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Canadian Academy of Osteopathy Privacy Policy

Introduction

At CAO, we are committed to maintaining the accuracy, confidentiality and security of your personal information. We have developed this privacy policy to describe our privacy policies and practices and to provide you with information about how we may collect, use and disclose the personal information of the individuals who access and use our website located at www.canadianosteopathy.ca (the “Website”).

It is CAO’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer (i.e. Student Services Coordinator) for more information.

What is Personal Information?

For the purposes of this privacy policy, we consider personal information to be any information that describes you as an identifiable individual, other than your business title or business contact information when used or disclosed for the purpose of business communications.
For example, personal information includes your name, age, email address, preferences (such as asking to receive our emails or special offers), usage habits (including how and when you use the Website) and, where applicable, payment details.

What Personal Information Do We Collect?

  • Information You Submit. We may collect the personal information that you submit to us, such as your name, address and any other contact or other information that you choose to provide by making inquiries on our Website, corresponding with us via email using the hyperlinks created for that purpose or through other communication methods.
  • Technical Data. We may collect and use technical data and related information, including but not limited to, technical information about your device, system, Website software and peripherals. We will also collect information about any errors your device may experience when accessing or using the Website. Unless provided directly by you, the technical data we collect through the Website is de-identified and aggregated.
  • Use of the Website. We may collect information related to your use of the Website, including information about gameplay, use history, advertising with which you interact within the Website and inferences to create profile about preferences and characteristics as a consumer. Unless provided directly by you, data related to your use of the Website that we collect through the Website is de-identified and aggregated.

In addition to the above, any information we collect or that you provide directly to us may be de-identified or aggregated with the information of other users in order to gain an understanding of the usage habits and preferences of our users and to assist us with the selection and adjustment of future content and features for the Website.

Aggregated and de-identified information may also be shared with third parties for a variety of purposes including, without limitation, in order to permit us to improve the Website, to engage in
marketing or similar activities, or otherwise for business purposes. This information is aggregated across all users in order to protect the usage habits of individual users.

We do not sell your personal information. However, we permit various third parties to collect information for business purposes, such as for marketing or relating to school admissions processes. CAO is not responsible for how such third parties collect, use or disclose your personal information.

For more information about how such third parties collect, use or disclose your personal information, please review the terms of their privacy policies, including:

  1. Verity IQ: https://www.verityiq.com/privacy-policy.html.
  2. Enrollment Resources: https://virtualadviser.com/privacypolicy.html

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why Do We Collect, Use, and Disclose Personal Information?

We may collect personal information from you for a variety of purposes, including to:

  • establish, maintain and manage our relationship with you;
  • comply with your requests;
  • enable us to provide certain security and privacy safeguards;
  • deal with security, debugging and technical support issues;
  • protect us against error, fraud, theft and damage to our goods and property; and
  • comply with applicable law or regulatory requirements.

How Do We Use and Disclose Your Personal Information?

We may use and disclose your personal information:

  • for the purposes described in this Privacy Policy; or
  • for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When Do We Disclose Your Personal Information?

We may share your personal information with our employees, volunteers, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist CAO in the provision of services to you; and third parties whose services we use to conduct our business.

For example, we may share your personal information from time to time with our third party information technology, data processing and payment processing service providers so that we may operate our business. As a result, your personal information may, subject to applicable laws, be collected, used, processed, stored or disclosed in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.

Further, your personal information may be disclosed:

  • as permitted or required by applicable law or regulatory requirements;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • to protect the rights and property of CAO;
  • during emergency situations or where necessary to protect the safety of a person or group of persons;
  • where the personal information is publicly available; or
  • with your consent.

A Few Words about On-line Safety

It is important to remember that while we take steps to protect your personal information and the integrity of the Services that you sign up to enjoy, no security measures are perfect or impenetrable. If you post personal information in public places, others may send you unsolicited email messages or attempt to contact you in other ways. CAO is not responsible for the collection, usage or disclosure of your personal information by third parties to whom you voluntarily disclose such information.

Always be cautious about the information you provide or store online.

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

Choice/Opt Out

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

How is Your Personal Information Protected?

CAO endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

What about Third Party Advertisements or Links to other Websites?

You should be aware that companies that advertise on our Website may use their own cookies. This Policy does not cover how these companies use their cookies.

Our Website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. CAO is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Retention of Your Personal Information

CAO will retain your personal information only for so long as it is necessary for the purpose for which the information was collected. Some specific time frames are set out in our other policies, where we indicate the type of information is collected from you; however, we may, in accordance with applicable law, revise the retention schedule as is reasonable and appropriate in the circumstances. You may ask our Privacy Officer for more details on our retention schedules and policies.

Inquiries or Concerns

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is [email protected]

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website and we encourage you to refer back to it on a regular basis.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon CAO any obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

Modifications to this Privacy Policy

From time to time, we may make changes to this privacy policy to reflect changes in our legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this privacy policy on the Website and we encourage you to refer back to it on a regular basis. This privacy policy was last updated on August 17, 2021.

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