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Politique de confidentialité


The (the “Site”) is operated by Green Action Centre (“GAC”).  We respect your right to control your personal information.  Whether you are tracking transportation or sharing content, we want to make sure that the personal information that you disclose to us remains secure.  That is why we have developed this Privacy Policy, which governs how we collect, use and disclose your personal information (the “Privacy Policy”).  

This page contains the Privacy Policy for the Site, as well as for any other websites or microsites operated by GAC in connection with the BikeWalkRoll Application, including any tools, forums, event registration pages, social media pages, contest entries, blogs, and/or online donations or grants (collectively, the “Sites”), and for the BikeWalkRoll web application offered by GAC (together with the Sites, the “Service”).

By accessing or using the Service, you consent to the collection, use and disclosure of your personal information by GAC in accordance with this Privacy Policy.  You may choose not to provide us with your personal information.  However, if you make this choice we may not be able to provide you with the application, service, or information that you requested.

  1. Definitions.  

For the purposes of this Privacy Policy, the following words have the following meanings:

collection” means the act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent” means voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative, such as a parent or guardian.  Express consent is permission that is granted by an individual taking a positive step to signify consent and may be given orally, electronically or in writing.  Implied consent is the assumption of consent that can reasonably be inferred from a user's action or inaction.

user” means an individual who uses the Service provided by GAC, including anyone who accesses or visits the Sites.

 “disclosure” means making personal information available to a third party.

employee” means an employee of GAC, and for the purpose of this Privacy Policy only, includes volunteers, and independent and other contractors performing services for GAC.

personal information” means information about an identifiable individual, but not aggregated information that cannot be associated with a specific individual.  For a registered user, such information may include (but is not limited to) account information and any recorded complaints.

“registered user” means an individual who has created and registered an account with GAC.

third party” means an individual other than the user, or the user's agent, or an organization outside GAC.

use” means the treatment, handling, and management of personal information by and within GAC.

  1. Collection and Use of Personal Information

The majority of personal information collected for the Service is designed to be public. With a few exceptions, users have control to share as much or little data with us as they wish.

Below is a table detailing personal information that may be collected, how it’s used, where it’s displayed and whether or not it is required to use the Service:


Details of Use




User filled text field. Used to create a user profile to use the Service.



Email Address (registered users)

Required for login to uniquely identify a user or verify survey input. Not required for viewing the Sites or doing unverified surveys as a guest.



Public email address (“champion level” user)

Required for login of a registered user at the “champion level”. Email address of a registered user at the “champion level” is displayed alongside the organization they work for so that other users may be able to contact them for more information.




Passwords are “salted and hashed” which means GAC does not have access to user passwords.



Classroom Grade level

Inputted by the user from a list when submitting a survey. Purpose is to compare transportation habits and trends by children of different age brackets



Classroom Nickname or ID

Inputted by the user. An optional field for tracking a specific classroom’s progress or comparing “scores” or hosting competitions.




User filled text field. Used for display purposes on a user’s profile page.




User filled text field. Used for display purposes on a user’s profile page.



Instagram Username

User filled text field. Creates a link to a user’s Instagram profile.



Twitter Username

User filled text field. Creates a link to a user’s Twitter profile.



Correspondence with GAC employees

Used for answering any questions, concerns, or comments you may have about the Service or problems that you report.



Comments, photographs and other content that you may post to the Service

User uploaded data.



Technical Information We Collect Automatically

When you visit the Sites, we may collect, using electronic means, technical information. This technical information (some of which in certain instances may be considered personal information) is aggregated and used to measure and improve effectiveness of our Sites. We do not attempt to combine this technical information with other personal information we collect on our Sites.

Below is a table detailing technical information collected, how it’s used, where it’s displayed and whether or not it is required to use the Service:


Details of Use



Browser Details

Used for website analytics.



IP Address

Used for website analytics. Used to determine in which general geographical location the Service is being used.




Used to center the map. Used for website analytics. User may opt-in and provide latitude/longitude when page loads on the Sites, based on browser/device settings. Used to determine in which general geographical location the Service is being used.



  1. Purpose of Collection of Personal Information

GAC collects your personal information and will use your personal information as is reasonably required for the following purposes:

  1. if you are a registered user, to establish and maintain your BikeWalkRoll account;

  2. to provide the BikeWalkRoll web application, or the other services or information that you request;  

  3. to verify that you are old enough to give your consent to the terms and conditions of the End User Licence Agreement and this Privacy Policy;

  4. to verify the authenticity of BikeWalkRoll transportation survey results you have submitted;

  5. to verify your identity if you submit comments, photographs or other content to the Service;

  6. to allow you access to submit comments, photographs or other content to the Service;

  7. to respond to questions, comments, requests or complaints that you submit to GAC;

  8. to process your registration for certain events or contests;

  9. if you are a member of a BikeWalkRoll team, to allow you to send messages to and receive messages from your teammates and to otherwise participate in team activities;

  10. to edit and moderate comments and content posted to Service and to otherwise administer the interactive features of the Service;

  11. to track GAC’s communications with you;

  12. to analyze use of the Service and to improve the Service;

  13. to send emails, newsletters, regular mail or other communications you have consented to receive from GAC;

  14. to send prizes and/or gifts that you have qualified to receive;

  15. to provide Service-related announcements or notifications to you;

  16. to fulfill a purpose that we disclose to you when we request your personal information;

  17. to meet legal and regulatory requirements.

