Introduction
This website is operated by Thinkaholic Associates Inc. (“Thinkaholic
Associates Inc.”, “we”, or “us”). Thinkaholic Associates
Inc. cares about and is committed to your privacy. This implies we do not
transfer, distribute, disclose, rent or sell any of your Personal Information
(as defined below) to third parties except as provided for in
this Privacy and Cookies Policy (the “Privacy Policy”).
Effective Date and Scope
This Privacy Policy is effective as of AUG 01, 2022.
Thinkaholic Associates Inc. has developed policies and
procedures consistent with the Personal Information Protection and
Electronic Documents Act (“PIPEDA”), the EU General Data
Protection Regulation (“GDPR”) and other relevant privacy
laws. This Privacy Policy governs our practices to the collection, use and
disclosure of Personal Information that we collect through visitors and users
of our website and individuals who otherwise provide us with Personal
Information (collectively, “Users”). By visiting and using our website,
you expressly consent to our collection, use and disclosure of Your Personal
Information in accordance with this Privacy Policy.
We also process Personal Information as a data processor/service
processor on behalf of our customers (please see “Thinkaholic Associates Inc.
as a Service Processor” below).
Our website is not intended for or directed at children under
the age of 16 years and we do not knowingly collect information relating to
children under this age.
Contacting us:
If you have any questions about our Privacy
Policy or your Personal Information, or to exercise any of your rights as
described in this Privacy Policy or under privacy laws, you can connect with us
using the Contact Us Page and the related information mentioned there.
Definitions
To better understand this
Privacy Policy, Thinkaholic Associates Inc. has set out some basic definitions
to use when reading and interpreting it.
- Collection: the
act of gathering, acquiring, recording, or obtaining Personal Information
from any source, including third parties, by any means.
- Consent: voluntary
agreement to the collection, use and disclosure of Personal Information
for defined purposes.
- Disclosure: making
Personal Information available to a third party for that party’s own
use.
- Personal
Information: information about an identifiable
individual that is recorded in any form, but does not
include aggregated information or depersonalized that cannot be
associated with a specific individual.
- Transfer: making
Personal Information available to a third party for processing, storage or
otherwise, solely to be used on behalf of Thinkaholic Associates Inc..
- Use: the
treatment, handling and management of Personal Information by and
within Thinkaholic Associates Inc.
Accountability
Thinkaholic Associates Inc. is responsible for the Personal
Information under our possession and control. We have designated a Privacy
Officer to be responsible for our compliance with this Privacy Policy and
privacy legislation.
Accountability for our compliance with the provisions of this
Privacy Policy rests with the Privacy Office within Thinkaholic Associates Inc.,
which has designated one or more persons to be accountable for compliance with
this Privacy Policy. We may delegate to other individuals within the Thinkaholic
Associates Inc. to act on behalf of designated person(s) or to take
responsibility for the day-to-day collection and processing of Personal
Information. The Privacy Office has been created to ensure Users have a
designated avenue to answer their privacy-related inquiries.
We will make known, upon request, the title of the person or
persons designated to oversee our compliance with this Privacy Policy.
Thinkaholic Associates Inc. shall implement policies and
practices to give effect to these principles, including:
- Implementing procedures to protect Personal
Information;
- Establishing procedures to receive and respond to
complaints and inquiries;
- Training staff and communicating to staff information
about the organization’s policies and practices and their duties and
obligations with respect to privacy; and
- Developing information to explain the organization’s
policies and procedures.
What Personal Information Do We Collect?
Information That You Provide Us
You may provide us with information through our website, by
email, over the phone or otherwise communicate or be in contact with us as a
business customer or business contact, when you:
- request
additional information about our services or company, or ask us to contact
you;
- use
our services as a client or customer;
- receive
customer support;
- register
with us to register for a training course that we offer; and
- make
any comment or contribution on our website.
The categories of personal information you provide may include:
- first
and last name;
- job
title and company name;
- email
address;
- phone
number
- mailing
address;
- password
to register with us;
- your
personal or professional interests;
- the
category or type of organization you work for;
- information
that you may submit to us while taking our courses, such as course
assignments or discussion board comments; and
- any
other identifier that permits Thinkaholic Associates Inc. to make contact
with you.
Information That We Collect From You
When you participate in our consulting/coaching/training
sessions, our consultants/coaches and instructors may take notes about items
discussed during the session.
Thinkaholic Associates Inc. uses third party provided software
and collects stores and uses information about your visits to our website and
about your computer, tablet, mobile or other device through which you access
our website. This includes the following information:
- technical
information, including the Internet protocol (IP) address, browser type,
internet service provider, device identifier, your login information, time
zone setting, browser plug-in types and versions, operating system and
platform, and geographical location; and
- information
about your visits and use of the website, including the full Uniform
Resource Locators (URL), clickstream to, through and from our Site, pages
you viewed and searched for, page response times, length of visits to
certain pages, referral source/exit pages, page interaction information
(such as scrolling, clicks and mouse-overs), and website navigation and
search terms used.
