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Terms of Service

Table of Contents

1. Definitions

  • Actionable Policy means Policy Items or elements of a Candidate’s Policy Platform that Polity considers to be a real call to action or promise by the Candidate for a specific policy to be implemented. Polity considers the inclusion of absolute words (e.g. shall, will, must), and dates, budgets, financial forecasts or other information that display that the Candidate has a real intention for the Policy Item to be implemented, or that the candidate intends to be held accountable to their promises, as evidence that the Policy Item is Actionable Policy. 
  • Business contact information means an individual’s name, position name or title, business telephone number, business address, business e-mail, business fax number and other similar business information.
  • Candidate means the individual who is, or will be, nominated and registered under the proper regulatory authority to run for political office in an election, and includes any member of the Candidate’s campaign team, including employees, volunteers, agents, officers or directors. 
  • Chief Privacy Officer (“CPO”) means the authorized employee of Polity who oversees the development and enforcement of Polity’s Privacy Policy.
  • Commissioner means the Information and Privacy Commissioner appointed under the Freedom of Information and Protection of Privacy Act.
  • Company Personnel means all officers, directors, employees, consultants, contractors and agents of Polity.
  • Content means any media, in text, video, image, hyperlink, sound or other form, uploaded to the Service. 
  • Employee means an individual employed by an organization and includes an individual who performs a service for or in relation to or in connection with an organization, such as: an apprentice, volunteer, participant or student; or an individual under contract or in an agency relationship with the organization.
  • Employment and Education Record means the complete record of all of the Candidate’s employment history and post-secondary education where the Candidate has spent more than one year with that employer or educational institution. 
  • Policy Card means the presentation of a Candidate’s Policy Items on a Politician Profile that includes (i) a description of the core substance of the Policy Item, and (ii) a description of the Policy Item that does not exceed one hundred (100) words. 
  • Policy Platform means the compilation of all of the Candidate’s Policy Items that have been published in writing on the Candidate’s website. 
  • Policy Item means those individual policies that can be distinguished from other Policy Items included in the Candidate’s Policy Platform. 
  • Promotional Video means all advertisements, propaganda or other media designed to influence the decision of voters to vote, donate or volunteer for the Candidate that have been, or will be, uploaded to social media or other video sharing sites, including YouTube, Facebook, Twitter, Reddit or Vimeo. 
  • Marketing Data means information that includes the User’s psychographic, demographic, ideological or political information that Polity uses for the purpose of carrying out specified purposes (defined below).
  • Material Information means all information, facts or changes to the Candidate’s Policy Platform, News Mentions, Promotional Videos or Employment and Education Record that may influence a Reasonable Voter’s decision to vote, donate, volunteer or otherwise support the Candidate. 
  • News Mention means all mentions, press releases or other coverage of the Candidate by reputable news sources or journalists.
  • Personal Employee Information means personal information reasonably required by an organization that is collected, used or disclosed solely for the purposes of establishing, managing or terminating an employment relationship.
  • Personal Information means information about an identifiable individual, that includes the individual’s name, email address, occupation, payment history, financial information, and Marketing Data, but does not include business contact information.
  • Political Party means an organization registered with the proper election regulator in Canada as a political party.
  • Privacy Laws mean the provincial and federal laws of Canada that govern the use, retention and disclosure of Personal Information.
  • Reasonable Voter means a voter in Canada of sound mind who is representative of the broader electorate and is located in the jurisdiction in which the election is, or will, take place. 
  • Record means a record of information in any form or in any medium, whether in written, printed, photographic or electronic form or any other form, but does not include a computer program or other mechanism that can produce a record.
  • Service means Polity’s site, products or services. 
  • User means a subscriber, viewer, client, customer or other visitor of Polity’s website, products or services who, through continued use of the Service, are bound by this Agreement, and all other policies, disclosures and agreements to which they consent to.

2. Rules Governing Users

(a) Introduction

Polity Media Inc. (“Polity“, “we“, “us“, “our“) is a technology company headquartered in Calgary, Alberta that provides Users (“you“, “your“) information that Polity believes is relevant to your decision to vote, donate, volunteer or otherwise support a Candidate. A User may also be a Candidate, to which Polity provides a crowdfunding portal which the Candidate can use to reach larger audiences, share their message, and find voters, donors and volunteers. 

Through use or viewership of Polity’s site, products or services (“Service”) you agree to be bound by this Terms of Service (“Agreement”). This Agreement outlines your right to use the Service and the conditions that apply to your use of the Service. Your Agreement with us will also include the Advertising On Polity Guidelines if you provide advertising or sponsorships to the Service or incorporate paid promotions in your content. Your Agreement with us will also include any contractual agreements entered into with Polity if you are a Candidate who has claimed your Politician Profile. 

(b) Who May Use the Service?

Age Requirements

You must be at least 13 years old to use the Service; however, children of all ages may use the Service if enabled by a parent or legal guardian.

Permission by Parent or Guardian

If you are under 18, you represent that you have your parent or guardian’s permission to use the Service. Please have them read this Agreement with you.

If you are a parent or legal guardian of a User under the age of 18, by allowing your child to use the Service, you are subject to the terms of this Agreement and responsible for your child’s activity on the Service. 

Businesses

If you are using the Service on behalf of a company or organisation, you represent that you have authority to act on behalf of that entity, and that such entity accepts this Agreement.

