Politique de confidentialité

1. Who we are

Forever Canadian is a non-partisan, citizen-driven civic mobilization initiative based in Alberta. We operate the bilingual (English / French) website https://www.forever-canadian.ca to inform Canadians about the Forever Canadian campaign, build community, and invite supporters to register on the List in order to receive updates about the campaign.

Forever Canadian is not affiliated with any political party, candidate, or electoral campaign. Forever Canadian is not a registered charity under the Income Tax Act (Canada) and we do not issue charitable tax receipts.

Forever Canadian is accountable for personal information in our control, including personal information we transfer to third parties for processing on our behalf. We have designated an individual to act as Privacy Contact, reachable at info@forever-canadian.ca, in accordance with PIPA s. 5 and PIPEDA Principle 1 (Accountability).

2. Scope

This Policy applies to personal information collected:

• through the Sign-Up Form on https://www.forever-canadian.ca and any other registration entry-points operated under the same domain;
• automatically when you visit the website (such as basic server logs and approximate geolocation derived from your IP address); and
• through any reply you send to our welcome or update emails.

This Policy does not apply to:

• personal information collected at https://secure.forever-canadian.ca (donations) — see the Donations Privacy Policy at that domain;
• personal information collected at https://team.forever-canadian.ca (the volunteer / team platform; team-platform inquiries: team@forever-canadian.ca) — see the policies on that platform;
• personal information collected at https://store.forever-canadian.ca (the Forever Canadian Store, operated on a third-party e-commerce platform) — see the Store’s own Privacy Policy at https://store.forever-canadian.ca/policies/privacy-policy. Store-related inquiries should be directed to store@forever-canadian.ca; or
• third-party websites we may link to from forever-canadian.ca.

3. What personal information we collect

3.1 Information you provide on the Sign-Up Form

When you register on the List we ask you for:

• First name (required)
• Last name (optional)
• Email address (required)
• Mobile phone number (optional, Canadian numbers only)
• Postal code (required, Canadian format)
• Your consent to receive updates from the Forever Canadian movement (required — you must check the consent box to submit the form)

We do not ask for, and we do not want, any of the following on the Sign-Up Form: your street address, your date of birth, your government identification, your payment-card information, or any sensitive information (such as health, racial or ethnic origin, religion, sexual orientation, or political-party membership).

3.2 Information collected automatically

When you visit https://www.forever-canadian.ca or submit the Sign-Up Form, certain information is automatically received by our hosting and security infrastructure for the purposes of operating, securing and improving the website. This may include:

• the IP address of the device making the request, together with the approximate geolocation (country, region, city) derived from that IP address;
• standard HTTP request information such as your browser user-agent;
• standard server logs (timestamps, URLs requested, HTTP status codes, error traces); and
• aggregate, non-identifying website-usage analytics (such as page views, referrer, country, and device type).

We do not use Google Analytics, advertising pixels, or third-party cross-site tracking technology on https://www.forever-canadian.ca. The aggregate analytics we use do not set cross-site tracking cookies and do not identify you personally.

3.3 Information you send us by email

If you reply to one of our emails, or write to info@forever-canadian.ca or any other Forever Canadian inbox, we receive your email message, your email address, and any information you choose to include.

3.4 Anti-abuse signals

We use industry-standard anti-abuse measures on the Sign-Up Form to detect and silently reject submissions made by automated systems. We do not publish details of those measures, as doing so would itself reduce their effectiveness.

4. Why we collect this information (Purposes)

In accordance with PIPA s. 13 and PIPEDA Principle 2 (Identifying Purposes), we collect, use and disclose personal information only for the following purposes:

