FRATERNALWEB PRIVACY POLICY
Effective date: September 2, 2026
Version: 2026-09-02

0. THE COMPANY; OUR PRIVACY OFFICER

  0.1 "Company," "we," "us," and "our" mean FraternalWeb Limited, a
  corporation existing under the laws of the Province of Ontario,
  Canada, with a mailing address of Office 911, 145 1/2 Church St, Unit
  5, Toronto, ON M5B 1Y4, Canada (Ontario Corporation Number
  1001724366).

  0.2 Privacy Officer. The Company has designated an individual who is
  accountable for the Company's compliance with this Policy and with
  applicable privacy legislation. That individual holds the office
  below, and their name will be provided on request:

    The Privacy Officer
    FraternalWeb Limited
    Office 911, 145 1/2 Church St, Unit 5, Toronto, ON M5B 1Y4, Canada
    privacy@frweb.org

  0.3 All privacy questions, access and correction requests, consent
  withdrawals, and privacy complaints should be sent to
  privacy@frweb.org. Other Company addresses (help@frweb.org for support
  and info@frweb.org for general enquiries) are monitored, and a privacy
  request received at either will be routed to the Privacy Officer, but
  using privacy@frweb.org will be faster and starts the response clock
  described in Section 15 without delay.

1. SCOPE OF THIS POLICY; WHO IT APPLIES TO; DEFINITIONS

  1.1 This Privacy Policy explains how the Company collects, uses,
  discloses, and protects information in connection with the
  FraternalWeb platform, including frweb.org and every Chapter subdomain
  of frweb.org (collectively, the "Service"). It should be read together
  with our Terms of Service.

  1.2 Four groups of people are described in this Policy, and different
  parts apply to each:

    (a) Chapters and their Administrators -- the organizations that
        subscribe to the Service and the individuals who run their
        Backends. Sections 2, 5.1, 9, 10, 11, 13, 14, and 15 are most
        relevant to you.

    (b) Members -- individuals with their own member accounts.
        Section 3 is written specifically for you.

    (c) Event registrants, form submitters, and newsletter subscribers
        who are not Members. Section 4 is written specifically for you.

    (d) Visitors to a public Tenant Site who do not submit anything.
        Section 4.5 is written specifically for you.

  1.3 Definitions. This Policy uses the same defined terms as our Terms
  of Service. In particular:

    (a) "Chapter" means any lodge, council, chapter, fraternal or civic
        organization, or other entity that registers to operate a
        Tenant Site and Backend on the Service.

    (b) "Administrator" means whichever individual(s) currently hold
        administrator-level access to a Chapter's Backend.

    (c) "Member" means an individual who completes the Service's own
        account signup process (typically using an invite link provided
        by a Chapter) to obtain access to that Chapter's Backend as an
        individual member.

    (d) "Personal Information" means information about an identifiable
        individual.

    (e) "PIPEDA" means the Personal Information Protection and
        Electronic Documents Act (Canada), together with its
        regulations, as amended or replaced.

  1.4 A Chapter's acceptance of this Policy is an organizational
  commitment made through whoever currently serves as its Administrator,
  in the same manner described in Section 1.6 of the Terms of Service.

  1.5 What this Policy does not cover. This Policy does not cover: (a) a
  Chapter's own privacy practices outside the Service, including the
  paper, spreadsheet, or other records it keeps independently; (b)
  third-party websites or services that a Chapter links to or embeds on
  its Tenant Site; or (c) the practices of the third-party providers
  listed in Section 9.2, each of which is governed by its own privacy
  policy.

2. OUR ROLE, AND A CHAPTER'S ROLE, REGARDING PERSONAL INFORMATION

  2.1 Two different kinds of decision. The Service has a fixed set of
  built-in categories for tracking a Chapter's members and related
  individuals -- currently including name, email address, phone number,
  role or office assignments, degree or rank progression history, dues
  and payment status/history, and event RSVPs, among others described in
  Section 5. These categories, and how the Service's own features
  process them (for example, how a "mark dues paid" action is recorded,
  or how a degree-advancement entry appears in a member's history), are
  designed and controlled by the Company as part of the Service's
  feature set. A Chapter cannot add, remove, or redefine these
  categories, and every Chapter's Backend uses the same fixed fields.

  2.2 Within those fixed categories, a Chapter's Administrator(s) -- and
  anyone else the Chapter grants a relevant permission to -- decide
  which specific individuals to add as members (or event attendees or
  newsletter subscribers), and what specific values to enter, update, or
  remove for them: for example, that a particular person's dues are now
  paid, that a particular person advanced to a new degree, or that a
  particular person holds a particular role. Some fields, such as a
  Member's own name or phone number, may also be updated directly by
  that Member within their own account. In most cases this information
  mirrors records a Chapter already keeps independently of the Service
  (such as its own paper or spreadsheet dues ledger); the Service is, in
  substance, digitizing and mirroring that Chapter's own recordkeeping.