(c) Permissions and Restrictions

You may access and use the Service as made available to you, as long as you comply with this Agreement and applicable law. The following restrictions apply to your use of the Service. You are not allowed to:

  1. access, reproduce, download, distribute, transmit, broadcast, display, sell, license, alter, modify or otherwise use any part of the Service or any content except: (a) as expressly authorized by the Service; or (b) with prior written permission from Polity and, if applicable, the respective rights holders;
  2. circumvent, disable, fraudulently engage with, or otherwise interfere with any part of the Service (or attempt to do any of these things), including security-related features or features that (a) prevent or restrict the copying or other use of content or (b) limit the use of the Service or content;
  3. access the Service using any automated means (such as robots, botnets or scrapers) except (a) in the case of public search engines, or (b) with Polity’s prior written permission; 
  4. collect or harvest any information that might identify a person (for example, usernames or faces), unless permitted by that person; 
  5. use the Service to distribute unsolicited promotional or commercial content or other unwanted or mass solicitations;
  6. cause or encourage any inaccurate measurements of genuine User engagement with the Service;
  7. misuse any reporting, flagging, complaint, dispute, or appeals process, including by making groundless, vexatious, or frivolous submissions;
  8. use the Service to view or listen to Content other than for personal, non-commercial use; or
  9. use the Service to (a) sell any advertising, sponsorships, or promotions placed on, around, or within the Service or content, other than those allowed on the Advertising on Polity Guidelines; or (b) sell advertising, sponsorships, or promotions on any page of any website or application that only contains content from the Service or where Content from the Service is the primary basis for such sales.  


(d) Reservation

Using the Service does not give you ownership of or rights to any aspect of the Service, including user names or any other Content posted by others or Polity.

(e) Changes to the Service

Polity is constantly changing and improving the Service. We may also need to alter or discontinue the Service, or any part of it, in order to make performance or security improvements, change functionality and features, make changes to comply with law, or prevent illegal activities on or abuse of our systems. These changes may affect all users, some users or even an individual user. Whenever reasonably possible, we will provide notice when we discontinue or make material changes to our Service that will have an adverse impact on the use of our Service. However, you understand and agree that there will be times when we make such changes without notice, such as where we feel we need to take action to improve the security and operability of our Service, prevent abuse, or comply with legal requirements. 

(f) License to Polity

By providing content to the Service, you grant to Polity a worldwide, non-exclusive, royalty-free, sublicensable and transferable license to use that content (including to reproduce, distribute, prepare derivative works, display and perform it) in connection with the Service and Polity’s (and its successors’ and Affiliates’) business, including for the purpose of promoting and redistributing part or all of the Service.

(g) Right to Monetize

You grant to Polity the right to monetize your content on the Service (and such monetization may include displaying ads on or within Content or charging users a fee for access). This Agreement does not entitle you to any payments. 

(h) Removing Your Content

You may remove your content from the Service at any time. You must remove your Content if you no longer have the rights required by these terms.

(i) Removal of Content By Polity

If we reasonably believe that any content is in breach of this Agreement or may cause harm to Polity, our users, or third parties, we may remove or take down that Content in our discretion. We will notify you with the reason for our action unless we reasonably believe that to do so: (a) would breach the law or the direction of a legal enforcement authority or would otherwise risk legal liability for Polity or our Affiliates; (b) would compromise an investigation or the integrity or operation of the Service; or (c) would cause harm to any user, other third party, Polity or our Affiliates. 

(j) Other Legal Terms

Warranty Disclaimer

OTHER THAN AS EXPRESSLY STATED IN THIS AGREEMENT OR AS REQUIRED BY LAW, THE SERVICE IS PROVIDED ‘AS IS’ AND POLITY DOES NOT MAKE ANY SPECIFIC COMMITMENTS OR WARRANTIES ABOUT THE SERVICE. FOR EXAMPLE, WE DON’T MAKE ANY WARRANTIES ABOUT: (A) THE CONTENT PROVIDED THROUGH THE SERVICE; (B) THE SPECIFIC FEATURES OF THE SERVICE, OR ITS ACCURACY, RELIABILITY, AVAILABILITY, OR ABILITY TO MEET YOUR NEEDS; OR (C) THAT ANY CONTENT YOU SUBMIT WILL BE ACCESSIBLE ON THE SERVICE.  

Limitation of Liability

EXCEPT AS REQUIRED BY APPLICABLE LAW, POLITY, ITS AFFILIATES, OFFICERS, DIRECTORS, EMPLOYEES AND AGENTS WILL NOT BE RESPONSIBLE FOR ANY LOSS OF PROFITS, REVENUES, BUSINESS OPPORTUNITIES, GOODWILL, OR ANTICIPATED SAVINGS; LOSS OR CORRUPTION OF DATA; INDIRECT OR CONSEQUENTIAL LOSS; PUNITIVE DAMAGES CAUSED BY:

  1. ERRORS, MISTAKES, OR INACCURACIES ON THE SERVICE;
  2. PERSONAL INJURY OR PROPERTY DAMAGE RESULTING FROM YOUR USE OF THE SERVICE;
  3. ANY UNAUTHORIZED ACCESS TO OR USE OF THE SERVICE;
  4. ANY INTERRUPTION OR CESSATION OF THE SERVICE;
  5. ANY VIRUSES OR MALICIOUS CODE TRANSMITTED TO OR THROUGH THE SERVICE BY ANY THIRD PARTY;
  6. ANY CONTENT WHETHER SUBMITTED BY A USER OR POLITY, INCLUDING YOUR USE OF CONTENT; AND/OR
  7. THE REMOVAL OR UNAVAILABILITY OF ANY CONTENT.

 

THIS PROVISION APPLIES TO ANY CLAIM, REGARDLESS OF WHETHER THE CLAIM ASSERTED IS BASED ON WARRANTY, CONTRACT, TORT, OR ANY OTHER LEGAL THEORY.

