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Privacy Policy 

Last modified: 09/23/2020

INTRODUCTION

Plusplus Tutors Inc. and our affiliates and subsidiaries (“Company” or “We”) respect your privacy and are committed to protecting it by complying with this policy.
This policy describes:
· How we collect, use, disclose, and protect the personal information of our customers and website users (“you”).
· Describes the types of information we may collect from you or that you may provide when you visit the website www.plusplustutors.com (our “Website”).
· Our practices for collecting, using, maintaining, protecting, and disclosing that information.
We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
This policy applies to information we collect, use, or disclose about you:
· On this Website.
· In email, text, and other electronic messages between you and this Website.
· Through mobile and desktop applications you download from this Website, if any, which provide dedicated non-browser-based interaction between you and this Website.
· When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.
This policy DOES NOT apply to information that:
· We collect offline or through any other means, including on any other Company or third-party website (including our affiliates and subsidiaries).
· You provide to or is collected by any third party (including our affiliates and subsidiaries), through any application or content (including advertising) that may link to or be accessible from or on the Website.
Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.
Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.


CONSENT

The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except as provided by law.
Consent is required for the collection of personal information and the subsequent use or disclosure of such information. Exceptions to such requirement are specified in Applicable Privacy Laws.
The Company may not, as a condition for the supply of a product or a service require an individual to consent to the collection, use or disclosure of personal information beyond what is necessary for such purposes.
The adequacy of the form of consent depends upon the circumstances and the type of information that is being collected.
Should the Company collect sensitive information about you or your child, we will require your explicit consent.
You may withdraw his/her consent at any time, subject to legal or contractual restrictions and reasonable notice. The Company will inform you of the implications of such withdrawal.

LIMITING COLLECTION

The collection of personal information shall be limited to that which is necessary for the purposes identified by the Company. The information shall be collected by fair and lawful means.
Personal information shall not be collected indiscriminately. Both the amount and the type of information collected shall be limited to that which is necessary to fulfill the purposes identified.


LIMITING USE, DISCLOSURE AND RETENTION

Personal information shall not be used or disclosed for purposes other than those for which the information was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
The Company may disclose your personal information to third parties who assist us in the conduct of our business. Prior to disclosing your personal information, we will ensure that such third parties will protect your personal information adequately.
Employees and contractors who have access to personal information shall only be those whose function and responsibility specifically include the handling of such personal information. The right of access is restricted according to the nature and scope of the individual function and responsibility.
Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous.
As one of the purposes for which the Company collects, uses and/or discloses personal information is the operation of its business, in the event that all or part of the assets of the Company are sold to a new owner, all personal information, or that part of the personal information associated with the assets being sold, will be transferred (disclosed) to the new owner, subject to certain conditions.

SAFEGUARDS

Personal information shall be protected by security safeguards which are commensurate to the sensitivity of the information.
The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The nature of the safeguards will vary according to the sensitivity of the information. The Company will monitor security developments and re-assess the risks at regular intervals.
The methods of protection will include physical measures, organizational measures and technological measures. All personal information shall be handled on a “need-to-know” basis and each member of the Company shall be responsible for the protection of the personal information used in his or her job function.
The Company shall regularly make all of its employees and contractors aware of the importance of maintaining the security of personal information.
Care shall be used in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to such information.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:
· Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
· Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
· Third parties or publicly available sources, for example, our business partners.
Information You Provide to Us
The information we collect directly from you on or through our Website may include:
· Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our mailing list, newsletter or other services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
· Records and copies of your correspondence (including email addresses), if you contact us.
· Your responses to surveys that we might ask you to complete for research purposes.
· Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
· Your search queries on the Website.
Information We Collect Through Cookies and Other Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
· Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
· Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
· Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Third Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our Website so that you can enjoy free content.
You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:
· To present our Website and its contents to you.
· To have the students access recordings for educational purposes.
· To provide you with information, products, or services that you request from us.
· To send you newsletters, information brochures, emails or other promotional as well as non-promotional content.
· To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
· To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
· To notify you about changes to our Website or any products or services we offer or provide though it.
· To improve our Website, products or services, marketing, or customer relationships and experiences.
· To allow you to participate in interactive features, social media, or similar features on our Website.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at care@plusplustutors.com. For more information, see Choices About How We Use and Disclose Your Information.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
· To our subsidiaries and affiliates.
· In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our customers and users is among the assets transferred.
· To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
· To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
· To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your personal information:
· To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
· To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

Link to our Terms of Use: https://plusplustutors.com/terms-of-use/

· If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.
You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada. See Contact Information and Challenging Compliance.
By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
· Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
· Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your email address or contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by sending us an email stating your request to care@plusplustutors.com. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

IMAGE AND VIDEO RELEASE

By using this Website or third party platforms through our Services, you are providing the Company consent to have your photos and videos taken and used in marketing material by us (such as on our website and in our brochures) as well as for educational purposes. For the purposes of clarification, the video sessions will be recorded on a third party to help students access the recorded sessions and enhance their learning experience. If you do not wish to provide consent on the image and video release, you may let us know by emailing care@plusplustutors.com no later than 7 days prior to the start of the course.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at care@plusplustutors.com to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:
· Information protected by solicitor-client privilege.
· Information that is part of a formal dispute resolution process.
· Information that is about another individual that would reveal their personal information or confidential commercial information.
· Information that is prohibitively expensive to provide.
If you are concerned about our response or would like to correct the information provided, you may contact us by sending us an e-mail stating your concern to care@plusplustutors.com.

INDIVIDUAL ACCESS

Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Before granting an individual access to the personal information, a member of the Company must consult the Privacy Officer or that person’s delegate. There are restrictions on the grant of access in Applicable Privacy Laws, for instance 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, the Company will inform your whether or not it holds personal information about you or your child. When the Company provides you with information regarding the personal information in its possession or control, 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 providing you with any information, the Company will verify and satisfy itself as to your identity.
Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.
When a challenge is not resolved to your satisfaction, the substance of the unresolved challenge shall be recorded by the Company. When appropriate, the existence of the unresolved challenge should be transmitted to third parties having access to the information in question.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us using the contact information listed below. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.

CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time to time. It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated.
We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at care@plusplustutors.com. We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact us using the contact information listed above.

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