  2.3 How this works under PIPEDA. PIPEDA does not divide the world into
  "controllers" and "processors." Instead, it holds an organization
  accountable for Personal Information in its possession or custody,
  including information the organization transfers to a third party for
  processing on its behalf, and requires the organization to use
  contractual or other means to ensure a comparable level of protection
  while the information is being processed by that third party.
  Applying that framework:

    (a) Your Chapter is the organization accountable to you for the
        membership information it keeps about you. It decides to record
        you, decides what to record, decides why, and is responsible for
        having a lawful basis and any required consent for doing so. It
        remains accountable for that information even though it is
        stored on our Service.

    (b) The Company holds and processes that information on your
        Chapter's behalf, for the sole purpose of providing and
        supporting the Service. We do not sell it, rent it, trade it, or
        use it for our own marketing, advertising, profiling, or
        artificial-intelligence training purposes.

    (c) The Company is separately accountable, in its own right, for:
        the Personal Information we collect directly from Chapters and
        Administrators for billing, account administration, support,
        and security; the technical and usage information described in
        Section 5.6; the design of the Service's fixed data categories
        and built-in processing logic; and the safeguards described in
        Section 11.

  2.4 Practical effect. This division determines who you should approach
  for what. Requests to change what your Chapter records about you --
  your dues status, your degree or rank history, your offices, whether
  you are listed at all -- go to your Chapter, because those are your
  Chapter's decisions and its records. Requests about how the Service
  itself handles information, about our safeguards, or about information
  we hold in our own right, come to us at privacy@frweb.org. Section 15
  explains how we handle a request that reaches us but belongs with your
  Chapter.

  2.5 A note on other legal regimes. The description above is written to
  PIPEDA. If a different framework applies to a particular Chapter or a
  particular individual -- for example Quebec's private-sector privacy
  law, or a law outside Canada that uses controller/processor concepts
  -- the allocation of legal roles under that framework may be
  characterized differently. Section 18 addresses this. A Chapter
  subject to such a framework should obtain its own advice.

3. PRIVACY NOTICE FOR INDIVIDUAL MEMBERS

  3.1 This Section 3 is addressed specifically to Members -- individuals
  who complete the Service's own account signup (typically using an
  invite link from a Chapter) to access a Chapter's Backend. It
  summarizes, in one place, what Personal Information about you the
  Service processes and the choices and rights available to you. It
  supplements, and does not replace, the rest of this Policy.

  3.2 What is processed about you. As described more fully in Section 2
  and Section 5, the Service processes Personal Information about you
  that your Chapter's Administrator(s) enter or maintain using the
  Service's fixed built-in fields (such as your name, email address,
  role/office history, degree or progression history, and dues/payment
  records), together with information you provide directly when
  creating or using your own account (such as your login credentials,
  and any profile fields -- like your name or phone number -- that you
  are permitted to edit yourself), and technical and usage information
  described in Section 5.6.

  3.3 Why it is processed. Your information is processed to operate the
  member portal for you and your Chapter: to authenticate your sign-in,
  display your own membership records to you, let your Chapter's
  Administrator(s) maintain accurate records (such as dues status,
  degree/rank, or role), process event RSVPs, and send you transactional
  communications like invite links, sign-in links, and notices from
  your Chapter. Section 6 sets out the full list of purposes.

  3.4 Your consent. By completing your account signup, you consent to
  the Company processing your Personal Information as described in this
  Policy, for the purpose of providing you and your Chapter with access
  to the Service. Section 7 explains the form your consent takes and how
  you can withdraw it. You are not asked to, and do not need to, agree
  to any billing or commercial terms -- those apply only to your
  Chapter, as explained in Section 8 of the Terms of Service.

  3.5 Who can see your information. Within your Chapter's Backend, your
  information is visible to your Chapter's Administrator(s) and to any
  other person your Chapter has granted a permission level that includes
  access to member records. Your Chapter -- not the Company -- decides
  who those people are. Your Chapter may also choose to publish some
  information (for example, an officer's name and contact details) on
  its public Tenant Site; if you hold an office and do not wish to be
  listed publicly, raise that with your Chapter. Company personnel may
  access your information only as described in Section 11.3.