POLITY AND ITS AFFILIATES’ TOTAL LIABILITY FOR ANY CLAIMS ARISING FROM OR RELATING TO THE SERVICE IS LIMITED TO THE GREATER OF: (A) THE AMOUNT OF REVENUE THAT POLITY HAS PAID TO YOU FROM YOUR USE OF THE SERVICE IN THE 12 MONTHS BEFORE THE DATE OF YOUR NOTICE, IN WRITING TO POLITY, OF THE CLAIM AND (B) CAD $500.

Indemnity

To the extent permitted by applicable law, you agree to defend, indemnify and hold harmless Polity, its Affiliates, officers, directors, employees and agents, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney’s fees) arising from: (i) your use of and access to the Service; (ii) your violation of any term of this Agreement; (iii) your violation of any third party right, including without limitation any copyright, property, or privacy right; or (iv) any claim that your Content caused damage to a third party. This defense and indemnification obligation will survive this Agreement and your use of the Service.

Third-Party Links

The Service may contain links to third-party websites and online services that are not owned or controlled by Polity. Polity has no control over, and assumes no responsibility for, such websites and online services. Be aware when you leave the Service; we suggest you read the terms and privacy policy of each third-party website and online service that you visit.

(k) Governing Law

All claims arising out of or relating to these terms or the Service will be governed by Alberta law, and will be litigated exclusively in the courts of Alberta, Canada. You and Polity consent to personal jurisdiction in those courts.

 

3. Updating the Candidate's Politician Profile

 (a) General 

The Candidate’s Politician Profile includes information that Polity considers to be the Material Information relevant to a Reasonable Voter’s decision to vote, donate, volunteer or otherwise support the Candidate. 

The Candidate’s Politician Profile shall be controlled by either Polity or the Candidate. During the period in which Polity controls the Politician Profile, the Politician Profile shall be governed by subsections (a) and (b) of this section. After activating the Candidate’s Politician Profile, paying the requisite fees, agreeing to Polity’s Terms of Service and undergoing an authentication process, the Candidate may take control of the Candidate’s Politician Profile. During the period in which the Candidate is in control of the Candidate’s Politician Profile, the Politician’s Profile shall be governed by subsections (a) and (c) of this section. 

The Candidate shall remain in control of the Candidate’s Politician Profile for as long as the Candidate remains in good standing with Polity. The Candidate shall remain in good standing with Polity for so long as the Candidate has not been accused or convicted of a crime, has not taken legal action against Polity, has not engaged in behaviour that could cause repetitional damage to, degrade or humiliate Polity, and is not in breach of any contractual terms between Polity and the Candidate, or in breach of Polity’s Terms of Service, Privacy Policy or Cookies Policy. Polity has the sole discretion to intervene and retake control of the Candidate’s Politician Profile, without reimbursement, compensation or liability, in the event that the Candidate is no longer in good standing with Polity. 

(b) Polity’s Duty to Update the Politician Profile with Material Information

During the period in which Polity is in full control of the Candidate’s Politician Profile, Polity shall, at its sole discretion, update the Candidate’s Politician Profile as soon as reasonably practical to include all Material Information that Polity considers may change or influence a Reasonable Voter’s decision to vote, donate, volunteer or otherwise support the Candidate. 

Polity has the sole discretion to alter or change the Candidate’s Politician Profile for the purpose of enhancing what Polity determines to be useful to its users’ understanding of the Candidate’s Material Information, including (i) paraphrasing Policy Items to fit as Policy Cards, (ii) altering the titles of policy items, (iii) taking extractions or quotes from the Candidate’s Material Information to be displayed on the Politician Profile, or (iv) selecting images and videos to be used on the Candidate’s Politician Profile. Polity shall take all reasonable steps to not alter the core message or pith and substance of the Candidate’s Material Information, and to otherwise act as a responsible and reliable steward of the Candidate’s Material Information. 

In updating the Candidate’s Policy Platform, Polity shall categorize the Candidate’s Policy Platform and Policy Items into the following categories to be included as Policy Cards on the Candidate’s Politician Profile: 

  • Economic Policy includes any Policy Items that describe the Candidate’s stance or plan on the economy, fiscal policy, monetary policy, or the collection or spending of taxes. 
  • Social Policy includes any Policy Items that describe the Candidate’s stance or plan on trending social issues and matters of public policy, including racial issues, gender issues, gay marriage, transgenderism, defunding the police, affordable housing, religion, equity, free speech, the culture war, immigration, revisionism and Indigenous issues. 
  • Environmental Policy includes any Policy Items that describe the Candidate’s stance or plan on climate change, the environment, the energy sector, energy sources or makeup, green urban design, transit, vehicles or C02 emissions. 
  • Leadership includes any Policy Items that describe the Candidate’s leadership philosophy, outlook on governance or otherwise describe how the Candidate intends to lead if they are elected, and may include Policy Items that are not included in the other categories. 
 

Polity has the sole discretion to include in the Candidate’s Politician Profile only those Policy Items published in the Candidate’s Policy Platform that Polity considers to be Actionable Policy. Any utterings made by the Candidate on social media, in private, in the news or otherwise in passing, but never solidified on the Candidate’s website or official Policy Platform, may not be considered by Polity to be Actionable Policy and may therefore not be included on the Candidate’s Politician Profile. Polity considers the inclusion of absolute words (e.g. shall, will, must), and dates, budgets, financial forecasts or other information that display that the Candidate has a real intention for the Policy Item to be implemented as evidence that the Policy Item is Actionable Policy. 