How Do We Use Your Personal Information?
Thinkaholic
Associates Inc. uses your Personal Information for the following purposes:
- to fulfill your requests for
information about our company and our products and services;
- to help you meet your regulatory
compliance requirements such as tax filing with CRA, business
registrations and bank compliances;
- to enroll you in our leadership
and training courses and provide you with Course Materials and other
information and materials that you request from us;
- to communicate with you about your
requests and inquiries;
- to recommend or to offer you other
products and services based on your inferred interests;
- to communicate with you regarding
customer service issues; and
- to protect the security or
integrity of our website and our business.
We retain your Personal Information for as long as necessary to
fulfill the purposes for which we collected the information or as required by
law. Personal Information that is no longer required to fulfill the
identified purposes will be destroyed, erased or made anonymous according to
the guidelines and procedures established by Thinkaholic Associates Inc.
Personal Information does not include information that is
aggregated or anonymized in such a manner that it cannot be connected to any
individual. We may anonymize and aggregate the Personal Information we process
in such a way as to ensure that individuals cannot be identified from it. We
may use this anonymized and aggregated information for our own purposes
including for testing our systems, research, data analysis, developing new
products and services and improving our website and our products and services.
We may share this anonymized and aggregated information with third parties.
Consent
The knowledge and consent of the individual are required for the
collection, use, or disclosure of Personal Information, except in certain
circumstances as described below.
In certain circumstances, Thinkaholic Associates Inc. may
collect, use or disclose Personal Information without the knowledge and consent
of the individual. For example, legal, medical or security reasons may make it
impossible or impractical to seek consent. When information is being collected
for the detection and prevention of fraud or for law enforcement, seeking the
consent of the individual might defeat the purpose of collecting the
information. Seeking consent may be impossible or inappropriate where there is
an emergency threatening the individual's life, health or security, or where
the individual is a minor, seriously ill, or mentally incapacitated. In other
instances, information may be publicly available.
Where appropriate, Thinkaholic Associates Inc. will generally
seek consent for the use or disclosure of the information at the time of
collection. In certain circumstances, consent with respect to use or disclosure
may be sought after the information has been collected but before use (for
example, when Thinkaholic Associates Inc. wants to use information for a
purpose other than those identified above).
In obtaining consent, Thinkaholic Associates Inc. will use
reasonable efforts to ensure that a User is advised of the identified purposes
for which Personal Information collected will be used or disclosed.
The form of consent sought by Thinkaholic Associates Inc. may
vary, depending upon the circumstances and type of information disclosed. In
determining the appropriate form of consent, we shall take into account the
sensitivity of the Personal Information and the reasonable expectations of
Users.
Thinkaholic Associates Inc. will seek express consent when the
information is likely to be considered sensitive. Implied consent will
generally be appropriate where the information is less sensitive. In certain
circumstances, consent may be implied by a User’s actions. For example, providing
us Personal Information to create an account is implied consent to use such
information to provide the associated services.
You may withdraw consent at any time, subject to legal or
contractual restrictions and reasonable notice, however, withdrawing consent
may result in our inability to provide you with certain Services. In order to
withdraw consent, you must provide notice to Thinkaholic Associates Inc. in
writing.
Thinkaholic Associates Inc. as Service Provider
We collect and process Personal Information on behalf of our
clients in the provision of our service. In these circumstances Thinkaholic
Associates Inc. is acting as a service provider and our clients remain the
responsible organization in respect of Personal Information they provide to us
or that we collect on their behalf. To the extent that we are acting as a
service provider, we will process and use such personal information in
accordance with our client’s instructions and any agreement in place with our
customers. Thinkaholic Associates Inc. will only use such personal information
for the purposes of providing the services for which our clients have engaged
us.
Our clients are responsible for ensuring that these individuals’
privacy is respected, including communicating to the individuals in their own
privacy policies to whom Personal Information is being transferred to and
processed by.
As a service provider, Thinkaholic Associates Inc. may share
Personal Information where instructed by our clients (the responsible
organization). Where authorized by our client, we may also share Personal
Information with third party service providers who work for Thinkaholic
Associates Inc. and who are subject to security and confidentiality
obligations. Moreover, Thinkaholic Associates Inc. may provide Personal
Information to comply with a subpoena, warrant or other court order, government
institution requesting the information upon lawful authority, or as may be
otherwise required by law.
Where Thinkaholic Associates Inc. is acting as a service
provider, we will refer any request from an individual for access to Personal
Information which we hold about them to our clients Thinkaholic Associates Inc.
will not respond directly to the request.
Thinkaholic Associates Inc. will retain Personal Information
which we process on behalf of our clients for as long as needed to provide
services to our customers and in accordance with any agreement in place with
our clients.