  3.6 Your choices and rights. You may review or correct certain
  information yourself within your account (such as your name or phone
  number, where the Service allows self-editing). For information your
  Chapter's Administrator(s) control (such as your dues or degree
  records), contact your Chapter's Administrator. To exercise the access
  and correction rights described in Section 15, or to complain about
  our handling of your information under Section 16, contact
  privacy@frweb.org. If you no longer wish to use the member portal, you
  may ask your Chapter's Administrator to remove your account access;
  the underlying membership records may still be retained by your
  Chapter as its own organizational records, independent of the Service,
  in the same way a paper ledger would be.

  3.7 No commercial relationship. You are not a customer of the Company
  and have no billing relationship with us. Our processing of your
  Personal Information is not conditioned on any payment from you, and
  nothing in this Policy creates such an obligation.

4. PRIVACY NOTICE FOR EVENT REGISTRANTS, FORM SUBMITTERS, SUBSCRIBERS,
   AND PUBLIC VISITORS

  4.1 This Section 4 is addressed to people who interact with a public
  Tenant Site without holding a member account.

  4.2 If you register for an event or submit a form. A Chapter may
  enable public RSVP forms, contact forms, or other forms on its Tenant
  Site. We collect what you voluntarily submit -- typically your name,
  email address, and any information the form asks for -- and make it
  available to the Chapter that operates that Tenant Site, for the
  purpose of fulfilling your request (for example, confirming your RSVP
  or replying to your enquiry). The Chapter, not the Company, decides
  what its forms ask for, how long it keeps your submission, and what it
  does with it afterwards. If you want your submission deleted, contact
  the Chapter first; see Section 15.4 if you cannot reach it.

  4.3 If you subscribe to a newsletter. See Section 8, which explains
  how subscription and unsubscribing work, and who is legally the sender
  of the messages you receive.

  4.4 Submitting a form or subscribing does not create a member account,
  does not give you access to any Chapter's Backend, and does not make
  you a member of any Chapter.

  4.5 If you are just browsing. Visiting a public Tenant Site does not
  require you to provide any Personal Information. We automatically
  collect the technical and usage information described in Section 5.6
  for security, abuse prevention, and troubleshooting. Public Tenant
  Sites use only the strictly necessary cookies described in Section
  5.7, and we do not use advertising or cross-site tracking cookies. A
  Chapter may embed third-party content (such as a map, video, or
  calendar) on its Tenant Site, and that third party may collect
  information about you under its own privacy policy, over which we have
  no control.

5. INFORMATION WE COLLECT

  5.1 Account and Chapter information. When a Chapter is registered, we
  collect the Chapter's name, chapter/lodge number (if applicable),
  organization type, mailing address, chosen subdomain, and the
  registering Administrator's name and email address.

  5.2 Individual member information. Administrators may enter
  information about their Chapter's own members, which can include:
  name (and pre-/post-nominals), email address, phone number, role and
  office history, degree or progression history, dues and financial
  ledger records, and event RSVPs. Authentication information is also
  held: a member-selected password (stored only as a one-way
  cryptographic hash, never in readable form) or, if the member signs in
  with Google, an OAuth identifier -- we never see or store a Google
  account password. See Section 2 for how responsibility for this
  information is divided between the Company and your Chapter.

  5.3 What the Service is not designed to hold. The Service's fixed data
  categories are not designed for, and Chapters are contractually
  prohibited by Section 9.3 of the Terms of Service from entering,
  health or medical information, government identification or social
  insurance numbers, financial account or payment card numbers,
  biometric information, precise geolocation, or criminal history. If
  you become aware that such information has been entered about you,
  tell your Chapter and let us know at privacy@frweb.org.

  5.4 Content uploaded to the Service. Files, photographs, newsletters,
  event listings, correspondence, and form responses uploaded through a
  Chapter's Backend or public forms. Content may incidentally contain
  Personal Information -- a group photograph, a set of meeting minutes,
  a scanned letter -- and the Chapter that uploads it is responsible for
  having the right to do so.

  5.5 Payment information. Subscription payments are handled directly by
  our payment processor, Stripe, Inc. We do not receive or store your
  full payment card number. We do retain a Stripe-assigned customer
  identifier and invoice and payment status information for billing and
  account administration. Only Chapters make payments; Members do not.

  5.6 Technical and usage information. IP address, browser and device
  information, requested URLs, access timestamps, referring page, error
  and diagnostic records, email delivery and bounce records, and similar
  log data, collected automatically for security, fraud prevention,
  rate-limiting, deliverability, and troubleshooting purposes. Server
  and application logs are retained for approximately 90 days and then
  deleted or aggregated, except where a longer period is needed to
  investigate a specific security or abuse incident.

