Last updated: November 30, 2023

New Mode Consulting Inc. (“New/Mode”, “we”, or “us”) values and respects your privacy. We have prepared this privacy policy to explain the manner in which we collect, use and disclose personal information through websites, including their subdomains and subdirectories, owned, controlled, or operated by New/Mode or any other Affiliate (collectively, the “Sites”), our social media platforms, and other interactions with you. 

The Sites include, but are not limited to: newmode.net, newmode.ca, advocacymailer.com, advocacysender.com, changemailer.com, takeaction.online, newmode.social, nwmd.io, empathymailer.com, communitysender.com, newmode.online, getnewmode.com, advocacyvoice.com, conveyadvocacy.com, nwmd.social, and newmode.io. 

TABLE OF CONTENTS

• Our Approach to Privacy
• Collection and Use of Personal Information
• Sharing of Personal Information
• Jurisdiction and Cross-Border Transfer
• Information About Our Sites
• Safeguards and Retention
• Access to Information
• Use by Minors
• Your California, Uk, Europe and EEA Privacy Rights
• Updates to the Privacy Policy
• Contact Us
• Third Party Service Providers
  

OUR APPROACH TO PRIVACY

We believe in a new mode of operation for society, based on the following core values—and we partner with people and organizations who share them.

• Empowerment. We empower people to speak in their own voice and take action.
• Collaboration. We aim to help build a society that embraces new tools and processes for sharing and cooperation.
• Empathy. We celebrate and engage with diversity, uncover others’ needs, and find common ground and shared wins.
• Participation. We believe decision-making should be open, transparent, collaborative, and focused on those who will be most impacted in their daily lives.
• Sustainability. We help create more sustainable, vibrant, and resilient communities.
• Fairness. We work towards a fairer economy and society.

These values are at the heart of everything we do, including how we collect, manage, protect and use the information we collect from organizations who subscribe to our services (“Subscribers”), on behalf of our Subscribers, and from individuals who interact with us (“Users”, “you”).

Our values shape the privacy policy in the following ways:

Empowering people to speak in their own voice and take action

You should know exactly what information New/Mode collects about you, how it is used, how it is protected, how it can be accessed, and how it can be controlled.

Building a society that embraces new tools and processes for sharing and cooperation

New/Mode works in a collaborative ecosystem with partners to make its services as effective as possible, and to make it easier for Users to achieve their important social missions. This means data is shared with 3rd party sub-processors under contract with New/Mode, and/or under contract with Subscribers. You should know who those sub-processors are and have confidence that they meet stringent data security and privacy requirements.

Celebrate and engage with diversity, uncover others’ needs, and find common ground and shared wins

The privacy policy gives New/Mode the ability to learn directly from Users in order to provide them with guidance on making more powerful contributions, and to help New/Mode develop new and better ways to build power through our platform. At the same time, the privacy policy safeguards Personally Identifiable Information and assures you New/Mode is using data ethically and in accordance with public laws, regulations and policies.

Making decisions that are open, transparent, collaborative, and focused on those who are most impacted

We build rapidly based on what our Users are telling us about what they need. As a result, our policies may change as new products, services and features are developed. When this is the case, Users will be notified. 

Creating more sustainable, vibrant and resilient communities

New/Mode develops products, services and features that build community power to make the world fairer and more sustainable. Our privacy policies reflect this priority.

Working for a fairer economy and society

New/Mode’s mission leads us to empower those who often have the least economic and social power under existing structures. We believe it is especially important to protect the privacy of the people and organizations engaged in this work.

COLLECTION AND USE OF PERSONAL INFORMATION 

How we collect and use the personal information through the Website 

Creating an Account and Subscribing:  If you want to launch a campaign with us, we require you to create an account. We collect certain information to create and administer your account, such as your name, email address and password.  We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). If you become aware of any unauthorized access to or use of your account, you are required to notify us immediately.

In addition, in order to process Subscription payments, we (or our authorized third-party payment processor) will collect information such as your first and last name, email address, phone number, mailing address, delivery address, and your credit card or bank account payment information (including billing address, account number, expiry date and CVV/CVC code).

