WEBSITE PRIVACY POLICY ADVANTAGE ST. JOHN'S
Effective Date: July 6, 2026
LEGAL DISCLAIMER
This website https://www.advantagestjohns.ca and all associated subdomains (collectively, the “Website”) is owned and operated by Advantage St. John’s Inc. ("Advantage St. John's", also referred to as "we," "us," and "our").
By visiting or using the Website, you acknowledge that you have read and understood this Website Privacy Policy (the “Policy”). If you do not agree with the terms of this Policy, please do not use the Website.
By visiting or using this Website, you agree to the following terms and conditions.
Advantage St. John’s does not guarantee the accuracy, currency or completeness of the information on the Website.
Use of the information on the Website is at the user’s risk. Advantage St. John’s shall not be liable for any claims, expenses, damages (including direct, indirect, special or consequential damages), loss of profits, opportunities or information arising from:
· The use of or reliance on information on the Website;
· Inaccuracy or omission of information on the Website;
· Use of any third party websites linked from the Website;
· Any Internet software used in connection with the Website or computer viruses or other destructive programs downloaded or encountered as a result of using the Website;
· Any other matter connected with the Website.
The foregoing applies even if Advantage St. John’s is made aware of the possibility of such claims, expenses, damages or losses.
ABOUT THIS POLICY AND YOUR PRIVACY
Your privacy is important to Advantage St. John's.
This Policy explains how we collect, use, disclose, safeguard, and retain your Personal Information (as defined in this Policy) when you:
visit our Website, including to view the contents of the Website, request information, ask a question, register for an event, sign up for our mailing list, sign up for membership, or otherwise communicate with us;
voluntarily join our mailing list or subscribe to newsletters or updates;
contact us by email or through a contact form on the Website;
register for, events, programs, workshops, or other initiatives through the Website;
interact with us through our social media pages or other online services that link to this Policy;
otherwise interact with us through the Website; and
use any other websites, applications, platforms, programs, or services that are owned, operated, or provided by Advantage St. John's, or that contain a link or direction to this Policy,
(together, the "Services").
This Policy does not apply to third-party websites, applications, or services that may be linked to or from our Website or communications. Those third parties have their own privacy practices and we encourage you to review them before providing your Personal Information.
PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR PERSONAL INFORMATION. Advantage St. John's will obtain your consent where required by applicable law for the collection, use, and disclosure of Personal Information. By accessing or using the Services, or by submitting your Personal Information to us, you accept and agree to be bound by this Policy and you consent to our collection, use, and disclosure of your Personal Information for the purposes and in the ways described in this Policy. If you do not agree with this Policy, you may choose not to use the Services.
This Policy may be updated from time to time to comply with applicable privacy laws, regulations, standards, and best practices in Canada or elsewhere. Changes will take effect immediately upon posting to our Website. Where such changes are significant or materially affect your rights under this Policy, we will notify you by posting a notice on our Website. Your continued use of the Services following any change means that you accept and consent to that change. We recommend that you review this Policy regularly. If you have any questions or concerns, please contact us at info@advantagestjohns.ca .
APPLICABLE PRIVACY LEGISLATION
Advantage St. John's is a public body as defined under the Access to Information and Protection of Privacy Act, 2015, SNL 2015, c A-1.2 ("ATIPPA").
The collection, use, disclosure, protection, and retention of Personal Information by Advantage St. John's is governed by, and subject to, ATIPPA.
This Policy is designed to comply with ATIPPA and with the guidance and requirements of the Office of the Information and Privacy Commissioner in Newfoundland & Labrador.
Advantage St. John's has a designated ATIPP Coordinator who can be reached at info@advantagestjohns.ca .
In the event of any conflict between this Policy and the requirements of any Applicable Law(s), the Applicable Law(s) will prevail.
1. WHAT IS PERSONAL INFORMATION?
"Personal Information" is recorded information about an identifiable individual, as defined in ATIPPA. In other words, Personal Information is information about an individual whose identity can be determined from the information itself or from the information combined with other information available to us, either directly or indirectly. It can include, but is not limited to, an individual's name, home address, telephone number, email address, age, date of birth, sex, gender, preferred pronouns, marital or family status, identifying numbers, government identification, financial information, educational background, employment history, technical information (including device and browser type) collected automatically when you visit the Website, Internet Protocol (IP) address, and geo-location information, and any other information that identifies you or could reasonably be used to identify you.
Personal Information does not include:
certain business contact information used solely for the purpose of communicating with an individual in their professional capacity (such as their name, title, business address, telephone number, or business email address); and
de-identified, anonymized, or aggregated information that cannot reasonably be used to identify an individual.