  5.7 Cookies. We use cookies that are strictly necessary to operate
  the Service, and no others. We do not use advertising, analytics, or
  cross-site tracking cookies, and we do not present a cookie consent
  banner, because every cookie we set is strictly necessary to deliver
  a service you have requested. The cookies we set are:

    (a) a session cookie, which keeps you signed in to your account;

    (b) a security token, which protects forms against cross-site
        request forgery; and

    (c) a sign-in recognition cookie, which holds a random value that
        lets us tell whether your account has been used to sign in
        from that browser before. Because signing in uses a link sent
        to your email address rather than a password, telling you
        about a sign-in from a browser we do not recognize is how you
        would learn that someone else has obtained access to your
        email account. This cookie is not a credential and grants no
        access on its own: presenting it tells us only that the
        browser is familiar, and its sole effect is that we do not
        send you that notification.

  You can block or delete these cookies through your browser. Without
  (a) and (b) the Service will not function correctly; blocking (c)
  means only that you will be notified each time you sign in.

  5.8 Correspondence. If you contact us at any address ending in
  @frweb.org, we keep a record of that correspondence, including your
  address and the content of your message, so that we can respond,
  maintain a support history, and resolve disputes.

6. WHY WE USE INFORMATION (PURPOSES)

  6.1 We identify our purposes here rather than collecting information
  first and deciding later. We use the information described in Section
  5 to:

    (a) provide, operate, and maintain the Service, including hosting
        public Tenant Sites and operating Chapter Backends;

    (b) authenticate sign-ins and enforce account permissions;

    (c) process subscription payments and manage billing, invoicing,
        renewals, collections, and tax and accounting records;

    (d) send transactional and service communications -- invite links,
        sign-in links, RSVP confirmations, billing notices, security
        alerts, outage notices, and notices about changes to this Policy
        or the Terms of Service;

    (e) transmit newsletters and other messages that a Chapter chooses
        to send to its own recipients, as described in Section 8;

    (f) provide customer support and respond to correspondence;

    (g) detect, prevent, and investigate fraud, abuse, spam, and
        security incidents, including automated malware scanning of
        uploaded files, rate-limiting, and log review;

    (h) comply with legal obligations and respond to lawful demands;
        and

    (i) troubleshoot, debug, maintain, and improve the Service.

  6.2 If we intend to use Personal Information for a purpose not listed
  above and not compatible with the purpose for which it was collected,
  we will identify that new purpose and obtain consent before doing so.

  6.3 We do not use Personal Information held on the Service to train
  machine-learning or artificial-intelligence models, and we do not
  disclose it to any third party for that purpose.

  6.4 We collect only the information necessary for the purposes above.
  We do not require a Member to provide information beyond what is
  needed to operate the member portal, and we do not condition access on
  consent to any unnecessary collection.

7. CONSENT

  7.1 Form of consent. Where the law requires consent, we rely on:

    (a) express consent, given by an affirmative act -- for example,
        completing account signup after being presented with this
        Policy, submitting a form, or subscribing to a newsletter; and

    (b) implied consent, where the purpose is obvious from the
        circumstances and a reasonable person would expect it -- for
        example, using the email address you supply to send you the RSVP
        confirmation you asked for.

  7.2 We do not use pre-checked boxes to obtain consent, and we do not
  bundle consent to unrelated processing into acceptance of the Terms of
  Service.

  7.3 Withdrawing consent. You may withdraw your consent to processing
  that depends on consent, at any time, by writing to privacy@frweb.org
  or, where the processing is your Chapter's, by contacting your
  Chapter. We will tell you what withdrawal will mean before we act on
  it.

  7.4 Consequences of withdrawal. Some processing is necessary to
  operate an account at all -- authentication, security logging, and
  storing the records that make up the member portal. If you withdraw
  consent to that processing, we cannot continue to provide you with an
  account, and your access will end. Withdrawing consent to receive
  newsletters does not affect your account. Withdrawal is not
  retroactive, and does not require us to delete records we are required
  or permitted by law to retain, such as billing records.

  7.5 A Chapter cannot give consent on your behalf for purposes outside
  its own membership recordkeeping, and nothing in a Chapter's
  acceptance of this Policy constitutes your personal consent to
  anything beyond that.

8. NEWSLETTERS, BULK EMAIL, AND YOUR SUBSCRIPTION CHOICES

  8.1 Who is sending. When you receive a newsletter, bulletin, event
  invitation, or similar bulk message that originated from a Chapter's
  Backend, the Chapter is the sender. The Company operates the technical
  means of transmission on the Chapter's behalf. We do not write,
  review, approve, or select the recipients of those messages, and we do
  not use any Chapter's recipient list for our own purposes or share it
  with any other Chapter.

