Privacy Policy

Effective May 25, 2019.

Introduction

As a platform that facilitates meaningful public engagement, 76engage collects information to ensure that participation is constructive and measurable. As such, we are committed to respecting the privacy of the information provided by end users (participants) is protected following industry best practices.

We do not use personal information for purposes other than those for which it was collected, except with an individual’s consent or as required by law. Once personal information is no longer required to fulfill the identified purposes or other legal requirements, it will be destroyed, deleted or made anonymous. Personal information is retained only as long as necessary for the fulfillment of the purposes stated in this policy.

Our service does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

If you have any questions or concerns about this policy or our practices with regards to your personal information, please contact us.

What data does 76engage collect

Data supplied by users and administrators

Data supplied by users. Anonymous visitors can browse publicly accessible content without providing any personal information. Generally, users need an account to provide input, however some 76engage clients may choose to allow anonymous visitors to provide input. Some 76engage clients may also ask for personal information from anonymous visitors without requiring that these visitors create an account on the site.
To create an account, users must provide their email address, full name and postal code. Users have the option to create a screen name in order to prevent their full name to be shown on the website. Our clients may ask additional information from participants. For example, a client may ask that users provide their gender as part of the registration process.

76engage also collects GPS location information if authorized by users.

76engage also stores data inputted by users in the Contact Form. The Contact Form is a publicly accessible form that can be used by anonymous and logged in participants alike to send a message to the site administrators. In some cases, users may enter personal information in the message they send through the contact form. This information is stored in the 76engage’s database.

Data uploaded by administrators. 76engage administrators have the ability to upload email lists for the purpose of sending out email to a list of email addresses. This is typically used by administrators to send emails inviting users to participate on activities, provide input or access content. We do not permit the use of this feature to send unsolicited commercial email to people with whom administrators do not have a previous relationship. We cannot, however, control how administrators use these lists outside of 76engage nor can we enforce compliance of the methods through which administrators have obtained such lists.

Data collected automatically

User interests. As participants interact with the site, 76engage may collect participant interests based on their activity. For example, when a participant up-votes or comments on a post tagged with certain topic, 76engage may store this topic as being of interest to the participant.

Server logs. As a web application, 76engage collects and stores information in web server logs. This information includes the time and date of the request, the requester’s IP address, and device information such as Operating System and browser version.

Crash logs. When the application experiences a malfunction (crash), an automated notification may be sent to the engineering team with details about the crash. Crash logs do not include personally identifiable information and contain only the information needed for the engineering team to be able to reproduce and troubleshoot the error.

Analytics. Most 76engage installations use Google Analytics to help us and our clients understand how users use the site. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of 76engage. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Some clients may opt to use a different analytics solution.

Other tracking. Our clients may ask to include other tracking technology on their own installations of 76engage. For example, a client may ask that a floodlight tag be installed on a conversion page.

Why we collect this data

We collect data to:

Make sure participants are human. We may use third-party services to help keep automated bots from using the site. For example, we may use Google reCaptcha in conjunction with third-party maintained known spammer lists to prevent automated bots from registering accounts. We also require that users verify their accounts by clicking on a link sent to their email addresses. Until a user verifies his or her account, the account remains flagged as unverified.

Help maintain a constructive dialogue. We believe that by asking users to provide their real names, users will be more likely to keep conversations constructive. We also provide users who prefer not to disclose their full names publicly the ability to create a screen name which if provided, it is displayed next to that user’s comments and contributions on the site.

Ensure quality of participation. Unless otherwise configured by the 76engage administrator, we use cookies (if the user is logged in) or IP addresses in the case of anonymous visitors to limit the number of times one same person can submit input. 

Ensure that participants are from a specific location. We ask for postal code (full or partial, depending on our clients’ preferences) to ensure that participants live in places that are relevant to our clients. For example, during a consultation about transit in a specific city, it is important to our clients that the users who provide input live in this city. Postal code, as well as GPS information if authorized to be shared by the user, is also used to personalize the user experience. For example, 76engage administrators can choose to emphasize engagement activities that are most relevant in terms of proximity to the user.

Notify users of content of interest to them. Users may opt-in to receive automated notifications or invitations from 76engage administrators to participate on specific engagements or to access content that may of interest to them. 
Ensure acceptable use. We may use automated alerts to detect the use of specific keywords or phrases in participant input. For example, we may use this technology to get alerted when users disclose sensitive personal information that they do not need to disclose, or to be alerted to the use of inappropriate language. We may also identify specific users as repeated offenders or particularly bad actors in which case we and/or our clients may choose to terminate their accounts depending on the gravity of their behaviours. 76engage also stores users’ IP addresses. Access to IP addresses gives us the ability to perform intrusion detection analysis to ensure the safety of our users. In the event of a denial of service attack IP address information may be used to mitigate the attack in order to maintain service levels.

Improve the user experience. We use information about the most popular content, the time users spent on pages or the documents they download. We may also use information on whether participants received, opened and clicked on links contained in emails. We use this kind of information to determine which areas of the user experience should be improved. For example, we may use information about whether an email was delivered to an email address to ensure that the receiving mail server isn’t blocking mail from 76engage.

