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Privacy Policy

Keys Marketing Group Logo

1. Our commitment to privacy

14232321 Canada Inc., operating as Keys Marketing Group (“Keys Marketing Group,” “KMG,” “we,” “us” or “our”), is committed to respecting and protecting personal information.

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We provide fundraising, marketing, donor engagement, member engagement, data management and related services to Canadian charities, nonprofit organizations, membership organizations and other clients.

 

This Privacy Policy explains how we collect, use, disclose, retain and safeguard personal information:

  1. when individuals interact directly with Keys Marketing Group, including through our website, business relationships, recruitment and employment activities; and

  2. when Keys Marketing Group processes donor, supporter, member, prospect or other personal information on behalf of one of our clients.

 

We handle personal information in accordance with applicable Canadian privacy laws, communications requirements, contractual obligations and recognized industry practices.

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2. Scope of this policy

This Privacy Policy applies to personal information handled by Keys Marketing Group in connection with:

  • our website and online forms;

  • inquiries about our services;

  • current and prospective client relationships;

  • supplier and service-provider relationships;

  • email, telephone, SMS and other communications;

  • recruitment, applications, employment and contractor relationships;

  • fundraising, stewardship, membership, survey, lead-generation, data-management and marketing services performed for clients; and

  • our other business, operational and administrative activities.

 

This policy does not replace the privacy policy of a charity, nonprofit organization, membership organization or other KMG client. When we communicate with an individual on behalf of a client, the client’s privacy policy may also apply.

3. Our roles in handling personal information

Keys Marketing Group may handle personal information in two different capacities.

 

A. Information controlled by Keys Marketing Group

 

KMG determines how and why personal information is handled when the information relates to our own operations. This may include information about:

  • website visitors;

  • people who contact us;

  • current and prospective clients;

  • suppliers and business partners;

  • job applicants;

  • employees and contractors; and

  • individuals who subscribe to or interact with KMG’s own communications.

 

For this information, KMG is responsible for establishing the purposes for which the information is collected, used and disclosed.

 

B. Information processed on behalf of clients

 

KMG also receives and processes personal information from, or on behalf of, charities, nonprofit organizations, membership organizations and other clients.

 

In these situations, the client generally determines:

  • what personal information is collected;

  • the purposes for which it may be used;

  • which individuals KMG may contact;

  • the content and purpose of the communication;

  • the campaign, program or service being delivered; and

  • how long the information should be retained.

 

KMG processes this information according to the client’s instructions, our agreement with the client, applicable law, regulatory requirements and our privacy and security obligations.

 

Questions about a client’s underlying collection, use or disclosure of personal information should generally be directed to that client. KMG will assist its clients with privacy inquiries and requests where appropriate.

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4. What personal information we collect

The personal information we collect depends on the nature of the relationship and the services being provided.

 

Website visitors and people who contact us

We may collect:

  • name;

  • organization and job title;

  • business email address;

  • telephone number;

  • mailing address;

  • information submitted through a contact form;

  • correspondence and inquiry details;

  • communication preferences;

  • Internet Protocol address;

  • browser, device and operating-system information;

  • website activity and referring pages; and

  • cookie, advertising, analytics and similar technical information.

 

Clients, prospective clients, suppliers and business contacts

We may collect:

  • name and professional contact information;

  • organization, role and department;

  • account and relationship information;

  • proposals, agreements and project information;

  • billing, payment and transaction information;

  • meeting notes and correspondence;

  • service preferences and instructions;

  • records of consent and communication preferences; and

  • information needed to establish and administer the business relationship.

 

Job applicants, employees and contractors

We may collect:

  • name and contact information;

  • résumé, cover letter and employment history;

  • education, qualifications and professional credentials;

  • references;

  • interview notes and assessment information;

  • eligibility to work in Canada;

  • availability and scheduling information;

  • compensation, banking and payroll information;

  • tax and government identification information;

  • emergency contact information;

  • performance, attendance, training and quality records;

  • system-access and security information;

  • workplace communications;

  • accommodation information where voluntarily provided or otherwise lawfully collected; and

  • other information reasonably required to assess an application or administer an employment or contractor relationship.