  8.2 Consent to receive. Each Chapter is required by Section 7 of the
  Terms of Service to send only to people who have asked to receive its
  messages, or with whom it has a relationship that gives rise to
  implied consent under Canada's Anti-Spam Legislation, and is
  prohibited from using purchased, rented, traded, harvested, or
  scraped address lists. Each Chapter is responsible for keeping its own
  records of the consent it relies on.

  8.3 Unsubscribing. Every bulk message sent through the Service must
  contain an unsubscribe mechanism. Using it removes you from that
  Chapter's list. Unsubscribing from one Chapter's newsletter does not
  unsubscribe you from another Chapter's, because each Chapter maintains
  its own separate list. Unsubscribing also does not stop transactional
  messages that are necessary to operate your account, such as password
  resets and security notices; to stop those, you must close your
  account.

  8.4 Suppression. When you unsubscribe, we record that fact so the
  Service can prevent further sending to you, and we retain that record
  for as long as necessary to keep honouring your choice. This is one of
  the few cases where retaining your email address after you ask to be
  left alone is the privacy-protective outcome: without it, we could not
  reliably stop the next message.

  8.5 If you keep receiving unwanted messages. Contact the Chapter
  first, using the contact information the message is required to
  contain. If that does not work, write to privacy@frweb.org with a copy
  of the message. We investigate complaints of this kind and can
  suspend a Chapter's sending ability under Section 7.8 of the Terms of
  Service.

  8.6 The Company's own messages. We send Chapters and Administrators
  transactional and service messages about their accounts. We do not
  send marketing email to Members, and we do not add anyone to a
  marketing list as a result of using the Service.

9. HOW WE SHARE INFORMATION

  9.1 We do not sell Personal Information, and we do not share Personal
  Information with third parties for their own independent marketing
  purposes.

  9.2 We use the following categories of third-party service providers,
  solely as necessary to operate the Service. Each is bound by its own
  privacy policy, and each is required to provide a level of protection
  comparable to that described in this Policy while information is in
  its custody:

    - Stripe, Inc. -- payment processing and billing. Receives the
      Chapter's billing contact details and payment credentials, which
      it collects directly. Processes in the United States and
      elsewhere.
    - Google LLC -- optional "Sign in with Google" authentication, and
      Google Search Console for public Tenant Site indexing. Receives
      an account identifier for members who choose Google sign-in.
      Processes in the United States and elsewhere.
    - Email delivery infrastructure -- to transmit transactional
      messages and Chapter newsletters. Receives recipient addresses,
      message content, and delivery metadata.
    - Malware scanning -- to scan files uploaded to the Service. May
      receive file contents or cryptographic hashes of files.
    - Canadian Centre for Child Protection Inc. ("C3P"), operator of
      Project Arachnid -- to detect child sexual abuse material and
      harmful-abusive material of children. Images and videos uploaded
      to the Service are transmitted to C3P's "Shield" service and
      compared against its classified hash list. C3P is a registered
      Canadian charity; under its own terms it may retain, use, and
      share submitted media in furtherance of that purpose, including
      with organizations outside Canada that assist it in classifying
      such material. See Section 10.2.
    - Professional advisors (accounting, legal) and, where necessary,
      insurers -- may receive information relevant to a specific
      engagement or claim.

  9.3 Between Chapters. We do not share one Chapter's information with
  another Chapter. Each Chapter's data is logically separated within the
  Service.

  9.4 Legal disclosures. We may disclose information if required to do
  so by law, subpoena, court order, or other legal process, or where we
  believe in good faith that disclosure is necessary to protect the
  rights, property, or safety of the Company, our users, or the public,
  or to investigate suspected fraud, abuse, or a violation of the Terms
  of Service. Where we are legally permitted to do so, we will notify
  the affected Chapter before disclosing information in response to a
  legal demand.

  9.5 Business transfers. If the Company is involved in a merger,
  acquisition, financing, reorganization, or sale of assets, information
  may be transferred as part of that transaction, subject to this Policy
  or a successor policy of at least equivalent protection, and subject to
  applicable law.

  9.6 Aggregate and de-identified information. We may create and use
  aggregate or de-identified statistics that cannot reasonably be used
  to identify any individual -- for example, the total number of
  Chapters using a feature. This is not Personal Information and is not
  restricted by this Policy.

10. WHERE INFORMATION IS STORED; CROSS-BORDER PROCESSING

  10.1 The Service's primary infrastructure -- the application servers
  and databases holding Chapter Backends, Member records, and uploaded
  files -- is operated by the Company and located in Canada.

  10.2 Certain third-party providers listed in Section 9.2, notably
  Stripe and Google, process information in the United States and
  potentially in other countries. In addition, images and videos
  uploaded to the Service are sent to the Canadian Centre for Child
  Protection (Project Arachnid Shield) for child-protection screening.
  C3P is located in Canada, but its screening may process media on
  servers in the European Economic Area, and media that matches its
  hash list may be made available to child-protection organizations it
  works with in other countries, including outside Canada and the EEA.

