THE GREAT COMMISSION FOUNDATION PRIVACY POLICY

(Last updated: February 2021)

The Great Commission Foundation respects your privacy and is committed to protecting your personal information. This privacy policy will inform you as to how we look after your personal information when you visit our website at thegc.org (the “Website”), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you.

By submitting personal information to TGCF or its service providers and agents (collectively referred to as TGCF, “we”, “us” or “our” in this Privacy Policy), you agree that we may collect, use, and disclose such personal information in accordance with this Privacy Policy and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting our privacy manager. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

1. WHO WE ARE

2. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL INFORMATION COLLECTED

4. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION

5. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION

6. INTERNATIONAL TRANSFERS

7. HOW DO WE PROTECT THE CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

8. HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION

9. YOUR LEGAL RIGHTS

10. CONTACTING US

1. WHO WE ARE AND WHAT WE DO

TGCF is registered with Canada Revenue Agency as a foundation with charitable purposes. We have mission projects operating worldwide and work in collaboration with non-profits and other charities. TGCF collects and processes personal information through the following areas of operations:

• Our website for donors offers a user-friendly way for individuals to donate to TGCF’s projects which consist of non-profits, missionaries, mission projects and charities who have joined TGCF. TGCF collects and processes the donor’s personal information submitted through the Website. TGCF may also disclose personal information about its individual donors to the TGCF project they support. At the donor’s express request, choosing donations to remain anonymous, the donor’s information is not shared with the project they have chosen to support.

• Our tools and services for TGCF projects are made available to the project’s Agent to use to collect donations and launch fundraising events for the benefit of the TGCF project they represent.

All donations made through our tools and services (whether through our website for donors, our tools and services provided to TGCF’s project’s Agents) are made directly to TGCF (who issues donors their tax receipts). TGCF designates the donated amount (minus its non-commercial admin fee) to the project selected by the donor (unless, of course, your donation is intended by you to be to TGCF alone, in which case your donation in support of our activities is gratefully received and retained by TGCF in its entirety). The non-profits, missionaries and charities that are Agents of the TGCF, may require you to provide personal information directly to them in addition to the personal information that you provide to TGCF. TGCF projects are provided with our tools and services, and are required to agree to this Privacy Policy in its entirety. When you submit your personal information to other charities, you should be sure to read their privacy policies.

2. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

Personal information means any information about an individual from which that person can be identified. It does not include personal information where all references to the identity of the relevant individual have been removed (anonymous personal information).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

• Identity Personal information can include: o first name, last name, title, company you work for, and in the case of individuals representing our projects, your job title and role.

• Contact Personal information includes address, email address and telephone numbers.

• Financial Personal information includes bank account, credit card details and securities related information in the event you donate securities or mutual funds to TGCF (including your mutual fund or security name, number of units, investment firm, account number, financial advisor name, email, phone number.)

• Transaction Personal information includes details about payments to you (refunds) and from you (donations) and purchase of products.

• Technical Personal information includes internet protocol (IP) address, your login personal information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Marketing and Communications Personal information includes your communication preferences.

We also collect, use, and share Aggregated Personal information such as statistical or demographic information for any purpose. Aggregated Personal information could be derived from your personal information but is not considered personal information in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Personal information to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Personal information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric information). Nor do we collect any information about criminal convictions and offences.

If you provide TGCF with personal information of another individual, you represent that you have obtained all necessary consents from such person to enable us to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

This website is not intended for children under the age of 18 and we do not knowingly collect personal information relating to children.

3. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect personal information from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Transaction and Financial Personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

  • i. Make a donation (including one-time gifts, recurring gifts, and gifts of securities) and receive a tax receipt, if applicable; or

  • ii. Request information to be sent to you.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Personal information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, pixels, server logs and other similar technologies. We may also receive Technical Personal information about you if you visit other websites employing our cookies.

• Third parties or publicly available sources. We will receive personal information about you from various third parties as set out below:

  • i. Technical Personal information from:

    • A. digital marketing platforms such as Google Analytics, Google Tag Manager, MailChimp, Canva, Hubspot, AWeber, Blackbaud, Hootsuite, and other thirdparty marketing platforms.

    • B. advertising networks such as Google Adwords, Instagram, LinkedIn, Facebook, and Twitter. We use unique tracking codes in our emails and pixels on our website to allow us to share your technical information with such providers to track use of our site (including the performance of our ads) and to retarget ads.

  • ii. Contact, Financial and Transaction Personal information from providers of technical, payment processing and delivery services. Securities or mutual fund donations are processed by our broker.

4. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where you consent to such collection and use, such as by consenting to this Privacy Policy.

• Where needed to perform the service you are requesting.

• Where we need to comply with a legal obligation.

Note that we may process your Personal information for more than one lawful basis depending on the specific purpose for which we are using personal information. Please contact us if you need details about the specific legal ground we are relying on to process your Personal information where more than one ground has been set out in the table below.