2. HOW PERSONAL INFORMATION IS COLLECTED BY ADVANTAGE ST. JOHN'S
Purposes for Collection
We collect Personal Information from you when you visit the Website, and when you access or use the Services. This Personal Information is collected in various ways and for different reasons, as explained in this Policy, but is generally collected for the following purposes:
to deliver the Services and monitor their quality and operation;
to administer and manage membership in Advantage St. John's, including processing membership applications, renewals, and fees;
to administer and manage a mailing list;
to receive payments for Services, memberships, events, or other offerings;
to understand the needs and preferences of our members and other stakeholders;
to respond to your requests and enquiries;
to conduct research and statistical analysis relating to our Services;
to administer and enhance your relationship with us, including providing member benefits and communications;
to plan and administer events, programs, workshops, and other activities offered by Advantage St. John's;
to manage relationships with stakeholders, partners, and participants;
to comply with audit, compliance, and legal requirements, including any reporting or enforcement obligations applicable to Advantage St. John's, including obligations under ATIPPA;
to manage and develop our business and programs, including customizing our Services for current and future members and stakeholders;
to communicate with you, where you have provided your consent or where otherwise permitted by law, about current or future programs, events, advocacy efforts, and service offerings by us or by others that may be of interest to you;
to allow you to participate in interactive features, surveys, forums, events, or similar activities offered by Advantage St. John's;
to comply with this Policy; and
for any other purposes for which we have your consent, or for which consent is not required, under applicable law, including ATIPPA.
We collect only the Personal Information that is necessary for the identified purposes, as required by ATIPPA and, where applicable, PIPEDA.
We also use your Personal Information to protect the security of your account and information, to deliver support and respond to enquiries, and to send you important information about Advantage St. John's and our Services, including updates, changes to this Policy, and information about upcoming events and programs.
Information Collected Directly from You
Most of the Personal Information we collect from you is collected directly, when you actively provide it to us, for example, by completing a form on our Website, joining our mailing list, registering for an event, making a payment, contacting us by email through the Website, or otherwise interacting with us through the Website. The Personal Information we collect directly from you may include:
Individual information, such as name, age, date of birth, occupation, and/or preferred pronouns;
Contact information, such as email address, telephone number, physical address, and mailing address;
Membership and account information, such as your membership category, transaction history, interactions with us, communications and marketing preferences, and any other information provided in connection with your membership or account;
Financial information, such as credit card details, banking information, billing address, and third-party payment account information, where applicable;
Program and event information, such as registration details, attendance records, and accessibility needs or dietary restrictions you choose to disclose;
Communications, including questions, feedback, survey responses, and correspondence; and
Any other information you directly provide to Advantage St. John's through the Website.
Where we collect financial information, it is used solely to verify and process payments associated with membership fees, event registrations, and other Services, to detect and prevent fraud, and to meet applicable tax and financial reporting obligations. When you are directed to a third-party payment gateway to make payments for any Services, you must refer to the privacy policy, terms of use, refund policies, and any other applicable policies of that third party. WE ARE NOT RESPONSIBLE FOR ANY PRIVACY OR INFORMATION BREACHES ARISING OUT OF THE USE OF A THIRD-PARTY WEBSITE LINKED OR DIRECTED THROUGH OUR WEBSITE OR THE SERVICES.
If you provide your opt-in consent to receiving marketing and communications from Advantage St. John's, we will use your contact information to send you information about our programs, events, newsletters, advocacy efforts, and other matters of interest to the St. John's Region business community. You may withdraw your consent to receiving such communications at any time by contacting our Privacy Officer or by using the unsubscribe mechanism provided in any marketing communication we send you.
If you choose to link any of your social media accounts to our Services, or interact with us on social media, we may use your social media information for marketing and communications purposes or to contact you about our Services and programs.
Information Collected Automatically
We also collect certain information automatically when you interact with or access our Website. The information we collect automatically may include:
Technical information, such as device type, operating system, browser type, IP address, cookies, time zone settings, time and date of access, language settings, crash and diagnostic logs, and unique device identifiers;
Usage information, such as search terms used to find our Website, pages requested and visited on our Website, referring pages, log files, date and time of access, scrolling habits, links clicked, and frequency of visits; and
Geo-location information, such as the approximate location of your IP address and the location from which you access the Services, where enabled on your device.
This information is collected using server log files and, where applicable, cookies or similar technologies. It is used in aggregate, non-personally identifiable form to administer and improve the Website, monitor usage patterns, and ensure the security and integrity of our systems. It is not used to identify individual visitors unless required for security or law enforcement purposes.
