Privacy Policy
Funding Change Privacy Policy
Last Revised: August 2026
7174366 Manitoba Ltd., operating as Funding Change (“Funding Change,” “we,” “us” or “our”), is committed to protecting the privacy and security of Personal Information handled through our technology and services.
This Privacy Policy explains how Funding Change collects, uses, discloses, protects and otherwise handles Personal Information in connection with the Funding Change Platform.
1. About This Privacy Policy
This Privacy Policy applies to the Funding Change Platform and the services made available through it.
For purposes of this Privacy Policy:
“Platform” means Funding Change's websites, applications, software, charitable gaming technology, payment and transaction functionality, point-of-sale functionality, administrative portals, reporting and analytics tools, integrations, services, and other products, features and functionality made available by Funding Change from time to time.
“Personal Information” means information about an identifiable individual, or other information treated as personal information under applicable privacy legislation.
“Partner” means a charitable, non-profit, religious, foundation or other eligible organization that uses the Platform in connection with a charitable gaming, fundraising or related program.
“Participant” means an individual who purchases or receives a ticket, enters or participates in a charitable gaming program, or otherwise interacts with the Platform in connection with a Partner program.
“Regulatory Authority” means the applicable provincial gaming regulator or other governmental or regulatory authority having jurisdiction over a Partner, charitable gaming program or Funding Change.
This Privacy Policy should be read together with any applicable terms governing use of the Platform and the official rules applicable to the particular charitable gaming program in which you participate.
2. Our Role
Funding Change provides technology and related services that enable Partners to establish, operate and administer charitable gaming and fundraising programs.
Depending on the particular program and the services selected by a Partner, Funding Change may collect or process Personal Information:
directly from Participants or other users of the Platform;
on behalf of a Partner;
from a Partner in connection with its charitable gaming or fundraising program;
through authorized third-party service providers and integrations; or
where permitted or required by applicable law or a Regulatory Authority.
Partners may also collect, use and retain Personal Information independently of Funding Change. A Partner's handling of Personal Information outside the Funding Change Platform is subject to that Partner's own privacy practices and policies.
3. Personal Information We May Collect
The Personal Information collected through the Platform depends on how the Platform is used, the type of charitable gaming program, applicable regulatory requirements and the services selected by the Partner.
Identity and Eligibility Information
We may collect information required to identify an individual and establish eligibility to participate in a charitable gaming program, including:
name;
mailing or residential address;
date of birth or age confirmation;
province or jurisdiction of residence;
location or eligibility verification information; and
other information required under applicable law, licence conditions, official program rules or Regulatory Authority requirements.
Contact Information
We may collect:
email address;
telephone number; and
other contact information voluntarily provided to us.
Gaming and Transaction Information
We may collect or generate records relating to participation in a charitable gaming program, including:
tickets purchased or issued;
ticket numbers;
purchase or transaction amounts;
transaction dates and times;
payment status;
payment method category;
transaction or processor reference numbers;
refunds and cancellations;
chargebacks or disputed transactions;
prize and winner information; and
other records necessary to administer, reconcile or audit a charitable gaming program.
Partner and Authorized User Information
For individuals acting on behalf of a Partner, we may collect:
name and business contact information;
organization and position;
Platform account information;
licence and gaming program information;
authorized-user credentials and permissions; and
communications with Funding Change.
Technical and Device Information
When the Platform is accessed, certain information may be collected automatically, including:
Internet Protocol (IP) address;
browser and device type;
operating system;
access dates and times;
pages, functions or features accessed;
session information;
system and security logs; and
other technical information reasonably required to operate, secure and improve the Platform.
Location Information
Where required to confirm eligibility to participate in a charitable gaming program, the Platform or an authorized service provider may collect or process information relating to your location.
Location information is used for eligibility, regulatory and security purposes and is not used by Funding Change for marketing without appropriate consent.
Communications and Support
If you contact Funding Change, we may collect the information you provide as part of the communication, including information required to respond to questions, investigate issues or provide support.
