Why Change Academy

Why Change Academy (“we”, or “us”) recognizes the importance of privacy and the sensitivity of personal information. We are committed to protecting any personal information we hold. This privacy policy (“Privacy Policy”) outlines how we manage your personal information and safeguard your privacy.

Your Privacy Rights
The rights for protection of your personal information in dealing with us are established by the Personal Information Protection and Electronic Documents Act (PIPEDA). We are responsible for protection of the personal information we collect and hold. To ensure this accountability, we have developed this Privacy Policy, and trained our staff about the proper practices in compliance with applicable law and our Privacy Policy.

What personal information is protected?
PIPEDA defines “personal information” as any information about an identifiable individual. However, where an individual is employed by a business, business address and business contact details of that individual is considered business information, not personal information.

Why do we collect your personal information?
We collect personal information to:

• provide you with the services you seek from us;
• establish a business relationship with you, such as for billing purposes;
• market and promote our services;
• respond to your inquiries, questions, comments and testimonials submitted through this website, social media or otherwise;
• detect and protect us, and our other clients, suppliers and third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with our policies and contractual obligations;
• as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
• for any other purpose to which you consent.

Browser data and cookies

Certain basic information provided by your browser may be collected for statistical analysis and system security purposes (domain name, browser type, operating system, IP address, date and time of your visit, pages your visited as well as previous pages if they are linked to our web site).

With your permission, the web site will place a browser cookie for your convenience with repeated visits and for use to identify repeat visitors.

Fair and lawful collection

We collect information only by lawful and fair means, and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you.

Depending on the nature of our relationship, sometimes we may obtain information about you from other sources, for example from a government agency or registry.

Consent

In most cases, we will ask for your express consent, to collect, use, or disclose your personal information. Normally, we ask for your consent in writing, but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us.

When is your personal information disclosed?
We may need to lawfully disclose your personal information under certain specific circumstances:

• when you have consented to the disclosure;
• when we are required or authorized by law to do so, for example if a court issues a warrant or subpoena;
• if we engage a third party to provide administrative services to us (like an accountant or a computer file storage company) and the third party is bound by our Privacy Policy or a similar privacy policy; and
• if your personal information is publicly available, as that term is defined under PIPEDA.

Where do we store your information? How is it stored an protected?

Your Personal Information is stored on secured computers or servers controlled by us or our service providers, located either at our offices or at the offices of our service providers.

We take all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:

• premises security;
• restricted access to personal information;
• deploying and ensuring that service providers deploy technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access; and
• internal password and security policies.

Where your personal information is sent to a third party for processing, we ensure, through our contacts with them, that all of your personal information is kept secure.

Access to your personal information, updating and correcting errors
You may ask for access to any personal information we hold about you. Summary information is available on request. More detailed requests may require archive retrieval costs, which may be passed on to you by us.

Your rights to access your personal information are not absolute, and we may deny access when:

• it is required or authorized by law;
• to do so would reveal confidential commercial information, and the personal information cannot be severed from the record;
• to do so could reasonably be expected to threaten the life or security of another individual, and the personal information cannot be severed from the record; or
• the information was generated in the course of a formal dispute resolution process.

Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If during the course of our relationship, any of your information changes, please inform us so that we can make any necessary changes.

If we hold your personal information and you can establish that it is not accurate, incomplete or not up-to-date, we will take reasonable steps to correct it.

If we deny your request for access to, or refuse a request to correct information, we shall explain why.

Retention limits and the right to forget
We respect your privacy. Your personal information related to the content of a specific engagement, such as video recordings of a coaching session or drafts of your resumes, will be deleted no later than 30 days after completion of the engagement. You will be provided an opportunity to download that data before it is deleted.

If you wish to delete all of the personal information we hold about you, please communicate so in writing to us. After confirming your identity, provided that there is no legal restriction to deleting the information, it will be deleted within 30 days. Minimal billing records required for our tax compliance will be retained for 7 years and will not be used for any other purpose.

Privacy Officer

If you have any questions or wish to access your personal information, please write to:

Yulia Kosarenko
Director

Why Change Academy
Why Change Consulting Inc.
[email protected]