Personal information gathered by GAC is kept in confidence.  GAC staff are authorized to access personal information based only on their need to deal with the information for the reason(s) for which it was obtained.  Personal information will only be collected and used by authorized staff in a manner consistent with the activities of GAC.

  1. Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and obtain your express consent to do so pursuant to Section 15.

  1. Disclosure

GAC may disclose your personal information to:

  1. its employees, agents, partners, volunteers, and service providers as is reasonably necessary to enable these parties to perform a business, professional, charitable or technical support function for GAC. We currently partner with several third-parties who perform various functions in order to enable certain features on the Sites.

Below is a list of the third parties with whom we currently partner, what personal information we disclose, and for what purpose:



Personal Information Shared

Amazon Web Services: Simple Email Service

Website email delivery to users.

Email addresses.


Global content distribution, cyber attack protection, performance enhancement of the Sites

IP Address, Browser Details.

Google Analytics

Traffic/user statistics and analysis.

For more information on Google Analytics, see Section 9 of this Privacy Policy.

IP Address, Browser Details.

Google Maps

Display maps, including a user’s present location.

Latitude, Longitude.


Newsletter delivery.

IP Address, Browser Details.

  1. a person who, in the reasonable judgment of GAC, is seeking the information as your agent; and

  2. a third party or parties, where you consent to such disclosure or the disclosure is required by law.

Corporate Reorganization and Business Transfers

We may also disclose your personal information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.  

User Content

If you voluntarily submit or post any information, photographs or other content (“User Content”) to any GAC blog or forum, Twitter pages, Facebook pages or other social networking pages/sites, certain of your personal information may be automatically included in the posting, including without limitation, your user name and email address, and this information may be collected and used by others.  GAC has no control over and is not liable for the collection, use or disclosure of any posted User Content or your included personal information by users of the Service, including any blog, forums, Twitter pages, Facebook pages or other social networking pages/sites.  You are responsible for ensuring the protection of any of your personal information that you post to any GAC blog, forum, Twitter Page, Facebook Page or other social networking page or site.  We recommend that you do not include your home address, job title, telephone number or other more sensitive personal information in any User Content, unless you are entirely satisfied that such information should be made public.

  1. Safeguarding Your Personal Information

GAC is committed to safeguarding your personal information.  GAC uses appropriate security measures to protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction regardless of the format in which it is held.  The methods of protection and safeguards used by GAC include, but are not limited to, locked filing cabinets, need-to-know access and technological measures including the use of passwords, encryption and firewalls.  

We cannot ensure or warrant the security of any personal information we collect either directly or automatically from you, and you do so at your own risk. We also cannot guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our security safeguards. To the degree that personal information is of a sensitive nature, and in the event of a breach, there may be a risk of significant harm to you which includes bodily harm, humiliation, damage to reputation or relationships, loss of employment, business or professional opportunities, financial loss, identity theft, negative effects on the credit record and damage to or loss of property.

GAC takes care in disposing of or destroying personal information to prevent unauthorized parties from gaining access to the information.  GAC also ensures that its employees with access to personal information are made aware of the importance of maintaining the confidentiality of personal information.  Finally, GAC protects personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

  1. Retention of Personal Information

GAC will only keep personal information for as long as reasonably necessary to fulfil the relevant purposes set out in this Policy Privacy and in order to comply with our legal and regulatory obligations. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may also retain aggregated non-identifiable personal information indefinitely when you use the Service, become a registered user of the Service or after your account has been closed for research or statistical purposes. See Section 9 for more details on our collection of non-personal information.

Please note, if you are a registered user and your GAC account becomes inactive, GAC may choose not to retain your User Content, personal information associated with your GAC account, or any other records associated with your GAC account, for a period longer than three years after your GAC account becomes inactive, in which case such information may be destroyed. If your GAC account becomes inactive, you are solely responsible for exporting any such information from your GAC account that you may wish to retain.  

  1. Accuracy

GAC is committed to keeping your personal information as complete, up-to-date, and accurate as is necessary for the purposes for which it is to be used.  GAC will promptly correct or complete any personal information found to be inaccurate or incomplete.  Where appropriate, GAC will transmit amended information to third parties having access to the personal information in question.  Upon request, GAC will provide you with a reasonable opportunity to review the personal information in your file to review its accuracy.  Such personal information will be provided within a reasonable time of the request and at a minimal or no cost to you.

Also upon request, GAC will provide an account of the use and disclosure of your personal information and, where reasonably possible, will state the source of the information.  In providing an account of disclosure, GAC will provide a list of organizations to which it may have disclosed personal information about you when it is not possible to provide an actual list.