3. WEBSITE COOKIES
The Website may use cookies, web beacons, or similar technologies. Cookies are small files stored on your device when you visit our Website. We may use cookies and similar technologies to understand how our Website is used, to improve your overall online experience, and for security and functionality purposes. Except for strictly necessary cookies, most cookies expire at the end of your browsing session, though some may have an extended lifespan. Some cookies are persistent and will not expire until manually deleted or until their expiry date is reached.
Our Website may use the following types of cookies:
Necessary – These cookies are required to enable core Website functionality and to remember user preferences and choices, such as language preferences or customized settings. They are essential for our Website to function properly, for example, to maintain security and enable communication. They cannot be disabled in our systems. You may set your browser to block or alert you about these cookies, however, doing so may affect how our Website functions.
Performance and Analytics – These cookies provide quantitative measures of Website visitors. These cookies collect general usage data about our Website, such as the number of visitors, pages viewed, length of visit, bandwidth used, and the websites visited before and after our Website. This data is aggregated and is not linked to any identifying Personal Information, such as your name, address, email address, or telephone number.
Advertising – These cookies are used by advertising companies to serve ads that are relevant to your interests.
By using our Website, you agree that we may place these types of cookies on your device. If you prefer to restrict, block, or delete cookies, you can adjust your browser settings accordingly. If you choose to disable all cookies, we cannot guarantee that our Website or Services will work as expected. If you have any questions about our use of cookies, please contact our Privacy Officer.
4. HOW PERSONAL INFORMATION IS DISCLOSED TO THIRD PARTIES
Advantage St. John's does not sell, trade, or rent Personal Information. We may disclose your Personal Information to Advantage St. John's employees, contractors, and volunteers on a need-to-know basis, as described in this Policy or as permitted or required by applicable law.
We may also disclose Personal Information to third parties, including service providers, municipal partners, government departments, agencies, or authorities in Canada or elsewhere ("Third Parties"). Third Parties may provide us with services related to customer support, information technology, payment processing, event management, marketing, data analysis, research, legal compliance, and reporting. Third Parties may access Personal Information for the following purposes:
to help maintain the security of our Website, Services, network, and systems;
to collect, store, and/or process data on behalf of Advantage St. John's;
to help us deliver and improve the Services;
to provide marketing, communications, and promotional assistance;
to analyze how the Services are used;
to help Advantage St. John's fulfil its mandate with respect to the St. John's/CBS/Paradise Region business community and advance economic development in the Region;
to comply with applicable legislation; and
with your consent, for any other purpose disclosed by us at the time you provide the information.
Advantage St. John's does not sell your Personal Information or disclose it for any purpose other than those set out in this Policy.
We may also disclose your Personal Information in the following specific circumstances:
Within Advantage St. John's – To our employees, contractors, and volunteers who require access to carry out their responsibilities in connection with the Services, on a need-to-know basis.
With Your Consent or Direction – Where you authorize us to share your Personal Information with others, including other third-party service providers related to the operation of our Services.
For External Processing – To Third Parties instructed to process Personal Information on our behalf, subject to appropriate confidentiality and security measures consistent with this Policy.
For Legal Reasons or to Prevent Harm – We may use or disclose Personal Information to: (a) comply with a law, regulation, legal process, or governmental request (including requests under ATIPPA); (b) assert legal rights or defend against legal claims or proceedings; or (c) to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our policies, or threats to the security of our Services, public safety, or the safety of an individual.
As Required by ATIPPA – As a public body under ATIPPA, Personal Information in our custody or control may be subject to access to information requests and may be disclosed as required or permitted by that Act, including pursuant to a valid access request, subject to applicable statutory exceptions, including the protection of personal privacy.
If a legal process requires disclosure of your Personal Information, we will use our best efforts to notify you unless we are prohibited by law from doing so. If a non-disclosure period applies, we will notify you once that period has expired. We may be unable to provide notice in urgent or counterproductive circumstances, such as where there is a public safety concern or an individual emergency.
Where possible, we will use contractual measures to restrict how Third Parties use your Personal Information in accordance with this Policy and applicable law. Such contractual measures will require Third Parties to:
keep Personal Information confidential;
use Personal Information only for the purposes for which it is disclosed to them;
use de-identified or non-personal information where possible;
process Personal Information to at least the standards set out in this Policy; and
maintain privacy and security standards that comply with this Policy and applicable privacy legislation.
It is possible that, despite our safeguards and best efforts, your Personal Information may be accessed by law enforcement, governmental agencies, or national security authorities in the jurisdictions where Third Parties are located.