4. Payment and Banking Information
Funding Change does not store full credit card numbers, debit card numbers, online banking credentials or bank account login credentials as part of the Funding Change Platform.
Payment transactions are processed using authorized third-party payment processors, financial institutions, payment networks, payment-terminal providers or other payment technology providers, depending on the payment configuration selected by the Partner.
When you provide payment credentials in connection with a transaction, those credentials may be provided directly to the applicable third-party payment provider and are subject to that provider's security and privacy practices.
Funding Change may receive and retain limited information about a payment transaction where required to operate the Platform, administer the charitable gaming program, provide support, reconcile transactions, address refunds or chargebacks, prevent fraud or meet regulatory requirements. This information may include:
transaction amount;
transaction date and time;
payment status;
payment method type;
processor or transaction reference number;
authorization or response status;
refund information; and
chargeback or dispute information.
Funding Change does not require or use a Participant's full banking or payment credentials for marketing purposes.
Where a Partner processes payments independently of Funding Change, the Partner and its payment service provider are responsible for the collection and processing of the applicable payment credentials.
5. How We Use Personal Information
Funding Change may use Personal Information where reasonably necessary to:
provide, operate, maintain and support the Platform;
establish and administer charitable gaming programs;
issue, record and validate tickets or entries;
determine or verify eligibility to participate;
verify geographic or jurisdictional requirements;
process, record and reconcile transactions;
facilitate refunds and address payment disputes or chargebacks;
identify and communicate with winners;
provide customer and Partner support;
maintain accurate gaming and transaction records;
generate reports required by Partners or Regulatory Authorities;
prevent, detect and investigate fraud, misuse, security threats and unauthorized activity;
monitor and protect the integrity and security of the Platform;
troubleshoot and improve Platform functionality and performance;
comply with applicable legislation, regulations, licence terms, technical standards and Regulatory Authority requirements;
establish, exercise or defend legal rights;
satisfy contractual, accounting, audit and record-keeping requirements;
communicate administrative, transactional, security or service-related information; and
carry out other purposes to which an individual has expressly consented or that are otherwise permitted or required by law.
6. Marketing and Communications
Participation in a charitable gaming program does not automatically enrol you in marketing communications from Funding Change or a Partner.
Where consent is required by law, Funding Change will only use Personal Information for marketing purposes where the individual has opted in to receive those communications.
Similarly, Funding Change will not provide a Participant's Personal Information to a Partner for the purpose of sending marketing or promotional communications unless the Participant has provided the required consent.
Marketing consent is separate from information that must be collected, used or disclosed to administer a charitable gaming program.
Even where you do not opt in to marketing, Funding Change and/or the applicable Partner may still use your contact information where reasonably necessary to:
complete or confirm a transaction;
issue or administer a ticket or entry;
communicate important information about the gaming program;
provide requested customer support;
contact or verify a winner;
process a refund;
investigate a dispute, fraud concern or chargeback;
satisfy legal or regulatory requirements; or
provide other non-marketing communications necessary to administer the program.
Where you have opted in to marketing, you may withdraw your consent or unsubscribe at any time using the unsubscribe mechanism provided with the communication or by contacting the applicable organization.
Withdrawing marketing consent does not affect your ability to participate in a charitable gaming program unless particular information is independently required for eligibility, administration or regulatory purposes.
7. When We Disclose Personal Information
Funding Change does not sell Personal Information.
Funding Change does not disclose Personal Information to third parties for unrelated marketing purposes.
We may disclose Personal Information only where reasonably necessary for the purposes described in this Privacy Policy, where an individual has consented, or where permitted or required by law.
This may include disclosure to:
Partners
Information may be provided to the Partner responsible for the charitable gaming program where required to:
administer the program;
maintain required gaming records;
provide customer support;
reconcile transactions;
identify or contact winners;
investigate issues or disputes;
complete regulatory reporting; or
otherwise satisfy the Partner's legal or regulatory responsibilities.
