SMILECHINA PRIVACY POLICY FOR DONORS, SUPPORTERS AND OTHER EXTERNAL PARTIES

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At Project Smila China (“SmileChina”), we recognize the importance of privacy and are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that SmileChina collects from you, how we manage that personal information and what may happen to that personal information. Other policies describe how we treat the personal information of employees, independent contractors and/or volunteers of SmileChina.

SmileChina is responsible for the personal information that we collect and store. To ensure this accountability, we have designated a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer may be found towards the end of this Privacy Policy.

What is Personal Information?

Personal information is any information about an identifiable individual, other than the person’s business title or business contact information (such as business phone number and business address). Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

What Personal Information do we Collect?

We collect and maintain different types of personal information about individuals with whom we interact which is relevant for purposes that a reasonable person would consider appropriate for a donor-charity relationship.

This includes:

• Contact and identification information, such as your name, address, telephone number and e-mail address;
• Donation information such as date of gift, amount of gift, appeal (the campaign you contributed to), name of spouse or partner if it was a joint gift; receipt number. As much of our communication (thank you, mailings etc) is in either English or French, not bilingual, we also collect preferred language.
• Financial information such as your payment methods and preferences, billing and banking information (credit card number and expiry date or chequing account transit numbers, whichever payment type you prefer in order to process your donation);
• Product and service related information concerning the sale of greeting cards, books and gifts and other products or services that we provide to you;
• Other personal information used for purposes that a reasonable person would consider appropriate in light of the circumstances.

As a general rule, SmileChina collects your personal information directly from you and will not collect personal information about you from a third party without your consent. However, we occasionally exchange the names of some of our supporters with other like-minded charities and so, we may also receive information (name and contact information only) collected by those other charities. Where this is the case, we will take reasonable steps to ensure that those other charities have represented to us that they have the right to disclose your information to us.

Why Do We Collect Personal Information?

SmileChina collects personal information to further its fundraising and public education and advocacy commitments, as well as to establish, maintain and manage our relationship with you. Certain of the information is collected to satisfy the requirements of Canada Customs and Revenue Agency (CCRA).

How do we Use Your Personal Information?

We will not, without your consent, use your personal information for any purpose other than as described in this Privacy Policy, except where permitted or required by applicable law or regulatory requirements. We use your personal information for fundraising, to process donations, to respond to requests for information and to periodically keep you informed and up to date on SmileChina activities and campaigns. If you register as a user on our Web site (www.smilechina.com), in addition, we use your personal information to send you special offers and updates, our newsletter, service announcements relating to our Web site and to invite you to participate in surveys or contests.

When do we Disclose Your Personal Information?

SmileChina does not sell your personal information to any third party. We will share your personal information with employees who require such information to establish, maintain and manage our relationship with you. Third party service providers may be engaged by SmileChina to perform a variety of functions, such as to mail our brochures, to process your donation, to fulfill your order or to provide technical services for our Web site etc. These third party suppliers have access to personal information if needed to perform the functions for which they are retained. However, we direct that those third party suppliers may only use such personal information for the purpose of performing their roles and may not use it for any other purpose. In these cases, where the information is transferred to a third party, SmileChina will demand reasonable assurance that the third parties will protect your information in conformity with our privacy practices.

SmileChina will not otherwise disclose your personal information for purposes other than those for which it was collected, except as may be permitted or required by law, or with your consent.

Consent

It is important to us that we only collect, use or disclose your personal information which is not publicly available, where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction.

Typically, we will seek your consent at the time that we collect the personal information. In certain circumstances, your consent may be obtained after collection but prior to its use or disclosure. If we plan to use or disclose your personal information for a purpose not previously identified, we will advise you of this purpose before such use or disclosure.

If, prior to March 23, 2005, you have donated to SmileChina or purchased goods from us, or if you have received mailings requesting your support, or interacted in any way, we may have in our data base your contact information and possibly other information about you (depending on the previous interaction). Unless you advise us to remove your contact information, we will continue to use the personal information we have collected for the purposes, and in the manner described in this Privacy Policy.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting SmileChina Supporter Relations Department as set out above. In some circumstances, a change in or withdrawal of consent may severely limit our ability to acquire products or services from, or provide products or services to, you. If you are a SmileChina donor or supporter, we are required, by law, to maintain certain of your personal information for CCRA purposes.

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable legal and regulatory requirements.

Choice/Opt-Out

Unless you advise us otherwise, by receiving this Privacy Policy you are deemed to have given your consent to the collection, use and disclosure of your personal information for the purposes explained in this Privacy Policy, including sharing your name and contact information with like-minded charities. If you do not wish your name to be traded to other like minded charities, or if you wish to refuse your consent, please contact a SmileChina Supporter Relations representative using the contact information set out above.

How is Your Personal Information Protected?

SmileChina maintains physical, electronic and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to prevent your personal information from loss and unauthorized access, modification or disclosure.

Updating Your Personal Information

Since we use your personal information to contact you, it is important that the information contained in our records is both accurate and current. If you wish to verify, correct or update your personal information, or if your personal information happens to change during the course of our business relationship, you are responsible for keeping us informed of such changes. Please contact info@smilechina.com to update your information.

Access to Your Personal Information

You can request to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. At that time, we will need specific information from you to enable us to search for, and provide you with, the personal information that we hold about you. A nominal fee may apply depending on the type of information requested.

SmileChina’s Web Site

SmileChina has developed its own Web site privacy policy which you can view if you visit www.smilechina.com. When you visit our Web site, registration is not a precondition to access. However, by visiting the site, you may be identified by your IP address and cookies, or small data files, will be sent to your computer through your browser. The only other personal information that we collect and store via the Web site is that information which you knowingly provide to us by corresponding with our employees via e-mail, or by making an on-line donation or purchase.

Non-personal information, such as the name of the domain from which you access the Internet, the dates and times you access our Web site and the Internet address of the Web site from which you may be linking directly to our Web site, is collected and used to determine the volume of traffic on our Web site. This information also enables us to identify ways in which our Web site can be improved to serve you better.

The security of personal information is a high priority at SmileChina and its affiliates. We maintain this Web site and all associated data with technical, administrative and physical safeguards to protect against loss, unauthorized access, misuse, modification and improper disclosure. All underlying machines and firewalls at network access points have restricted access. While no computer system can ever be fully protected against every possible hazard, we provide reasonable and appropriate security controls to protect our Web site and its information.

Our Web site contains links to other Web sites that may be subject to less stringent privacy standards. SmileChina cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these Web sites. You should review the privacy policies of these Web sites before providing them with personal information.

By using our Web site, or permitting your children to use the SmileChina Web site, you signify your consent to the contents of the SmileChina Web Site Privacy Policy.

Inquiries, Concerns and Requests for Access

If you have any questions about this Privacy Policy or to access your personal information, please contact the office of our Privacy Officer. Please note that all requests to access personal information must be in writing or by e-mail.

Revisions to this Privacy Policy

SmileChina may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or enhancements to the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our Web site, and we encourage you to refer back to it on a regular basis. Any changes to this Privacy Policy will be effective from the time they are posted. This Privacy Policy was last updated on March 23, 2005.