The Board Class

PRIVACY POLICY

Last Updated: September 2024

PURPOSE OF THIS PRIVACY POLICY

The purpose of this Privacy Policy is to establish rules that govern the collection, use, disclosure, and retention of personal information by 1087339 Ontario Limited o/a The Board Class (“we” or “us”) in a manner that recognizes the need to balance an individual’s right of privacy with respect to Personal Information and our need to collect, use, and/or disclose that information in order to provide our services.

We have a practice of protecting the privacy and security of customer/end user records. We are committed to meeting our obligations under Canadian data privacy laws, including the Personal Information Protection and Electronic Documents Act, S.C. 2000, c. 5, and applicable provincial laws. We adhere to the privacy principles set out below, which govern the way we collect, use, store and disclose personal information that is obtained in the course of development, sales, promotion and distribution of our products.

DEFINITION

"Personal Information" means any factual or subjective information, recorded or not, about an identifiable person (e.g. age, name, address, income, phone number, etc.). Personal information does not include the name, title, or business address or telephone number of an employee of an organization.

This Privacy Policy applies to any Personal Information provided to or collected by us through any and all of our websites, by e-mail, facsimile, postal mail, hand delivered, verbally, or any other means.

While interacting or communicating with us, you do not need to provide any information about yourself. However, if you choose to provide Personal Information to us, we will take the necessary steps to safeguard it to the furthest extent possible.

OUR COMMITMENT AND PROCEDURES

We are committed to protecting the privacy of our customers and end users and to ensuring that all Personal Information gathered by us is kept confidential and is treated in a manner that a reasonable person would consider appropriate in the circumstances.

All Personal Information under our control or custody shall be regarded as confidential and available only to authorized users. Subject to specific limitations and exceptions, individuals (or their legal representatives) may access their own Personal Information contained in records under our custody or control following the process outline in this Policy.

We are accountable and transparent in how we treat Personal Information. We will not lend, sell, rent, or trade our mailing lists or other Personal Information.

Only our employees and contractors are authorized to access Personal Information on a need-to-know basis for the purposes noted below.

The following are our key privacy principles, based on the Canadian Standards Association's Model Code for the Protection of Personal Information, set out in Schedule 1 of Canada’s Personal Information Protection and Electronic Documents Act:

1. We Are Accountable for the Personal Information in Our Custody.

We are responsible for the Personal Information in our custody or control, including Personal Information that has been transferred to a third party for processing. We use contractual or other means to ensure the protection of any Personal Information in the possession of a third party. Our employees and agents shall be responsible for any Personal Information that they have in their possession at all times.

The President of 1087339 Ontario Limited is our Privacy Officer, accountable for our compliance with this Privacy Policy, although other individuals within 1087339 Ontario Limited may have responsibility for the day-to-day collection and processing of Personal Information and may be delegated to act on behalf of the Privacy Officer.

2. We Will Let You Know the Purpose of Any Collection of Personal Information.

Disclosure and Consent.

When Personal Information is required to be collected from you, we will – either before or at the time of collection - identify and document the purpose for which it is being collected and explain how it will be used.

Use.

The Personal Information we collect will only be used to manage our operations and for various purposes associated with the services we provide. We collect, use, and disclose Personal Information only for purposes that a reasonable person would consider appropriate in the circumstances.

The main purposes for which we generally use Personal Information are:

(a) to provide services to our customers;

(b) to provide customers access to our products;

(c) to respond to customer inquiries about accounts and other services;

(d) to understand our customers and prospective customers’ needs and to offer products and services to meet those needs;

(e) to maintain and manage relationships and provide customer service;

(f) to determine your solicitation preferences and whether you have subscribed to or unsubscribed from any of our mailing lists or publications;

(g) to track communications with you;

(h) to identify and authenticate you in our information system and network;

(i) to provide, administer and protect our websites, information system and network;

(j) tor privacy and quality management audits and training;

(k) tor data analysis and data management;

(l) for other purposes that we have told you about and for which you have given us your consent; and

(m) to fulfill other purposes permitted or required by law.

Unless required by law, we will not use your Personal Information for a new purpose without your knowledge and consent.

3. We Will Get Your Consent for the Collection, Use, and Disclosure of Your Personal Information.

When Is Consent Necessary?

Consent is required for the collection, use, and disclosure of Personal Information. We will get your consent for the use and disclosure of your Personal Information either prior to or at the time of collection.

What Type of Consent Will be Obtained?

In determining the form of consent to collect, use, or disclose your Personal Information (implied or express consent, verbal or written consent), we will take into account the sensitivity of the Information and applicable legal requirements. Regardless of the form of consent given, we will ensure that your consent is knowledgeable, voluntary, and related to the Personal Information in question.

In certain circumstances, obtaining your consent may be inappropriate. The federal Personal Information Protection and Electronic Documents Act and provincial privacy laws provide for exceptions where it is impossible or impractical to obtain consent.

