Privacy Policy


Welcome to The Colour Project community, and thank you for helping us build a more colourful world, together! The Colour Project Society (“TCP” or “we” or “our”) is committed to respecting your privacy. This Privacy Policy is applicable to TCP and sets out our policy on the information TCP may collect about you, the choices you have regarding the use of your information, and how your personal information is protected when you use this website (the “Site”), and the TCP platform (the “Platform”). TCP complies with Canadian federal and provincial privacy laws and regulations including the Personal Information Protection Act and Personal Information Protection and Electronic Documents Act.

This Privacy Policy does not apply to information that you may submit to sites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third party websites.

Your use of the Site and the Platform signifies your acknowledgment of and consent to this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Site and the Platform. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice and by posting such revised terms to the Site. Your continued use of the Site and the Platform following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively or to personally identifiable information already in our possession, we will provide you with notice of the modifications or amendments and seek your consent for such use.

1. Collection of Information

When you visit the Site, you will be invited to provide your phone number to access the service. The Site may also collect other information when you visit the Site that does not personally identify you, such as the type of browser and operating system you are using, your IP address, and your device identifiers (non-personally identifiable information or “non-PII”). Such information is sometimes collected to improve the design and content of the Site or to analyze site usage. Information shall be collected by fair and lawful means, and shall not be used for purposes other than those identified by TCP.

Personally Identifiable Information

TCP considers “Personal Data” to include information that alone or when in combination with other information may be used to readily identify or contact you, such as: email address, username, name, address, or phone number. TCP does not consider Personal Data to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual. Any user can request a download of their own Personal Data that TCP currently stores, if any. At the request of any user, TCP will delete that user’s account and associated Personal Data, unless that user has breached the terms laid out in the Terms of Service and caused harm or abused our Services or other members, in which case TCP retains the right to retain information related to that user in order to provide more security and safety to our members. 

As a general matter, you can browse the Site without submitting your personally identifiable information to us. TCP will only collect your personally identifiable information where it is knowingly provided by you, such as in the following ways:

  • You may voluntarily provide your phone number to begin using the core TCP service. Other than TCP, the only party with access to the phone number will be our service provider, Twilio, outside of crisis situations in which we may provide your phone number to Crisis Services Canada for support (please see our Terms of Use). Twilio manages message routing between users of the TCP service and TCP volunteers. You can review the Twilio Privacy Policy here and the Crisis Services Canada Privacy Policy here.

  • You may voluntarily provide additional personally identifiable information when you request assistance

  • You may voluntarily post on social media accounts involving TCP and/or the Site using your personal account. TCP will never post or ask to post to on your social media pages

  • You may voluntarily submit user generated content on any part of the Site that permits it or through the Platform

  • You may voluntarily provide personally identifiable information on any other place on the Site that permits it or through the Platform

Non-Personally Identifiable Information

In addition, when you interact with the Site, we may collect certain information that does not identify you individually and our servers may automatically keep an activity log of your use of our Site (“non-personally identifiable information” or “non-PII”). Generally, we collect and store the following categories of non-personally identifiable information:

  • Number of guests on the Site. The Site may post such information in the aggregate on the Site or provide such information to third parties.

  • Device information about your computer, mobile device, or other device that you use to access the Site. This information may include IP address, unique device identifiers, browser type, browser language, and other transactional information. Such information, such as Cookies, may be disabled by turning them off in their own browser.

  • Usage information about your use of the Site. This information includes a history of the pages you view. We use this information to provide you with a more customized experience on the Site.

  • Additional “traffic data” such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses.

  • Your search terms and search results on the Site, as well as other information regarding your use of the Site.

TCP Volunteer Applicants

All interested applicants for the position of TCP Volunteer will be required to submit Personal Data as requested. Any information supplied by or on behalf of an applicant for purposes of becoming a TCP Volunteer will be maintained confidentially by TCP. Please note that TCP may have additional privacy terms that apply to TCP Volunteers. Such terms will be made available when an applicant applies to be a TCP Volunteer or otherwise accesses his or her account.

2. How TCP Uses Your Information

We may use your personally and non-personally identifiable information in the following ways:

A. General Uses. We may:

  • Provide you with the content, products and services you request

  • Communicate with you through text or email about your account or transactions with us and send you information about features and enhancements on or to our Site

  • Communicate with you about changes to our policies

  • Optimize or improve our products, services and operations

  • Detect, investigate, and prevent activities that may violate our policies or be illegal

B. Combination of Your Personally Identifiable Information

We may use the information from one portion of the Site on other portions of Site, and we may combine information gathered from multiple portions of the Site and / or through the Platform into a single user record. 

