Gurpreet Singh Dhillon Municipal Campaign
Regional Councillor Candidate – Wards 9 & 10, Brampton

The Gurpreet Singh Dhillon Municipal Campaign (“Campaign,” “we,” “us,” or “our”) respects the privacy of residents, supporters, volunteers, Website visitors, community members, and other individuals who interact with the Campaign.

This Privacy Policy explains how the Campaign may collect, use, disclose, retain, and protect personal information through its website, campaign activities, forms, events, email communications, SMS/text messaging program, and other interactions.

We seek to handle personal information responsibly and in accordance with applicable Canadian and Ontario laws and the requirements applicable to municipal election campaigns, including requirements relating to the handling of voters’ list information under the Municipal Elections Act, 1996.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information collected through or in connection with:

• the Campaign Website;
• Campaign contact forms;
• email subscriptions;
• SMS/text message subscriptions;
• volunteer registration;
• campaign sign requests;
• event registrations;
• community surveys;
• requests for information;
• communications with Campaign staff or volunteers;
• campaign events;
• authorized Campaign activities;
• voter information made available to the Campaign in accordance with applicable election laws; and
• other Campaign-related interactions.

This Privacy Policy does not govern independent third-party websites or services that may be linked from the Campaign Website.

2. Personal Information We May Collect

Depending on how you interact with the Campaign, we may collect information such as:

Contact Information

• name;
• email address;
• telephone or mobile number;
• mailing address;
• postal code; and
• preferred method of communication.

Campaign Participation Information

We may collect information relating to:

• volunteer interests;
• event registrations;
• campaign sign requests;
• availability to volunteer;
• areas or neighbourhoods of interest;
• community concerns;
• survey responses;
• feedback;
• questions submitted to the Campaign; and
• interactions with Campaign representatives.

SMS/Text Messaging Information

If you subscribe to SMS communications, we may collect:

• your mobile telephone number;
• the date and time you opted in;
• the method or source through which consent was provided;
• messaging preferences;
• messages sent to or received from the Campaign;
• STOP, HELP, and other messaging requests; and
• records necessary to demonstrate or administer messaging consent.

Email Communications

If you subscribe to emails or communicate with the Campaign electronically, we may collect:

• your email address;
• subscription preferences;
• messages you send to us;
• engagement information associated with Campaign communications where available; and
• unsubscribe requests.

Website and Technical Information

When you visit the Website, certain technical information may be collected automatically, depending on the technologies used by the Website, such as:

• Internet Protocol (IP) address;
• browser type;
• device type;
• operating system;
• pages viewed;
• referring website;
• approximate geographic information derived from an IP address;
• date and time of Website access;
• Website interaction information; and
• cookie or similar technology identifiers.

3. Information From Forms

When you voluntarily submit information through a Campaign form, we collect the information you choose to provide.

Forms may be used for purposes including:

• contacting the Campaign;
• volunteering;
• requesting a campaign sign;
• receiving campaign updates;
• attending events;
• submitting community feedback;
• participating in surveys;
• requesting assistance or information; or
• opting in to communications.

Where practical, the purpose for collecting information will be stated on or near the relevant form.

4. Information Obtained for Electoral Purposes

As a registered municipal election candidate, the Campaign may receive access to voter information that is legally made available for electoral purposes.

Any copy of the voters’ list received by or on behalf of the Campaign will be handled separately and in accordance with the applicable requirements of the Municipal Elections Act, 1996.

The Campaign will:

• use voter-list information only for permitted electoral purposes and not for commercial purposes;
• restrict access to individuals who require it for authorized Campaign activities;
• obtain required written acknowledgements before sharing copies with authorized Campaign workers where required;
• maintain required records relating to persons who receive copies;
• prohibit unauthorized further sharing;
• require physical copies provided to authorized recipients to be returned as required;
• require electronic copies provided to authorized recipients to be destroyed as required;
• obtain applicable written confirmations of destruction; and
• destroy Campaign copies of the voters’ list by the legally required deadline at the end of the Campaign.

Voters’ list information will not be sold or used for unrelated commercial marketing.

5. How We Use Personal Information

The Campaign may use personal information to:

• communicate with residents and supporters;
• respond to questions or requests;
• provide campaign and election updates;
• administer SMS and email communications;
• organize Campaign events;
• coordinate volunteers;
• process campaign sign requests;
• conduct community outreach;
• understand issues that are important to residents;
• conduct surveys and receive feedback;
• manage Campaign activities;
• maintain records of communication consent and opt-out requests;
• improve Website performance and usability;
• maintain Website and information security;
• detect or prevent misuse, fraud, or security incidents;
• fulfill applicable election-law requirements;
• comply with legal obligations; and
• otherwise operate the Campaign.

We will not use personal information for purposes that are materially unrelated to the purpose for which it was collected without appropriate authorization or another lawful basis.