We are committed to obtaining meaningful consent and using clear explanations and plain language to make sure that our consent processes are understandable and user friendly.

You Can Withdraw Your Consent.

You have the right at any time to withdraw or cancel your consent to the collection, use or disclosure of your Personal Information by contacting our Privacy Officer at [email protected] . Withdrawals of consent only take effect from the date of cancellation. They cannot be retroactive. We will advise your if a withdrawal could have any consequences.

4. We Limit the Collection of Personal Information.

We do not collect, use or disclose more Personal Information than is reasonably necessary to meet the identified purposes. We collect Personal Information only by fair and lawful means.

What Type of Information Will be Collected?

The types of information (including Personal Information) we may collect from you will depend on how you use our services and which services you use.

When you use our website, we may need to collect your name, e-mail address, and mailing address in order to process your requests. We may also monitor web traffic patterns to help us better design our website to meet your needs. Device-specific information, such as your operating system version and device type, may be collected to enhance your app experience.

When Will Information be Collected?

We collect information from you when you:

• subscribe to our website to receive free or paid products (including online courses, eBooks, and webinars;

• submit questions, requests, other communications to us via forms, e-mail, or other communication media;

• visit any of our webpages; or

• participate in any promotions, demonstrations, contests, surveys, or other marketing events. 

How Will Financial Information be Treated? 

If you make a purchase on our website, we will use a third-party payment processor such as Stripe or PayPal. Payments will be encrypted through the Payment Card Industry Data Security Standard (PCI-DSS) using secure socket layer technology (SSL) and stored with AES-256 encryption. Please note that no method of transmission over the Internet or electronic storage is completely secure. 

Your purchase transaction data will be stored by the third-party payment processor only as long as is necessary to complete your purchase transaction; no payment information will be stored by us. 

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our site and service providers. 

Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Information will be handled by these providers. 

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your Personal Information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your Personal Information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

5. We Limit the Use, Disclosure, and Retention of Personal Information.

We collect, use, and/or disclose Personal Information only for the original purposes for which it was collected, unless we have consent to use it for a different purpose or if we are required to do so by law. If we want to use or disclose your Personal Information for a new purpose, we will advise you of this purpose in writing and obtain consent.

We keep Personal Information only as long as necessary to achieve the purposes for which it was collected, although we may retain certain Personal Information for a longer period of time if we are required to do so by a governmental agency (such the Canada Revenue Agency), applicable legislation, or by our insurers.

If you make a request to access your Personal Information, we will keep that Personal Information for as long as is necessary to allow you to fully seek any remedies (exhaust any recourse) that you may have under federal and provincial legislation across Canada.

When Personal Information no longer needs to be retained, it will be disposed of by means of shredding or another secure disposal method, with care taken to prevent unauthorized parties from gaining access to the Personal Information.

We may share Personal Information with the parties set out below for the following purposes:

• professional advisors, such as lawyers, auditors, bankers and insurers who provide us with legal, accounting, auditing, banking and insurance services;

• government, regulatory authorities, law enforcement, dispute resolution bodies, courts and similar entities to comply with any legal or regulatory obligation, to detect and prevent crimes or to assert or defend legal rights and interests;

• any persons or entities where we have a legitimate business reason for doing so, such as to manage risk, to process payments to you or to someone on your behalf or to perform or carry out the terms of any contract between us;

• to the transferee, if we transfer, sell or dispose of all or substantially all of our assets or operations;

• to anyone we reasonably believe is your agent; and

• to other third parties if you have given consent.

We require all third parties to respect the security of Personal Information and to treat it in accordance with all applicable legal requirements. All third-party service providers are required to enter into contractual agreements with us that prevent them from using your Personal Information for their own purposes and require them to use your Personal Information only for specific purposes in accordance with our instructions and all applicable legal requirements.

We will not sell, trade or rent your Personal Information to others without your consent. We may provide aggregate statistics about our customers, sales, traffic patterns, website usage and related information to trusted third parties. These aggregate statistics will include no personal identifying information.

6. Reasonable Steps Must be Taken by Us, and by You, to Ensure the Accuracy of Your Personal Information in Our Custody.

Although we will use reasonable efforts to ensure that your Personal Information is as accurate, complete, and up-to-date as necessary for the purposes for which we collected the Personal Information, ultimately, you will be responsible for ensuring that we have your current and complete Personal Information in our records.

We will not routinely update Personal Information, unless such a process is necessary to fulfill the purposes for which the Personal Information was collected.

To change or modify your Personal Information previously provided to us, please send an e-mail to [email protected].

7. We Use Safeguards to Protect Personal Information.

We will use appropriate procedures and security measures to protect Personal Information in our custody or control against theft, loss, and unauthorized use, disclosure, modification, or disposal, regardless of the format in which the Personal Information is held.