Our Website may also include links to third-party websites, plug-ins, social networks, or applications. If you click on one of these links, the third party may be able to collect, use, or disclose your Personal Information. We do not control third-party websites and are not responsible for their privacy practices. We encourage you to review the privacy policy of any third-party website you visit before providing your Personal Information.
5. NON-PERSONAL INFORMATION
We may aggregate, redact, de-identify, or anonymize your Personal Information so that it can no longer reasonably be associated with you individually ("Non-Personal Information"). We reserve the right to use, disclose, or make Non-Personal Information publicly available, or to share it with Third Parties, for any legitimate purpose, including research, statistical, or business purposes relating to economic development in the St. John's/CBS/Paradise Region, without further notice to you and without your consent. For example, we may share de-identified data with our partners, the municipalities of the St. John's, CBS or Paradise or other stakeholders in support of our economic development mandate.
6. HOW PERSONAL INFORMATION IS STORED, RETAINED, AND PROTECTED
We will retain your Personal Information for as long as is necessary or reasonable to fulfil the purposes for which it was collected, to meet our legal and regulatory obligations (including any applicable retention schedules under ATIPPA or other applicable legislation), to serve our legitimate business interests, and to prevent harm, as described in this Policy. In retaining and storing your Personal Information, it will be protected appropriately.
We process and store your Personal Information on a secure server located Canada that is hosted by Triware Technologies. Where necessary for the purposes described in this Policy, Personal Information may be transferred to service providers or partners located in other provinces or countries. By providing your Personal Information or otherwise engaging with our Services, you consent to such transfer, storage, or processing.
For additional information on Advantage St. John's' policies and practices regarding the use of service providers outside of Canada, please contact our Privacy Officer.
We use physical, electronic, contractual, and administrative safeguards appropriate to the sensitivity of the Personal Information held by us, designed to protect against accidental loss and against unauthorized access, use, alteration, or disclosure. We may engage Third Parties to ensure that appropriate measures are in place.
The security of your Personal Information also depends on you. Where you have a password to access your account or to use our Services, you are responsible for keeping that password confidential. Please use a strong and unique password and do not share it with anyone.
The Internet is not completely secure. Although we use all reasonable efforts to protect your Personal Information, we cannot guarantee the security of Personal Information transmitted via our Website or Services. We are not responsible for any circumvention of privacy settings or security measures.
Where Personal Information is processed outside Newfoundland and Labrador or Canada, it may be subject to the laws of that jurisdiction. Other jurisdictions may have privacy and data protection laws that differ from, and may be less protective than, the laws of Canada or the Province of Newfoundland and Labrador. In these circumstances, the governments, courts, authorities, or regulatory agencies of that jurisdiction may be able to access your Personal Information, depending on the laws. You agree to this risk when using our Services.
We securely dispose of Personal Information when it is no longer required, for example, by secure shredding of paper records and secure deletion of electronic records. We may also anonymize your Personal Information so that it can no longer be associated with you, and we reserve the right to use such anonymized and de-identified data for any legitimate business purpose without further notice to you as described above in Non-Personal Information.
Privacy Breach Notification
In the event of a privacy breach that creates a real risk of significant harm to an individual, Advantage St. John's will take steps to contain, investigate, and remediate the breach. As a public body under ATIPPA, we will notify affected individuals and report to the Newfoundland & Labrador Office of the Information and Privacy Commissioner (“OIPC”) as required by ATIPPA and any other applicable legislation.
7. HOW TO ACCESS, CORRECT, OR DELETE YOUR PERSONAL INFORMATION
Advantage St. John's uses all reasonable efforts to keep your Personal Information accurate and complete, however, we rely on you to inform us if your Personal Information needs to be updated or corrected.
Access
Individuals have the right to request access to their Personal Information held by Advantage St. John's. The regime that governs your access request, and the timeline within which we must respond, will depend on the nature of your request and the context in which the information was collected, as explained below:
Under ATIPPA – As a public body under ATIPPA, Advantage St. John's is subject to formal access to information request procedures under that Act. If you wish to make a formal request to access Personal Information (or other records) held by Advantage St. John's under ATIPPA, we are required by law to respond within 20 business days of receiving your written request. This statutory deadline may be extended in certain limited circumstances permitted under ATIPPA, for example, where the request requires a large volume of records to be reviewed, or where third-party consultation is required. We will notify you if an extension is necessary. Requests under ATIPPA may be subject to applicable fees as set out under ATIPPA and its regulations.