(c) The Candidate’s Duty to Update the Politician Profile with Material Information

During the period in which the Candidate is in control of the Candidate’s Politician Profile, the Candidate shall update, change or include in their Politician Profile as soon as reasonably practical, in the requisite area of the Candidate’s Politician Profile, all Material Information that may change or influence a Reasonable Voter’s decision to vote, donate, volunteer or otherwise support the Candidate, including:

  1. the Candidate’s Policy Platform; 
  2. News Mentions;
  3. Promotional Videos; and
  4. the Candidate’s complete employment and education record. 

The Candidate shall not hide, downplay, refuse to include or otherwise alter any Material Information on the Candidate’s Politician Profile that the Candidate considers to be damaging or harmful to the Candidate’s electability or reputation if that Material Information may change or influence the decision of a Reasonable Voter to vote, donate, volunteer or otherwise support the Candidate. 

In updating the Candidate’s Policy Platform, the Candidate shall categorize the Candidate’s Policy Platform and Policy Items into the following categories to be included as Policy Cards on the Candidate’s Politician Profile: 

  • Economic Policy includes any Policy Items that describe the Candidate’s stance or plan on the economy, fiscal policy, monetary policy, or the collection or spending of taxes. 
  • Social Policy includes any Policy Items that describe the Candidate’s stance or plan on trending social issues and matters of public policy, including racial issues, gender issues, gay marriage, transgenderism, defunding the police, affordable housing, religion, equity, free speech, the culture war, immigration, revisionism and Indigenous issues. 
  • Environmental Policy includes any Policy Items that describe the Candidate’s stance or plan on climate change, the environment, the energy sector, energy sources or makeup, green urban design, transit, vehicles or C02 emissions. 
  • Leadership includes any Policy Items that describe the Candidate’s leadership philosophy, outlook on governance or otherwise describe how the Candidate intends to lead if they are elected, and may include Policy Items that are not included in the other categories. 
 

Each Policy Card shall include (i) a title that describes the Policy Item’s core substance, and (ii) a description of the Policy Item that shall not exceed one hundred (100) words.

Polity retains the right to, at its sole discretion, access the Candidate’s profile and alter the information, structure, design and settings for the purpose of implementing changes, fixing bugs, updating information or ranking higher in search engines (SEO) (e.g. by changing the HTML tag of a title to be better understood by a web crawler). 

4. Candidate's Duty to Comply with Privacy Policy

A Candidate who uses the Service, or has otherwise collected data on Polity’s users, agrees to be bound by, and abide by, Polity’s Privacy Policy, and any other privacy or data law or regulation governing the Candidate’s collection of data.

Any violation of the Privacy Policy shall result in the Candidate losing their status of good standing with Polity, and expose the Candidate to legal and other repercussions. The Candidate, and not Polity, shall be held responsible for any breaches or misuses of data by the Candidate for any data collected by using the Service.

5. Candidate's Duty to Comply with Election Laws

A Candidate who uses the Service shall comply with all applicable election laws and regulations, including rules governing campaign finance, donation limits, financial disclosures and voter information handling. 

Polity shall not be help responsible or liable for any breach of election laws or regulations that result from the Candidate’s use of, or reliance on, the Service. 

A Candidate who uses the Service shall comply with all applicable copyright laws in and outside of Canada. In particular, the Candidate shall only use media, including images and videos, where use of such media would not infringe on the copyrights of another person, wherever that person may be located. 

Polity shall not be held responsible or liable for any breach of copyright laws that result from the Candidate’s infringement of copyright laws. 

7. Privacy Policy

(a) General

This section outlines general principles and legal requirements, regarding user and former user privacy and the confidentiality of user and former user information, that govern the conduct of Polity Media Inc. (“Polity”, “we”, us”, “our”) in the course of business and in compliance with federal and provincial privacy laws. Company Personnel receive training about, and are bound by, this Privacy Policy.

By using Polity’s services, products or website, the user (“user”, “you”, “your”) acknowledges, understands and consents to the collection, use and disclosure of your Personal Information in accordance with, and with limitation by, this Privacy Policy.

This Privacy Policy applies to all individuals whose Personal Information Polity collects, uses or discloses in the course of doing business. It is Polity’s practice to only disclose your Personal Information as required or authorized by law or as otherwise set out in this policy.

Polity reserves the right to change this policy from time to time as industry practice, the law, Polity’s procedures, or public policy may change from time to time. Any changes to this policy shall be uploaded to Polity’s website as soon as reasonably practical.

(b) Principles of Privacy Law

 The following are the principles of fair information practices incorporated into the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA), Alberta’s and British Columbia’s respective Personal Information Protection Act (PIPA), and Quebec’s Act Respecting the Protection of Personal Information in the Private Sector – together, the “Privacy Laws”.

Every business that carries on “commercial activities”, including Polity, is subject to the application of the Privacy Laws as they relate to the collection, use and disclosure of Personal Information. The Privacy laws only apply to information about human beings.

Polity is required to comply with the Privacy laws in all of its business practices that involve Personal Information about individuals.  

Principle 1 – Accountability 

All officers, directors, employees, consultants, contractors and agents of Polity (referred to collectively as “Company Personnel”) are responsible for Personal Information (and confidential information about Polity) to which they have access as a result of their relationship with Polity and for compliance with Polity’s Privacy Policy. The CPO is responsible for Polity’s compliance with the Privacy Laws.

