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Privacy Policy

Section 01

Our Commitment to Your Privacy

BenaMakenga (the “Organization”) respects the privacy of its donors, volunteers, staff, program participants, and website visitors. We collect only the personal information we need, use it only for the purposes we describe, and safeguard it appropriately.

This Policy explains what personal information we collect, why we collect it, how we use and protect it, and the choices available to you. We handle personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

Section 02

Scope of This Policy

This Policy applies to personal information collected through our website, our donation and newsletter forms, our programs and events, and our correspondence with you — whether that information is collected in Canada or in the countries where we operate internationally.

It does not apply to third-party websites or services we link to. When you leave our site or use a third-party payment or social media platform, that provider’s own privacy policy governs your information.

Section 03

Information We Collect

The information we collect depends on how you interact with us. We collect it directly from you, except where you have consented to collection from another source or collection is otherwise permitted by law.

  • Donor Information Name, mailing address, email address, telephone number, donation amount and date, payment method type, and any designation or dedication you provide with your gift.
  • Volunteer and Applicant Information Contact details, résumé or experience, availability, references, and — where a role requires it — background or vulnerable sector check results.
  • Subscriber Information Name and email address where you sign up for newsletters, appeals, event invitations, or program updates.
  • Program Participant Information Information needed to deliver services and report on outcomes, which may include demographic details and, where strictly necessary, sensitive information collected with consent.
  • Technical Information IP address, browser and device type, pages visited, referring site, and dates and times of access, collected automatically through server logs and analytics.
  • Correspondence The content of emails, forms, and messages you send us, and records of our responses.
Payment Card Details We do not collect or store full payment card numbers on our own systems. Card details are entered into, and processed by, our third-party payment providers under their own security standards.
Section 04

How We Use Your Information

We use personal information only for the purposes for which it was collected, or for a purpose you would reasonably consider consistent with it, including to:

  • Process donations, issue official donation receipts, and administer recurring gifts;
  • Acknowledge your support and, where you have consented, recognize donors publicly;
  • Send newsletters, appeals, impact reports, and event invitations where you have consented to receive them;
  • Respond to your questions, requests, and correspondence;
  • Recruit, screen, and support volunteers, staff, and board members;
  • Deliver, evaluate, and report on our charitable programs;
  • Understand how our website is used and improve its content, security, and accessibility;
  • Meet our legal, regulatory, audit, and CRA reporting obligations.
What We Do Not Do We do not sell, rent, trade, or lease donor lists or personal information to any third party, and we do not share your information with other organizations for their own marketing purposes.
Section 05

Consent

We collect, use, and disclose personal information with your knowledge and consent, except where the law permits or requires otherwise. Depending on the sensitivity of the information, consent may be express or implied by your actions — for example, providing your address so we can mail you a receipt.

You may withdraw your consent at any time, subject to legal and contractual restrictions and reasonable notice. Withdrawing consent may limit our ability to provide certain services to you. It does not affect our obligation to retain donation records required by the Income Tax Act.

Section 06

Donation and Payment Security

Online donations are processed through third-party payment providers using encrypted connections. Card data is transmitted directly to the processor and is not retained by the Organization.

We retain a record of your gift — amount, date, and the details required on an official donation receipt — because the Income Tax Act requires it.

Section 07

Cookies and Website Analytics

Our website uses cookies and similar technologies. Cookies are small files stored on your device that allow the site to function correctly, remember your preferences, and help us understand how the site is used.

7.1  Types of Cookies We Use

  • Strictly necessary: required for the site to operate, including security and donation form functionality. These cannot be disabled through our site.
  • Analytics: help us measure traffic and understand which content is useful, in aggregate form.
  • Functional: remember choices such as language or display preferences.

7.2  Managing Cookies

Most browsers allow you to refuse or delete cookies through their settings. Disabling cookies may affect the functionality of parts of our site, including donation forms. Where required by applicable law, we will seek your consent before setting non-essential cookies.

Section 08

Disclosure to Third Parties

We disclose personal information only in the following circumstances:

  • Service providers: payment processors, email and CRM platforms, website hosts, and professional advisors who perform services on our behalf. They are permitted to use the information only for the purpose we specify and are required to protect it.
  • Legal and regulatory requirements: where disclosure is required or permitted by law, including reporting obligations to the Canada Revenue Agency and responses to lawful requests by public authorities.
  • Audit and governance: to our auditors and legal counsel in connection with their professional duties.
  • Protection of persons: where necessary to protect the safety of an individual or to investigate a suspected breach of law or of our Code of Conduct.
  • With your consent: in any other case, only where you have agreed.
Section 09

International Transfers

Because we operate internationally and use service providers that may store data outside Canada, your personal information may be processed or stored in another country.

In those cases, the information may be subject to the laws of that jurisdiction and accessible to its courts and law enforcement. We take reasonable contractual and organizational measures to ensure a comparable level of protection wherever your information is handled.

Section 10

Retention of Information

We retain personal information only as long as necessary to fulfil the purposes for which it was collected and to meet our legal obligations.

Donation records and receipt copies are retained for a minimum of six (6) years from the end of the applicable fiscal year, as required by the Income Tax Act. When information is no longer required, it is securely destroyed, erased, or anonymized.

Section 11

Safeguards

We protect personal information with safeguards appropriate to its sensitivity, including restricted access on a need-to-know basis, secured premises and devices, encrypted transmission of donation data, and confidentiality obligations for staff, volunteers, and service providers.

No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we act promptly to investigate and address any suspected breach.

Section 12

Your Rights

Subject to limited exceptions in law, you may:

  • Ask what personal information we hold about you and how it has been used and disclosed;
  • Request access to that information;
  • Ask us to correct information that is inaccurate or incomplete;
  • Withdraw consent to further use or disclosure;
  • Ask that we stop contacting you.

We will respond to a written request within the time limits set by applicable privacy law. We may need to verify your identity before acting on a request.

Section 13

Email Communications

We send commercial and fundraising email only in accordance with Canada’s Anti-Spam Legislation (CASL). Every such message identifies the Organization, provides our contact information, and includes an unsubscribe mechanism.

You may unsubscribe at any time using the link in any message or by contacting us directly. We will continue to send transactional messages such as donation receipts and responses to your enquiries.

Section 14

Children and Youth

Our website is not directed at children, and we do not knowingly collect personal information from a child online without the consent of a parent or guardian.

Where our programs serve children or youth, information is collected with the consent of a parent or guardian and handled with heightened care, in accordance with our safeguarding obligations.

Section 15

Photographs, Stories, and Testimonials

We use photographs, video, and personal stories to communicate the impact of our work. Where an identifiable individual is featured, we obtain informed consent before publication, in a language and format the person understands.

Consent may be withdrawn for future use at any time. Where publication could create a risk to a person’s safety or dignity, we anonymize or decline to publish.

Section 16

Changes to This Policy

We may update this Policy to reflect changes in our practices, technology, or legal obligations. The revised Policy takes effect when posted to this page, and the “last updated” date will be revised.

Where a change is material, we will take reasonable steps to notify you.