Information provided to a Partner for these operational purposes is separate from optional marketing consent.
Regulatory and Government Authorities
Funding Change may provide information to a Regulatory Authority or other governmental authority where required to verify or administer a gaming program, comply with licence conditions, satisfy reporting or audit requirements, investigate suspected non-compliance or otherwise comply with applicable law.
Service Providers
Funding Change may use third-party providers to perform functions that support the Platform, which may include:
payment processing;
payment-terminal technology;
hosting and cloud infrastructure;
security and fraud prevention;
communications;
email or messaging;
location or eligibility verification;
analytics;
technical support; and
other technology or operational services.
Funding Change provides service providers only with the information reasonably necessary for the applicable service and takes reasonable steps to require appropriate privacy and security protections.
Legal and Security Purposes
Personal Information may also be disclosed where Funding Change reasonably believes disclosure is necessary or permitted to:
comply with applicable law, legal process or a lawful request;
investigate fraud, security incidents or suspected unlawful activity;
enforce agreements or Platform terms;
protect the rights, property or security of Funding Change, a Partner, Participants or others; or
establish, exercise or defend a legal claim.
8. Regulatory Requirements
Charitable gaming is regulated provincially in Canada, and applicable requirements may differ between jurisdictions and programs.
Funding Change may collect, use, disclose and retain information where necessary to comply with:
applicable federal or provincial legislation;
regulations;
licence conditions;
official gaming rules;
electronic gaming or raffle standards;
technical standards;
record-keeping requirements;
reporting and audit requirements; and
other lawful requirements imposed by an applicable Regulatory Authority.
Where regulatory requirements differ between jurisdictions, Funding Change may handle information differently as necessary to comply with the requirements applicable to the particular program.
9. Service Providers and Data Processing Locations
Funding Change uses third-party service providers to support aspects of the Platform and its operations.
Personal Information may therefore be processed by an authorized service provider in the jurisdiction in which that provider or its infrastructure operates, subject to applicable law, contractual requirements and the configuration of the applicable service.
Funding Change takes reasonable steps to select service providers that maintain appropriate privacy and security safeguards and to limit the information made available to them to what is reasonably necessary to provide their services.
Where Personal Information is processed outside an individual's province or outside Canada, it may be subject to the laws of that jurisdiction and may be accessible to courts, law-enforcement agencies or governmental authorities in accordance with applicable law.
Where applicable legislation requires specific notice, consent or other measures relating to processing outside Canada, Funding Change will take reasonable steps to satisfy those requirements.
Questions regarding the processing locations used by Funding Change's service providers may be directed to the Funding Change Privacy Officer.
10. Cookies and Similar Technologies
The Platform may use cookies and similar technologies to:
maintain user sessions;
enable Platform functionality;
remember user preferences;
protect against fraud and unauthorized access;
understand Platform performance and usage; and
improve the Platform.
Certain cookies or technologies may be necessary for the Platform to function properly.
Where required by applicable law, optional cookies or similar technologies will be used in accordance with applicable consent requirements.
Browser settings may allow users to block or delete certain cookies. Disabling necessary cookies may affect Platform functionality.
11. Security
Funding Change maintains administrative, technical and physical safeguards appropriate to the nature and sensitivity of the Personal Information within its custody or control.
These safeguards may include:
access controls;
authentication measures;
encryption;
network and infrastructure protections;
security monitoring and logging;
backup and recovery measures;
vulnerability and system-management practices;
employee and contractor access restrictions; and
privacy and security policies and procedures.
No electronic system or method of transmission can be guaranteed to be completely secure. Funding Change continually evaluates and updates its safeguards as appropriate to the nature of the Platform, the information being handled and applicable legal and regulatory requirements.
12. Privacy and Security Incidents
Funding Change maintains processes to identify, investigate and respond to suspected privacy and security incidents.
Where an incident involving Personal Information creates a legal obligation to notify affected individuals, a Regulatory Authority, a privacy regulator or another organization, Funding Change will provide notification in accordance with applicable law.