  1. Non-Personal Information

Non-personal information is information that does not identify you and which we are unable to connect to other information in order to identify you.  GAC may collect any or all of the following non-personal information:

  1. Aggregated survey data that you submit to the Service regarding the number of students who bike, walk, bus, use a skateboard, wheelchair to get to school in your neighbourhood and community;

  2. The Sites use Google Analytics, a web analytics service provided by Google, Inc. ("Google").  Google Analytics uses "cookies" which are text files placed on your computer to help the Sites analyze how users use the Sites.  Cookies enhance the convenience and use of a website.  The information generated by the cookie about your use of the Sites (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google will use this information for the purpose of evaluating your use of the Sites, compiling reports on website activity for the Sites’ operators and providing other services relating to website activity and Internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.  You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that doing so may affect your use of the Sites and your ability to access certain features of the Sites.  By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Google currently offers a free Google Analytics opt-out tool for Internet Explorer 7-10, Google Chrome, Mozilla Firefox, Apple Safari and Opera, which is available at

  3. We may also use additional analytics programs from time to time to process non-personal information about you.

We make no attempt to link this non-identifying information with the identity of individuals using the Service. Your non-identifying information may be permanently archived for future use.

  1. Additional European Economic Area Disclosures

Our Role as Data Controller and Data Processor

GAC generally acts as the data controller of your personal information submitted through the Sites.

If you are situated in the European Economic Area (“EEA”) and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us as provided under Section 11. If you are situated in the EEA and have a complaint, please contact our Privacy Officer us as provided under Section 11.

Legal Basis for Processing Your Personal Information

Our legal basis for collecting and using personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect it. Below are the types of lawful basis that we may rely on to process your personal information:

Legal Basis for Processing

Explanation of Legal Basis


You have given consent to us for the processing of your personal information for one or more specific purposes.

Legitimate Interest

Processing your personal information to enable us to provide and improve the Services to you, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at as provided under Section 11.

Performance of a Contract

Processing your personal information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

Processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject.

Change of Purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

Your Personal Information Rights

If you are situated in the EEA, you have the following rights:


Explanation of Right

Right of Access

The right to make a written request for details of your personal information and a copy of that personal information.

Right to Rectification

The right to have inaccurate information about you corrected or removed.

Right to Erasure (‘Right to be Forgotten’)

The right to have certain personal information about you


Right to Restriction of Processing

The right to request that your personal information is only used for restricted purposes.

Right to Automated Decisions

The right to contest any automated decision made where such a decision is based solely on automated processing, including profiling, which produces legal effect concerning you or similarly significantly affects you.

Right to Object

The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interests.

Right to Data Portability

The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format.

Right to Withdraw Consent

The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent.

To exercise any of these rights, please contact us as provided in Section 11. These rights are not absolute and they do not always apply in all cases.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request in order to help us respond efficiently to your request.

You will not have to pay a fee to access your personal information (or to exercise any of the above rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

  1. Contact Us

To submit an inquiry, complaint, request a review of your personal information, correct or update your personal information, withdraw your consent or request more information or additional copies of the Privacy Policy contact:

Green Action Centre Privacy Officer

Mailing Address:  3rd floor, 303 Portage Avenue, Winnipeg, MB, R3B 2B4

Telephone No.:  1-204-925-3777 or 1-866-394-8880 (toll free number)

E-mail:  info at  

  1. Unsubscribe

If you no longer wish to receive electronic communications from GAC regarding contests, project updates or other BikeWalkRoll information, please unsubscribe here.

  1. Complaints

GAC will promptly investigate all complaints concerning our compliance with the Privacy Policy and our dealings with your personal information.  If a complaint is found to be justified, GAC will take appropriate measures to resolve the complaint including, if necessary, amending GAC’s policies and procedures.  You will be informed of the outcome of the investigation regarding your complaint.

  1. Withdrawing Consent

You may withdraw your consent to the collection, use or disclosure of your personal information by GAC at any time, subject to legal or contractual restrictions and reasonable notice.  In certain circumstances, your withdrawal of consent will result in the inability of GAC to continue providing aspects of the Service to you.  Please contact GAC for more information regarding the implications of withdrawing consent.

  1. Privacy Policy Changes

We may modify this Privacy Policy to accommodate changes in our services, changes in technology and legal developments. If we make changes to this Privacy Policy, we will provide notice through our Services, or by other means to provide you the opportunity to review the changes before they become effective. For example, we may place a prominent notice on the Sites or e-mail you to let you know of an updated Privacy Policy.

If we make significant changes to this Privacy Policy, we will provide at least 30 days’ notice through our Services, or by other means, to provide you the opportunity to review the changes and provide your required consent before they become effective. A significant change may be using personal information for a new purpose or disclosures to new third parties.

You acknowledge that your continued use of our Services after we modify this Privacy Policy, publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

If you object to any changes to the Privacy Policy you may close your account.  

Whenever we update the Privacy Policy, we will change the date below to indicate when the changes were made.

Date:  April 22 2019