“01 Learning Canada Inc.” is a training center established in accordance with the laws of Ontario. When “01 Learning” or “we” used in this context, “01 Learning Canada Inc.” is meant.
Keep your personal information safe is of paramount importance for “01 Learning”. “01 Learning” abides by the regulations pertaining to the Federal Personal Information Protection and Electronic Documents Act together with the applicable provincial privacy legislation (the “Applicable Privacy Laws”).
“Collection” is construed as the act of gathering, obtaining or collecting personal information from any third party hereof.
“Consent” refers to a voluntary agreement on a proposal or an action fulfillment. Any consent here may be either “express” or “implied”.
Express consent is an explicit, verbal or written one. Express consent is also unambiguous and does not require any implication on the part of the persons looking for the consent. Implied consent is defined as follows: where consent may reasonably be inferred from an action or inaction of an individual.
“Customer” refers to an individual who is a client of “01 Learning Computer Science, Programming and Robotics Center”.
“Disclosure” is regarded as making personal information accessible to any third party out of “01 Learning”.
“Personal Information” are the information about an identifiable individual. “Use” is considered as the management and processing of personal information.
Accountability for 01 Learning’s compliance with the privacy principles shall rest with 01 Learning’s Privacy Officer. Such individual may delegate other individuals to take action on his or her behalf. The individual shall be recognized as the “Privacy Officer”.
“01 Learning” is accountable for any personal information put at its disposal, which may include the information transferred to it by a third party as well as personal information collected by a third party assisting us in the area of marketing.
“01 Learning” will only disclose your personal information to a third party if it is satisfied that such party will grant a comparable level of protection to your personal information hereof. “01 Learning” picks contractors or third parties out guaranteeing that technical, organizational and security actions will adequately protect your personal information in this regard.
A) Implementing procedures to maintain personal information
B) Establishing procedures to receive and reply to complaints and inquiries
C) Providing staff with trainings and communicating to staff information on 01 Leaning’s policies and practices hereof
D) Developing information to explain 01 Learning’s policies and procedures E) Monitoring developments in privacy and security continuously
The purposes for which personal information is gathered shall be identified by “01 Learning” before or at the time of the information collection.
“01 Learning” collects personal information only for the purposes of running its business which includes:
- Improving our Math and Reading programs
- Security of a child
- Franchise recruitment
- Institute management
- Identifying and communicating with individuals interested in receiving information about our methods, curriculum, services as well as other marketing purposes (often to be referred to as the secondary marketing)
- Abiding by governmental rules and regulations
- Recruitment and employment purposes
- Providing its staff with training
- Operating its websites
“01 Learning” generally applies such personal information to run its business and serve its customers as mentioned above.
On condition that the business is conveyed to a new owner, the personal information will also be transferred subject to the limitations of Principle 5.
The purposes for which information is collected shall be recognized by the member before the time of information collection. Only information that is essential for the purposes that have been identified may be collected. The purposes for the collection, application and disclosure will be communicated to the respective individuals.
The knowledge and consent of the person are needed for the collection, use or disclosure of personal information except as provided by the law. Consent is essential for gathering of personal information and the subsequent use or disclosure of such information. Exceptions to such requirement are stipulated in Applicable Privacy Laws.
While acting as a service provider to a franchise holder or other organizations such as a private school in regards to collection, use or disclosure of personal information, a member of “01 Learning” obtains and adheres to any form of consent previously obtained by such organization, contingent upon the exceptions provided for in Applicable Privacy Laws. “01 Learning” may not, as a condition for supplying of a product or a service, require an individual to consent to the collection, use or disclosure of personal information beyond what is required for such purposes. The adequacy of the form of consent is subject to the circumstances and type of information which is collected. In principle collection, use or disclosure of personal data regarding racial and ethnic origins, political opinions, religious beliefs or details about the health or sexual orientation of concerned individuals is not allowed, except when such is required or allowed by the law, as these are mainly sensitive categories of personal information. Should “01 Learning” collect sensitive information on you or your child, we will require your explicit consent in this regard. You may withdraw his/her consent at any time, contingent upon legal or contractual restrictions and reasonable notice. “01 Learning” will also notify you of the implications of such withdrawal.
Personal information collection shall be limited to that which is required for the purposes identified by “01 Learning”. The information is collected by reasonable and legitimate means. Personal information shall not be indiscriminately collected. Both the amount and type of information collected in here shall be limited to that which is required for fulfillment of the purposes identified hereof.
Personal information shall not be used or revealed for purposes other than those for which the information was collected, except with the consent of the individual or as required by the law. Personal information shall be retained only as long as essential for the fulfillment of those purposes.
