PRIVACY POLICY

Last Updated: October 22, 2018

 This privacy policy (the “Privacy Policy” or “Policy”) sets out the terms and conditions under which you may access, provide and/or download content offered on the website located at https://redworkscoaching.com, https://redworkscoaching.ca, https://redworkscommunications.com, https://redworkscommunications.ca, and https://powerupyourretirement.com (collectively referred to as the “Site”), and use our services and other features of the Site (collectively, the “Services”). This Policy applies to all users of the Site and the Services and is incorporated into and made a part of the the general Terms of Use. “We”, “us” or “our” is defined as Redworks Communications (“Redworks”) and its affiliates, officers, agents, partners, and employees. Where applicable, “you” or “your” is defined as an individual user of the Site and/or Services. Your use of the Site and Services means that you accept, and agree to abide by, all provisions of this Privacy Policy.

 

Application of This Policy

We have created this Privacy Policy to explain the type of information gathered from your visit to and use of the Site and Services and how such information may be used. This Privacy Policy will be continuously assessed against new technologies, business practices and our users’ needs. Please check this Privacy Policy from time to time for updates by checking the date of the “Last Update” at the top of this page. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain Services, email notification of Privacy Policy changes). You acknowledge and agree that your access to our Site and your use of the Services following any posted changes to the Privacy Policy indicate your acceptance of such changes.

 

What is Personal Information?

Redworks is respectful of data privacy and adopts best practices in compliance with applicable privacy laws and regulations, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the EU General Data Protection Regulation (“GDPR”).  If you are a European (EU) resident, please note that there are a number of provisions in this Privacy Policy that apply uniquely to you. 

In this Privacy Policy, “Personal Information” means information that identifies or can be used to identify a living individual, including, without limitation, your name, address, e-mail address, country of residence, and other information when such information is combined with other information.  Personal Information does not include business contact information and also does not include “aggregate” information, which is data we collect about and through the use of our Website and the Services and may include anonymized data which does not identify any individuals. Our Privacy Policy does not restrict or limit our collection and use of aggregate information or other types of non-personal information.

Consent

By accessing the Site and using the Services, you fully understand, accept, and voluntarily consent to the collection, use, retention and disclosure of Personal Information in accordance with this Privacy Policy. It is always your choice whether or not you provide us with your Personal Information; however, a decision to withhold Personal Information may, in some instances, restrict or prevent us from providing you certain features of the Services.   

 

Collection of Personal Information

Certain features of the Services may require you to first complete a registration process and establish an account (“Account”). In doing so, you will be required to provide basic information which may include your first and last name, organization’s name, valid email address and establish a password (“Account Information”). We will retain Account Information and associate it with your Account. You are responsible for updating and maintaining the truth and accuracy of the Personal Information you provide to us relating to your Account.

 

How to Opt-Out / Withdraw Consent

You can withdraw your consent for the use of your Personal Information at any time by requesting the deletion of your Account or by providing written notice to us of that withdrawal. However, you acknowledge that we may retain Personal Information for audit or archival purposes or as required by applicable federal and provincial laws. You can also review and update your Personal Information through the user features in your Account, if applicable. If you opted-in to receive marketing communications, but wish to discontinue receiving the same, you may follow the “unsubscribe” instructions included within each e-mail communication. Though you may choose to not receive marketing communications, you cannot opt-out of receiving transactional or Account communications related to the Services that you have requested (e.g. service confirmation e-mails and receipts) or important updates from us from time to time relating to the Services or updates to the legal terms that govern your use of the Site and the Services.

 

How We Use Your Information

We collect Personal Information by fair and lawful means and limit the collection of Personal Information to what is necessary for the purpose for which it was collected. You acknowledge that we may use Personal Information that you voluntarily disclose to us to:

·         provide you with certain services;

·         respond to your request for services offered through the Site;

·         enhance products or services to better suit your needs; and

·         notify you about products, services, and other opportunities we think will be of interest to you, at all times in compliance with applicable laws.

 

Disclosure of Your Personal Information

Except as otherwise disclosed to you, we will not sell or rent your Personal Information to any other party and will only use and disclose your Personal Information for the purposes for which it was collected as described in this Privacy Policy. However, you agree that we may disclose your Personal Information in the circumstances set out below:

·         we may disclose your Personal Information with your prior consent, which you hereby expressly provide by accessing or using the Site and the Services;

·         we may be required by law to disclose Personal Information without your consent in the event of emergency situations or when required by government or other legal authority;

·         we also disclose Personal Information to third parties in connection with a corporate re-organization, merger or amalgamation, or the sale of all or substantially all of our assets, provided that, where appropriate, any party to whom the information is disclosed is bound by agreements or obligations, and required to use or disclose your Personal Information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise; and

·         we may share your Personal Information with service providers who perform certain of the Services on our behalf.  For example, we may hire other companies to provide data storage, to host websites, to assist in direct marketing, to conduct audits, etc. Those companies will be permitted to obtain only the Personal Information they need only as necessary to provide services to us. Each company is bound by agreement or obligations with us to implement and maintain reasonable security procedures and practices in order to use and disclose your Personal Information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise. We take all reasonable measures and precautions to protect your Personal Information when it is being handled by our service providers. If you wish to obtain more information on our use of service providers and our policies and practices regarding such service providers, please contact us as set forth below.

 

 

Retention of Personal Information

We maintain information about you for as long as we provide Services to you, and for as long as it remains necessary for identified purposes or as required by law which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, Account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints.

