TOTALLEADER SOLUTIONS INC.
PRIVACY POLICY
(AS OF JUNE 15, 2017)
TotalLeaderSolutions Inc. (“TotalLeader”) is
committed to protecting and preserving your privacy. Please read this Privacy Policy
carefully to fully understand how we collect, share, and protect information
about you.
You control
how your personal information is collected, used and disclosed. Other than is
necessary to provide you with the service you expect from TotalLeader(as explained in this document and when you use the website), TotalLeader gives you control over your personal
information. TotalLeader does not, and will not, sell
or commercially distribute your personal information without your consent.
TotalLeaderrespects your privacy by
meeting or exceeding standards set by law. Our privacy commitment is based on
the ten principles of the Canadian Standards Association Model Code for the
Protection of Personal Information, all of which are enshrined in law in the Personal Information Protection and
Electronic Documents Act (Canada) (“PIPEDA”).
This privacy
commitment adopts the definition of personal information from PIPEDA: “personal
information” means information about an identifiable individual, but does not
include the name, title or business address or telephone number of an employee
of an organization.
In most cases
where TotalLeader is called upon to handle personal
information, it is in the course of providing services to you and your
employer, including analysing information you provide to TotalLeaderthrough our website and proving reports and other analyses of that information to
you and your employer, including, without limitation, in connection with our TotalLeader®Management Training and LeadershipStages®Assessment
training programs (the “Services”).
This privacy
commitment applies to all collection, use, and disclosure of personal
information by TotalLeader about current, past and
prospective clients. It does not apply to third-party personal information thatTotalLeader may handle when it acts as an agent
handling the personal information on behalf of a third party.
Website Privacy Notice and Consent
By accessing
and using our website, you agree that you have read and understand this Privacy
Policy. You accept and consent to our privacy practices, as well as the uses or
disclosures of information about you that are described in this Privacy Policy.
How Do You Get My Consent?
When you
provide us with personal information necessary to providing the Services (e.g.
to complete an online assessment), to complete a transaction, to verify your
credit card, or to place an order, we imply that you consent to our collecting
it and using it for that specific reason only.
If we ask for
your personal information for a secondary reason, like marketing, we will always
ask you for your consent and/or ask you to opt-in to receive commercial
electronic messages.
How Do I Withdraw My Consent?
You may
withdraw your consent for us to (1) send you commercial electronic messages as
understood by Canada’s Anti-Spam Law (“CASL”),
or (2) collect, use or disclose your personal information, at any time, by
contacting us at [jonathan@totalleadersolutions.com]. However, your withdrawal
of consent may mean that we may not be able to provide the Services effectively
to you.
Why Do We Collect Your Personal Information?
We collect
your personal information in order to (1) provide or offer the Services (such
as to assess yours and your organization’s needs and capabilities and provide
coaching and other assistance as part of our TotalLeader®Management Training and LeadershipStages™Assessment training programs), (2) to field inquiries through our website; and
(3) for use in researching and further developing our business systems and
operations, including our assessment and training programs.
How Do We Collect Your Personal Information?
We only
collect personal information that is reasonably necessary for the legitimate
purposes identified and for which consent has been obtained. Whenever possible,
we collect your personal information directly from you, or from persons you
have requested to provide us with such information.
In operating
our website, we may collect and process the following data about you:
(i)When you provide background
information to us about your organization so that we can provide you with the
Services, we collect the personal information you give us such as your name,
address, and email address;
(ii)Information you provide when
you complete any online assessments through our website;
(iii) other information that you provide directly to us by filling in
forms on our website (such as our “Contact Us” form); and
(iv) informationprovided to us when you communicate with us for any reason.
How Do We Use Your Personal Information?
The
information that we collect and store relating to you is primarily used to
enable us to provide the Services to you and your employer in the best possible
manner.
In addition,
we may use the information for the following purposes:
(i)to provide you with information
relating to the Services;
(ii)to follow up on client or user
comments and suggestions;
(iii) to manage and develop our business systems and operations, including
our analytical and coaching methods and practices; or
(iv) tomonitor and
conduct an analysis of our website’s traffic and usage patterns.
