|At Nicole Brazzale Coaching (referred to as “The Company”), we are committed to providing our website visitors with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our website visitors, protecting their personal information is one of our highest priorities.
While we have always respected our website visitors’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our website visitors of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting website visitors’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our website visitors’ personal information and allowing our website visitors’ to request access to, and correction of, their personal information.
Scope of this Policy
Personal Information –means information about an identifiable individual including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information]. Personal information does not include contact information (described below).
Policy 1 – Collecting Personal Information
1.2 We will only collect website visitors information that is necessary to fulfill the following purposes:
· To verify identity;
· To verify creditworthiness;
· To contact our website visitors;
· To identify our website visitors’ preferences;
· To understand the needs of our website visitors;
· To provide information about the goods and services that we offer or that we will be offering
· To offer you information relevant to the website’s main purpose
· To open and manage an account;
· To deliver requested products and services
· To process a subscription or transaction;
· To provide goods or services to the website visitor;
· To enrol the website visitor in a program;
· To send out association membership information;
· To ensure a high standard of service to our website visitors;
· To meet regulatory requirements;
· To improve our website.
Information We Collect About You
When you access the Website, the Company will learn certain information about you during your visit.
Information You Provide To Us. The Website provides various places for users to provide information. We collect information that users provide by filling out forms on the Website, communicating with us via contact forms, responding to surveys, search queries on our search feature, providing comments or other feedback, and providing information when ordering a product or service via the Website.
We use information you provide to us to deliver the requested product and/or service, to improve our overall performance, and to provide you with offers, promotions, and information.
The information we collect automatically is used for statistical data and will not include personal information. We use this data to improve our Website and our service offerings. To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.
Similar to other commercial websites, our website utilizes a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
2.1 We will obtain the website visitors’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the website visitors’ voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a website visitor is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the website visitor does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), website visitors can withhold or withdraw their consent for Nicole Brazzale Coaching to use their personal information in certain ways. A website visitors’ decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the website visitor in making the decision.
2.5 We may collect, use or disclose personal information without the website visitors’ knowledge or consent in the following limited circumstances:
· When the collection, use or disclosure of personal information is permitted or required by law;
· When the personal information is available from a public source (e.g., a telephone directory);
· When we require legal advice from a lawyer;
· For the purposes of collecting a debt;
· To protect ourselves from fraud; and
· To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose the website visitor’s personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
· To conduct surveys in order to enhance the provision of our services;
· To contact our website visitors directly about products and services that may be of interest;
3.2 We will not use or disclose website visitor personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use personal information to make a decision that directly affects the website visitor, we will retain that personal information for at least one year so that the website visitor has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain website visitor personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that the personal information is accurate and complete where it may be used to make a decision about the website visitor or disclosed to another organization.
5.2 Website visitors may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the website visitors’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to adopting commercially reasonable security measures to protect our website visitors’ personal information from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 We will use appropriate security measures when destroying personal information such as shredding documents and/or deleting electronically stored information.
6.3 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Website Visitors with Access to their own Personal Information
7.1 Website visitors have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.4 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the website visitor of the cost and request further direction from the website visitor on whether or not we should proceed with the request.
7.5 If a request is refused in full or in part, we will notify the website visitor in writing, providing the reasons for refusal and the recourse available to the website visitor.
If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail, and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.
We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Your Information.
We will maintain the information you send via e-mail in accordance with applicable federal law.
In compliance with the CAN-SPAM Act, all e-mails sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.
Our emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at anytime.
Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.
How And Why We Collect Information
The Company collects your information in order to record and support your participation in the activities you select. If you register to download a book or resources, sign up for our newsletter, and/or purchase a product from us, we collect your information. We use this information to track your preferences and to keep you informed about the products and services you have selected to receive and any related products and/or services. As a visitor to this Website, you can engage in most activities without providing any personal information. It is only when you seek to download resources and/or register for services that you are required to provide information.
If you are outside the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will automatically enroll you to receive our free email newsletter. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to email@example.com requesting to unsubscribe from future emails.
If you are in the European Union and opt to receive any free resources, participate in any free training programs, register for a webinar, register for a live event, register for a seminar, or purchase any products sold by the Company on this Website, we will only enroll you to receive our free email newsletter if you affirmatively consent to it. If you do not wish to receive this newsletter, you can unsubscribe anytime. We include an “unsubscribe” link at the bottom of every email we send. If you ever have trouble unsubscribing, you can send an email to firstname.lastname@example.org requesting to unsubscribe from future emails.
How Do We Use the Information That You Provide to Us?
We use personal information for purposes of presenting our Website and its contents to you, providing you with information, providing you with offers for products and services, providing you with information about your subscriptions and products, carrying out any contract between you and the Company, administering our business activities, providing customer service, and making available other items and services to our customers and prospective customers.
From time-to-time, we may use the information you provide to us to make you offers to purchase products and services provided by third parties in exchange for a commission to be paid to us by such third parties. Should you opt to take part in such promotions, the third parties will receive your information.
From time-to-time, we may use the information you provide to us to display advertisements to you that are tailored to your personal characteristics, interests, and activities.
Disclosure Of Your Information
As a general rule, we do not sell, rent, lease or otherwise transfer any information collected wither automatically or through your voluntary action.
We may disclose your personal information to our subsidiaries, affiliates, and service providers for the purpose of providing our services to you.
We may disclose your personal information to a third party, including a lawyer or collection agency, when necessary to enforce our terms of service or any other agreement between you and the Company.
We may provide your information to any successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s asserts and/or business.
We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights or when compelled by a court or other governmental entity to do so.
How Do We Protect Your Information and Secure Information Transmissions?
We employ commercially reasonable methods to ensure the security of the information you provide to us and the information we collect automatically. This includes using standard security protocols and working only with reputable third-party vendors.
Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information is never transmitted via email.
The Company may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.
For site security purposes and to ensure that this service remains available to all users, the Company uses software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage.
Visitors’ GDPR Rights
If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:
We will retain the any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.
You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.
You have the right to seek restrictions on the processing of your data.
You have the right to object to the processing of your data and the right to the portability of your data.
To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Nicole Brazzale Coaching’s compliance with this policy and the Personal Information Protection Act.
8.2 Website visitors should direct any complaints, concerns or questions regarding Nicole Brazzale Coaching’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the website visitor may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Nicole Brazzale Coaching’s Privacy Officer:
Effective as of September 9, 2018