Last updated: November 18, 2024

1. INTRODUCTION
Welcome to the Kin Theory Database, a website found at https://www.kintheory.org (the “Site”) and operated by the Centre for Aboriginal Media (Ontario) doing business as ImagineNATIVE (“ImagineNATIVE”, “we”, or “us”). The Site exists to help Indigenous peoples seek recognition, partnership, and support to counter pressures that threaten guardianship around the globe. This Privacy Policy is intended to inform you about our policies and procedures regarding the collection, use, and storage of personal information we receive from Site visitors and others who use engage with us or use our services (“you”). We understand and greatly value the importance of your privacy. We will only use your personal information in accordance with this Privacy Policy, unless otherwise required by applicable law.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES DESCRIBED IN THIS PRIVACY POLICY, DO NOT USE THE SITE.

2. TYPES OF INFORMATION WE COLLECT.
The types of personal information we collect will depend on the nature of your dealings with us. We may collect and use several types of information about you including:
● Personal Information which is information that can reasonably be used to directly or indirectly identify, locate or contact you, such as your name, address, age, image, biography, phone number, identification and email address.
● Non-Personal Information which is information that does not directly or indirectly identify you or any other individual, such as demographic information, statistical or aggregated information, technical information and information about your interactions with the Services.

3. INFORMATION WE COLLECT.
A. Information You Provide Us.
In order to access and use our Site and the services we provide, we may ask you to provide the following information:
● When you create a user account, we require you provide us with your name and email address.
● To create an artist portfolio for the Kin Theory Database, you may be required to provide your image, name, pronoun, Indigenous group, ethnicity, fluent languages, country of birth/residence, professional biographical information and other information you wish to be publicly available in your profile.
● When you subscribe to our newsletter we require that you provide us with your email address.
● When you communicate with us, whether through email, telephone, in-person, social media, in response to our surveys, or other communication platforms, we may collect the contents of any such communications and your contact information, including your name and email address.
● We reserve the right to request other types of information in the future

B. Information About Your Use of the Services.
Usage Information
We collect information about your use our services, such as the ways in which you use our Site, the way you respond to us when we send you emails or communications or your preferences when you interact with our Site.

Information We Collect Automatically When You Use the Services
When you access or use our Services, we automatically collect information about you, including:

● Log Information: We may collect technical data including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, and browser plug-in types and versions.
● Device Information: We may collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers and mobile network information
● Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies, web beacons and session replay . As you are probably aware, cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits. Web beacons are electronic images that may be used in our Site or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. Session replay provides the ability to replay a visitor’s interaction with our Site, such as mouse movements, clicks and page visits, in helping us to better understand your experience. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site.

Information We Collect from Other Sources

We may also obtain information from other sources and combine that with information we collect. For example, we may collect information about you from third parties, including but not limited to social media sites, data enrichment providers, fraud prevention vendors and partners, and publicly available sources.

4. HOW WE USE YOUR INFORMATION.
We use the information we collect to provide, maintain and improve our Site and services, such as to administer your account and to optimize your use of our Site.
We may also use the information we collect to:
● provide you with our services;
● make publicly available your artist portfolio in accordance with the mandate of our Site;
● perform our contractual obligations to you;
● provide customer support and respond to your requests and inquiries;
● send you technical notices, updates, security alerts and support and administrative messages;
● Communicate with you, including through our newsletter, about our services and provide news and information we think will be of interest to you;
● monitor and analyze trends, usage and activities in connection with our Site;
● detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
● debug to identify and repair errors impairing existing intended functionality;
● undertake activities to verify or maintain the quality or safety of our Site, and to improve, upgrade, or enhance our Site;
● detect, investigate and prevent fraudulent and other illegal activities and protect the rights and property of ImagineNATIVE and others;
● personalize and improve the Site;
● comply with our legal and financial obligations.
● produce reports which may be used at our sole discretion provided that any data or reports will be anonymized and not refer to any individual user.