C. Legal Grounds for Handling Personal Data

Some laws require organizations to inform users about the legal ground they rely on to use or disclose your Personal Data. To the extent those laws apply to TCP, our legal grounds include:

  • We handle your Personal Data to create an account (user or volunteer) and to provide our services to you

  • We need to use and sometimes disclose Personal Data in certain ways to comply with our legal obligations

In many cases, we handle your personal data on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes:

  • Providing a safe and enjoyable user experience

  • Service to users

  • Communications

  • Protecting our users, community, personnel and property

  • Analyzing and improving our offerings (such as collecting information about how you use our services to optimize the design and usability of certain features)

  • Anonymizing and aggregating user data for research to improve our Services

  • Managing legal issues

  • As part of the consent process any Personal Data collected is only disclosed and shared with emergency personnel if TCP becomes aware of and believes that you or others are in imminent risk of harm

  • Where required by law, and in some other cases, we handle Personal Data on the basis of your implied or express consent

3. Information Shared With Third Parties

TCP may employ outside agents, meaning other companies or individuals, to perform functions on its behalf, such as sending messages and analyzing data. Twilio, our third-party service provider, assists with routing text messages between users of the service and TCP volunteers, and as such will have access to users’ phone numbers. Such agents have access to personally identifiable information needed to perform their functions, but shall protect it according to their Privacy Policy and Terms of Use, and will not use it for other purposes. TCP may also release personal information when it believes, in good faith, that such release is reasonably necessary to enforce or apply the provisions of its Terms of Use or to protect the rights, property or safety of TCP or the Site, its users, or others, including situations in which we have reason to believe a user of the service may be in need of crisis intervention. 

TCP is not a professional counselling or crisis intervention service, and volunteers do not provide any advice. Our model is one of active listening and referral to community resources only. In instances where we have reason to believe that crisis intervention may be required, we may release your phone number to Crisis Services Canada for assistance, and any chat logs that may be necessary to support intervention. You can review the Crisis Services Canada Privacy Policy here.

TCP shall disclose personally identifiable information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.

TCP retains the right to transfer your personal information to a successor in interest pursuant to a change of control of the Site or a sale of all or substantially all of the Site’s assets.

We may disclose or share non-personally identifiable information (or other information, other than personally identifiable information) in any manner that we deem appropriate or necessary, as described below.

4. Use of Cookies, Web Beacons and Third Party Tracking Information

Like many websites, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. The Site’s cookies do not personally identify users, but they do identify a user’s computer as well as the first name of the person logging in. The Site may use cookies to remember information users give to the Site. We may also use cookies to monitor traffic, improve the Site and make it easier and/or relevant for your use. You can modify your browser settings to disable or reject cookies; however, some features of the Site may not work as designed if you do so. For more information on cookies and how to disable them, you can consult the Interactive Advertising Bureau at www.allaboutcookies.org.

We may also use web beacons. A web beacon is an invisible graphic on a web page that can collect personally identifiable and non-personally identifiable information about your use of a given website. We do not share personally identifiable and non-personally identifiable information we may collect through such web beacons, such as names, email addresses and phone numbers, without your express permission.

Some content or applications, including advertisements, on the Site may be served by unaffiliated third parties, including advertisers, ad networks and servers, content providers and application providers. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. To learn more about the use of this information or to choose not to have this information used by our third party advertising partners by opting out, please visit the Digital Advertising Alliance at http://www.aboutads.info or the Network Advertising Initiative by clicking http://www.networkadvertising.org/managing/opt_out.asp.

Your browser or device may include “Do Not Track” functionality. Because a “Do Not Track” compliance protocol has not yet been finalized, TCP’s information collection and disclosure practices, and the options that we provide to users, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

5. Aggregate Information

We may aggregate information so that it is not Personal Data, and we may use and share such aggregated information for training and quality assurance purposes, for purposes of delivering our services, for purposes of expanding and improving our services and for other lawful purposes. This data is anonymized and stored securely.

From time to time, we may change our information practices. You will have the opportunity to opt out before TCP uses your information for any purpose not previously disclosed in our privacy notice.

7. Protecting Your Information

We are committed to ensuring the security of your personally identifiable information and take reasonable security measures to protect such information. We will take all reasonable measures to safeguard your personally identifiable information once we receive it; however, the security of data transmitted over the Internet or any other public network cannot be guaranteed.

It is advisable for you to protect the privacy of your own information. You are responsible for taking precautions to protect the security of any personally identifiable information that you may transmit over any home networks, wireless routers, wireless (WiFi) networks or similar devices. You are responsible for the security of your information when using unencrypted, open access or otherwise unsecured networks. Comments that you submit through text messages may be recorded and stored on the Site, via the Platform, and elsewhere on the Internet. It is therefore important that you are careful and selective about the personal information that you disclose about yourself and others, and in particular, you should not disclose sensitive, embarrassing, proprietary or confidential information to TCP on the Site or via the Platform.

Data Retention

All text messages sent and received by TCP volunteers and users of the texting platform will be securely stored for one year. TCP will store your user account and associated Personal Data as long as your account is active.

8. Opt-Out Provisions

You may opt-out of continuing to text with a TCP volunteer at any time by texting “STOPCHAT” to the volunteer you are in contact with. If you have any concerns, you can email us at hello@thecolourproject.ca.

9. Children

The Site is not intended for children under 13 years of age and TCP does not knowingly collect personal information from children under 13 years of age. If you are under 13 years of age, do not provide personal information to TCP without providing us with consent from your parents. If we discover that a child under the age of 13 has provided us with personal information and we do not have parental consent, TCP will immediately delete that child’s information from the Site. If you believe that TCP has been provided with the personal information of a child under the age of 13 without parental consent, please notify us immediately at hello@thecolourproject.ca.

10. Contacting the Site

If you have any questions or concerns about this Privacy Policy, the practices of the Site and / or Platform, the content available on the Site or your interactions with the Site or via the Platform, you can contact TCP at hello@thecolourproject.ca.