Privacy Policy

1. Introduction

Just Canvass is a service operated by Just Canvass Solutions Ltd. ("Just Canvass," "we," "our," or "us"). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including our website and application.

Just Canvass is operated from Canada. We comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable Canadian privacy legislation. Where our services are used in connection with federal, provincial, or municipal elections, campaign organizations should be aware of their obligations under the Canada Elections Act and applicable provincial election legislation regarding voter data.

We are accountable for the personal information under our control, including information transferred to third parties for processing on our behalf. The individual responsible for our compliance with this policy and with PIPEDA is our Privacy Officer, who can be reached using the details in Section 16 (Contact Information).

2. Information We Collect

We follow the principle of data minimization, collecting only the personal information necessary to provide our services. Campaign organizations should similarly limit the voter data they collect through our platform to what is necessary for their campaign purposes.

2.1 Personal Information You Provide

We collect information that you voluntarily provide to us, including:

• Account information (name, email address, password)
• Profile information
• Content you create or upload through our services
• Communications with us (support requests, feedback, inquiries)
• Any other information you choose to provide

2.2 Automatically Collected Information

When you use our services, we automatically collect certain information, including:

• Device information (device type, operating system, browser type and version)
• Usage data (pages visited, features accessed, time spent, interactions)
• Log data (IP address, access times, referring URLs)
• Location data (when you enable location services)
• Cookies and similar tracking technologies (as described in Section 6)

2.3 Voter and Supporter Data (Third-Party Information)

Campaign organizations may upload or input voter lists, supporter information, canvassing notes, and interaction records through our platform. This data is provided and controlled by the campaign organization. Just Canvass does not independently use, sell, or share voter or supporter data. We process it solely to provide our services to the campaign organization.

Campaign organizations are responsible for ensuring they have lawful authority to collect and use this data in accordance with PIPEDA and applicable Canadian law.

2.4 Sensitive Information

Our platform may be used to record political opinions, voting intentions, and other sensitive information about voters and supporters. This data is classified as sensitive personal information and receives heightened protection. Campaign organizations must obtain meaningful consent before recording political opinions. Just Canvass applies additional security safeguards to this data, including role-based access controls.

3. Data Controller and Processor Roles

When a campaign organization uses Just Canvass to manage voter and supporter data, the campaign organization is the data controller and Just Canvass acts as a data processor. Campaign organizations are responsible for obtaining appropriate consent for the collection, storage, processing, and disclosure of voter and supporter information in accordance with PIPEDA and applicable Canadian law.

Just Canvass processes voter and supporter data solely on the campaign organization's instructions and in accordance with our Voter Contact Services Agreement.

When collecting account information from users who sign up for our services directly, Just Canvass acts as the data controller.

4. Consent

We obtain consent that is appropriate to the sensitivity of the personal information being collected, used, or disclosed. The form of consent we rely on varies with the circumstances and the type of information.

Where Just Canvass is the data controller — for example, when you create an account directly with us — you consent to our collection, use, and disclosure of your personal information as described in this Privacy Policy by creating an account and using our services.

Sensitive information. Because political opinions, voting intentions, and similar information are sensitive personal information, we and campaign organizations rely on express, opt-in consent before such information is recorded. We do not infer consent for sensitive information from inaction.

Withdrawing consent. You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. If you withdraw consent, we will explain the likely consequences, which may include our inability to continue providing some or all of our services to you. To withdraw consent, contact us using the details in Section 16.

Campaign organizations. Where a campaign organization is the data controller for voter and supporter data, that organization is responsible for obtaining, recording, and maintaining meaningful consent from the individuals whose information it collects through our platform, in accordance with PIPEDA and applicable election legislation.

5. How We Use Your Information

We use the collected information to:

• Provide, operate, and maintain our canvassing platform
• Enable campaign management and voter outreach activities
• Facilitate team coordination and data synchronization
• Generate analytics and insights for your campaign
• Improve and optimize our services
• Communicate with you about updates, support, and service-related information
• Ensure security and prevent fraudulent activity
• Comply with legal obligations

Our platform includes consent management tools to help campaign organizations respect voter preferences, including do-not-contact flags and communication channel preferences. Campaign organizations are responsible for honouring these preferences and obtaining appropriate consent before contacting voters.

6. Information Sharing and Disclosure

6.1 We Do Not Sell Your Personal Data

We do not sell, rent, or trade your personal information to third parties for marketing purposes. We will never share personal data records or individual user information with third parties except as described in this policy.

6.2 Anonymized and Aggregated Data

We may share anonymized or aggregated statistics and data that cannot be used to identify you individually. This may include general usage statistics, trends, and analytics. This aggregated data does not contain any personal information.

6.3 Legal Requirements

We may disclose your information if required by law, court order, subpoena, or governmental regulation, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

6.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change and provide you with choices regarding your information.

6.5 With Your Consent

We may share your information for other purposes with your explicit consent.

7. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience and collect information about how you use our services.

7.1 Types of Cookies We Use

• Essential Cookies: These cookies are necessary for our services to function properly. They enable core functionality such as user authentication, security, and network management.
• Analytics Cookies: We use Google Analytics to understand how visitors interact with our website. These cookies collect information about pages visited, time spent on pages, and other usage statistics to help us improve our services.
• Advertising and Conversion Cookies: We use the Google Ads tag and the Meta (Facebook) Pixel to measure the performance of our advertising, understand which ads lead people to contact us, and reach relevant audiences. These technologies set cookies and may collect information such as pages viewed and actions taken on our site (for example, opening or submitting our quote request form).