1. To create and maintain your record on the List — so we can recognize you as a supporter, link a future sign-up to your existing record (deduplication by email), and show that you have given consent to communications.
2. To send you a welcome email confirming your sign-up — sent once when you first register.
3. To send you updates about the Forever Canadian campaign, upcoming events, milestones, volunteer opportunities and, where applicable, voting and referendum information — using the email address you provided. SMS or text-message updates may be sent to a phone number you provide, only where you have given express consent for that channel.
4. To match Supporters with regional activity — your postal code and any approximate geolocation we derive from your IP help us identify which Supporters are near a particular event or canvassing area. We do not publish your postal code and we do not use it to identify you to other Supporters.
5. To honour an unsubscribe or withdrawal of consent — recording the fact and timestamp of an unsubscribe request so we can stop sending you communications.
6. To operate, secure and improve the website — including detecting and preventing fraud, abuse, automated attacks, and technical errors; investigating security incidents; and improving site performance and content based on aggregated, non-identifying analytics.
7. To comply with legal obligations — including obligations under PIPA, PIPEDA, CASL, Alberta’s Charitable Fund-raising Act (RSA 2000, c C-9) and its regulation (where applicable to our fundraising activities), Alberta’s Election Finances and Contributions Disclosure Act (where applicable), the Income Tax Act (Canada), and other applicable Canadian and Albertan law.
8. To respond to inquiries you send us by email.

We will not use your personal information for any new purpose that a reasonable person would not consider appropriate in the circumstances without first obtaining your consent.

We do not:

• sell, rent, lease or trade your personal information to anyone;
• share your information with political parties, candidates, electoral campaigns, or unrelated organizations;
• use your information for behavioural advertising or to build advertising profiles;
• combine your information with data brokers’ files to enrich your record.

5. Legal basis for collection (Consent and Reasonable Purposes)

We collect, use and disclose your personal information on the basis of your knowledge and consent (PIPA s. 7; PIPEDA Principle 3). Consent is given when you complete the Sign-Up Form and check the consent box (“I agree to receive updates about the Forever Canadian movement”) before submitting.

We rely on your express consent for:

• adding you to the List and sending you ongoing email updates from Forever Canadian (this is also our basis for compliance with CASL for any commercial electronic message);
• sending you SMS messages, where you provide a mobile phone number for that purpose.

We rely on the reasonable purposes standard under PIPA s. 11 and the corresponding standard under PIPEDA, supplemented (where applicable) by legitimate purposes related to security and fraud prevention, for:

• automatically collected operational and security information (such as basic server logs and approximate IP-based geolocation); and
• the operation of the anti-abuse measures referred to in Section 3.4.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice — see Section 11 below (“Your rights”).

6. Compliance with Canada’s Anti-Spam Legislation (CASL)

Where any email or SMS we send to you constitutes a “commercial electronic message” within the meaning of CASL, we comply with CASL by:

• only sending you the message after you have given your express consent through the Sign-Up Form;
• clearly identifying Forever Canadian as the sender and providing our mailing address;
• including a working unsubscribe mechanism in every commercial electronic message we send to you, processed within 10 business days; and
• honouring withdrawals of consent promptly.

You can unsubscribe at any time using the link at the bottom of every email we send, or by visiting https://www.forever-canadian.ca/unsubscribe and entering your email address. Unsubscribing only affects emails (and, if you provided one, SMS messages) sent to that address; it does not delete your record from the List automatically — see Section 9 (Retention) and Section 11 (Your rights).

7. Service providers and disclosures

We use a small number of carefully selected service providers to operate the website and the List. Each service provider receives only the personal information it needs to perform its function on our behalf, is bound by written terms requiring it to protect that information and use it only for our purposes, and is reviewed by us for its privacy and security practices.

The current categories of service providers we engage are:

• Vercel
• Neon
• Upstash
• Amazon Web Services
• Botler AI

We do not publish a detailed description of the role each service provider performs, the configuration we use, or what specific information each receives, because doing so would provide a roadmap for attackers and would itself reduce the effectiveness of our security controls. We will, however, identify the function of each provider on reasonable request by a Supporter, an auditor, or a regulator (including the Office of the Information and Privacy Commissioner of Alberta or the Office of the Privacy Commissioner of Canada).

We may add or change service providers from time to time. If we materially change the categories of recipients of your personal information, we will update this Policy and, if appropriate, give you notice.