When you
browse our website, we also automatically receive your computer’s Internet Protocol
(IP) address in order to provide us with information that helps us learn about
your browser and operating system.
Email
marketing (if applicable): With your express permission, and in compliance with
CASL, we may send you emails and/or other updates about the Services or future
program offerings.
When Do We Disclose Your Personal Information?
We will only
disclose your personal information for the legitimate purposes identified to
you and for which consent has been obtained, or if required or authorized by
law. For example, we may disclose your information:
(i)to your employer in connection
with our performance of the Services;
(ii)where it is necessary to
establish or collect fees or payment;
(iii) if a court issues a subpoena; or
(iv) if we engage a third party to provide administrative services for
our benefit, in which case we shall use contractual or other means to protect
the personal information that is being provided to the third party.
Since
our clients sometimes take a break from using our Services but later return and
expect to be able to access their past information when they do, we never
destroy your records unless you request us to do so in writing. If you want to
make a request for destruction of your records, please contact our designated
privacy contact person, listed at the end of this policy. . .
What About Third Parties?
In general, any
third-party providers used by us will only collect, use, and disclose your
information to the extent necessary to allow them to perform the services they
provide to us.
However,
certain third-party service providers, such as payment gateways and other
payment transaction processors, if any, will normally 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, as we have no responsibility or control over how they handle
your personal information. Once you leave our website or are redirected to a
third-party website or application, you are no longer governed by this Privacy
Policy.
In particular,
remember that certain providers may be located in or have facilities that are
located a different jurisdiction than either you or us. So if you elect to
proceed with a transaction that involves the services of a third-party service
provider, then your information may become subject to the laws of the
jurisdiction(s) in which that service provider or its facilities are located.
As an 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 U.S.
legislation, including the Patriot Act.
When you click
on links on our website, they may direct you from our site. We are not
responsible for the privacy practices of other sites and encourage you to read
their privacy statements.
Security
To protect
your personal information, we have put in place physical, electronic, and
managerial procedures to safeguard and secure the information we collect on our
website to make sure it is not inappropriately lost, misused, accessed,
disclosed, altered, or destroyed. Such measures will vary depending on the
sensitivity, amount, format, nature, and storage of the personal information.
If, at any
time, you provide one of our third-party payment gateways or payment
transaction providers with your credit card information, you acknowledge that
no method of transmission over the Internet or electronic storage is 100%
secure, meaning transmission of such data is therefore entirely at your own
risk..
Age of Consent
By using this
site, you represent that you are at least the age of majority in your state or
province of residence, or that you are the age of majority in your state or
province of residence and you have given us your consent to allow any of your
minor dependents to use this site.
Updating Your Information and Correcting Errors
Since we use
your personal information to provide the Services to you and your employer, it
is important that the information be accurate and up-to-date.
If any of your
information changes, is inaccurate, or is incomplete, please inform us so that
we can make any necessary changes.
Access to Your Personal Information
We will
respond promptly to any request for access to, or correct, your personal
information. There will be no cost for reasonable requests to such access or
correction, unless you request copies of records or your request involves significant
retrieval costs. We will advise you of the cost, if any, prior to the retrieval
of such records or information. We will not respond to requests for access to
personal information that are frivolous, vexatious, or repetitious.
In certain
circumstances, we may be unable to provide access to some or all of the
personal information that we hold about you. Such circumstances include those
where the personal information cannot be separated from the records of others,
cannot be disclosed for reasons of personal security or commercial
confidentiality, or is protected by professional standards relating to
confidentiality or solicitor-client privilege.
Changes to this Privacy Policy
We reserve the
right to modify this privacy policy at any time without notice to you, so
please review it frequently. Changes and clarifications will take effect
immediately upon their posting on the website.
Contacting Us
If you would
like to (1) access, correct, amend or delete any personal information we have
about you, (2) register a complaint, or (3) simply want more information about
our privacy practices, contact our designated privacy contact person, Jonathan Creaghan, at [jonathan@totalleadersolutions.com].