In all cases, we may be unable to provide access where doing so would reveal confidential commercial information, compromise an investigation, interfere with dispute resolution, reveal information protected by legal privilege or another applicable confidentiality protection, or where such access is otherwise restricted under ATIPPA, or other applicable law.
If you are unsure which regime applies to your request, please contact our Privacy Officer and we will help direct your request appropriately.
Correction
If you believe the Personal Information we hold about you is inaccurate or incomplete, you may contact our Privacy Officer to request a correct and we will make corrections where reasonably possible. We may require a written request and identity verification before processing any correction. We will not make changes that we believe would violate any legal requirement or render information incorrect.
Deletion
To request deletion of your Personal Information, you must submit a written request to our Privacy Officer. We will use commercially reasonable efforts to delete your Personal Information promptly following receipt of your request. Please be aware that full deletion across all systems, including those of Third Parties who store or process data on our behalf, may take additional time due to technical, operational, or contractual limitations. We may also be required to retain certain Personal Information to comply with legal obligations, including retention schedules under ATIPPA, or to enforce our policies, resolve disputes, ensure the safety and integrity of our Services, or prevent harm.
How to Submit a Request
All requests relating to your Personal Information should be directed to our Privacy Officer in writing. Contact details are set out in this Policy. We will assess each request promptly and respond within the applicable timeline described above.
8. CONSENT AND HOW TO WITHDRAW
We collect, use, and disclose Personal Information only for the purposes described in this Policy and as permitted or required by applicable law, including ATIPPA. By agreeing to this Policy, you consent to our collection, use, and disclosure of your Personal Information as described herein.
If we wish to collect, use, or disclose your Personal Information in a manner or for a purpose not described in this Policy, we will obtain your consent (including by updating this Policy), unless consent is waived or not required under applicable law.
You have the right to withdraw or modify your consent, in whole or in part, at any time. To do so, please contact our Privacy Officer. Please note that withdrawal or modification of consent may prevent us from being able to provide you with certain Services or to enable certain features or functions. We will do our best to explain the impact of your decision when you contact our Privacy Officer.
11. CHILDREN'S PRIVACY
Our Services are not intended to be used or accessed by individuals under 19 years of age, which is the age of majority in Newfoundland and Labrador. We do not knowingly collect, use, disclose, or solicit Personal Information from individuals under such age and we ask that no one under such age provide their Personal Information to us without appropriate parental or guardian consent. If we learn that we have inadvertently collected Personal Information from a minor without appropriate consent, we will delete that Personal Information as soon as reasonably possible. If you believe we might have received Personal Information about a minor, please contact our Privacy Officer.
12. COMPLAINTS AND OVERSIGHT
As a public body under ATIPPA, Advantage St. John's is committed to complying with applicable privacy legislation, including ATIPPA. We take all privacy concerns seriously and will address them promptly and in good faith.
Step 1 – Contact Our Privacy Officer
If you have a concern or complaint about how we handled your Personal Information, we encourage you to first contact our Privacy Officer using the contact information provided herein. We will do our best to resolve your concern promptly and to your satisfaction.
Step 2 – Contact the Office of the Information and Privacy Commissioner (ATIPPA)
If you are not satisfied with our response to your concern or complaint, and your matter relates to the handling of your Personal Information by Advantage St. John's as a public body under ATIPPA, you may file a complaint with the OIPC. The OIPC's contact information is available at www.oipc.nl.ca.
13. HOW TO CONTACT US AND OUR PRIVACY OFFICER
If you object to the collection, use, or disclosure of your Personal Information; if you are seeking access to, correction of, or deletion of your Personal Information; if you wish to withdraw or modify your consent; or if you wish to file a complaint, make an enquiry, or ask questions about this Policy, please contact our Privacy Officer at info@advantagestjohns.ca .
14. CHANGES TO THIS POLICY
We may update this Policy from time to time in our sole discretion. The "Last Updated" date at the top of this page reflects the date of the most recent revision. Changes take effect as soon as we post them to our Website.
Where material changes are made, we will notify you by email or by posting a notice on our Website or applicable platforms that link to this Policy, and where required by applicable law, we will obtain your consent. Your continued use of the Services after any such changes means that you accept and consent to those changes. We recommend that you review this Policy regularly for updates.
If you have any questions or concerns about this Policy or any changes made to it, please contact our Privacy Officer.
15. GOVERNING LAW
This Policy is governed by and construed in accordance with the laws of the Province of Newfoundland and Labrador, including ATIPPA. Any disputes relating to this Policy or to the privacy practices of Advantage St. John's shall be subject to the jurisdiction of the courts of the Province of Newfoundland and Labrador.