“01 Learning” may reveal your personal information to third parties assisting us in the conduct of our business. Before disclosing your personal information, we will ensure that such third parties will adequately protect your personal information. Personnel and contractors accessing to personal information shall only be those whose function and responsibility specifically include management of such personal information. The accessibility right is restricted in accordance with the nature and scope of the individual function and responsibility. The personal information that is no longer necessary for fulfillment of the identified purposes will be removed, erased or made unidentified.
In the accuracy principle, personal information must be accurate, complete and up-to-date as required for the purposes for which it is to be applied. This is specifically of paramount importance where the information is used for the purpose of some evaluation or judgement. The extent to which the personal information shall be accurate, complete and up-to-date will depend on the use of the such information taking into account the interests of the individual. “01 Learning” has taken measures to ensure that your personal information that is applied on an ongoing basis, including the information disclosed to third parties, is generally accurate and up-to-date.
When appropriate, “01 Learning” communicates adjustments to your personal information to contractors having access to your personal information.
Personal information is protected by security safeguards which are commensurate with the information sensitivity. Also, the security safeguards shall protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, any use or adjustments hereof. The nature of the safeguards will vary in compliance with the sensitivity of the information. “01 Learning” will also monitor security developments and re-assess the risks regularly. The methods of protection will include physical, organizational and technological measures. All the personal information shall be handled on a “need-to-know” basis and each member of “01 Learning” must be responsible for the protection of the personal information applied in his or her job function.
“01 Learning” shall regularly make all of its employees and contractors aware of the significance of maintaining the security of personal information. Care shall be used in the disposal or destruction of personal information to prevent unauthorized parties from accessing to such information.
“01 Learning” makes available to individuals’ specific information regarding its policies and practices with respect to the management of personal information. “01 Learning” shall be open about its policies and practices in relation to management of such personal information. Any person is able to obtain the information about 01 Learning’s policies and practices without unreasonable effort. Such information will be available in a form which is generally understandable. The available information must include:
A) The correct legal name of “01 Learning”
B) How the person may contact the Privacy Officer with respect to complaints or inquiries
C) Advice that the person can gain access to the personal information held by “01 Learning” in writing to the Privacy Officer, confirming and verifying their identity, and also requesting the specified information
D) A description on the type of personal information held by “01 Learning” including a general account of its use
E) A copy of any brochures or other information explaining 01 Learning’s policies, standards or codes
F) What kind of personal information is generally made available to related organizations.
G) Advice that the individual may refuse to allow the use of his or her data for purposes of direct marketing, which must be given no later than the time of the first inclusion in a mailing.
Upon a request, an individual is notified of the existence, use and disclosure of his or her personal information and shall be given access to that information. A person is also able to challenge the accuracy and completeness of the information and have it modified as appropriate. Before an individual accessibility to the personal information, a member of “01 Learning” must consult with the Privacy Officer or that person’s delegate in this regard. There are some limitations on the grant of access in Applicable Privacy Laws, e.g. where such disclosure would reveal personal information about a third party that cannot be severed from the information about the individual making the request. Upon receiving your access request, “01 Learning” will inform you whether or not it holds any personal information about you or your child. When “01 Learning” provides you with the information regarding the personal information in its possession or control also, it will provide an account of the use that has been made or is being made and an account of the third parties to which the information has been disclosed. Before provision of any information for you, “01 Learning” will verify and satisfy itself as to your identity. Moreover, “01 Learning” shall reply to your request within a 30-day interval. Furthermore, “01 Learning” may need a reasonable payment for the information provided only if it has notified you of the approximate expenses in advance and you have advised “01 Learning” that the request is not being withdrawn. If you establish the inaccuracy or incompleteness of your personal information, “01 Learning” must modify the information as required hereof. Depending on the nature of the information challenged, modification involve the correction, omission or addition of information. Where appropriate, the modified information shall be conveyed to third parties who have accessibility to the information in question. When a challenge is not solved to your satisfaction, “01 Learning” will record the substance of the unresolved challenge. When applicable, the existence of the unresolved challenge should be transmitted to third parties having access to the information in question.
A person is able to address a challenge with respect to compliance with the above mentioned privacy principles to the Privacy Officer. The person’s responsible for 01 Learning’s compliance is the Privacy Officer. All inquiries and complaints will be made to 01 Learning’s Privacy Officer by an email.
01 Learning Canada Inc.
The Privacy Officer regularly checks all complaints. If a complaint is recognized to be justified, the Privacy Officer will take necessary actions including adjusting its policies and practices if necessary. Where the complaint arises out of a customer matter, the customer will be promptly notified of such measures.
The Privacy Officer may make changes to this policy so as to adapt the changing business conditions and for other reasons in this regard. In the event that in the opinion of the Privacy Officer acting reasonably such changes will allow “01 Learning” to make materially greater use and/or disclosure of any personal information, the individuals affected by such changes will be obviously notified of the changes and their proposed effect, and also provided with an opportunity to withdraw their consent regarding gathering, application or disclosure of their personal information.