 

Safeguards We Have in Place

We store and process your Personal Information on our servers in Canada, and may store and process your Personal Information in other jurisdictions if you choose to have our Site and Services’ technology platform elsewhere. Accordingly, your data may be available to government bodies or their agencies in Canada as well other jurisdictions under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information. We employ reasonable managerial and technical measures to ensure that your Personal Information is secure. Notwithstanding the forgoing, we cannot guarantee that our security measures will prevent our computers from being illegally accessed, and the data on them stolen or altered. We assume no liability or responsibility to you or to any third party arising out of any loss, misuse, destruction, or alteration of your Personal Information.

 

Notwithstanding the forgoing, we cannot guarantee that our security measures will prevent our computers from being illegally accessed, and the data on them stolen or altered.  We assume no liability or responsibility to you or to any third party arising out of any loss, misuse, destruction, or alteration of your Personal Information. Please refer to the Office of the Privacy Commissioner of Canada's website at https://www.priv.gc.ca/ for information about how to protect yourself against identity theft.  EU residents, please note that the Office of the Privacy Commissioner of Canada is not responsible for enforcing compliance with the GDPR.

Collection of Non-Personal Information

You acknowledge and agree that from time to time we may collect non-personal information from your use of the Services, which may include, without limitation, server log files, environmental variables (such as MAC address, computer type (Windows or Macintosh), screen resolution, IP addresses, or areas of a site being clicked on most frequently, OS version, Internet browser, and Internet browser version) in order to help us better deliver the Services and user experience. We and our service providers (including ad servers, outbound email vendors, affiliate vendors and search engine advertising agencies, and providers of web analytics tools) and business partners may also use “cookies” as well as so-called “pixel tags,” “web beacons,” “clear GIFs” and other similar technologies to help us deliver a better service and user experience and to facilitate your ongoing access to and use of the Services Cookies are files saved to your computers through your Web browser to enable websites or service providers systems to recognize your browser and capture and remember certain information. We use cookies to understand and save your preferences for future visits and to compile aggregate data about site traffic and site interaction, so that we can offer better site experiences and tools in the future. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular website, to your computer. If you choose to reject all cookies, you may not be able to access the Services.  To learn more about cookies, please visit http://www.allaboutcookies.org/. You may find more information about opting out of most third-party service cookies at www.networkadvertising.org or other related sites. To the extent that any cookie can uniquely identify a computer, mobile device, or tablet (“Device”), or the person using that Device, and you are an EU resident, under the GDPR, this is Personal Information.  Therefore, this Privacy Policy shall apply to such personal data collected by IIBC.

Data Breach Notification

In the unlikely event of a data breach of Personal Information, we will notify you without delay.  This notification will be provided within 72 hours, unless the breach is unlikely to impact your rights and freedoms.

Cookies

A cookie, also known as an HTTP cookie, web cookie, or browser cookie, is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity (http://en.wikipedia.org/wiki/HTTP_cookie).

 

Google; Facebook

We may use remarketing services to advertise on third party websites to you after you have visited our Services from time to time. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Services. In certain circumstances, your implied consent to our accessing, using or disclosing your Personal Information is provided if you do not instruct your web browser to refuse all Cookies or to indicate when a Cookie is sent or if you do not opt out of Google Analytics or other similar services, as indicated below.

(a)          Google Inc. (“Google”): Google AdWords is a remarketing service provided by Google. You may opt-out of Google Analytics for Display Advertising and customize Google’s Display Network ads by visiting Google’s Ads Setting page.  Google also recommends installing the Google Analytics Opt-Out Browser Add-On. This service provided by Google allows visitors to prevent their data from being collected and used by Google Analytics;

 

(b)          Facebook, Inc. (“Facebook”): We may use Facebook’s advertising services from time to time. You can opt-out of interest-based advertising from Facebook by visiting their website; or

 

(c)           Any other types of usage on other third party websites.

  

Third-Party Links

We do not include or offer third-party products or services on the Site through the use of links.

 

Payment Processor

We provide payment processors with the minimal set of personal and billing information required to process your payment and minimize fraudulent payment risk. You acknowledge and agree that we make no representation, warranty, covenant, or claim regarding, and we expressly disclaim and deny any responsibility or liability for, the privacy practices in regard to any Personal Information that we disclose on your behalf or you provide to these providers directly or any other party in relation to purchasing a product or service from our Site.

When payment is made by credit card, credit card information, including the card number, expiry date and security code, are securely collected by us and passed directly to payment processors over a secure socket layer.  Credit card data is not retained by us in any form.

 

Interpretation of This Privacy Policy

This Privacy Policy does not create or confer upon any individual any rights, or impose any obligations on us, in addition to any rights or obligations imposed by Canada’s applicable federal and provincial privacy laws. Should there be any inconsistency between this Privacy Policy and Canada’s applicable federal and provincial privacy laws, this Privacy Policy will be interpreted to comply with the applicable privacy laws. Unless otherwise stated above, the Services that we provide are controlled and operated by us from Canada, and we do not intend that the Services subject us to the laws or jurisdiction of any state, country or territory other than that of Canada. We do not represent or warrant that the Services are appropriate or available for use in any particular jurisdiction. Those who choose to access the Site and the Services do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Services’ and Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

 

Privacy Policy Information

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact us by email or by phone:

 

You can contact us about this privacy statement by email:

Redworks Communications
Email: marielle@redworkscoaching.com

 

We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.