In addition to the disclosures above, we may disclose personal information:

• to public authorities (for example, the Office of the Information and Privacy Commissioner of Alberta, the Office of the Privacy Commissioner of Canada, Elections Alberta, the Government of Alberta, or the Canada Revenue Agency) where disclosure is required or permitted by law, including under PIPA, PIPEDA, the Charitable Fund-raising Act, the Election Finances and Contributions Disclosure Act, the Income Tax Act (Canada), or an applicable court order, subpoena, warrant, or audit;
• to advisors (auditors, lawyers, accountants) bound by duties of confidentiality, where necessary to obtain professional advice or defend a legal claim;
• in connection with legal proceedings or to respond to a lawful court order, subpoena, or warrant;
• to protect the rights, property and safety of Forever Canadian, our staff, volunteers, Supporters, or the public, including to investigate and respond to suspected fraud, abuse, harassment or threats; and
• in the unlikely event of a transfer, merger, restructuring, dissolution or wind-up of Forever Canadian, in which case the recipient organization will be required to handle the information in a manner consistent with this Policy.

We do not disclose personal information for direct marketing by anyone other than Forever Canadian.

8. Storage location and cross-border transfers (notice under PIPA s. 13.1 and s. 13.2)

Forever Canadian is based in Alberta, Canada. We aim to keep Supporter records in Canadian hosting regions wherever reasonably possible.

However, some of the service providers listed in Section 7 are headquartered outside Canada (including in the United States), and personal information may be processed by them in jurisdictions outside Canada when you visit our website or when our systems use their services.

Personal information that is transferred to or stored in another country, or accessed by a service provider headquartered in another country, may be subject to the laws of that country, including laws that compel disclosure of personal information to foreign courts, law-enforcement, regulatory or national-security authorities. We contractually require our service providers to protect personal information to a standard comparable to the one that applies in Alberta and Canada, and to use it only for the purposes for which we transferred it.

If you would like more information about how your personal information is handled when transferred across borders — including the way Forever Canadian uses service providers outside Canada to collect, use, disclose or store personal information — you can contact our Privacy Contact, Forever Canadian at info@forever-canadian.ca (subject: “Privacy”). This notice is provided in accordance with PIPA s. 13.1 and s. 13.2.

9. How long we keep your information (Retention)

We keep personal information only as long as is reasonable for the purposes for which it was collected, after which we destroy, erase, anonymize or aggregate it. Our current retention practices are:

• Active supporter records — kept for the duration of the Forever Canadian campaign and for one year after the campaign ends, unless you ask us to delete your record sooner.
• Records of unsubscribed Supporters — kept in a suppressed state (not sent any further communications) for at least three years after the unsubscribe, in order to honour your withdrawal of consent and document our CASL compliance (reflecting, among other things, the three-year limitation period under section 51 of CASL).
• Operational and security information (such as basic server logs and IP-based geolocation) — kept for a limited period appropriate to the purposes described in Section 4, and then aggregated or deleted.
• Anti-abuse signals — kept only for the short period necessary for the anti-abuse mechanism to function, and then discarded.
• Email and SMS delivery logs at our service providers — kept for a limited period set by, and at, those service providers.
• Records required to demonstrate consent and legal compliance (for example, the date of a consent, the version of the Policy in force at the time, or unsubscribe timestamps) — kept for as long as needed to demonstrate compliance with PIPA, PIPEDA, CASL, the Income Tax Act (Canada), Alberta’s Charitable Fund-raising Act and Alberta’s Election Finances and Contributions Disclosure Act, including any applicable limitation periods.

After the retention period, personal information is destroyed, erased, or anonymized in accordance with our internal record-destruction procedures.

10. Security safeguards

Forever Canadian protects personal information using administrative, physical and technical safeguards appropriate to its sensitivity, in accordance with PIPA s. 34 and PIPEDA Principle 7 (Safeguards). These include encryption of personal information in transit, strict access controls on the systems that hold Supporter records on a need-to-know basis, server-side handling of all credentials, server-side validation of every form submission, and ongoing monitoring and review.

We do not publish a detailed breakdown of our security controls — including the specific anti-abuse, anti-bot, encryption, access-control or monitoring mechanisms we use, or the role each service provider plays in our infrastructure — because doing so would itself reduce the effectiveness of those controls and would expose Supporters to greater risk. We will, however, describe our safeguards at a level appropriate for review by an auditor or regulator on reasonable request.

No method of transmission over the internet or electronic storage is 100% secure; we do not warrant absolute security, and we encourage you to use a strong, unique password for your email account and to keep your device software up to date.