  10.3 What that means. While Personal Information is in a foreign
  jurisdiction, it is subject to the laws of that jurisdiction, and may
  be accessible to the courts, law enforcement agencies, regulators, and
  national security authorities of that jurisdiction, in some cases
  without notice to you and without any right of challenge available to
  you under Canadian law. We provide this notice so that you can make an
  informed decision; using the Service means accepting that this is the
  case for the categories of information described in Section 9.2.

  10.4 If we change hosting or service providers in a way that moves
  Personal Information to a different country, we will update this
  Policy and, where the change is material, notify Chapters in
  accordance with Section 19.

11. SAFEGUARDS

  11.1 We protect Personal Information with safeguards appropriate to
  its sensitivity. Our current measures include:

    (a) encryption of sensitive data at rest, with per-Chapter
        separation of uploaded files;

    (b) encryption of data in transit using HTTPS/TLS;

    (c) passwordless authentication: the Service does not use, set,
        or store member passwords at all. Members sign in either with a
        single-use link sent to their email address, which expires
        shortly after it is issued, or with Google. There is therefore
        no member password for us to store, for you to reuse, or for an
        attacker to steal from us;

    (d) logical separation of each Chapter's data, so that one
        Chapter's Backend cannot access another's;

    (e) role-based permissions within each Chapter's Backend;

    (f) automated malware scanning of uploaded files;

    (g) rate-limiting and logging to detect and slow abuse; and

    (h) restriction of administrative access to authorized Company
        personnel.

  11.2 We review these measures periodically and may change them as our
  assessment of appropriate safeguards evolves. This Section describes
  our practices; it is not a warranty. No method of electronic storage
  or transmission is completely secure, and we cannot guarantee that
  unauthorized access, disclosure, alteration, loss, corruption, or
  destruction of data will never occur. The allocation of legal
  liability for such events is addressed in Sections 15 and 16 of the
  Terms of Service, not in this Policy.

  11.3 Company access to your information. Company personnel access
  Chapter and Member information only where necessary to operate,
  secure, support, or troubleshoot the Service -- for example, to
  investigate a support request, respond to a security incident, or
  perform a database migration -- and are bound by confidentiality
  obligations. We do not browse Chapter data for any other reason.

  11.4 Backups. We perform backups of Service data on an approximately
  hourly basis as a matter of operational practice. Backups contain
  Personal Information and are protected by the measures in Section
  11.1. Because backups are periodic rather than continuous, and because
  backup media are overwritten or expire on their own cycle, deleted
  information may persist in backups for a limited period after deletion
  from the live Service; see Section 13.5. The status of our backup
  process as an operational measure rather than a commitment is
  addressed in Section 11 of the Terms of Service.

  11.5 Your part in security. Much of the security of your information
  depends on you. Because sign-in is passwordless, THE SECURITY OF YOUR
  EMAIL ACCOUNT IS THE SECURITY OF YOUR FRWEB ACCOUNT: anyone who can
  read your email can request a sign-in link and use it. Keep that
  mailbox under your sole control, secure it with a strong unique
  password and multi-factor authentication with your email provider, do
  not share your account or forward sign-in links to anyone, sign out on
  shared devices, and tell us promptly if you think your email account
  or your frweb account has been compromised. Section 3 of the Terms of
  Service sets out these obligations in full.

12. ACCURACY

  12.1 Personal Information should be as accurate, complete, and current
  as is necessary for the purposes for which it is used. Inaccurate
  membership records can have real consequences -- a member wrongly
  shown as in arrears, or a degree or office record that is wrong.

  12.2 Most of the substantive records about you are entered and
  maintained by your Chapter, and your Chapter is responsible for
  keeping them accurate. Where the Service permits you to edit your own
  fields, you are responsible for keeping those current.

  12.3 We do not routinely update Personal Information on our own
  initiative, because doing so would mean second-guessing a Chapter's
  records. If you tell us information we hold in our own right is
  inaccurate, we will correct it. If you tell us information your
  Chapter holds is inaccurate, Section 15.4 applies.

13. RETENTION AND DELETION

  13.1 We keep Personal Information only as long as necessary for the
  purposes identified in Section 6, or as required by law.

  13.2 Active Chapters. We retain Chapter and Member information for as
  long as the Chapter's account remains active.

  13.3 Inactive Chapters. If a Chapter's account becomes inactive due to
  non-payment and remains inactive for a further period (currently
  expected to be approximately one additional week), we may permanently
  delete the Chapter's Tenant Site, Backend data, uploaded files, and
  associated member information, as described in Section 17 of the Terms
  of Service. Chapters are strongly encouraged to maintain their own
  current export copies at all times.