7.2 Managing Cookies

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse cookies or delete certain cookies. However, if you disable essential cookies, some features of our services may not function properly.

7.3 Third-Party Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users interact with our services. The information generated by the cookie about your use (including your IP address) will be transmitted to and stored by Google. You can opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on.

7.4 Advertising and Conversion Measurement

We use Google Ads and Meta (Facebook) advertising tools to measure the effectiveness of our advertising campaigns and to show relevant ads. When you interact with our marketing site — for example, opening or submitting our quote request form — we may share event and conversion data with Google and Meta.

To help match these conversions to the corresponding ad interaction, we may share a hashed (irreversibly encrypted) version of the information you provide in the quote form, such as your email address, name, and postal code. This hashing is performed before the data is transmitted, so Google and Meta receive only a coded value, not your information in readable form. We may use features such as Google Enhanced Conversions and Meta Advanced Matching / Conversions API for this purpose. We do not send the readable contents of your quote request to advertising platforms, and we do not use these tools to share voter or supporter data.

You can limit this type of tracking by adjusting your cookie settings, using your browser's privacy controls or ad-blocking tools, and reviewing the ad-personalization settings offered by Google and Meta.

8. Data Security

We implement appropriate technical, organizational, and physical security measures, proportionate to the sensitivity of the information, to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Role-based access controls limiting canvasser access to assigned areas and data
• Secure authentication mechanisms
• Regular backups
• Secure cloud infrastructure
• Regular security assessments

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

8.1 Service Providers and Data Processing

We use reputable third-party service providers to store and process data on our behalf, such as cloud hosting and infrastructure providers. We remain accountable for the protection of personal information handled by these providers and require them, through contractual and technical measures, to maintain safeguards comparable to those described in this policy and to use the information only for the purpose of providing services to us.

9. Data Retention

We retain your personal information for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy. We keep personal information only as long as necessary for the identified purposes, then securely destroy it in accordance with documented retention and destruction procedures. Where personal information has been used to make a decision about an individual, we retain it long enough to allow the individual to access that information.

9.1 Account Data

When you request account deletion, we will delete your personal data within 30 days of your request. During this 30-day period, your data will be marked for deletion and will not be accessible or used for any purpose.

9.2 Campaign Data Upon Termination

When a campaign organization terminates their account, they may export their voter and supporter data within 90 days. After this period, voter and supporter data will be permanently deleted from our systems. Campaign organizations retain full ownership of voter and supporter data collected through our platform.

9.3 Legal and Compliance Retention

We may retain certain information for longer periods where required by law or where reasonably necessary to resolve disputes, enforce our agreements, or comply with our legal, regulatory, accounting, or audit obligations. In each case, we retain only the information required for the specific obligation and for no longer than the applicable limitation or retention period.

9.4 Anonymized Data

We may retain anonymized or aggregated data indefinitely for analytics and service improvement purposes, as this data cannot be used to identify you personally.

10. Accuracy of Information

We make reasonable efforts to ensure that the personal information we hold is as accurate, complete, and up-to-date as is necessary for the purposes for which it is used. You can review and update your account information at any time, and you may ask us to correct information you believe is inaccurate or incomplete (see Section 12, Your Rights and Choices).

Campaign organizations are responsible for the accuracy of the voter and supporter data they input or upload through our platform, including keeping contact details and do-not-contact preferences current. We do not routinely update voter or supporter data, as this information is controlled by the campaign organization.

11. Data Breach Notification

In the event of a data breach involving personal information that creates a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner of Canada as required under PIPEDA. We will also notify campaign organizations whose voter or supporter data may have been affected.

Notifications will be made as soon as feasible after discovery of the breach and will include information about the nature of the breach, the data involved, and the steps we are taking to address it.

12. Your Rights and Choices

Under PIPEDA, you have certain rights regarding your personal information:

• Access: You can request a copy of the personal information we hold about you
• Correction: You can request that we correct inaccurate or incomplete information
• Deletion: You can request that we delete your personal information
• Object or Restrict: You can object to or request that we restrict certain processing activities
• Data Portability: You can request a copy of your data in a structured, commonly used format
• Withdraw Consent: Where processing is based on consent, you can withdraw your consent at any time

To exercise any of these rights, please contact our Privacy Officer at hello@justcanvass.ca. We will respond to your request within 30 days, as required under PIPEDA. If we need additional time, we will notify you of the extension and the reason for it within that period. We may ask you to verify your identity before fulfilling a request.

Access to your personal information is generally provided free of charge. If a minimal cost would apply to respond to a request, we will inform you of the estimated cost in advance so that you may decide whether to proceed. On request, we will also tell you how your personal information has been used and, where reasonably possible, the third parties to which it has been disclosed.

If a campaign organization is the data controller for the information you are inquiring about (for example, voter or supporter records), we will direct your request to, or assist you in contacting, that organization.

13. Third-Party Links and Services

Our services may contain links to third-party websites, applications, or services that are not owned or controlled by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access.

14. Volunteer and Canvasser Obligations

Campaign organizations are responsible for training their canvassers and volunteers on proper data handling practices, including the confidentiality of voter information collected through our platform. Canvassers and volunteers must not record assumptions about household members' opinions and must limit data collection to what is necessary for the campaign's identified purposes.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated Privacy Policy on this page
• Updating the "Last Updated" date at the top of this policy

Your continued use of our services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically.

16. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer at:

Privacy Officer
Just Canvass Solutions Ltd.
Email: hello@justcanvass.ca
Website: www.justcanvass.ca

We will make every effort to respond to your inquiry promptly and address any concerns you may have. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.