use or return to our websites, providing you with a more seamless experience. You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features of our websites.

Please refer to your browser instructions or help screen to learn more about how to block, delete and manage cookies on your computer or mobile device. You can also use the quick links below, based on the browser type that you are using:

Leveraging third party unsubscribe functionality

We may use third parties that use certain technologies to analyze your browsing behaviour as you visit our websites. You can manage your privacy preferences with respect to these third parties by leveraging their unsubscribe functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our websites and apps. For more information about the cookies used on our website, please read our Cookies Notice.

For example, Google Analytics uses cookies to analyze your browsing behaviour on our websites. This information is not provided to us in a personally identifiable format and is collected through your ad settings on your device or browser. If you would like to opt out of Google’s ad settings, please go to www.google.com/settings/ads or use the Google opt out browser add-on located at https://tools.google.com/dlpage/gaoptout .

We also may embed links to other websites, including social media websites, on our websites. For more information about social media plug-in protocols, such as “Like” buttons on Twitter, Facebook or Instagram and its impact on your privacy rights, please visit the appropriate social media help center (e.g., Facebook’s Help Center at https://www.facebook.com/help/).

How do we protect and store personal information?

The privacy and security of your information is extremely important to us. We are committed to protecting your personal information and use a combination of administrative, physical, and technical safeguards to do so. We store your personal information for as long as it is necessary to provide you with our programs and services and for a reasonable time thereafter, or as permitted or required by law.

How we protect personal information

In order to protect your personal information, we maintain administrative, technical, and physical safeguards. By having these safeguards, we aim to avoid the loss, misuse, unauthorized access, disclosure, or modification of your personal information that we hold. These safeguards also apply to when we dispose of or destroy your personal information.

Where we keep personal information

In general, we store, access and use personal information in Canada. Some of our service providers may access, process or store your personal information outside of Canada in the course of providing their services to us.

When we engage a service provider which operates outside of Canada, personal information may be stored, processed, accessed or used in any country in which the service provider operates. Where personal information is stored or used outside of Canada, it is subject to the law of the jurisdiction in which it is used, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. The countries where our service providers are currently located include the United States, the Netherlands, Austria, Belgium, France, Germany, Greece, Hong Kong, Switzerland, Italy, Japan, Mexico, Norway, South Africa, Spain, Sweden, the United Kingdom, and India. We use all reasonable safeguards, including contractual requirements with our service providers, to protect your personal information wherever it is located.

If you are located in the EEA: we may transfer your personal information to countries for which adequacy decisions have been issued, or pursuant to contractual protections for the transfer of personal information to third parties, such as the European Commission Standard Contractual Clauses or their equivalent under applicable law, or rely on certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable.

How long we keep your personal information

We will store your personal information for only as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your personal information will be securely destroyed or anonymized (so the information no longer identifies you).

Please note that if your personal information is collected by a third party, it will be retained in accordance with the privacy policies and records retention requirements of that third party.

How do I request access to my personal information?

You have the right to access and update the personal information we hold about you, subject to any legal restrictions. We will provide you with access to your personal information within a reasonable time frame.

You may also withdraw your consent to the collection, use and sharing of your personal information, subject to legal or contractual restrictions and reasonable notice (if you are located in the EEA or Switzerland, you can withdraw your consent to us processing your data at any time, where such processing is based on consent).

If you are located in the EEA or Switzerland, you may have the following additional rights:

You have the right to ask us to stop using or to restrict the processing of your personal data in certain cases, i.e. where it’s not needed to do what you provided it to us for, or if there is some disagreement about its accuracy or legitimate use.
In some cases, you have your personal data deleted from our database (“right to erasure”) or to have it transferred to another organisation (“right to data portability”). Where you have requested that we don’t send you marketing materials we’ll need to keep some limited information in order to ensure that you’re not contacted in the future.

You may exercise these rights by using this form.

If you have any questions about your rights, please contact the MSF Canada Privacy Officer or EU Data Protection Officer.

If you have any concerns about the way your data is being used or if you would like to make a complaint, please contact us using the details above. You’re also entitled to make a complaint to the Office of the Privacy Commissioner of Canada or the privacy commissioner of your province or territory of residence.

If you are located in the EEA or Switzerland and have any concerns about how we handle your personal data or if you would like to make a complaint, please contact the EU Data Protection Officer.

You may also have the right to make a complaint before the supervisory authority of your country of residence.

How do I know if there are changes to the privacy notice?

We may make changes to this notice from time to time. Any changes we make will become effective when we post a modified version of the notice on this webpage. If we make any material changes to the notice, we may also post or push a notice through our digital properties. By continuing to participate in our programs, and/or use our services or purchase our products after the modified version of the notice has been posted, you are accepting the changes to the notice. If you do not agree to the changes in our notice, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the notice. The “Effective Date” at the top of the notice indicates when it was last updated.

Whom do I contact with privacy questions?

If you have any questions about how we handle your personal information, please contact our Privacy Officer.

MSF Canada Privacy Officer:

Phone: +1 416 964 0619

Toll-free: +1 800 982 7903

Email: privacy@toronto.msf.org

Address: 551 Adelaide Street West, Toronto, ON, M5V 0N8, Canada

EU Data Protection Officer:

Email: DataProtection.IO@geneva.msf.org