Thank you for trusting us with your information. We are committed to protecting your information while you conduct business on the Internet, telephone or in person.
Overview of Policy
This Policy will explain to you the kinds of information we collect from you, why we collect such information and how we utilize it. Specific questions we address include:
Our commitment to you includes our compliance with and adherence to applicable laws and policies governing our collection and use of your personal information including PIPEDA (the Personal Information Protection and Electronic Document Act) (Canada), the General Data Protection Regulation (GDPR) (European Union) and Privacy Shield frameworks (U.S. and Switzerland).
Accordingly, this Policy also explains your principal rights under such data protection laws with respect to the collection of your personal information, including your rights:
What is Personally Identifiable Information (“PII”)?
Why Do We Collect PII from You?
We collect your PII for program registration, purchases of goods and services (if available through your program) and transfer of necessary information to certain third parties, and to:
We also may utilize your PII to contact you for the purpose of:
How Do We Collect PII?
Information SCHOOL and GOS Collects
We collect information in two ways:
We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). SCHOOL and GOS may associate your device identifiers or phone number with your SCHOOL and GOS Account.
When you use the Services or view Content, we may automatically collect and store certain information in server logs. This may include:
If any Service includes a unique application number, this number and information about your installation (for example, the operating system type and application version number) may be sent to SCHOOL and GOS when you install or uninstall that Service or when that Service periodically contacts our servers, such as for automatic updates.
We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches.
We use various technologies to collect and store information when you visit the Website and/or access the Services, and this may include sending one or more cookies or anonymous identifiers to your device.
We collect telephone log information such as your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.
How We Use Information We Collect
We use the information we collect from the Website and Services to provide, maintain, protect and improve the Services, to develop new services and functions, and to protect SCHOOL and GOS and our users.
When you contact SCHOOL and GOS, we may keep a record of your communication to help resolve any issues you might have. We may use your email address to inform you about the Services, such as letting you know about upcoming changes or improvements.
We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of the Services.
We will ask for your consent before using PII for a purpose other than those that are set out in this Policy.
SCHOOL and GOS may process your PII on a server located outside the country where you live.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide web services and functionalities for the users.
Cookies may be either "persistent" cookies or "session" cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Don't Want to Accept Cookies?
If you do not want to accept cookies you should end your browsing on this site or change the cookie setting in your browser. Most web browsers allow control of cookies through the browser settings.
Accessing, Updating and Erasing Your Personal Information
You have the right to know whether your PII is included in our databases and, if so, to confirm that such PII is accurate and relevant for the purposes for which we collected it. Upon reasonable request by email, to us (at [EMAIL ADDRESS]), you may review your PII stored in our databases and, as permitted by applicable law and our policies, correct, erase, or block any data that is incorrect. You also may edit your PII by logging into your account profile. In making modifications to your PII, you must provide only truthful, complete and accurate information. To request deletion of PII, you must submit a written request to us at [EMAIL ADDRESS].
Requests for PII
Unless prohibited by law or regulatory order, we will provide notice to the appropriate parties when either of the following circumstances arise: (a) a legally binding request for disclosure of PII is made by a government authority (unless we are prohibited by law or regulation from providing such notice); or (b) requests received from you (i.e., the owner of the PII). If we receives a request by you to access your PII, we will provide you such access, unless prohibited by law.
Satisfying Requests for Access, Modifications, and Corrections
We will endeavor to respond in a timely manner to all reasonable written requests by you to view, modify, or delete your PII.
Information We Share
We do not share PII with companies, organizations and individuals outside of SCHOOL and GOS unless one of the following circumstances applies:
We will share PII with companies, organizations and/or individuals outside of SCHOOL and GOS when we have your consent to do so. We require opt-in consent for the sharing of any PII.
If your SCHOOL and GOS subscription is managed for you by a domain administrator then your domain administrator and resellers who provide user support to your organization will have access to your SCHOOL and GOS subscription information (including your email and other data). Your domain administrator may be able to:
We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Policy and any other appropriate confidentiality and security measures.
We will share personal information with companies, organizations or individuals outside of SCHOOL and GOS if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
We may share aggregated, non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of the Services.
In addition, financial transactions relating to the Website and/or Services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your transactions, providing refunds where appropriate and dealing with complaints and queries relating to such transactions and refunds.
We work hard to protect SCHOOL and GOS and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:
While we endeavor to protect and secure the PII provided to us through the Website, data transmissions over the internet are always subject to some risk of unauthorized access or disclosure. As a result, we do not warrant the security of PII provided to it through the Website and visitors assume all risks associated with the transmission of that PII.
Limited Collection, Use, Disclosure and Retention
We limit the collection, use and disclosure of PII to those purposes we have identified in this Policy.
In addition, all of our employees and contractors are obligated to sign non-disclosure agreements prohibiting use or disclosure of PII except as required to perform their employment/contracting duties.
We retain PII as required under applicable laws. If no statutorily prescribed retention period applies, we will retain PII only for as long as necessary to meet its intended purposes. Once any prescribed retention period expires, or if we otherwise no longer are required to retain PII to fulfil its intended purpose, such PII is either destroyed or rendered anonymous, in a manner intended to prevent disclosure.
Our Policy applies to the Website and Services and any other services offered now or in the future by SCHOOL and GOS.
Enforcement and Dispute Resolution
We are committed to resolve your concerns about your privacy and our collection or use of your PII.
If your question or concern cannot be satisfied through interaction with us via email, we have further committed to refer unresolved privacy complaints to an independent dispute resolution mechanism administered by the Council of Better Business Bureaus.
If you do not receive timely acknowledgement by us of your complaint, or if your complaint is not satisfactorily addressed by us, individuals residing in the EU may bring a complaint before the BBB EU Online Privacy Shield. Information about how to file a complaint before the BBB EU Privacy Shield program can be found at: www.bbb.org/EU-privacy-shield/for-eu-consumers/. Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism. In Canada, you may register a complaint through the Office of the Privacy Commissioner of Canada at this link: https://www.priv.gc.ca/en/report-a-concern/. In the United States issues can be raised to the Federal Trade Commission: https://ftccomplaintassistant.gov/#&panel1-1.
Alternatively, under the GDPR, if you reside in any EU Member State and are concerned that we is mishandling your personal data, or that any other of your rights under the GDPR have been violated, you may lodge a complaint with the lead supervisory authority of the Member State in which you live (i.e., the independent public authority established by your Member State further to GDPR Article 51).
Complaints and Questions
We will respond to complaints or questions about our compliance with this Policy and with governing legislation. We will investigate and attempt to resolve all issues.
If you have any questions or concerns about your privacy and our role in protecting it, or any other questions about this policy, please contact us by email at [email protected].
This Policy may be amended from time to time, consistent with PIPEDA, GDPR, the Privacy Shield or Swiss Safe Harbor principles and other applicable data protection and privacy laws and principles. We will provide notice of any such amendments by posting such changes to our Website, intranet, through email and/or by other means. We will notify customers if we make changes that materially affect the way we handle previously collected PII, and we will enable customers to choose whether their PII may be used in any materially different manner.
We respect your privacy and its protection is of the utmost importance to us.
We hope you find this Policy helpful and informative.
Dated: August 21, 2018