Last updated June 2018
The purpose of this Privacy Statement is to inform you about the types of personal information Glass of Learning Inc. (as follows, “Glass of Learning”, “we” or “us”) collects, uses and discloses.
We are proud to demonstrate our commitment to your privacy by complying with the laws and regulations under applicable privacy laws in Canada, including the Personal Information Protection and Electronic Documents Act.
I. Who this statement applies to and what it covers
This Statement applied to individuals who use any website, product or service of ours that links to this Statement (we call these our “Services”).
Within our Website, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them.
Children’s Privacy. Our Services are not generally aimed at children. In the limited circumstances where we may collect and use personal information about children, for example to develop an education resource, we will comply within the appropriate laws and regulations.
II. Who we are
Glass of Learning is an Ontario-based facilitation, training and consulting company that identifies training needs in many sectors, including: manufacturing, fast food (QSR), food services, banking and retail.
We are based in South-Western Ontario, and deliver our training across Canada, North America and Europe.
III. Sources of personal information
We collect personal information about you from your interactions with us and from certain third party and other sources.
We obtain personal information from you:
- Through your interactions with us and our Services, such as when you use our Services, request information or contact us for support.
- Through your system/device and use of our Services. Our servers, logs and other technologies automatically collect system/device and usage information to help us administer, protect and improve our Services, analyze usage and improve users’ experience.
- Through cookies and similar technologies included in our Services. More information relating to cookies can be found further down in this privacy statement.
We also collect personal information about you from third parties such as:
- The person(s) arranging for you to access our Services (e.g., your employer or our subscriber).
- An organization to which you belong where that organization provides you access to our Services.
- Partners who work with us in relation to your Service.
- Publicly available sources such as public websites, or other data in the public domain, to help us maintain data accuracy and provide and enhance the Services.
IV. What types of personal information we collect
Types of personal information we collect depends on how you are interacting with us and which Services you are purchasing or using.
The personal information we collect consists of the following:
- Name and contact data, such as, first and last name, email address, phone number, and other similar contact data
- Account credentials, such as passwords and other security information for authentication and access
- User content, such as, communications and files provided by you in relation to your use of the Services
- Payment information, such as payment card number (credit or debit card), and the security code associated with your payment instrument, if you make a payment
- Usage information and browsing history, such as, information about how you navigate within our Services, your browsing history and which elements of our Services you use the most
- Location data, for Services with location-enhanced features. If we need your consent to collect geo-location data, we will collect this separately.
- Demographic information, such as, your country and preferred language.
V. How we use personal information
This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. We use personal information to provide and improve Services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Further information is set out below.
We process personal information about you on the basis that it is:
- Necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfill that contract (i.e., to provide you with Services).
- In our or a third parties’ legitimate interests: details of those legitimate interests are set out in more detail below (e.g., provision of Services that we are contractually obligated by a third party, such as your employer or our subscriber, to deliver to you).
- Where you give us your consent: we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent.
- For compliance with a legal obligation.
VI. Legitimate interests for use
We use personal information for a number of legitimate interests, including to provide and improve Services, administer our relationship with you and our business, for marketing and in order exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.
- To set up and administer your account, provide technical and customer support and training, verify your identity and send important account, subscription and Services information.
- To administer our relationship with you, our business and our third-party providers.
- To deliver and suggest tailored content such as news, research, reports and business information. We analyze the way you use our Services to make suggestions to you for features or Services that we believe you will also be interested in, and so that we can make our Services more user-friendly.
- To personalize your experience with our Services. We may retain your browsing and usage information to make your searches within our Services more relevant and use those insights to target advertising to you online on our websites.
- To contact you in relation to, and conduct surveys or polls you choose to take part in and to analyze the data collected for market research purposes.
- To display information you choose to post, share, upload or make available in chat rooms, messaging services, and community and event forums and for related collaboration, peer connection, games and information exchange.
- To provide any third party, who has made our Services available to you.
- For internal research and development purposes and to improve, test and enhance the features and functions of our Services.
- To provide you with marketing as permitted by law.
- To meet our internal and external audit requirements, including our information security obligations.
- To enforce our terms and conditions.
- To protect our rights, privacy, safety, networks, systems and property, or those of other persons.
- For the prevention, detection or investigation of a crime or other breach of law or to comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence.
- In order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work.
- In order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.
Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms.
We delivery marketing and communications to you across various platforms such as email, telephone, text messaging, direct mail and online. Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication, including our newsletter, it will include instructions on how to opt out of receiving these communications in the future.
VIII. How we share your personal information
We share personal information within the Glass of Learning group, with our partners and third-party service providers, the person providing for your access to our Services and in accordance with the law. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us.
IX. Your rights
You may have rights under European and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information.
We will honour your rights under applicable data protection laws. You have the following rights under European laws and may have similar rights under the laws of other countries.
Right to subject of access: the right to make written request for details of your personal information and a copy of that personal information
Right to rectification: The right to have inaccurate information about you corrected or removed
Right to erasure (“right to be forgotten”): The right to have certain personal information about you erased
Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
Right to opt out of marketing: You can manage your marketing preferences by unsubscribe links found in the communications you receive from us or by contacting us
Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third party’s legitimate interest
Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format.
Right to withdraw consent: The right to withdraw consent you have previously given us to handle your personal information.
These rights are not absolute and they do not always apply in all cases.
WHAT IS A COOKIE?
A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.
Absolutely necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, Services you have asked for, such as booking an appointment, cannot be provided.
Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies only collect information in an aggregated format. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.
Functionality cookies: These cookies allow the website to remember choices you make and provide enhanced, more personal features. They may also be used to provide Services you have asked for, such as watching a video or commenting on a blog. These cookies cannot track your browsing activity on other websites.
Targeting and adverting cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.
You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.
We understand that you may want to know more about cookies. Here is a useful resource that provides detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org
XI. Contact us
If you have any questions, comments, complaints or suggestions in relation to data protection or this Statement, or any other concerns about the way in which we process information about you, please email us at email@example.com