Funding Change Website Privacy Policy

Last revised March 16, 2016

This Funding Change Website Privacy Policy (this "Privacy Policy") governs your access to and use of the websites, services and applications (collectively, the "Site") which are owned, operated or provided through third party websites, by 7174366 Manitoba Ltd. (“Funding Change”).

In this Privacy Policy, "Personal Information" means information about an identifiable individual. “We” means (and “us”, “our”, and “ours” refer to) Funding Change. “You” means (and “your” refers to) the user of the Site. "Raffle Organizers" means charitable and religious organizations who hold fundraising raffle draws (each draw, a "Raffle") and "Raffle Entrants" means people who purchase tickets (each, a "Ticket"), as part of a Raffle.


1. Acceptance of Terms

By accessing and continuing to use the Site, and by providing certain Personal Information to Funding Change through the Site, you are indicating your acceptance to be bound by the terms and conditions of this Privacy Policy. If you do not accept these terms and conditions, please do not access or use the Site, or provide Personal Information through the Site.

2. Modifications and Notices

We may revise this Privacy Policy, at any time, by updating this posting. We may provide notice to you of material revisions by means of a general notice on the Site. Your continued use of the Site after such revisions are posted, will signify your agreement to these revised terms. Therefore, you should visit this page periodically to review this Privacy Policy.

3. Funding Change Respects Your Privacy

Funding Change is committed to protecting the privacy of all of our users of the Site and maintaining the integrity of any Personal Information that we collect, use, retain or disclose via the Site. The purpose of this Privacy Policy is to inform you about how and why we collect Personal Information on the Site, to outline the steps we take to safeguard your Personal Information, and to provide you with a Funding Change contact number if you have any questions or concerns about our privacy practices.

4. General Information

Our Internet servers may passively and automatically collect certain information about website visitors’ traffic patterns, which may be linked to their Internet Protocol (IP) addresses (which are unique Internet “addresses” assigned to all Internet users by their Internet Service Providers). Server logs may record statistical information, such as visitors’ IP addresses, type of operating systems, time and duration of visit, pages requested, and identify categories of visitors by items such as domains and browser types. These statistics are generally collected and used on an aggregate basis.

  • Cookies: The Site may use "cookies". Cookies are small text files offered to your computer by servers in order to keep track of your browser as you navigate a website. Cookies may be stored on your hard drive, or in temporary (cache) memory, in which case they are deleted when you shut down your browser or turn off your computer. We may use cookies to record session information, such as your browsing habits and past activity, to enable us to provide you with improved services such as customized webpage content. You can disable cookies using your Internet browser's settings. Please consult your browser's help function for information about how to disable cookies. Note that if you disable cookies, certain features of the Site may not function properly.
  • Links to Third Party Websites: The Site may contain links to other websites that are provided as a convenience only, and which may have different privacy policies and practices than we do. We have no responsibility for these third party websites, and you are advised to review the privacy policies of any third party websites you choose to visit.

5. What Personal Information do we Collect, and how do we Collect it?

In the course of operating the Site, we have collected and will collect Personal Information from you, including:

  • information you voluntarily submit directly to us when you register an account or use the Site to purchase a Ticket. User profile information you submit to us may include your name, address, phone number, date of birth and email address. In the case of a Raffle Organizer, we will ask for the Provincial gaming authority's assigned licence number for your Raffle, in addition to other information which is required to verify your raffle with the Provincial Regulator and identify your Raffle to users of the Site. If you are a Raffle Entrant, we will ask for information which is required to process your payment for Tickets, such as your credit card information. If we make such a service available, we may also ask for information which permits the electronic transfer of funds into an account you may set up for that purpose;
  • information you voluntarily submit to us, when you post, transmit or submit messages, opinions or other content, including, but not limited to, text, photographs, images, illustrations, graphics or multimedia clips and any other user generated content (collectively, "Submitted Materials"), to or through the Site (whether directly or indirectly, through third party websites and applications), and to interact with Funding Change and other users within, or in connection with, the Site; and
  • information we may passively and automatically collect from you, such as your IP address, and other information about website visitors’ traffic patterns, as discussed above.

In some cases, your Personal Information may be submitted to us indirectly, through a third party service provider, such as Facebook Connect, Twitter, Google+ and Instagram. In other cases, you may be asked to provide information to a third party, such as when you submit billing information to service providers we use to process payments on our behalf.