Personal information does not include information that is
aggregated or anonymized in such a manner that it cannot be connected to any
individual. We may anonymize and aggregate the Personal Information we process
in such a way as to ensure that individuals cannot be identified from it. We
may use this anonymized and aggregated information for our own purposes
including for testing our systems, research, data analysis, developing new
products and services and improving our website and our products and services.
We may share this anonymized and aggregated information with third parties.
Usage of Google Analytics
Thinkaholic
Associates Inc. uses Google Analytics, which is a web analytics service offered
by Google that tracks and reports website traffic. Google uses the data
collected to track and monitor use of the Services. The data is shared with
other Google services. Google Analytics uses cookies to track information about
traffic and visitors and sends such information: (i) to Google servers in the
United States and (ii) to Thinkaholic Associates Inc.. Google Analytics does
not identify any individual users or associate Your IP address with any other
data held by Google. Thinkaholic Associates Inc. uses such information in the
aggregate to compile statistical reports about the activity on our website as
well as to benchmark the website to other third parties who also use Google
Analytics. In addition, Google may use the collected data to contextualise and
personalise the ads of its own advertising network. This information is used by
Thinkaholic Associates Inc. to improve our services and their functionality.
Google’s privacy policy can be found here: policies.google.com/privacy.
You may
disable cookies using Your browser's settings. Please consult your browser's
help function for information on how to disable cookies. Note that if you
disable cookies, certain website features may not function to their fullest
potential.
You may
opt-out of Google Analytics by clicking here: tools.google.com/dlpage/gaoptout?hl=en
Do We Disclose your Personal Information to Others?
We may share your Personal Information with our service
providers that help us with our business operations. For example, we may
transfer information with service providers who provide us with marketing and
promotional services. We require our service providers to keep your Personal
Information secure. In addition, our service providers may not use or disclose
Personal Information for any purpose other than providing the services on our
behalf unless we or they have obtained your consent.
We may transfer any information we have about you in connection
with a merger or sale (including transfers made as part of insolvency or
bankruptcy proceedings) involving all or part of our business or as part of a
corporate reorganization or stock sale or other change in corporate control.
Subject to the foregoing, only Thinkaholic Associates Inc.’s and
our service providers’ employees with a business need to know, or whose duties reasonably
so require, are granted access to Personal Information about Users.
All such employees will be required as a condition of employment to
contractually respect the confidentiality of your Personal Information.
We may also disclose your Personal Information where we have
reason to believe that it is relevant to the investigation or decision to
investigate a breach of the laws of Canada, a province or territory of Canada,
or a foreign jurisdiction, and we are legally permitted to do so.
Law Enforcement Requests
We will disclose Personal Information without your knowledge or
consent if we receive an order, subpoena, warrant or other legal requirement
issued by a court, tribunal, regulator or other person with jurisdiction to
compel disclosure of your personal information.
Storage Outside of Canada
We will generally only store Personal Information in the
jurisdiction it was collected from or generated at. However, we may transfer
Personal Information to our service providers outside of Canada. We require
that our service providers safeguard your Personal Information. However, if
your Personal Information is used or stored outside of Canada, it will also be
subject to the laws of the country in which it is used or stored.
How can you Access and Modify your Personal Information or Make
a Complaint?
If you have questions or concerns about Personal Information
collected by us and would like assistance accessing that information, please
contact our Privacy Office. As noted above, when we act as a service provider
on behalf of clients, we will direct such requests to our applicable client.
How Do We Protect your Personal Information?
We have implemented administrative, technical and physical
measures to safeguard your Personal Information against accidental or
unlawful destruction or accidental loss, alteration, unauthorized disclosure or
access of Personal Information. This includes:
- utilizing access controls and firewall controls of
computer servers;
- limiting access of employees to, and the use of,
Personal Information through the use of passwords and graduated levels of
clearance.
- the use of pseudonymization and encryption of Personal
Information, where appropriate;
- measures to ensure the ongoing confidentiality,
integrity, availability and resilience of its systems and services; and
- a process for regularly testing, assessing and
evaluating the effectiveness of technical and organizational measures for
ensuring the security of the processing of Personal Information.
Although we take precautions against possible breaches of our
security systems, no company can fully eliminate the risks of unauthorized
access to your Personal Information and no website is completely secure. We
cannot guarantee that unauthorized access, hacking, data loss or breaches of
our security systems will never occur. Accordingly, you should not transmit
Personal Information to us using our website if you consider that information
to be sensitive.
Links to Third-Party Websites
You may be able to access third-party websites through links
available on our websites. These links are provided for your convenience. We do
not have any control over those third-party websites and we do not provide any
guarantee that the privacy practices of the hosts of those websites meet our
standards. Your use of such third-party websites is at your own risk and will
be governed by the privacy policies of those websites and not by this Privacy
Policy. Do not transmit Personal Information using those websites without
reading the privacy policies governing those websites.
Notice to Persons Outside of Canada
This Privacy Policy is governed by the laws of Canada and
applicable provincial laws. By submitting Personal Information to us, you
understand that your Personal Information will be subject to the laws of Canada
and applicable provincial laws.