6. SMS/Text Messaging Privacy

The Campaign may provide an optional SMS/text messaging program.

If you voluntarily provide your mobile number and opt in, the Campaign may send you campaign-related information including:

• election information;
• campaign updates;
• community announcements;
• event reminders;
• voting reminders;
• volunteer opportunities;
• surveys;
• requests for feedback; and
• related Campaign communications.

Message frequency may vary. Message and data rates may apply.

Opting Out

You may stop receiving SMS messages at any time by:

Replying STOP to any Campaign text message, or
Texting STOP to (647) 825-0910.

You may receive a final message confirming your unsubscribe request.

Help

For SMS assistance:

Reply HELP to receive help, or contact:

info@gurpreetsinghdhillon.com

No SMS Donation Solicitation

The Gurpreet Singh Dhillon Municipal Campaign will never use its SMS/text messaging program to solicit monetary donations.

We will not ask you through SMS to provide:

• credit or debit card information;
• online banking credentials;
• payment passwords;
• gift cards;
• cryptocurrency;
• wire transfers; or
• other payment credentials.

If you receive such a message claiming to represent the Campaign, please report it to info@gurpreetsinghdhillon.com.

7. Mobile Information — No Sale or Marketing Disclosure

The Campaign maintains strict protections regarding mobile information.

No mobile information will be shared or sold with third parties or affiliates for marketing or promotional purposes.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

The Campaign does not sell, rent, trade, or otherwise provide mobile telephone numbers or SMS opt-in information to third parties or affiliates for their independent marketing or promotional purposes.

Information provided specifically for participation in the Campaign’s SMS program will be used only for purposes associated with Campaign communications, consent management, opt-out administration, compliance, security, and other purposes necessary to administer the Campaign’s messaging program.

8. Selling Personal Information

The Campaign does not sell personal information.

We do not sell, rent, or trade voter, supporter, volunteer, Website visitor, email subscriber, or mobile subscriber information to data brokers, advertisers, businesses, political organizations, or other third parties for their independent marketing purposes.

9. When Information May Be Disclosed

Except for the specific mobile-information restrictions described above, the Campaign may disclose limited personal information where reasonably necessary to organizations or individuals that provide operational services to the Campaign.

These may include service providers assisting with:

• website hosting;
• cybersecurity;
• cloud storage;
• email delivery;
• campaign management systems;
• analytics;
• form processing;
• payment processing, where applicable;
• accounting or auditing;
• professional advice; or
• other technology and administrative services.

Such service providers should receive only information reasonably necessary to perform authorized services and are expected to handle that information consistently with their contractual and legal obligations.

The Campaign may also disclose information when reasonably necessary to:

• comply with applicable law;
• satisfy an election reporting requirement;
• respond to a lawful order or legal process;
• protect the security or integrity of Campaign systems;
• investigate suspected fraud or unlawful activity; or
• protect the rights, safety, or security of the Campaign or others.

Mobile information and text messaging originator opt-in data and consent are subject to the additional restrictions stated in Section 7 above and will not be shared or sold to third parties or affiliates for marketing or promotional purposes.

10. Campaign Contributions

If the Campaign accepts contributions through the Website or another authorized method, certain information may need to be collected and retained to comply with Ontario municipal election law.

This information may include:

• contributor name;
• contributor address;
• amount contributed;
• date of contribution;
• payment-related transaction information; and
• other information required for Campaign financial records.

Payment card information may be processed directly by an authorized payment processor rather than stored by the Campaign.

Election legislation may require certain contributor information to be included in Campaign financial statements or otherwise made publicly available.

Where disclosure is legally required, the Campaign will disclose the information required by law.

11. Cookies and Similar Technologies

The Website may use cookies and similar technologies to:

• maintain Website functionality;
• understand Website usage;
• remember user preferences;
• improve Website performance;
• measure Campaign outreach; and
• protect against security threats.

Some cookies may be placed by third-party services integrated with the Website.

Depending on your browser and the technologies used by the Website, you may be able to block or delete cookies through your browser settings.

Blocking certain cookies may affect Website functionality.

12. Website Analytics

The Campaign may use website analytics services to better understand how visitors interact with the Website.

Analytics information may include aggregated or technical information such as:

• pages viewed;
• session duration;
• browser or device type;
• traffic source;
• approximate location; and
• Website interactions.

Where reasonably possible, the Campaign will seek to limit the collection of information to what is appropriate for Website administration, measurement, security, and Campaign outreach.

13. Social Media and Third-Party Platforms

The Campaign may operate pages or accounts on social media and other third-party platforms.

If you interact with the Campaign through those platforms, the platform provider may collect and process information according to its own privacy policy and terms.

The Campaign does not control the privacy practices of independent social media providers.

Users should review the privacy settings and policies of the services they use.