All inquiries or concerns regarding the use of Personal Information, including information that has been transferred by Polity to a third party (for example, for processing), must be directed to the CPO, as the first point of contact at Polity. The CPO may also bring in other departments of Polity, as necessary, to assist in resolving the inquiry or concern.

Principle 2 – Identifying Purposes

The purposes for which Personal Information is collected and used must be identified, documented and disclosed to clients at or before the time their information is collected. Polity is only permitted to collect, use, disclose and retain Personal Information to the extent necessary to fulfill the purpose for which the information was collected, or otherwise required by law.

Before Polity may use Personal Information for a purpose not previously identified to the user, the new purpose must be identified and unless the use is required by law, client consent must be obtained before his or her information may be used for the new purpose.

Polity collects Personal Information for the following purposes:

  1. to assess the eligibility of a Political Candidate to run for elected office;
  2. to verify the identity of a Political Candidate in order to authenticate their profile on Polity’s site;
  3. to provides services to users, including services connected to advertising, campaigning, fundraising, polling, surveying, policy analysis, and data analysis, collection, retention and distribution;
  4. to maintain records for Polity;
  5. to inform individuals about Polity’s products and services that Polity believes may be of interest to them;
  6. to better understand an individual’s interests in our products and services;
  7. to provide warranties for products and services;
  8. to provide information on future opportunities;
  9. to verify access rights to our website;
  10. to conduct market research;
  11. to enforce Polity’s legal relationship with its users;
  12. as is necessary in contemplation of a business transaction;
  13. to procure, analyze and transact in information, data and trends about a users’ political beliefs, ideologies, demographics, psychographics or other relevant information about voters, potential voters, users, volunteers, Political Parties, lobbyists, politicians, public figures, public interest organizations, registered charities, Political Campaigns or other participants in the democratic process;
  14. complying with statutory and regulatory requirements;
  15. protecting Polity and its clients from error and fraud; and
  16. for any other purpose related to the products and services of Polity or its affiliates to which clients may consent.

 

Principle 3 – Consent                                            

Knowledge and consent of users are required for the collection, use and disclosure of Personal Information.

The consent obtained by Polity will generally be express consent, with notice of the purposes of collection and other relevant information being provided to clients in subscription agreements or other similar agreements or through Polity’s Privacy Policy.

Subject to restrictions imposed by law or under a contract and reasonable notice, consent may, at any time, be withdrawn by a user. Polity must inform a user where there are implications of withdrawing or refusing the user’s consent.

Principle 4 – Limiting Collection 

Personal Information is not to be collected by Polity indiscriminately. The amount and the type of Personal Information collected must be limited to that which is necessary for the purpose of the collection identified to the user. Further details on limiting collection are described below in the “Limitation on Collection” section.

Principle 5 – Limiting Use, Disclosure and Retention

Caution should be exercised in regard to the disclosure of Personal Information. In general, Personal Information should be disclosed for the purpose for which it was collected, with the express consent of the client or as required by law. If there is any doubt, Company Personnel should speak to the CPO prior to disclosing Personal Information. In some circumstances, for example, where it is necessary in connection with the provision of a service and the client’s consent has been obtained, Polity may disclose Personal Information to an affiliate or financial service providers, such as banks and others involved in financing or facilitating transactions by Polity or operations of Polity.

Polity may be required by law to disclose Personal Information to taxation and regulatory authorities and agencies. In this regard, Polity may have to file with the appropriate securities commission, a report that includes Personal Information such as the client or users’ name and address. Such information is collected indirectly by securities regulators, under the authority granted to them in securities legislation, for the purposes of the administration and enforcement of the legislation. Personal Information will be retained for a period of seven years following the end of the client relationship. After seven years, all client documentation will be destroyed in a manner commensurate with its sensitivity unless there are securities laws or other legal requirements that require its retention.

Polity may transfer Personal Information to service providers under contract that provide accounting, legal, tax preparation or other similar services. Polity remains responsible for Personal Information while it is in the hands of third-party service providers. Polity will protect the information by requiring in its contractual relationships with its service providers that the service providers afford Personal Information the same level of protection as it is given by Polity.

Principle 6 – Accuracy

Personal Information must be as accurate, complete, and up to date as necessary for the purposes for which it is to be used and will only be routinely updated where necessary for those purposes.

Principle 7- Safeguards

Personal Information will be protected against loss, theft, unauthorized access, use, disclosure, copying, or modification by safeguards appropriate for sensitive information. Personal Information (and confidential information of Polity) will be retained in a designated secure area or electronic database.

Company Personnel are individually responsible for ensuring the confidentiality, appropriate use and protection of all Personal Information to which they have access.

Polity records Personal Information electronically on computer servers where only authorized Company Personnel have access. Polity authorizes Company Personnel and third-party service providers to have access to Personal Information only on a need-to-know basis in order to fulfil their job requirements and obligations.

Principle 8 – Openness

Clients have a right to access Polity’s Privacy Policy which includes information about its management of Personal Information including contact information for the Privacy Officer and the means by which a client may gain access to and request the correction of his or her Personal Information being held by Polity.

Principle 9 – Individual Access

On request, a client shall be informed of whether or not Polity is holding his or her Personal Information, the use to which it has been put by Polity and the organizations to which it has been disclosed or the type of organizations to which it may have been disclosed where more precise information is not available.

Requests for access must be made in writing. Access to a client or users’s own Personal Information will be provided except where doing so would likely reveal Personal Information about a third party that cannot be severed from the Personal Information. Access may also be withheld where:

  • the Personal Information is protected by solicitor-client privilege;
  • providing access would reveal confidential commercial information;
  • providing access could reasonably be expected to threaten the life or security of another individual;
  • the Personal Information was collected without consent because obtaining consent could have compromised the availability or accuracy of the information and the information is required for investigating the breach of a contract, federal or provincial law;
  • the information was generated in the course of a formal dispute resolution process; or
  • the information is required to be kept confidential under other applicable laws.