We collect your Personal Information when you sign up for an account, when you register a Raffle with us, when you purchase a Ticket, when you provide Submitted Materials to us and any other time when you choose to provide us your Personal Information. If you do not want to provide your Personal Information to us, then you should not use the Site to register your Raffle or purchase a Ticket, or to provide Submitted Materials.

We collect this Personal Information for the following purposes:

  • to offer services to you and others through the Site, including the registration of Raffles and the purchase of Tickets. In order to allow Raffle Organizers to sell Tickets to Raffle Entrants, we need to verify each Raffle, so much of the information we collect from Raffle Organizers will be used for this purpose. We also collect information about Raffle Entrants, so that winners can be contacted by Raffle Organizers. In addition, we are required to retain information about Raffle Organizers and Raffle Entrants, as required by the Provincial Regulator and related laws and agreements, including The Liquor and Gaming Control Act, associated regulations, the raffle terms and conditions and technical standards for electronic raffle systems which are created and revised by the Provincial Regulator, from time to time, and such other terms or conditions as may be set by the Provincial Regulator, in connection with your Raffle (collectively, the "Provincial Regulator Rules"). The Personal Information we collect from Raffle Entrants, to comply with the Provincial Regulator Rules, includes:
    1. your name, address and birth date, so that your identity can be verified, when you are issued a Ticket or if you win a Raffle. We collect your address to confirm you are eligible to purchase tickets. We also collect your birth date, so that we can verify if you are at least 18 years of age, if required to use the site. In some cases, this information may also be required by a third party payment processor we use to process your payments for Tickets;
    2. your email address and telephone number, so that you can be contacted by us or the Raffle Organizer, if you win a Raffle, or for such other purposes as are set out in this Privacy Policy or the Funding Change Terms of Use;
    3. your physical location, to verify the province in which you are located;
    4. the number of Tickets you have purchased and the cost of all Tickets you have purchased, which Provincial Regulator Rules require to be recorded and retained, for each Raffle;
    5. records of your account and log-in activity, so that unusual activity or periods of inactivity can be monitored to ensure the integrity of the Raffle, in accordance with the Provincial Regulator Rules, and, in some circumstances, disclosed to the Provincial Regulator; and
    6. the winner's identity, which is disclosed to the Provincial Regulator and made available to the public, together with the winner's prize, in accordance with the Provincial Regulator Rules;
  • to advertise, develop, enhance and provide services and products to viewers and users of the Site, including sharing Submitted Materials to other users of the Site. If you permit us, we will share your name and email address with the Raffle Organizer whose Raffle you have entered. If you do not want us to share that information, you can opt out, using the Site's communication settings (provided that you will need to provide sufficient contact information for the Raffle Organizer to contact you, if you win a Raffle);
  • to protect users of the Site and Funding Change against error and fraud; and
  • to carry out any other purpose that you have authorized or that is required or permitted by law.

Further reference in this Privacy Policy to "Identified Purposes" means the reasons set out in this Section 5.

6. What About Children?

People under the age of 18 are permitted to use the Site where permitted by the Provincial Regulator and the official Raffle Rules. Parents and legal guardians are responsible for ensuring their children do not use the Site in any other case.

7. Does Funding Change disclose your Personal Information to Others?

Funding Change does not disclose Personal Information to third parties for any other purposes other than those for which it was collected and which have been identified to you. For example, Personal Information may be disclosed in the following circumstances:

  • by publishing details about Raffles and Raffle Organizers, so that Raffle Entrants can buy Tickets;
  • by sharing Raffle information and Provincial Regulator licence numbers with Provincial Regulators, to verify the authenticity of Raffles;
  • by sharing contact information of Raffle Entrants with Raffle Organizers, so that Raffle Organizers can contact Raffle winners;
  • by publishing the first and last name of Raffle winners on Funding Change, in order to comply with Provincial Regulator Rules; or
  • by sharing information about Raffles, Raffle Organizers and Raffle Entrants with the Provincial Regulator, to comply with the Provincial Regulator Rules. The nature of these disclosures to the Provincial Regulator has been described in Section 5 above.

Other disclosures of Personal Information may occur in order to fulfil the Identified Purposes which are set out in Section 5 above. If we plan to use Personal Information for a different purpose, we will do so with your consent, or as required or permitted by law.