Taking a New/Mode Action: If you take an action hosted by us (such as sending an email to an elected representative), either on our Sites or through another form of communication, you will be required to provide your name and email address, along with other required and/or optional information configured by the Subscriber. We may display or otherwise share this information (subject to your consent). 

We typically do not process most Special Categories of Personal Data. However, by the nature of our platform serving those concerned with public policy, we may process Special Categories of Personal Data, including, but not limited to: political opinions; philosophical beliefs; and association membership.

We do not solicit Special Categories of Personal Data, but New/Mode Subscribers may use our services to do so. Any Special Categories of Personal Data collected and processed are done so by New/Mode as a Data Processor, as defined under GDPR, on behalf of a New/Mode Subscriber. Subscribers must certify that their control of Special Categories of Personal Data is undertaken in a lawful manner in the jurisdictions where they are collecting the data.

If you choose to publish Special Categories of Personal Data, you do so of your own accord, at your own risk, and consent to our processing of it.

Donating to Support a Cause: Depending on the campaign, you may be able to donate money to support the cause. If you choose to donate, we (or our authorized third-party payment processor) will collect information such as your first and last name, email address, phone number, mailing address, delivery address, and your payment information (including billing address, credit card number, expiry date and CVV/CVC code) in order to process your payments and deliver your order. If you choose to pay for your order through PayPal or a similar service, you will be directed to the service’s web page where you will enter your payment information. We exchange information about your transaction with the service in order to process your payment. For more information, please see the service’s privacy policy.

Visiting the Sites: You do not have to create an account to visit or use our Sites. However, we do collect some personal information when you visit our Sites. Please see the "Information about our Sites” section below, for detailed information regarding the personal information we collect when you visit and use our Sites, and the choices you have with regards to that collection. 

Marketing: If you sign-up to receive marketing communications such as email newsletters, we collect your email address as well as other information to help us tailor our communications to you. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.

Customizing Audiences: We may use services provided by third-party platforms (such as social media and other websites) to serve targeted advertisements on such platforms to you or others, and we may provide a hashed version of your email address or other information to the platform provider for such purposes. To opt-out of the use of your information for such purposes, please send a request using any of the methods set forth in the Contact Us section below.

Requesting a Demo or Pricing: When you request a demo or pricing estimate for a campaign through the Website we will collect your name, email address, name of your organization and information about the campaign. We use this information to understand your needs so that we can provide you with an appropriate response and to schedule a meeting if required.  

Signing up for a Webinar or Downloading Resources: If you choose to sign-up for a webinar available through our Sites or download resources we will collect your name, email address and information about the number of employees at your organization in order to register you for the webinar or to enable you to download the resources. 

Signing up to Become a Partner: If you choose to join the New/Mode network as a partner, we will collect your name, email address and company name in order to schedule a call with you to learn more about your suitability to become a partner. 

Surveys: From time to time, we may offer you the opportunity to participate in one of our surveys. The information obtained through our surveys is used in an aggregated, de-identified form. We use this information to help us understand our users and to enhance our products and services.

Contacting Us: When you contact us with a comment, question or complaint a request form on our Sites, you may be asked for information that identifies you, such as your name, email address, and organization name, along with additional information we need to help us promptly answer your question or respond to your comment.  We may retain this information to assist you in the future and to improve our customer service and service offerings.

Personalizing and Improving Services: We may use any of the above data collection to personalize and improve services delivered to you and other Users. 

SHARING OF PERSONAL INFORMATION

We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

Service Providers: Your personal information will be transferred (or otherwise made available) to certain third parties, including our affiliates and subsidiaries, that provide services on our behalf. We use service providers to provide services such as hosting the Sites, conducting data analysis, processing payments, providing customer service support, deploying emails and surveys on our behalf, providing information technology and related infrastructure services and providing advertising and marketing services. Our service providers, affiliates and subsidiaries are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers, affiliates or subsidiaries may transfer or store your data outside of the jurisdiction in which you reside (which may include transfer or storage outside of Quebec, the UK, and EU for Quebec, UK and EU residents). Our service providers, affiliates or subsidiaries may be located in the US, Canada, UK or EU.