 

More information about gaining access to individual information is detailed in the “Access to and Correction of Information” section, below.

Principle 10 – Challenging Compliance 

 A client may address any concerns with respect to Polity’s compliance with the above principles or Polity’s Privacy Policy to the CPO. Polity has procedures regarding client or user complaints which Company employees must explain to clients if concerns about Personal Information management are raised. The complaint process is outlined in the “Access to and Correction of Information” section, below.

(c) Collection and Protection of Personal Information 

Under the Alberta and British Columbia Personal Information and Protection Acts, Personal Information collected about an individual prior to January 1,2004:

  • is deemed to have been collected pursuant to consent given by that individual;
  • may be used and disclosed by the organization for the purposes for which the information was collected; and
  • subsequent to January 1, 2004, will be treated in the same manner as information collected thereafter.

 

The purpose for collecting Personal Information is set out in this policy. Any necessary consents shall be obtained before Personal Information is collected, used or disclosed. 

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain Personal Information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form), or electronically (by clicking a button).

In cases that do not involve sensitive Personal Information, we may rely on “opt-out” consent.

The amount and type of Personal Information collected by Polity is defined by law and shall be limited to what is necessary to fulfill the identified purpose. Personal Information shall only be used or disclosed for the purposes for which it is collected. Exceptions may be made with the consent of the individual or if authorized or required by law.

Personal Information collected by Polity or on behalf of Polity will be sent to Polity’s head office in Calgary and will be subject to the laws of Canada.

Personal Information collected by Polity may be shared with affiliated companies or third parties retained by Polity, which assist Polity in carrying out various services. Polity carefully scrutinizes and examines third parties to confirm that similar standards are utilized by such third-party companies with regards to collection and use of Personal Information.

Non-Personal Information Automatically Collected from Site

Polity receives and sends data from Polity’s servers and from your browser when you visit our website, including your IP address, the time and information about the page you requested and the website through which you were linked to our site, if any. Polity may use tracking technologies in a variety of ways, including keeping count of return visits to our site, accumulating and reporting anonymous, aggregate data, statistical information on website usage, and determining which features, functionality, or changes to the website, products or services that users prefer.

Your internet browser has a feature called “cookies”, which store small amounts of data on your computer about your visit to our website. Cookies tell us nothing about who you are unless you specifically give us Personal Information. You do not need to have cookies turned on to visit our site. You may also elect to not allow cookies to be collected by selecting certain options on your browser.

Limitation on Collection 

Polity will not collect Personal Information unless the information is necessary for one or more of its business activities or in order for the organization to comply with regulatory or legal requirements.

As an employer, we are required to obtain certain information regarding our employees in accordance with Canada Revenue Agency reporting requirements.

Notification Required for Collection 

Where Personal Information is to be collected directly from a user, reasonable steps will be taken to ensure the user is aware of the purpose of collection. When Personal Information is to be obtained from third parties such information will be limited to that required for the identified purpose and will be collected by lawful and fair means for purposes directly related to Polity’s activities. An individual may give his or her consent in writing, electronically or verbally.

Withdrawal of Consent

Clients will be given a reasonable opportunity to decline or object to the proposed collection, use or disclosure of their Personal Information. Such withdrawal of consent must be provided to Polity in writing upon receipt of which we will inform the client of the likely consequences to this action.

Limitations on Use or Disclosure

Polity will only use or disclose information regarding our users or employees for the purpose for which it was collected or where a lawful exception applies. Company Personnel of the firm are only authorized to access or use Personal Information in the legitimate performance of their duties and strictly on a need-to-know basis.

The misuse of Personal Information is a serious offence and is not permitted by the Privacy Laws. Polity considers that a failure by staff to comply with this policy will constitute serious misconduct and accordingly will give rise to disciplinary action which may include dismissal. Agents and contractors shall be contractually bound to comply with the Privacy Policy.

Disclosure of Personal Information

Polity is regulated by a number of governmental and regulatory organizations. From time to time these bodies may demand that we produce, or make available for inspection, documents and information that clients have provided us for the following regulatory purposes:

  • surveillance of fundraising-related activity;
  • compliance, review and other regulatory audits;
  • investigation of potential regulatory and statutory violations;
  • regulatory databases;
  • enforcement or disciplinary proceedings;
  • information sharing with regulatory authorities and law enforcement agencies in any jurisdiction in connection with any of the foregoing; and
  • under law we are required to provide the CRA with any information they may request regarding our clients or employees.

 

We also have relationships with other non-regulatory organizations that require us to share or make available information regarding clients and/or their accounts. Specifically, we are required to share and/or provide information to the following organizations:

  • Blair & Co Advertising: provides Polity with web development, advertising and other marketing services.

*Facebook Pixel:
The Facebook pixel is a small piece of JavaScript that we’ve installed within the website in order to optimize ads, report on conversions across devices, and create custom audiences of website visitors for use in Facebook ads.

“The Facebook Pixel was designed from the bottom up with privacy in mind. In order to use this product, the website does not need to collect or send names, email addresses or other contact information to Facebook.
We never share information from your website with your competitors or third parties. All information we use is aggregated with millions of other signals before being read by our optimization systems. Facebook uses information obtained from websites that install Pixels to improve its ads (as noted in our terms). This data is aggregated before it’s used.