If we have reason to believe a breach involving your personal information presents a real risk of significant harm to you, we will notify you and the appropriate authorities (including the Office of the Information and Privacy Commissioner of Alberta and, where applicable, the Office of the Privacy Commissioner of Canada) in accordance with applicable law.

11. Your rights

Subject to limits set out in applicable law, you have the right to:

• Access the personal information we hold about you, and request information about how it is being used and to whom it has been disclosed (PIPA s. 24; PIPEDA Principle 9).
• Correct personal information that is inaccurate or incomplete (PIPA s. 25).
• Withdraw your consent to our continued use of your personal information, on reasonable notice. Note that withdrawing consent may mean we cannot continue to provide certain services to you — for example, if you withdraw consent to email communications, we will stop sending you updates.
• Unsubscribe from emails — at any time, using the unsubscribe link at the bottom of any email we send you, the unsubscribe page at https://www.forever-canadian.ca/unsubscribe, or by emailing info@forever-canadian.ca with the subject “Unsubscribe”.
• Request deletion of your personal information, subject to legal retention requirements (some information must be kept under PIPA, PIPEDA, CASL, the Income Tax Act (Canada) or Alberta election-finance / charitable-fund-raising legislation).
• Make a complaint about our handling of your personal information.

To exercise any of these rights, email info@forever-canadian.ca with the subject “Privacy Request”. We may ask you to verify your identity before acting on a request that involves disclosure or correction of personal information. We will respond within 30 days (or such other period as required by applicable law). There is generally no charge for an access request; if a fee is permitted by law for a particular request, we will tell you in advance and offer you the chance to modify or withdraw the request.

If you are not satisfied with our response, you may also contact:

• Office of the Information and Privacy Commissioner of Alberta (OIPC) — https://www.oipc.ab.ca/
• Office of the Privacy Commissioner of Canada (OPC) — https://www.priv.gc.ca/
• For CASL complaints, the Canadian Radio-television and Telecommunications Commission (CRTC) — https://www.fightspam.gc.ca/

12. Cookies and similar technologies

The public website https://www.forever-canadian.ca currently does not set cookies for marketing, advertising, or cross-site tracking. We do not use Google Analytics, advertising pixels, social-media re-targeting tools, or third-party cross-site identifiers on this site.

We may use a small number of strictly necessary cookies, local-storage entries, or similar mechanisms required for the website to function — for example, to remember your selected language (English or French). If we add additional cookies in future (for example, on a future logged-in feature), we will update this Policy and, where required by law, ask for your consent.

The team platform at https://team.forever-canadian.ca, the donations portal at https://secure.forever-canadian.ca, and the Forever Canadian Store at https://store.forever-canadian.ca each have their own cookie disclosures published at those domains. The Store, in particular, is operated on a third-party e-commerce platform and uses the cookie and tracking technologies described in the Store’s own Privacy Policy.

13. Children and minors

The website and the List are not directed at children. We do not knowingly collect personal information from anyone under the age of 14, and the Sign-Up Form is intended for individuals who are 18 years of age or older. If you believe a child has submitted personal information to the List, please contact info@forever-canadian.ca and we will promptly delete the record.

14. AI and automated processing

Forever Canadian does not use the personal information collected through the Sign-Up Form to make automated decisions that have legal or similarly significant effects on you. Internal tooling that supports our team may use artificial intelligence to summarize or categorize incoming inquiries; any such use is supervised by Forever Canadian personnel and does not result in your personal information being used to train third-party generative-AI models for unrelated purposes.

15. No-spam, no-sale commitment

Forever Canadian commits that we will:

• never sell, rent, lease, or trade your personal information;
• never send you unrelated marketing or third-party advertising;
• never share your information with political parties, candidates, electoral campaigns, or unrelated organizations; and
• always honour your withdrawal of consent within the timelines required by CASL and applicable privacy law.

16. Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted at https://www.forever-canadian.ca/en/privacy-policy with a new “Effective date” above. Material changes will be highlighted at the top of the page for a reasonable period and, where required by law, we will give you notice and (if applicable) ask for your renewed consent. We encourage you to review this Policy periodically.