Sarah Delicate Training

Privacy Policy

Last Revision: March 2021

Bell Browne Molnar Delicate Consulting (“BBMD”) is the creator and owner of the Sarah Delicate e-Learning Portal located at sarahdelicate.ca (“Website”). The purpose of this Privacy Policy (“Policy”) is to inform you about BBMD’s practices relating to the collection, use and disclosure of your Personal Information (as defined below), which may be collected by us through your navigation of and/or your registration as a student or subscriber on our Website (“User”); through your purchase and/or use of our training and development and/or consulting services (“Services”) and/or through your communications with BBMD. This Policy also explains how you can contact us if you have questions about our Policy or if you would like to make a change to any information that we may be holding about you.

The application of this Policy is subject to applicable laws, including legislation, regulations and the orders or lawful requests of any courts or legal authorities.

By becoming a User of our Website or by using our Services, you consent to the collection, use and disclosure of your Personal Information. We strongly recommend that you read this Policy carefully and retain it for future reference. This Policy may change from time to time so please check this Policy periodically for updates. Your continued use of this Website after we make changes indicates that you accept and consent to those changes. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use and disclose your Personal Information.

Personal Information

For the purpose of this Policy, “Personal Information” means any information, recorded in any form, about an identifiable individual, or an individual whose identity may be inferred or determined from such information, that can be used on its own or with other information to identify, contact or locate a single person, but does not include your name, title or information that is publicly available, such as business contact information or information found in a telephone directory.

What Personal Information We Collect 

We collect our Website User’s Personal Information in order to effectively provide our Services to our Website Users. This information includes but is not limited to contact information (such as names, mailing addresses, e-mail addresses and telephone numbers), educational background and current employment, billing information and details of transactions you carry out through our Website, user name or any other identifier we may use to contact you, records and copies of your correspondence with us and our Website and your responses to surveys that we might ask you to complete for research purposes.

As you navigate through and interact with our Website, we may also collect certain information about your equipment and browsing actions and patterns, including, but not limited to:

• Details of your visits to our Website, including traffic and location data, logs and other communication data and the resources that you access and use on our Website; and
• Information about your computer and Internet connection, including your IP address, operating system and browser type.

How We Collect Your Personal Information

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email or otherwise;
• Automated technologies (such as cookies, web beacons or tags) or interactions as you navigate our Website; and
• Third parties or publicly available sources.

A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 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 beacons are small electronic files that permit us to count Users who have visited pages of our Website and for other related statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

We may also use automated technologies to collect information about your online activities over time and across third-party websites or other online services (behavioural tracking). Third parties, such as Google, Facebook and Instagram may collect or retrieve your Personal Information from our Website or elsewhere on the Internet to provide targeted ads. To learn more or to opt-out of tailored advertising, please visit the Network Advertising Initiative website and Digital Advertising Alliance of Canada Opt-Out Tool.

How We Use Your Personal Information

We use the Personal Information we collect from you to:

• Present our Website and its contents to you;
• Facilitate communications between you and us or our Website;
• Provide you with information, products or Services that you request from us;
• Provide you with notices about your account and orders or course progress;
• Carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements;
• Complete a transaction with you when you purchase a product or use a Service provided by us;
• Notify you about changes to our Website or any products or Services we offer or provide though it;
• Improve our Website, products or Services, measure or understand the effectiveness of the advertising we serve to you and others and to deliver relevant advertising to you;
• Estimate our audience size and usage patterns and analyze trends and track movements around our Website;
• Gather demographic information about our user base;
• Store information about your preferences, allowing us to customize our Website to provide you with a personalized experience;
• Recognize you when you return to our Website;
• Fulfill the purposes for which you provided the information or that were described when it was collected; or
• Fulfill any other purpose with your consent.

The Personal Information that we collect may be assigned to a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change respecting BBMD or our Website.

If you have any questions about how we use your Personal Information, please contact us.

When We Disclose Your Personal Information

BBMD does not disclose Personal Information to individuals, organizations or corporations outside of BBMD, aside from sub-contractors contracted by BBMD to deliver BBMD’s Services, at any time, for any reason, except with the consent of the User or:

• As required or authorized by law or by order or requirement of a court, administrative agency or other governmental tribunal;
• To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes;
• Where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
• Where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
• Where the information being disclosed or used is in the public domain.