The Facebook pixel collects five types of data:

HTTP Headers – Anything present in HTTP headers. HTTP Headers are a standard web protocol sent between any browser request and any server on the internet. HTTP Headers include IP addresses, information about the web browser, page location, document, referrer and person using the website.

Pixel-specific Data – This includes Pixel ID and the cookie.

Button Click Data – This includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.

Optional Values – Developers and marketers can optionally choose to send additional information about the visit through Custom Data events. Example custom data events are conversion value, page type and more.

Form Field Names – This includes website field names like ‘email’, ‘address’, and ‘quantity’ when a person purchases a product or service. The pixel does not capture field values unless an advertiser includes them as part of Advanced Matching or optional values.

We use data sent by the Facebook pixel to enable you to use our ad products, to better reach people who visit your website, to optimize your ads, and provide rich reports and insights about the conversions that result from your ads. Like other businesses in this space we also use this information to improve our advertising and to serve more relevant ads to people. This is a process known as interest based advertising and it is a common industry practice.” https://www.facebook.com/business/m/privacy-and-data

 

Use or Disclosure Without Consent 

 Polity may use or disclose Personal Information about a user without consent under the following circumstances:

  1. a reasonable person would consider that the use or disclosure of the Personal Information is clearly in the interests of the individual and consent of the individual cannot be obtained in a timely way or the individual would not reasonably be expected to withhold consent;
  2. the use or disclosure of the Personal Information is pursuant to a statute or regulation of Alberta, another province that Polity operates in, or a federal statute of Canada that authorizes or requires the use;
  3. the use or disclosure of the information is for the purpose of complying with a subpoena, warrant or order issued or made by a court, person or body having jurisdiction to compel the production of information or with a rule of court that relates to the production of information;
  4. the information is publicly available;
  5. the use or disclosure of the information is necessary to respond to an emergency that threatens the life, health or security of an individual or the public;
  6. the use or disclosure of the information is necessary in order to collect a debt owed to the organization or for the organization to repay to the individual money owed by the organization; and/or
  7. the disclosure of the information is for the purposes of protecting against or for the prevention, detection or suppression of fraud and the organization disclosing the information is permitted or otherwise empowered under an enactment of Alberta or another province Polity operates in, or the federal government of Canada to carry out those purposes.

 

Care of Personal Information and Accuracy of Information 

Polity will use its best efforts to ensure that Personal Information is relevant, accurate, complete and up to date for the purpose for which it is to be used. Where Personal Information is collected directly from an individual, it will be presumed to be accurate and complete at the time of collection, unless there is other information which suggests it is not. Personal Information will be updated as required by the regulatory authorities.

Protection of Information 

Polity will take reasonable steps to protect the Personal Information it holds from misuse or loss and from unauthorized access, modification or disclosure.

Polity will document security, storage and disposal requirements for all Personal Information for which it is responsible. In documenting these requirements Polity will take into consideration the sensitivity of the information, its form and volume, its frequency of use and retention period, the circumstances of its use and storage, and any legal or regulatory requirements.

Polity maintains third party agreements with those companies whose employees have access to our premises and/or Personal Information we collect as a result of our relationship with them (i.e. cleaners, identification verification service, etc.). Polity carefully selects third party service providers, with which we share this information, and ensures that they have similar privacy standards which comply with the Privacy Laws.

Retention and Disposal of Information

Polity will document retention and disposal requirements for all Personal Information for which it is responsible, taking into consideration the sensitivity of the information, its form, the circumstances of its use and any legal or regulatory requirements.

When Personal Information is no longer required to be kept, such information will be destroyed or made anonymous in a controlled and secure manner in order to prevent any unauthorized persons having access to that information. Personal Information which is the subject of a complaint, inquiry or legal process will not be destroyed until the resolution of that process.

(d) Access to and Correction of Information 

Individuals are entitled to inquire whether Polity holds Personal Information concerning them and, if so, to be advised of its use and disclosure. Individuals are also entitled to obtain a copy of the information we have on file. Most of the information can be assessed by logging into their online account. If additional information is required, written request has to be submitted.

How to Request a Copy of Personal Information

To obtain a copy of their Personal Information, clients must submit a written request to Polity’s CPO. In this regard, the request may be sent by Canada Post mail to:

Polity Media Inc.

Attention: Privacy Officer.

Suite 201 239-10th Avenue S.E

Calgary, Alberta T2G 0V9

Time Limit for Response 

Polity will respond to a written request for access, acknowledging the request within 14 business days. If a request is straightforward, Polity will provide a copy of the information on file within 14 business days or, if the request is more complicated, within 30 business days.

There may be circumstances under which we may not be able to provide clients with certain information. For example, the information may have been destroyed or, in our opinion, it is too costly, or we are unable to retrieve the information. In some cases, your request for Personal Information may be denied or access may be restricted as permitted or required by law (information which is subject to legal privilege, information related to third-party or confidential commercial information).

Fees 

Polity will not charge individuals a fee for access to Personal Information concerning them, unless requests are considered unnecessarily frequent or extensive.

Correction of Information on File

Any individual may challenge the completeness or accuracy of Personal Information concerning them and request that the information be corrected. To amend any information we have on file, clients must submit a written request detailing the changes to be made. Our CPO will acknowledge the request and provide written confirmation that the changes or amendments have been made

(e) Reviews and Complaints

An individual who believes his or her privacy may have been interfered with or compromised by Polity may initiate a complaint requesting a review of the matter.