14. Third-Party Links

The Website may contain links to external websites, including government websites, news sources, social media platforms, event services, map providers, and other resources.

The Campaign is not responsible for the privacy practices, security, accuracy, or content of external websites.

Visiting an external website is subject to that site’s own terms and privacy policy.

15. Information Security

The Campaign seeks to use reasonable administrative, organizational, physical, and technical safeguards appropriate to the sensitivity of information in its possession.

These measures may include:

• limiting access to authorized Campaign personnel;
• password and account controls;
• appropriate access permissions;
• secure website connections;
• security updates;
• controlled access to Campaign systems;
• secure storage practices; and
• procedures for disposing of information when it is no longer required.

However, no electronic system or Internet transmission can be guaranteed to be completely secure.

We encourage users not to send passwords, banking credentials, government identification numbers, or other highly sensitive information through general Campaign forms, email, or SMS.

16. Data Minimization

The Campaign seeks to collect only information that is reasonably necessary for legitimate Campaign, electoral, administrative, security, or legal purposes.

We encourage individuals not to provide unnecessary sensitive information when communicating with the Campaign.

17. Retention of Personal Information

Personal information will be retained only for as long as reasonably necessary for the purpose for which it was collected, to administer Campaign activities, maintain appropriate records, satisfy legal requirements, resolve disputes, or protect Campaign systems.

Different categories of information may have different retention periods.

For example:

• SMS unsubscribe records may be retained to ensure that opt-out requests continue to be respected;
• Campaign financial records may be retained for the period required under election law;
• voter-list information will be destroyed according to the specific requirements applicable to municipal election candidates; and
• information that is no longer reasonably required may be securely deleted, destroyed, or anonymized.

Where the Campaign is legally required to retain a particular record, that legal requirement will take priority over a deletion request for the required retention period.

18. End of Campaign and Voters’ List Destruction

The Campaign recognizes the special rules governing copies of the municipal voters’ list.

On or before the date required by applicable election law at the end of the Campaign, the Campaign will take required steps to:

• destroy the copy of the voters’ list received from the municipal clerk;
• retrieve and destroy applicable physical copies provided to authorized Campaign workers;
• ensure that applicable electronic copies have been destroyed; and
• obtain required written confirmations concerning destruction of electronic copies.

Required acknowledgements and destruction confirmations will be retained for the period required by applicable election rules.

19. Access, Correction, and Privacy Requests

You may contact the Campaign if you wish to:

• ask what personal information you voluntarily provided to us;
• update or correct your contact information;
• change communication preferences;
• unsubscribe from Campaign communications;
• withdraw consent where applicable;
• request deletion of information where the Campaign is not legally required to retain it; or
• raise a question or concern about our privacy practices.

Requests may be submitted to:

info@gurpreetsinghdhillon.com

We may need to take reasonable steps to verify a request before acting on it.

Certain information may need to be retained where required by election law, financial reporting requirements, security obligations, or other applicable law.

20. Withdrawal of Communication Consent

You may change your communications preferences at any time.

For SMS:

Reply STOP or text STOP to (647) 825-0910.

For SMS assistance:

Reply HELP.

For email or other communication requests:

Email: info@gurpreetsinghdhillon.com

Withdrawal from optional Campaign communications will not affect your right to vote, your ability to contact the Campaign, or your ability to participate in the municipal election.

21. Information About Other People

If you submit personal information about another person through the Website, you should have appropriate authority or permission to provide that information.

You should not submit sensitive information about another person without authorization.

22. Changes to This Privacy Policy

The Campaign may update this Privacy Policy from time to time to reflect changes in:

• Campaign operations;
• Website functionality;
• communication practices;
• technology;
• service providers;
• election requirements; or
• applicable laws and regulations.

The most current version will be posted on the Campaign Website with an updated “Last Updated” date.

Material changes may be communicated through the Website or another reasonable method where appropriate.

23. Campaign and Government Disclaimer

This Website and its privacy practices relate to the independent Gurpreet Singh Dhillon Municipal Campaign.

The Campaign Website is not operated by or on behalf of the City of Brampton, Region of Peel, Elections Ontario, the Province of Ontario, or any other governmental or election authority.

The Campaign’s reference to Wards 9 & 10, the City of Brampton, municipal programs, or governmental bodies does not imply government sponsorship or endorsement.

24. Contact Us

If you have questions, concerns, requests, or complaints regarding this Privacy Policy or the Campaign’s handling of personal information, please contact:

Gurpreet Singh Dhillon Municipal Campaign
Regional Councillor Candidate – Wards 9 & 10, Brampton

Email: info@gurpreetsinghdhillon.com
Phone: (647) 825-0910

SMS Support

Reply HELP to receive help.

SMS Opt-Out

Reply STOP to stop receiving messages, or text:

STOP to (647) 825-0910

Message frequency may vary. Message and data rates may apply.