  13.4 Categories with their own retention periods:

    - Billing and payment records: retained for the period required by
      Canadian tax and corporate law, currently six (6) years from the
      end of the relevant fiscal period, even after an account closes.
    - Server and application logs: approximately 90 days, as
      described in Section 5.6.
    - Correspondence with us: two (2) years from the last message in the
      thread, unless it relates to an ongoing matter.
    - Unsubscribe and suppression records: retained indefinitely, for
      the reason given in Section 8.4.
    - Breach records: at least twenty-four (24) months, as required by
      law; see Section 14.4.

  13.5 Residual copies. After deletion from the live Service,
  information may persist in backup media, logs, or caches for a limited
  period until those media are overwritten or expire in the ordinary
  course. We do not extract individual records from backup media on
  request. Residual copies remain protected by Section 11 and are not
  restored into the live Service except as part of a general
  restoration.

  13.6 Requesting deletion. You may request deletion of Personal
  Information by contacting your Chapter's Administrator or by emailing
  privacy@frweb.org. We will respond as described in Section 15,
  subject to any retention we are required or permitted to maintain by
  law or for legitimate purposes such as billing records, fraud
  prevention, or the suppression records in Section 8.4.

14. IF THERE IS A BREACH

  14.1 A breach of security safeguards means the loss of, unauthorized
  access to, or unauthorized disclosure of Personal Information
  resulting from a failure of our safeguards or from their absence.

  14.2 If we become aware of a breach affecting a Chapter's information,
  we will notify that Chapter's Administrator(s) without undue delay
  after confirming it, and give them the information reasonably
  available to us about what happened, what categories of information
  were involved, and what we have done in response.

  14.3 Determining whether individuals must be notified. Because your
  Chapter is the organization accountable to you for its membership
  records (Section 2.3), your Chapter is responsible for assessing
  whether a breach creates a real risk of significant harm to any
  individual, and for making any resulting report to the regulator, any
  notification to affected individuals, and any notification to other
  organizations that could reduce the risk. We will assist with that
  assessment. Where a breach affects information for which the Company
  is accountable in its own right, or where the law places the reporting
  obligation on us, we will report and notify as the law requires.

  14.4 Records. We maintain a record of every breach of security
  safeguards involving Personal Information under our control, whether
  or not it triggers a notification requirement, and retain that record
  for at least twenty-four (24) months. We will make those records
  available to the regulator on request.

  14.5 What notification will contain. Where we notify you directly, we
  will describe the circumstances, the day or period it occurred, the
  Personal Information involved, what we have done to reduce the risk of
  harm, what you can do to reduce your own risk, and how to contact us
  for more information.

  14.6 Notifying us. If you believe your account has been compromised,
  or you can see information belonging to someone else, tell us
  immediately at privacy@frweb.org or help@frweb.org, and do not access
  or copy information that is not yours.

15. YOUR RIGHTS: ACCESS, CORRECTION, AND HOW TO EXERCISE THEM

  15.1 Subject to applicable law, you may: ask whether we hold Personal
  Information about you; ask for access to it and for an account of how
  it has been used and to whom it has been disclosed; ask that it be
  corrected if it is inaccurate or incomplete; ask that it be deleted,
  subject to Section 13; and withdraw consent, subject to Section 7.

  15.2 Making a request. Write to privacy@frweb.org. Tell us what you
  are looking for, and enough detail to locate it. We may ask you to
  verify your identity before we disclose anything -- this protects you,
  and we will ask only for what is needed to confirm you are who you say
  you are.

  15.3 Our response. We will respond no later than thirty (30) days
  after we receive your request. If we need more time -- because meeting
  that deadline would unreasonably interfere with our operations, or
  because we need to consult or convert information into another format
  -- we will tell you within the original thirty days that we are
  extending, why, and by how long, and we will tell you that you may
  complain to the regulator about the extension. Access is normally
  provided free of charge; if a request would involve more than minimal
  cost, we will tell you the estimated cost in advance and proceed only
  if you confirm.

  15.4 Requests that belong with your Chapter. If your request concerns
  records your Chapter controls -- your dues, your degree or office
  history, whether your Chapter records you at all -- we will refer you
  to your Chapter and let your Chapter know you have asked, unless the
  law directs otherwise. Your Chapter is responsible for responding
  within the time the law allows. If your Chapter does not respond, or
  cannot fulfil the request using the Service's own features, tell us
  and we will provide reasonable assistance.