How to Initiate a Complaint 

 Individuals will be required to submit a written complaint to our CPO who will consider the complaint and attempt to resolve it. Our CPO, or another authorized individual, will reply to the individual within 45 working days. If the complaint is not resolved in a manner acceptable to the individual, the firm will advise of:

  • the general reasons for that outcome, where appropriate; and
  • information on the further action that the individual can take under the Personal Information Protection Act, including his or her right to take the complaint to the Privacy Commissioner should he or she remain dissatisfied with the firm’s handling and/or outcome of the complaint.

 

Appeal to the Privacy Commissioner

 As noted above, an individual who is not satisfied with Polity’s handling of his or her privacy complaint may ask the Privacy Commissioner to review any decision, act or failure of Polity. The Privacy Commissioner has powers to investigate and make a determination on the complaint.

How to Request a Review or Initiate a Complaint 

To ask for a review or to initiate a complaint an individual must submit a written request to the Commissioner within 30 days from the day he or she was notified of the firm’s decision. Please note that a longer period may be allowed by the Commissioner.

Notifying Others of a Review

Upon receipt of such a request, the Commissioner must give a copy of the written request to the organization concerned.

Inquiry by the Privacy Commissioner

If a matter under review or relating to a complaint is not referred to mediation, settled pursuant to mediation or resolved, then the Commissioner may conduct an inquiry and decide all questions of fact and law arising in the course of the inquiry. The individual making the complaint and the organization concerned will be given an opportunity to make representations to the Commissioner and be represented by a lawyer at the proceeding. 

(f) Limitation on Unenforceable Provisions

If any provision or part of this Privacy Policy is unenforceable because of any rule of law, regulation or public policy, such unenforceable provision or part shall be severed from this Policy and shall not affect the remainder of this Agreement.

8. Cookies Policy

(a) Introduction 

This Cookie Policy explains how Polity Media Inc. (“Polity”) uses cookies, how you can manage your cookie choices and how you can contact Polity with questions about Polity’s use of cookies. By using the Polity website, you agree to the use of cookies as described in this Cookie Policy. 

(b) What are cookies? 

A cookie is a small file containing a string of characters that is sent to your browser when you visit a website and stored by your browser. 

Cookies may either be “session” or “persistent”. Session cookies expire at the end of your user session when you close your browser. Persistent cookies remain stored on your browser and may capture your settings, activities and preferences on the website or other websites until a specified expiry date, unless deleted earlier. Most cookies collect general information (such as how users arrive at and use a website) but some cookies may collect personal information. 

Cookies may be placed by the organization that owns or operates the website or a third party. For example, an organization may hire a third party service provider to place cookies on the organization’s behalf (such as website analytics) or a third party may place cookies for its own purposes (such as advertising to you). Cookies placed by a third party may gather data across multiple websites or sessions 

(c) What cookies does Polity use? 

Polity uses the following kinds of cookies: 

  • Strictly Necessary Cookies: Polity uses cookies that are required for the operation of the Polity website, such as cookies that permit you to login to your account with Polity.
  • Functional Cookies: Polity uses functional cookies to store the choices you have made on the Polity website, such as your personalized settings and preferences.
  • Analytical Cookies: Polity uses analytical cookies to collect information on how you use the Polity website, such as the pages you view, the products you purchase and the device, operating system and browser type you use.
  • Targeting Cookies: Polity uses targeting cookies to record your use of the Polity website (including the pages you view and the links you click) to deliver targeted content to you.

 

Cookies may be placed by Polity or by a third party.

(d) How can you manage cookies? 

You may choose to decline or disable cookies if your web browser permits, but doing so may affect your ability to access or use certain features of the Polity website. 

(e) Changes to this Cookie Policy 

Polity may change this Cookie Policy from time to time by posting a new version of this Cookie Policy on the Polity website. Polity use of cookies will be governed by the version of this Cookie Policy in effect at that time. Accordingly, you should check the “Last Updated” date of this Cookie Policy (at the top of this Cookie Policy) and review any changes since the last version. If Polity makes material changes to this Cookie Policy, we will highlight these changes on our website.

(f) Contacting Polity

If you have any comments or questions about this Cookie Policy or how Polity uses cookies, please contact the following individual at Polity by mail or e-mail at: 

[email protected]

Polity Media Inc.

Attention: Privacy Officer.

Suite 201 239-10th Avenue S.E

Calgary, Alberta T2G 0V9

9. Forms, Surveys and Polls

(a) Mail List Subscription

By entering your email and postal code into any of the forms on Polity’s website, you agree to be added to Polity’s mailing list, where you will receive updates, news, offers and other relevant marketing information. 

(b) Accuracy & Integrity 

The polls on Polity’s website reflect traffic to the site and the viewpoints and beliefs of those particular users. Polity does not warrant or make representations that the polls perfectly and accurately reflect voter intentions of a particular jurisdiction. 

While Polity strives to preserve the integrity and accuracy of its forms, surveys and polls, Polity does not warrant or make representations that all of the submissions are accurate. By entering your email and postal code into a form, survey or poll, you give Polity permission to investigate and send you security check emails for the purpose of maintaining the integrity of its forms, surveys and polls. 

(c) Dealing with Polity, Not the Candidates

Many of the forms on Polity’s website are administered and controlled by Polity and not the candidates. The candidates who are working with Polity will receive these submissions directly. For the candidates that Polity is not working with, Polity will do its best to forward any form submission to the proper candidate that the voter is trying to reach. 

 

10. Limitation on Unenforceable Provision

If any provision or part of this Agreement is unenforceable because of any rule of law, regulation or public policy, such unenforceable provision or part shall be severed from this Agreement and shall not affect the remainder of this Agreement.