 

Some employment information may be subject to separate internal privacy, security, retention and human-resources policies.

 

Donors, supporters, members and other individuals connected to our clients

Depending on the client, campaign or service, we may process:

  • name;

  • mailing address;

  • email address;

  • telephone number;

  • preferred language;

  • demographic or segmentation information provided or authorized by the client;

  • donor, supporter, subscriber or membership status;

  • donation and transaction history;

  • previous campaign responses;

  • communication preferences;

  • consent, unsubscribe and suppression records;

  • do-not-call and do-not-contact instructions;

  • notes from conversations;

  • survey answers;

  • interests in a client’s mission, programs or services;

  • pledge or gift information;

  • payment-processing status or limited payment-related information;

  • records of telephone calls, emails, SMS messages and other interactions; and

  • other information required to perform the services requested by the client.

 

KMG does not seek to collect more personal information than is reasonably required for the applicable purpose or client service.

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5. How we collect personal information

We may collect personal information:

  • directly from an individual;

  • through our website, forms, emails, SMS messages or telephone calls;

  • from a current or prospective client;

  • from an employer, supplier or business partner;

  • through job applications and recruitment activities;

  • through publicly available professional or business sources, where permitted;

  • through service providers and technology platforms;

  • through cookies, analytics tools, advertising pixels and similar technologies; or

  • as otherwise permitted or required by law.

 

When KMG performs services for a client, the personal information will usually be provided by the client or collected during interactions conducted on the client’s behalf.

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6. Why we use personal information

KMG’s own business activities

 

We may use personal information to:

  • respond to questions and requests;

  • provide information about our services;

  • prepare proposals and agreements;

  • establish and manage client and supplier relationships;

  • deliver and improve our services;

  • administer projects, accounts, invoices and payments;

  • conduct business planning, reporting and quality assurance;

  • communicate with clients, prospective clients and business contacts;

  • send permitted newsletters, service updates or promotional communications;

  • organize meetings, demonstrations and events;

  • maintain the operation and security of our website, systems and networks;

  • understand website use and improve website content;

  • measure the effectiveness of our marketing and communications;

  • provide relevant advertising or remarketing, where permitted and selected through the website’s cookie controls;

  • prevent fraud, misuse, security incidents and unauthorized access;

  • comply with legal, regulatory, contractual and insurance requirements;

  • establish, exercise or defend legal claims;

  • recruit and assess applicants;

  • administer employment and contractor relationships; and

  • fulfil other purposes identified at or before the time of collection.

 

Services performed for clients

 

When acting on behalf of a client, we may use personal information to:

  • conduct fundraising and donor-engagement campaigns;

  • request one-time or monthly donations;

  • upgrade, reactivate, recover or renew donor support;

  • welcome, thank and steward donors and supporters;

  • communicate information about a client’s mission, programs, campaigns or impact;

  • conduct surveys, research and supporter engagement;

  • administer membership or subscription activities;

  • respond to inquiries;

  • confirm and update contact information;

  • record communication preferences;

  • process or facilitate authorized donations, pledges and transactions;

  • send email or SMS communications approved by the client;

  • manage inbound and outbound telephone communications;

  • maintain do-not-call, unsubscribe and suppression records;

  • validate, clean, match, segment, analyze and report on data;

  • measure campaign performance and prepare client reports;

  • monitor quality, provide training and confirm compliance;

  • investigate complaints, errors, fraud or security concerns; and

  • perform other services authorized by the client and permitted by law.

 

We do not use client-provided personal information for KMG’s own unrelated marketing purposes unless the individual has consented or the use is otherwise permitted by law and by our agreement with the client.

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7. Consent and other permitted uses

Where consent is required, KMG or the applicable client may obtain consent verbally, electronically, in writing or through an individual’s actions, depending on the circumstances and the sensitivity of the information.

 

Consent may be express or implied where permitted by law. In some circumstances, personal information may be collected, used or disclosed without consent where authorized or required by law.

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Individuals may withdraw consent to certain uses of their personal information, subject to legal, contractual and reasonable notice requirements. Withdrawing consent may affect our ability, or a client’s ability, to provide a requested service or complete a transaction.