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Table: Purposes for which we will use your personal information

• Marketing
  Where Canada’s Antispam Legislation ("CASL") applies to TGCF communications with users, donors or volunteers, TGCF is committed to complying with CASL and the provisions setting out the requirements for sending commercial electronic messages.
  
  You may receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
  
  You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. If you are receiving marketing messages from a TGCF project to which you donated through our Website and you no longer wish to receive such messages, then you should contact that project to make this request.
  
  Where you opt out of receiving these marketing messages, we may continue to use your personal information to provide you with the services you have requested from us.
  
  Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or

  • by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

• Cookies
  A cookie is a piece of information that a web server may place on your computer when you visit a website. Cookies are commonly used by websites to improve the user experience and have not been known to transmit computer viruses or otherwise harm your computer. Many cookies last only through a single website session or visit. Others may have an expiration date or may remain on your computer until you delete them.
  
  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

• Change of Purpose
  We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
  
  If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may share your personal information with the parties set out above for the purposes set out in the table Purposes for which we will use your personal information in this Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

By providing us with Personal information, you acknowledge and agree that your Personal information may be processed in other countries, including the United States, where laws regarding processing of Personal information may be less stringent than the laws in your country. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the Personal information. This will include putting appropriate contractual safeguards in place to ensure an adequate level of protection for the Personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal information out of Canada.

7. HOW DO WE PROTECT THE CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION?

We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse, or alteration.

We have implemented information security policies and rules for employees, in conjunction with the technical security measures in place by our software providers, that are intended to protect the personal information that we have under our control from:

• unauthorized access,

• improper use or disclosure,

• unauthorized modification, and

• unlawful destruction or accidental loss.

All our employees, workers and personal information processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with, the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Site and all users of our Services.

We have procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?

We will only retain your Personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your personal information: see your legal rights Section below for further information.

In some circumstances we will anonymize your Personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Most of our donors and website users are Canadians and so our privacy policy has been drafted to help ensure compliance with applicable Canadian law. However, we have noted that (although we do not target our services to EU data subjects) some of our individual donors are from outside of Canada, including from the European Economic Area (“EEA”). For the benefit of such users, we also endeavor to provide adequate protection for the personal data of EU data subjects in accordance with applicable EU data protection laws and regulations, including the EU GDPR. Subject to certain exemptions, you have the following rights in relation to the Personal information we hold about you:

Subject to certain exemptions, you have the following rights in relation to the Personal information we hold about you:

• Your right of access:

  If you ask us, we will confirm whether we are processing your Personal information and subject to any applicable exemptions, provide you with a copy of that Personal information within the timescales provided for by law. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made multiple requests. In this case, we will notify you and keep you updated. If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification:

  If the Personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If you are entitled to rectification and if we have shared your Personal information with others, we will let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your Personal information with so that you can contact them directly.

• Your right to erasure:

  You can ask us to delete or remove your Personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your Personal information). If you are entitled to erasure and if we have shared your Personal information with others, we will take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal information with so that you can contact them directly.

• Your right to restrict processing:

  You can ask us to “block” or suppress the processing of your Personal information in certain circumstances such as where you contest the accuracy of that Personal information or you object to us. If you are entitled to restriction and if we have shared your Personal information with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your Personal information with so that you can contact them directly.

• Your right to personal information portability

  You have the right, in certain circumstances, to obtain Personal information you have provided us with (in a structured, commonly used, and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object:

  You can ask us to stop processing your Personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your Personal information, except if we can demonstrate compelling legal grounds for the processing; or

  • processing your Personal information for direct marketing.

• Your rights in relation to automated decision-making and profiling:

  You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering, or the performance of, a contract between you and us.

• Your right to withdraw consent:

  If we rely on your consent (or explicit consent) as our legal basis for processing your Personal information, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Your right to lodge a complaint with the supervisory authority:

  If you have a concern about any aspect of TGCF’s privacy practices, including the way we have handled your Personal information, you can report it to the relevant supervisory authority.

10. CONTACTING US

We have appointed a privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our privacy manager using the details set out below. If you have any questions about this Privacy Policy or our privacy practices, please contact our privacy manager by emailing: privacy.policy@gcfcanada.com.

You have the right to make a complaint at any time to the relevant supervisory authority for personal information protection issues. In Canada, you can contact the Office of the Privacy Commissioner of Canada (“OPC”), see: https://www.priv.gc.ca/en/contact-the-opc/. EU data subjects can contact their relevant data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

Links to Other Websites

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

Changes

TGCF reserves the right to modify or supplement this Privacy Policy at any time. If any changes are made to this Privacy Policy, a copy of the Privacy Policy as amended will be posted on our Website as soon as practicable following that update. Your continued use of the Website following such posting will signify your consent to its revised terms.