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your consent as required under applicable privacy laws. Where we are obliged or permitted to disclose information without consent, we will not disclose more information than is minimally required in the applicable circumstances.

Knowledge and Consent

 When you voluntarily provide us with your Personal Information, we will typically seek consent for the use or disclosure of such Personal Information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified).

The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations of the individual in the circumstances. When you fill out a form on our Website, for instance, you imply that we may use that information for the purpose for which you filled out the form.

BBMD keeps a record of its Website Users’ history with the organization, including participation in BBMD’s Services. By using the Website, you acknowledge that we may keep this record and consent to such retention, so that if your registration becomes inactive and you later decide to rejoin, will still have your previous registration history on file. We will not use this information for any other purpose except with your consent.

You may withdraw consent to the collection, use or disclosure of your Personal Information at any time, subject to legal restrictions (such as information kept to protect BBMD from liability) and reasonable notice. If you wish to withdraw your consent, please contact us by email at [email protected]. We will inform you of the implications of withdrawing your consent as appropriate.

How We Protect Your Personal Information

 The safety and security of your Personal Information is very important to us. While we cannot guarantee complete protection of your Personal Information, we follow commercially reasonable practices to protect Personal Information collected from you against accidental loss and unauthorized access, use, alteration and disclosure.

Our Website is hosted by Thinkific, who provides us with the online course creation platform through which we sell our products and provide our Services to you. Your data is stored through Thinkific’s data storage, databases and the general Thinkific application behind a firewall on a secure server.

When you make a purchase on our Website, we use a third-party payment processor, such as Stripe or Paypal, to process payments on our behalf. Payment Information is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS) (as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover) using secure socket layer technology (SSL).

Because the transmission of information via the Internet is not completely secure, any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website. You are responsible for keeping any passwords given to you or chosen by you, to access parts of our Website, confidential, and we urge you to be cautious about giving out information in any public areas of the Website, including message boards.

Retention of Your Personal Information

Except as otherwise permitted or required by applicable law or regulation, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements or to protect us from liability in the event of a dispute.

Unless you explicitly withdraw your consent, we will retain your name and contact information so that we may archive your participation in the organization. When you explicitly withdraw your consent to us retaining your Personal Information, or if your Personal Information is no longer necessary or relevant for the identified purposes or is not required to be retained by applicable laws, BBMD will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. We reserve the right to use anonymous and de-identified data for any legitimate business purpose without further notice to you and without your consent.

BBMD uses reasonable business practices to ensure we have adequate controls, schedules and practices for information, retention of records and destruction, which apply to your Personal Information. We will make reasonable business efforts to comply with a request to delete your Personal Information as long as technological restraints or legal constraints do not limit our ability to fulfill the deletion request. Where a request for deletion of Personal Information is declined, the individual making the request will be provided with the reasons for declining the request.

Changes to This Policy

We reserve the right to modify this Policy at any time. The Policy posted on the Website shall be deemed to be the Policy in effect. A current Policy can be obtained by contacting us. If we make any material changes to this Policy regarding how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account and/or through a notice on our Website homepage. We also include the date the Policy was last revised at the top of the Policy.

You are responsible for ensuring that we have an up-to-date, active and deliverable email address for you and for periodically visiting our Website and this Policy to check for any changes.

Correcting or Updating Your Information

 It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the Personal Information that we hold about you.

You may contact us if you would like to review, verify, correct or withdraw consent to the use of your Personal Information. We may not accommodate a request to view or change information if we believe that:

• The identity of the person requesting access cannot be confirmed;
• The Personal Information is not readily retrievable, and the burden or cost of providing it would be disproportionate to the nature or value of the Personal Information;
• The requested Personal Information does not exist, is not held or cannot be found;
• Disclosure of the Personal Information would compromise the confidentiality of another individual or threaten the safety of another person; and/or
• Non-disclosure of the Personal Information is required or permitted by law.

Where a request for access, or alteration of Personal Information is declined, the individual making the request will be provided with the reasons for declining the request, subject to any legal or regulatory restrictions.

Contacting Us

If you have questions about our treatment of your Personal Information or compliance with this Policy, you may contact Sarah Delicate, our Privacy Compliance Officer, using the contact information below:

Bell Browne Molnar & Delicate Consulting Inc.

207-190 Somerset Street West

Ottawa, ON K2P 0J4

[email protected]