Legal and Compliance: We and our Canadian, US, UK or EU service providers may provide your personal information in response to a search warrant to other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.

Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of New/Mode or as part of a corporate reorganization or other change in corporate control.

JURISDICTION AND CROSS-BORDER TRANSFER

We recognize there are additional risks that countries, such as those in the EU, associate with transferring Personal Data internationally. As a Canadian-based company that engages service providers (some of whom are located outside of Canada), we rely on a number of frameworks to mitigate those risks and provide our Subscribers and Users adequate protections. We rely in part on the EU’s decision that Canadian-based companies are recognized as affording adequate privacy protections under Article 45 of Regulation (EU) 2016/679, and the UK’s adequacy regulations for Canadian-based companies covered under and processing data that is covered under Canada’s Personal Information Protection and Electronic Documents Act. Additionally, we take care to use third-party services that either operate in countries who require adequate privacy protections, have adopted Binding Corporate Rules, or who are certified under frameworks such as the EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework, and Swiss-U.S. Privacy Shields. 

For transparency, we have included a list of these services as Exhibit A of this Policy, as well as reference to the relevant policies, adequacy decisions and/or certifications. We are, however, not responsible for the privacy or other practices of any third parties. 

INFORMATION ABOUT OUR SITES

Visiting our Sites: In general, you can visit our Sites without telling us who you are or submitting any personal information. However, we collect the IP (Internet protocol) addresses of all visitors to our Sites and other related information such as page requests, browser type, operating system and average time spent on our Sites. We use this information to help us understand our website activity and to monitor and improve our Sites.

Browser Cookies: Our Sites uses a technology called "cookies". A cookie is a tiny element of data that our Sites send to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Sites, you may not be able to take advantage of all of the website features.

Flash Cookies: Certain features of our Sites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Sites. Flash cookies are not managed by the same browser settings as are used for browser cookies. 

Web Beacons: Pages of our Sites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Analytics: We may use a third party such as Matomo to help us gather and analyze information about the areas visited on the Sites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Sites. These third parties may use cookies and other tracking technologies. You can obtain additional information on Matomo’s data privacy and security at the following links:

• Privacy Policy;
• Matomo ensures the privacy of your users and analytics data; and
• Security

Third Party Links:  Our Sites may contain links to other websites that New/Mode does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

SAFEGUARDS AND RETENTION

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfill their job requirements.

We have record retention processes designed to retain personal information for no longer than necessary for the purposes set out herein or as otherwise required to meet legal or business requirements.

Unfortunately, the transmission of information via the Internet is never completely secure. Although we do our best to protect your Personal Data, we cannot guarantee its security. If you have reason to believe that your data held by us is no longer secure, please immediately notify us by emailing privacy[at]newmode.net.

ACCESS TO INFORMATION

Subject to applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control. You may also withdraw your consent to our collection, use and disclosure of personal information (subject to legal and contractual restrictions). You may withdraw your consent or request access, updating and corrections of inaccuracies in your personal information in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

USE BY MINORS

New/Mode’s Sites are not directed to individuals under voting age in their jurisdiction, without parent or guardian approval. The Sites are not directed to individuals under the age of 13, whether or not they have received parent or guardian approval, and New/Mode does not knowingly collect Personal Data from individuals under the age of 13. 

YOUR CALIFORNIA, UK, EUROPE AND EEA PRIVACY RIGHTS 

California Civil Code Section § 1798.83 permits users of our Sites and Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy[at]newmode.net.

Users in the UK, Europe or the greater European Economic Area may also file a complaint with a supervisory authority in their country or region. 

UPDATES TO THE PRIVACY POLICY

We may update this privacy policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this page to ensure you are familiar with those changes. We will indicate at the top of this privacy policy when it was most recently updated.

CONTACT US

If you have any questions or comments about this privacy policy or the manner in which we or our service providers (including our service providers outside Canada) treat your personal information, or to request access to our collection of your personal information, please contact us at:

Andrew Lindsay, CTO
New Mode Consulting Inc.
312 Main Street
Vancouver, BC V6A 2T2
privacy[at]newmode.net

Exhibit A

Third Party Service Providers

Current as of September 30, 2023