Introduction
Superior Greenstone Association for Community Living (“SGACL”, “we”, “us”, or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect through our website and online 50/50 raffle, why we collect it, how we use and safeguard it, and the choices and rights available to you.
We handle personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Ontario law. By using this website, you acknowledge the practices described in this policy.
Questions about your data?
Contact our Privacy Officer at privacy@superiorgreenstonecl.ca. Details are in the Contact our Privacy Officer section below.
Who we are
Superior Greenstone Association for Community Living is a registered Canadian charity providing residential and community-based support to adults with intellectual and developmental disabilities in Northern Ontario.
- Legal name: Superior Greenstone Association for Community Living (SGACL)
- CRA charity number: 107625303RR0001
- Registered address: P.O. Box 970, Geraldton, ON P0T 1M0, Canada
- General enquiries: info@superiorgreenstonecl.ca
- Privacy Officer: privacy@superiorgreenstonecl.ca
Our online 50/50 raffle is conducted under licence from the Alcohol and Gaming Commission of Ontario (AGCO), Licence No. RAF1552567.
What personal information we collect
We collect only the information we need for the purposes described in this policy. The table below summarizes the categories of personal information we collect, why we collect it, and the legal basis for doing so under PIPEDA.
| Data type | Purpose | Legal basis |
|---|---|---|
| Name, email address and message content (contact form) | To respond to your enquiry, provide support, and keep a record of our correspondence. | Consent; our legitimate interest in responding to you. |
| Payment information (card details, billing name) | To process raffle ticket purchases and donations. Card data is entered directly into our payment processor’s hosted form — SGACL never sees or stores full card numbers. | Necessary to perform the transaction you request. |
| IP address and approximate geolocation | To confirm you are physically located in Ontario at the time of a raffle purchase, as required by our AGCO licence, and to protect the site from fraud and abuse. | Necessary for legal and regulatory compliance. |
| Cookies and analytics identifiers | To operate the site, remember your preferences, and — only with your consent — measure how the site is used. See the Cookie Policy. | Consent (analytics and marketing); necessity (essential cookies). |
| Raffle winner name and city | To publish results transparently and confirm the legitimacy of the draw, where the winner has consented to publication. | Consent; regulatory transparency requirements. |
| Account details (if you register) | To let you sign in, view your ticket history, and manage your communication preferences. | Necessary to provide the account service you request. |
How we use your information
We use the personal information we collect to:
- Process and confirm raffle ticket purchases and charitable donations;
- Verify eligibility (age and Ontario location) as required by our AGCO licence;
- Send transactional messages such as purchase confirmations and receipts;
- Respond to enquiries submitted through our contact form;
- Publish raffle results and notify and pay winners;
- Operate, secure, maintain, and improve our website;
- Send marketing communications where you have explicitly opted in (see Marketing & CASL); and
- Comply with legal, regulatory, and record-keeping obligations.
We do not sell your personal information, and we do not use it for automated decision-making that produces legal or similarly significant effects.
Cookies and similar technologies
We use cookies and similar technologies to run essential site functions, remember your preferences, and — only after you consent — to measure site performance and support marketing. Essential cookies (including those used for security, consent storage, and Ontario geolocation at the point of purchase) are always active because the site cannot function without them. Analytics and marketing cookies load only after you accept them.
You can review and change your choices at any time using the “Cookie settings” link in the footer. For a full list of the cookies we use, their providers, and their lifetimes, please see our Cookie Policy.
Sharing with third parties
We share personal information only with service providers that help us operate the website and raffle, and only to the extent necessary for them to perform their services. These providers are contractually required to protect your information and to use it only for the purposes we specify.
| Service provider | Role | Information shared |
|---|---|---|
| Payment processors (Stripe, Square, CanadaHelps) | Securely process ticket purchases and donations under PCI-DSS. | Card and billing details (entered directly with the processor), amount, transaction reference. |
| Rafflebox Technologies Inc. | Operates the raffle ticketing, draw, and winner administration. | Purchaser name, email, ticket numbers, eligibility confirmation. |
| Email delivery (SendGrid / Mailgun) | Send transactional and, where opted in, marketing emails. | Name, email address, message content. |
| Google (Analytics & Ads) | Measure site usage and campaign performance, only after you consent. | Pseudonymous usage data, cookie identifiers, IP address. |
We may also disclose personal information where required by law, court order, or a lawful request from a regulator such as the AGCO, or to protect the rights, safety, and property of SGACL and others.
Data retention
We keep personal information only for as long as necessary to fulfil the purposes described in this policy, to satisfy our legal and regulatory obligations, and to resolve disputes.
- Raffle ticket records: retained for at least 1 year, in line with AGCO requirements.
- Raffle confirmations and financial records: retained for at least 4 years, in line with AGCO and charity record-keeping requirements.
- Contact enquiries: retained for up to 2 years after your last contact, then deleted or anonymized.
- Consent logs: retained for at least 24 months to demonstrate that valid consent was obtained.
- Marketing subscriptions: retained until you unsubscribe, plus a short suppression record to honour your opt-out.
Your rights under PIPEDA
Subject to certain legal exceptions, you have the right to:
- Access the personal information we hold about you and be told how it is used and disclosed;
- Correct information that is inaccurate or incomplete;
- Withdraw consent to non-essential processing, subject to legal and contractual limits; and
- Complain about how we handle your personal information.
To exercise any of these rights, contact our Privacy Officer at privacy@superiorgreenstonecl.ca. We will respond within the timeframes required by PIPEDA. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca or 1-800-282-1376.
Marketing & CASL
We send marketing and newsletter emails only to people who have given us explicit, opt-in consent, in accordance with Canada’s Anti-Spam Legislation (CASL). We never pre-check consent boxes.
Every marketing message includes a clear unsubscribe link and our mailing address (P.O. Box 970, Geraldton, ON P0T 1M0, Canada). We action unsubscribe requests promptly, and in any event within 10 business days. Transactional messages — such as purchase receipts and winner notifications — are not marketing and are sent as part of the service you requested.
Publication of raffle winners
To keep our raffle transparent and to comply with our AGCO licence, we may publish the first name and city of winners (for example, “Jordan from Geraldton”). We publish this information only with the winner’s consent, obtained during the prize-claim process. We do not publish street addresses, contact details, or the full names of winners.
Geolocation
Because our raffle may lawfully be offered only to people physically located in Ontario, we check your location at the point of purchase. This check is requested only when you begin a purchase — never simply for visiting the site — and we explain why we need it before asking. Geolocation is a strictly necessary function of the purchase process and is not controlled by the cookie consent banner. We use the result solely to confirm eligibility and do not use it to track you.
Data breach procedure
We maintain safeguards designed to protect personal information against loss, theft, and unauthorized access, use, or disclosure. If a breach of security safeguards occurs that creates a real risk of significant harm to affected individuals, we will notify the Office of the Privacy Commissioner of Canada and the affected individuals as soon as feasible, and we will keep records of the breach as required by PIPEDA.
Children
Our website and raffle are intended only for adults aged 18 or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected such information, we will delete it. If you believe a minor has provided us with personal information, please contact our Privacy Officer.
Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will update the “Last updated” date at the top of this page and, where appropriate, provide additional notice. Previous versions are archived so that changes remain transparent.
Contact our Privacy Officer
If you have questions, concerns, or requests about your personal information or this policy, please contact our Privacy Officer using the details below.