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When KMG communicates on behalf of a client, the client is generally responsible for determining the appropriate authority for the communication. KMG supports clients by applying campaign instructions, consent records, suppression lists and communication preferences supplied or approved by the client.

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8. Telephone calls and call recording

KMG conducts inbound and outbound telephone calls for its own business purposes and on behalf of clients.

 

All fundraising calls conducted by KMG are recorded. Calls may also be monitored.

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Call recordings may be used for purposes such as:

  • confirming instructions, donations, pledges or transactions;

  • quality assurance;

  • agent coaching and training;

  • complaint investigation;

  • fraud prevention;

  • regulatory or contractual compliance;

  • confirming adherence to client requirements; and

  • protecting KMG, its clients and individuals involved in the call.

 

Individuals will be notified that a call is being recorded where required.

 

Call recordings and related notes may be accessible to authorized KMG personnel, the applicable client and approved service providers. Recordings are retained only for as long as reasonably required for the relevant business, legal, regulatory, quality, contractual or client purpose.

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9. Email and SMS communications

KMG may send email or SMS communications:

  • in response to an inquiry;

  • to administer a client, supplier, employment or business relationship;

  • to provide service, security or transaction information;

  • about KMG’s services, where permitted; or

  • on behalf of a client for fundraising, stewardship, membership, informational, survey or other authorized purposes.

 

Electronic messages will identify the sender or the organization on whose behalf the message is being sent, as appropriate.

 

Where an unsubscribe mechanism is required, recipients may use the unsubscribe link in an email or reply with the stated keyword, such as “STOP,” to an SMS message. Recipients may also contact KMG or the applicable client directly.

 

Unsubscribe requests will be processed in accordance with applicable requirements. Certain administrative, transactional, security or service-related communications may continue where necessary or permitted by law.

 

Message and data rates may apply to SMS communications, depending on the recipient’s mobile plan. Message frequency may vary by program or campaign.

 

An individual’s decision not to receive optional electronic communications will not prevent them from making a donation or obtaining services through another available method.

 

Specific SMS programs may also be governed by separate SMS Terms and Conditions provided by KMG or the applicable client.

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10. Donations and payment information

When KMG assists with a donation or other payment, payment information may be entered into or transmitted to a payment processor, fundraising platform, financial institution or system designated by the applicable client.

 

KMG seeks to limit its collection and storage of complete payment-card information. Payment information is handled according to the applicable process, client instructions, contractual requirements and payment-security standards appropriate to KMG’s role.

 

KMG does not determine how a client issues charitable tax receipts. Questions about donation receipts, refunds or the charitable use of donations should be directed to the applicable charity or nonprofit organization.

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11. Cookies, analytics and advertising technologies

Our website is hosted through Wix and uses cookies and similar technologies.

 

These technologies may be used to:

  • operate essential website functions;

  • remember visitor preferences;

  • understand how visitors use the website;

  • measure website traffic and performance;

  • maintain website security;

  • improve website content and user experience;

  • measure the effectiveness of marketing activities;

  • support advertising and remarketing activities; and

  • display more relevant content or advertising.

 

Some cookies and similar technologies may be placed by Wix or other third-party analytics, advertising, embedded-content or website-service providers.

 

When visitors first access our website, they may be presented with cookie controls that allow them to accept or decline non-essential cookies. Visitors may change their cookie choices through the available website controls or their browser settings.

 

Essential cookies may be required for the website to operate and may not be capable of being disabled through the website’s cookie preference tool.

 

Declining non-essential cookies may limit analytics, advertising or personalization activities but should not prevent access to the main public content of the website. Disabling certain cookies through a browser may affect website functionality.

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12. When we disclose personal information

KMG does not sell or rent personal information.