We use security safeguards appropriate to the sensitivity of the information. Our methods of protection include:

Physical measures - such as areas of restricted access and locked filing cabinets.

Organizational measures - such as security policies and procedures, employee training on privacy issues and limiting access on a "need-to-know" basis. We make all of our employees, as well as third party service providers, aware of the importance of maintaining the privacy and security of Personal Information. All of our employees must sign a confidentiality agreement. We require all third-party service providers to enter into contractual agreements that require them to respect the security of your Personal Information and to treat it in accordance with all applicable legal requirements.

Technological measures - such as passwords, encryption, audits as well as strong data security software and systems to protect the Personal Information in our custody from hackers and malicious intruders. Our software is routinely updated to maximize protection of Personal Information.

While we are committed to protecting Personal Information, our security practices and technology measures cannot guarantee absolute security of Personal Information and we cannot ensure or warrant the security of any information provided to us. If you believe your information may not be secure for any reason, please contact us immediately at [email protected]

The Personal Information collected by us may be shared, stored, or accessed in Canada or in other countries where we maintain an office, conduct business, and/or have internet facilities.

If Personal Information is stolen, lost, or accessed by an unauthorized person, we will notify the relevant individual(s) and/or other third parties (such as the Privacy Commissioner) at the first reasonable opportunity, if required to do so by applicable law.

8. We are Transparent About Our Privacy Policy.

If you have questions about this Privacy Policy, including how to exercise your legal rights, or if you would like specific information about how we manage your Personal Information, you can contact the Privacy Officer at [email protected]

This Policy is expected to change as the body of knowledge in this area grows and as the environment within which we operate evolves. When we make amendments to this Privacy Policy, we will change the “last updated” date at the top of this Privacy Policy and post the amended version on our website. An individual’s continued use of our website after any changes are made signifies such individual’s agreement with the terms of the revised Privacy Policy.

By providing us with your Personal Information, you are consenting to the collection, use, disclosure, and retention, by us, of your Personal Information, as set out in this Policy.

9. You Will Have Access to Your Personal Information.

Upon written request, and proof of identification, we will inform you whether or not we hold your Personal Information. We will allow you to access your Personal Information in accordance with applicable legislation.

Certain situations will prevent us from providing you with access to your Personal Information, including for legal, confidentiality, or security reasons. In such situations, we will give you written notice that states that the request for access is being refused, provide reasons for the refusal, and inform you that a complaint about the refusal can be made to the Office of the Privacy Commissioner of Canada. We will respond to a request for access within thirty (30) calendar days of receipt of the request, unless extensions are permitted under law and we have informed you of the length and reason for the extension.

If you inform us about the inaccuracy or incompleteness of your Personal Information, we will respond to the correction request, with the amendments, within thirty (30) days of receiving the request, unless extensions are permitted under law and we have informed you of the length and reason for the extension.

In certain circumstances, we will not correct a record of Personal Information, if prohibited from doing so under law. If a correction is refused, we will inform you of the refusal, the reasons for the refusal, your right to file a complaint regarding the refusal to the Office of the Privacy Commissioner of Canada, and your right to attach a statement of disagreement to our records (so that any other organization that has access to the Personal Information can view the statement).

10. You Have the Ability to Ask Questions and Challenge Compliance.

Our Privacy Officer can be contacted at [email protected] to answer any questions that you may have about our collection, use, disclosure, and retention of Personal Information, or to register a complaint. You have the right to register a complaint with the Office of the Privacy Commissioner of Canada. We are committed to investigating all complaints and taking appropriate action.

WEBSITES

Our websites were not designed and are not directed to children eighteen (18) years of age or younger. We are committed to protecting children’s privacy in an on-line environment. We do not intentionally collect or maintain Personal Information provided by children. By using our website(s), you represent that you are at least the age of majority in your jurisdiction of residence.

Our main websites (listed below) will be governed by this Privacy Policy:

www.TheBoardClass.com

www.TheBoardClass.ca

Even though links to third-party websites may be provided on our websites, we do not guarantee, and are not responsible for, the information collection and privacy practices of such third-party websites, which may differ from our site’s policies. Every site we link to originally went through an investigation for illegal content and was deemed acceptable at that time. However, websites change over time and we are not able to monitor these sites on an ongoing basis. If you notice something wrong with a site that we have linked to, please let us know and we will consider removing such links immediately.

Please review our Website Terms of Use available at www.TheBoardClass.com/pages/terms.

COOKIES

Cookies (i.e., information that our website’s server transfers to your computer) are used to help us identify website usage and preferences of our visitors so that we may improve our offerings to you. We use cookies to recognize your device and provide you with a personalized experience. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.

We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser. 

WEB ANALYSIS TOOLS

We may use web analysis tools that are built into our website to measure and collect anonymous session information.