Funding Change also maintains records of privacy and security incidents where required by applicable legislation.
13. How Long We Retain Personal Information
Funding Change does not retain Personal Information indefinitely or simply because it was collected through the Platform.
Personal Information is retained only for as long as reasonably necessary to:
provide the Platform and related services;
administer the applicable charitable gaming program;
complete and reconcile transactions;
provide support;
satisfy contractual obligations;
comply with applicable gaming and regulatory requirements;
meet accounting, audit and record-keeping obligations;
prevent or investigate fraud and security incidents;
resolve disputes or chargebacks; or
satisfy other applicable legal requirements.
Retention periods may differ depending on the nature of the information, the Partner, the type of charitable gaming program and the jurisdiction in which the program operates.
Where Funding Change processes Personal Information on behalf of a Partner, retention may also be governed by Funding Change's agreement with that Partner, subject to applicable legal and regulatory requirements.
When Personal Information is no longer reasonably required, Funding Change will securely delete, destroy or anonymize it in accordance with its applicable retention practices, subject to legal requirements and reasonable backup and archival processes.
Funding Change does not retain full credit or debit card numbers, online banking credentials or bank account login credentials as part of its Platform records.
14. Your Privacy Rights and Choices
Subject to applicable law, individuals may have the right to:
request access to Personal Information held about them;
request correction of inaccurate or incomplete Personal Information;
withdraw consent to certain uses of Personal Information;
change marketing preferences;
ask questions regarding Funding Change's privacy practices; and
make a privacy-related complaint.
Funding Change may require reasonable information to verify identity before responding to a request.
Certain information cannot be deleted or use of it discontinued immediately where Funding Change or a Partner is required to retain or use the information for legal, regulatory, gaming, transactional, security, dispute-resolution or other permitted purposes.
Withdrawal of consent may also affect Funding Change's ability to provide a particular service where the information is reasonably necessary to provide that service.
Marketing consent may be withdrawn at any time without affecting required transactional, regulatory or program-related communications.
15. Children and Age Requirements
Eligibility to participate in a charitable gaming program, including applicable minimum-age requirements, is determined by applicable law, requirements of the applicable Regulatory Authority and the official rules governing the particular program.
Funding Change does not knowingly encourage individuals who are not legally eligible to participate in a charitable gaming program to do so.
Where age verification is required, information may be collected or processed for the limited purpose of confirming eligibility and satisfying applicable legal or regulatory requirements.
16. Winner Information
Charitable gaming laws, licence conditions or official program rules may require certain information concerning a winner to be disclosed to the applicable Partner, Regulatory Authority or the public.
Funding Change will disclose winner information only to the extent reasonably necessary to administer the program and satisfy applicable legal, regulatory or official program requirements.
17. Third-Party Sites and Services
The Platform may contain links to or integrate with websites, applications, payment providers or services operated by third parties.
Funding Change is not responsible for the privacy practices of third parties when an individual interacts directly with their independent services.
Individuals are encouraged to review the privacy policies of applicable third-party providers.
18. Changes to this Privacy Policy
Funding Change may update this Privacy Policy from time to time to reflect changes to the Platform, our services, legal or regulatory requirements, technology or our privacy practices.
The revised Privacy Policy will identify the date on which it was last updated.
Where a change materially affects the manner in which Personal Information is collected, used or disclosed, Funding Change will provide additional notice or obtain additional consent where required by applicable law.
19. Contacting Funding Change and the Privacy Officer
Requests relating to access, correction, consent, privacy practices or complaints may be directed to:
7174366 Manitoba Ltd. o/a Funding Change Email: info@fundingchange.ca
Funding Change will review and respond to privacy inquiries in accordance with applicable law.
20. Language
You and Funding Change have requested and agree that this Privacy Policy and all related documents be drawn up in English.
Les parties ont demandé que la présente politique de confidentialité ainsi que tous les documents qui s'y rattachent soient rédigés en anglais.