 

We may disclose personal information:

  • to the client on whose behalf we collected or processed it;

  • to employees and contractors who require the information to perform their duties;

  • to technology, telephone, cloud-hosting, data-management, analytics, communications, security, recruitment, payroll, payment and professional service providers;

  • to website, analytics and advertising service providers, subject to the visitor’s cookie preferences where applicable;

  • to financial institutions and payment processors;

  • to auditors, insurers, legal counsel, accountants and other professional advisers;

  • in connection with a proposed or completed business transaction, subject to appropriate protections;

  • to investigate suspected fraud, misuse or security incidents;

  • to establish, exercise or defend legal rights;

  • to comply with a subpoena, court order, lawful request or other legal obligation;

  • to law-enforcement, regulatory or government authorities where permitted or required; or

  • with consent or as otherwise permitted by law.

 

Service providers are authorized to handle personal information only for the purposes for which they have been engaged or as otherwise permitted by law. KMG uses contractual, administrative and technical measures appropriate to the nature of the relationship and information.

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13. Processing outside Canada

KMG is a Canadian organization serving clients throughout Canada.

 

KMG seeks to store and process client-service information in Canada where reasonably available and appropriate. However, our website is hosted through Wix, and information associated with website operation, cookies, analytics, advertising technologies or website use may be stored, accessed or processed outside Canada.

 

Information processed in another jurisdiction may be subject to that jurisdiction’s laws and may be accessible to courts, government agencies or law-enforcement authorities in accordance with those laws.

 

KMG remains responsible for personal information under its control and uses measures appropriate to the nature and sensitivity of the information when engaging service providers.

 

Individuals may contact our Privacy Officer for more information about our use of service providers outside Canada.

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14. Safeguarding personal information

KMG uses administrative, technical, physical and contractual safeguards appropriate to the sensitivity, amount, format and use of the personal information.

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These measures may include:

  • privacy, confidentiality and security policies;

  • employee and contractor confidentiality obligations;

  • privacy and security training;

  • access controls based on job responsibilities;

  • multifactor authentication;

  • password and identity-management controls;

  • encryption and secure transfer methods;

  • endpoint and network security;

  • logging, monitoring and vulnerability management;

  • restricted storage locations;

  • backup and recovery measures;

  • secure disposal processes;

  • incident-response procedures;

  • supplier and service-provider controls; and

  • payment-security practices appropriate to KMG’s role.

 

No system or method of transmission is completely secure. KMG cannot guarantee absolute security, but we work to prevent unauthorized access, use, disclosure, alteration, loss or destruction of personal information.

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15. Privacy and security incidents

KMG maintains procedures for responding to suspected or confirmed privacy and security incidents.

 

When an incident involves information processed for a client, KMG will notify and assist the client in accordance with the applicable agreement and legal requirements.

 

Where KMG controls the affected information, we will assess the incident and provide notifications to affected individuals, regulators or other parties when required by law.

 

KMG maintains records of privacy breaches in accordance with applicable legal and regulatory requirements.

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16. Accuracy

KMG takes reasonable steps to keep personal information accurate, complete and up to date for the purposes for which it is used.

 

We rely on individuals and clients to provide accurate information and to advise us when information changes.

Individuals may request a correction by contacting KMG or, where the information is controlled by one of our clients, the applicable client.

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17. Retention and secure disposal

Keys Marketing Group retains personal information only for as long as reasonably necessary to:

  • fulfil the purposes for which it was collected;

  • provide contracted services;

  • meet client instructions;

  • maintain appropriate consent, communication and transaction records;

  • administer business, employment and supplier relationships;

  • respond to inquiries, access requests or complaints;

  • satisfy legal, regulatory, contractual, security and insurance requirements;

  • resolve disputes; and

  • establish, exercise or defend legal claims.

 

Retention periods vary according to the nature and sensitivity of the information, the purpose for which it is used, client requirements and applicable obligations.

 

In establishing and reviewing retention periods, KMG considers applicable Canadian privacy, telecommunications and electronic-communications requirements, including PIPEDA, CASL and CRTC requirements, as well as applicable international requirements, Payment Card Industry Data Security Standard requirements and recognized industry practices.

 

Information processed for a client may also be retained or deleted according to that client’s documented instructions and contractual requirements.

When personal information is no longer required, KMG securely deletes, destroys or anonymizes it, subject to applicable legal holds, backup processes and record-keeping obligations.