Analyze participant input. The actual contents of the submissions are reviewed on an ongoing basis, analyzed and included in reports and data exports. In some cases, reports and data exports may include information about the participant who submitted the input. This information is only available to 76engage staff who must have access to this information in order to comply with contractual requirements, and to authorized client administrators. The publishing of personal user information within reports is generally subject to explicit consent from the participants whose information will be featured on the reports. We cannot, however, enforce the use of personal information by our clients; this practice is governed by our clients’ specific privacy policies.

In some cases, we may use third-party systems to automatically analyze the toxicity of a user-generated submission, or to automatically analyze a corpus of submissions with the purpose of extracting concepts using natural language processing and machine learning. In both these cases, no personal information is transmitted to the third-party and the contents of the submissions are not stored on the third-parties’ servers.

Provide customer care and support. We may use information about our users in order to provide them with support. For example, we may ask users to authorize us to log in to their accounts to verify application behaviours that appear to be isolated to them. All access to information during the provision of client support is clearly disclosed to, and must be authorized by the user whom we are supporting.

Your privacy controls

76engage provides users the ability to access and control how their information is used within the application. Some actions on the information such as deleting information or withdrawing consent may need to be performed by 76engage administrators or by the engineering team. Users who wish to perform action on their information not available through the site’s user interface may contact us to request that such action be performed. All requests may be subject to verifying the requester’s identity and may be refused if in direct conflict with the law.

Access, update or to delete information. The personal information collected through 76engage can be reviewed and updated by the user who provided the information. Mandatory information such as email address may not be deleted without deleting the entire account. Users may be able to delete their accounts without our intervention. In some cases, and as determined by 76engage administrators, users may need to contact their administrator to have their account deleted.

Obtain and transfer information. Users can request their information and can choose to transfer such information to another service. Users can obtain their information by accessing logging in and visiting their account page.
Withdraw consent. After having provided consent, users have the right to withdraw consent at any time by contacting us and providing reasonable notice. Users can ask for their account to be deleted and their personal information removed from the database. Deleting an account may not delete comments users may have submitted.

Unsubscribing from notifications. 76engage complies with the CAN-SPAM Act that requires that users provide explicit consent to receive electronic messages by opting in. Users who have opted in to receive these messages can opt-out using a one-click unsubscribe method provided with every communication or by updating their subscription preferences.

How your information is shared

We will never sell, rent or trade your data with anyone except the client organization using 76engage to engage with users or as required by law.

With law enforcement. Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). 76engage may disclose user information in the good faith belief that such action is necessary to:

  • comply with a legal obligation
  • protect and defend the rights or property of 76engage or its clients
  • prevent or investigate possible wrongdoing in connection with 76engage
  • protect the personal safety of users of 76engage or the public
  • protect against legal liability

With clients. 76engage is licensed to client organizations who use it to engage with the public through online consultations. Our clients own all data collected through their own installations of 76engage. Each client owns its own data and cannot access data owned by another client.

With a new owner. If we are involved in a merger, acquisition or asset ----, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.

Retention and safety of information

Retention of personal information. We will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, enforce our legal agreements and policies, and only for as long as is necessary for the purposes set out in this policy.

Security of data. Personal information, whatever its form, will be protected by security safeguards appropriate to the sensitivity of the information. The safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. A detailed description of these measures can be requested by contacting us. Note that given the sensitivity of this information we may be required to verify your identity and we may choose not to share this information if we believe that it may compromise the efficacy of the measures they describe.

Where is information stored

Datacentres. We work with cloud hosting providers to host 76engage as a hosted, software-as-a-service (SaaS) solution. We host Canadian clients on Canadian datacentres and US clients on US datacentres. Datacentres store the database and server logs.

Cookies. A cookie is a small piece of information that is sent to a user’s computer when he or she accesses a website. 76engage stores cookies on users’ computers in order to make the experience of using the site friendlier to these users. 76engage does not, however, store or collect information from users for advertising or any other commercial purposes. Users can instruct their browsers to refuse all cookies or to indicate when a cookie is being sent. However, if users don’t accept cookies, they may not be able to use some functionality of 76engage. A detailed description of the cookies we store and retrieve can be seen on our Cookies Policy page.

Analytics data. 76engage installations that use Google Analytics store analytics data on Google’s servers. While we strive to anonymize all data transmitted to Google, there may be edge cases on which some personal information may be transmitted. We are not aware of any such case and should cases become known, we will eliminate them or update this policy if elimination isn’t feasible. 

Email delivery data. Email delivery data including email address and email subject may be stored in third-party services that we may use to facilitate the delivery of email.
User information, including personal information, may be transferred to—and stored on—systems located outside of a user’s state, province, country or other governmental jurisdiction where the data protection laws may differ than those from the user’s jurisdiction.

About this policy

We may update our Privacy Policy from time to time. We will notify users of any changes by posting the new Privacy Policy on the 76engage site. If we make material changes to this policy, we may notify users via our Website, by a blog post, by email, or by any method we determine to be appropriate. We will also change the "Effective date" at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Effective date and replace any prior Privacy Policies. Users are advised to review this Privacy Policy periodically for any changes.

Learn more

If you have any questions about this policy, please contact us via email at privacy@thornleyfallis.com.