There are a variety of circumstances where we may need to share Personal Information with third parties. For example, Funding Change may transfer Personal Information to a third party engaged by us to perform functions on our behalf (such as a payment processor) or to a public authority or agent of a public authority (such as the Provincial Regulator), if disclosure is reasonable for the purposes of investigating a breach of an agreement or a contravention of the laws of Canada or a province that has been, is being or is about to be committed and it is reasonable to expect that disclosure with the knowledge or consent of the individual would compromise the investigation.

In situations where we disclose Personal Information to third parties in accordance with this Privacy Policy, we do not disclose more information than is required and, where it is reasonable and practical to do so, enter privacy agreements with third parties to whom we disclose Personal Information.

8. Is your Personal Information Disclosed when you buy a Ticket?

We may share the Personal Information of Raffle Entrants with Raffle Organizers, such as names and email addresses, so that Raffle Organizers may contact Raffle Entrants about causes which Raffle Organizers believe may be of interest to them. Raffle Entrants can use the Site's communication settings to control whether or not this information is shared with Raffle Organizers. As discussed above, this information is also collected in order to comply with the Provincial Regulator Rules, which may in some cases require disclosure of this information, to the Provincial Regulator.

9. Transfer of Personal Information to Service Providers outside Canada

We will only use Personal Information for the purposes that we identify to you. We may engage service providers to assist us with fulfilling these purposes, and, in some instances, these service providers may be located outside Canada. However, any data which is transferred outside Canada is anonymized, before it is transferred.

We only select service providers that protect Personal Information in a manner that is comparable to the protection we provide under our own privacy policies. However, Personal Information may be subject to, and accessed under, the laws of the countries in which our service providers operate.

If you have any questions about our transfer of Personal Information to our service providers outside Canada, or if you would like to learn more about our privacy policies in that regard, please contact our Privacy Officer at the contact information provided below.

10. How does Funding Change safeguard your Personal Information?

Funding Change uses various means to help safeguard your Personal Information. Only authorized employees and agents have access to Personal Information. Funding Change employees who have access to Personal Information receive training regarding privacy protection. All computers on which Personal Information is stored, are password protected. Funding Change uses data encryption to increase the security of the Personal Information you provide to us via the Site.

Without limiting the foregoing, Funding Change has implemented safeguards, to protect information collected pursuant to each Raffle (which may include your Personal Information), including measures with respect to:

  • operation and server security, such as physical security measures and access controls;
  • network security;
  • significant event monitoring and logging;
  • backup and recovery;
  • data archiving;
  • verification of system software; and
  • system security (including firewalls, audit logs and remote access protocols).

11. How long will we Retain your Personal Information?

We will keep your Personal Information for as long as is necessary for us to fulfill the Identified Purposes. Generally speaking, that means we will destroy or anonymize your Personal Information when your account with us is no longer active. We are required by regulatory bodies, such as the Provincial Regulators, to keep all information about a Raffle (which may include your Personal Information, to the extent it has been collected as part of operating the Raffle as described in Section 5 above) for three years.

12. Your Consent/Verifying and Amending Personal Information

You may withdraw your consent for Funding Change to manage your Personal Information in a particular way, subject to legal or contractual restrictions and reasonable notice (for example, Raffle Entrants can use the Site's communication settings to control whether their Personal Information is shared with Raffle Organizers whose causes they have supported). However, this may limit our ability to provide you with certain services and/or products. You may contact Funding Change for more information regarding the implications of withdrawing consent.

You can also access and review your Personal Information held by Funding Change and make appropriate changes to it by contacting Funding Change. You may be required to put your request in writing and show us identification. The reason we ask for identification is to ensure that, among other things, we do not unintentionally release your Personal Information to a third party who is representing him/her as you.

Funding Change can be reached at:

  • Funding Change
  • 601-62 Albert St.
  • Winnipeg, MB R3B 1E9

You may update or request access to your Personal Information by writing or email to Funding Change at the addresses provided above.

13. Language

You and Funding Change have requested and agree that this Privacy Policy and all documents related to this Privacy Policy be drawn up in English. Les parties ont demandé que cette convention ainsi que tous les documents que s'y rattachent soient rédigés en anglais (version française).

14. Resolving Your Concerns

If you would like more information about Funding Change’s privacy practices, please contact the Funding Change Privacy Officer. Please let us know about your questions or concerns and we will do our best to help you.