 

Certain consent, unsubscribe, do-not-call and suppression information may be retained to ensure that an individual’s communication preferences continue to be respected.

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18. Accessing or correcting personal information

Subject to legal exceptions, an individual may request:

  • access to personal information under KMG’s control;

  • information about how that information has been used or disclosed; and

  • correction of inaccurate or incomplete information.

 

KMG may need to verify the requester’s identity before responding. We will not use identification information collected for verification for unrelated purposes.

 

Where a request concerns information that KMG processes on behalf of a client, we may refer the request to the client or assist the client in responding.

 

Access may be limited or refused where permitted or required by law, including where disclosure would reveal personal information about another person, confidential commercial information or information protected by legal privilege.

 

If access is refused, we will explain the reason unless prohibited by law.

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19. Communication preferences and do-not-contact requests

Individuals may ask not to receive certain communications by:

  • using the unsubscribe link in an email;

  • replying “STOP” or another stated unsubscribe keyword to an SMS;

  • advising an agent during a telephone call;

  • contacting the organization identified in the communication; or

  • contacting KMG’s Privacy Officer.

 

KMG maintains internal suppression and do-not-contact processes and applies client-provided suppression instructions to applicable campaigns.

 

Because KMG acts for multiple organizations, a request made in relation to one client or campaign may not automatically apply to communications from a different organization. Individuals should identify the organization or communication to which their request relates.

 

KMG will take reasonable steps to understand and apply an individual’s stated preference.

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20. Children’s information

KMG’s website and business services are not directed toward children.

 

KMG may process information relating to children or families when performing authorized services for a client whose mission or programs involve children. In those circumstances, KMG processes the information only for the client-authorized purpose and with safeguards appropriate to its sensitivity.

 

KMG does not knowingly use children’s personal information for its own direct marketing.

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21. Third-party websites and services

Our website and communications may contain links to websites, donation platforms or services operated by clients or other third parties.

 

KMG is not responsible for the privacy practices, content or security of third-party websites and services. Individuals should review the privacy policy of the relevant third party before submitting personal information.

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22. Employment and applicant information

Information submitted for employment may be used to:

  • assess qualifications and suitability;

  • communicate about an application;

  • conduct interviews and reference checks;

  • confirm eligibility to work;

  • consider an applicant for other suitable opportunities;

  • comply with employment and legal requirements; and

  • establish an employment or contractor relationship.

 

Applicant information may be shared with employees, contractors and service providers involved in recruitment, human resources, technology or administration.

 

Information about unsuccessful applicants will be retained only for as long as reasonably required for recruitment, record-keeping, operational and legal purposes, unless a longer period is required or consented to.

 

Employment information may be handled under additional internal policies that supplement this Privacy Policy.

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23. Privacy Officer

KMG has designated a Privacy Officer who is responsible for overseeing our privacy program and responding to questions, access requests, correction requests and complaints.

 

Privacy Officer
14232321 Canada Inc., operating as Keys Marketing Group
Box 847
Pemberton, British Columbia
V0N 1L0 Canada

Email: privacy@keysmarketinggroup.com
Telephone: 1-833-539-7360

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Please do not send payment-card numbers, government identification numbers, medical information or other highly sensitive information through unencrypted email.

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24. Questions and complaints

Questions, access requests, correction requests and privacy complaints may be submitted to our Privacy Officer.

 

Please include enough information for us to understand and respond to the matter, but do not include unnecessary sensitive information.

 

KMG will:

  • acknowledge and review the concern;

  • investigate as appropriate;

  • respond within a reasonable period;

  • explain the outcome; and

  • take corrective action where warranted.

 

Where a complaint relates to personal information controlled by a KMG client, we may refer the matter to that client and assist with the response.

Individuals may also have the right to contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.

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25. Changes to this policy

KMG may update this Privacy Policy periodically to reflect changes to our services, practices, technologies, legal obligations or regulatory requirements.

 

The updated policy will be posted on our website with a revised “Last updated” date. Where appropriate, we may provide additional notice of a material change.

 

Where a change materially affects how personal information is collected, used or disclosed, KMG will provide notice or obtain additional consent where required by law.

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