  15.5 When we may refuse. We may refuse access in the limited
  circumstances the law allows -- for example, where disclosing your
  information would reveal Personal Information about another
  identifiable individual and that information cannot be severed, where
  the information is protected by solicitor-client privilege, where it
  contains confidential commercial information, where disclosure could
  threaten the life or security of another individual, or where it was
  generated in the course of a formal dispute resolution process. If we
  refuse, we will tell you in writing, give our reasons, identify the
  provision we are relying on, and tell you how to complain under
  Section 16.

16. COMPLAINTS AND CHALLENGING OUR COMPLIANCE

  16.1 You may challenge our compliance with this Policy or with
  applicable privacy law. Write to the Privacy Officer at
  privacy@frweb.org, describing your concern. You do not need to use any
  particular form or wording.

  16.2 We will acknowledge your complaint, investigate it, and respond
  in writing with the outcome and the reasons for it. We aim to complete
  this within thirty (30) days, and will tell you if it will take
  longer. If your complaint is justified, we will take appropriate
  measures, including correcting our practices and, where necessary,
  amending this Policy.

  16.3 If you are not satisfied with our response, you may complain to
  the Office of the Privacy Commissioner of Canada. The OPC generally
  expects you to raise your concern with the organization first, which
  is why Section 16.1 comes before this step.

    Office of the Privacy Commissioner of Canada
    30 Victoria Street, Gatineau, Quebec K1A 1H3
    1-800-282-1376
    www.priv.gc.ca

  16.4 Depending on where you live, a provincial privacy regulator may
  also have jurisdiction over your complaint; see Section 18.

  16.5 A complaint about your Chapter's own handling of your information
  -- what it records, who it shares it with, whether it will correct a
  record -- is a complaint about your Chapter, and should be directed to
  your Chapter and, if unresolved, to the appropriate regulator for that
  Chapter.

17. CHILDREN'S PRIVACY

  17.1 The Service is intended for use by adults and is not directed at
  children. We do not knowingly collect Personal Information directly
  from individuals under the age of 18 for the purpose of creating an
  account.

  17.2 If we become aware that an individual under 18 has created an
  account, we may terminate that account and delete the associated
  information.

  17.3 Section 19 of the Terms of Service addresses Member Data a
  Chapter may enter about an individual under 18, such as historical or
  honorary records. A Chapter is solely responsible for having the legal
  right and any required consent -- including, where applicable, that of
  a parent or guardian -- before entering such information.

  17.4 If you are a parent or guardian and believe information about
  your child has been entered into the Service, contact the Chapter and
  write to us at privacy@frweb.org.

18. PRIVACY LAWS OTHER THAN PIPEDA

  18.1 This Policy is written to PIPEDA, the federal Canadian
  private-sector privacy law that applies to the Company.

  18.2 Alberta, British Columbia, and Quebec have their own
  private-sector privacy legislation, and Quebec's in particular imposes
  requirements that differ from PIPEDA in substance, not just in
  wording. A Chapter located in one of those provinces, or recording
  information about individuals located there, is responsible for
  identifying and meeting any additional requirements that apply to it.

  18.3 The Service is not designed or represented as compliant with the
  privacy law of any jurisdiction outside Canada. A Chapter operating
  outside Canada, or recording information about individuals outside
  Canada, is responsible for determining whether it may lawfully use the
  Service for that purpose.

  18.4 Canadian federal privacy law is currently under legislative
  review, and the framework that applies to the Company may change. If
  it does, we will update this Policy under Section 19.

19. CHANGES TO THIS POLICY

  19.1 We may update this Privacy Policy from time to time. The
  "Effective date" and "Version" at the top indicate when it was last
  revised.

  19.2 Material changes -- particularly any change to the purposes for
  which we use Personal Information, the categories of third parties we
  share it with, or where it is stored -- will be communicated by
  reasonable means, such as email to Administrators or a notice on the
  Service, before they take effect. Where a change requires consent
  under applicable law, we will obtain it rather than rely on notice.

  19.3 Where the Company requires affirmative re-acceptance of a revised
  version before continued use, a Chapter's re-acceptance is completed
  by whoever currently serves as its Administrator, consistent with
  Section 1.4 above and Section 1.6 of the Terms of Service.

  19.4 We keep prior versions of this Policy and will provide a copy of
  the version in effect on a particular date on request to
  privacy@frweb.org.

20. CONTACT US

  Privacy questions, access and correction requests, consent
  withdrawals, and complaints:

    Privacy Officer
    FraternalWeb Limited
    privacy@frweb.org
    Office 911, 145 1/2 Church St, Unit 5, Toronto, ON M5B 1Y4, Canada

  Technical support: help@frweb.org
  General enquiries: info@frweb.org