5. WHEN WE MAY SHARE YOUR INFORMATION WITH OTHERS.
We will not disclose information about you except in the following circumstances or as otherwise described in this Privacy Policy:
● Consent. We may disclose your personal information where you have provided us with your consent to do so, including by making your artist portfolio publicly available on our Site.
● Third Party Service Providers. We may share your information with third-party service providers we use to support our business (such as analytics and search engine providers that assist us with the improvement and optimization of our Site). For example, we may use third-party service providers to help us make the Site operate smoothly and to help us communicate with our users. Our third-party service providers are contractually obligated to keep personal information confidential and to use it only for the purposes for which we disclose it to them.
● Legal and Safety Factors. We may disclose personal information if required by law or in the event we need to share information with a third-party in order to protect a person’s safety and security or the safety and security of us or our employees.
● Corporate Change. We may disclose personal information to third-parties in connection with a corporate change, including any due diligence process, but such disclosure will be subject to this Privacy Policy continuing to govern treatment of personal information.
● Affiliate Companies. We may disclose personal information to our subsidiary and affiliate companies, but such disclosure will be subject to this Privacy Policy continuing to govern treatment of personal information.
● Professional Advisors. We may disclose personal information our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
● Non-Personal Information. We may disclose aggregated information about our users, and information that cannot be used to identify any individual without restriction.

6. THIRD PARTIES; ADVERTISEMENTS; LINKS
We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons, device identifiers, session replay, and other technologies to collect information about your engagement with our advertisements, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked and conversion information. Their collection and use of information is governed by their own privacy policies, over which we have no responsibility or control.

Our Site may contain links to third-party websites. Similarly, those third-party websites have their own privacy policies, and we have no control of or responsibility for the privacy practices of those third-parties. Clicking on a link to a third-party website may allow that third-party to collect or share information about you. We encourage you to read the privacy policy of any third-party website you visit

7. YOUR RIGHTS
By law you have the right to request access to and to correct the personal information that we hold about you. You may also have certain additional rights.
If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”). These include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time.
If you are a California resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to (i) request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information that we have collected about you; and (iii) the right to opt-out of sale of your personal information. As the terms are defined under the CCPA, we do not “sell” your “personal information.”
If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us at the address provided at the bottom of this Privacy Policy, specify your request, and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.
We will handle any request to exercise these rights in accordance with applicable law and any relevant legal exemptions. You may exercise these rights as permitted by the Site or by contacting us using the contact details below.

8. TRANSFERRING YOUR PERSONAL INFORMATION TO OTHER COUNTRIES
We may export your data outside of Canada to third party service providers which are based outside and/or process data outside Canada. We transfer personal data to recipients outside of Canada on the basis of standard contractual clauses approved by the European Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en or on the basis that the country in question is the subject of an adequacy decision by the UK or European Commission.

In addition, it is possible for users of the Site to access the Site online from anywhere in the world, and if any such access involves access to your personal data, that data may be processed outside Canada by the relevant user. The relevant user or their company is solely responsible for their processing of that data off our platforms, but any use within our Site is governed by our contract with that user.

9. DATA SECURITY
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted using our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

10. DATA RETENTION
Except as otherwise permitted or required by applicable law, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for.

11. WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent. To withdraw your consent, if applicable, contact us at the address provided at the bottom of this Privacy Policy. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

12. CHILDREN UNDER THE AGE OF 13
Our Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use the Site or provide any information to us. If we learn we have collected or received personal information from a child under 13 we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the contact information below.

13. CHANGES TO OUR PRIVACY POLICY
We will post any changes we make to this Privacy Policy with a notice at the top of this page that the Privacy Policy has been updated. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Site home page.

14. CONTACT US
We welcome your questions, comments, and requests regarding this Privacy Policy and our privacy practices. Please contact us at:
Email: info@imagineNATIVE.org
Mailing Address: 401 Richmond Street West, Suite 446 Toronto, ON M5V 3A8