Date Updated: November 09, 2023

CyberToronto Inc. (“CyberToronto”, “we”, “our” or “us”) recognizes the importance of privacy. The purpose of this Privacy Statement is to inform you about the types of personal information we collect, use and disclose. It explains the choices you have regarding such collection, use, and disclosure, and how you may access and correct that information.

WHAT THIS PRIVACY STATEMENT COVERS

This Privacy Statement covers the following topics:

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share Your Personal Information
• Your Consent and Withdrawal of Consent to Collection, Use and Disclosure
• Opting Out of Marketing Communications
• Retention of Personal Information, International Transfer and Storage
• Information Security
• Accessing and Updating Your Personal Information
• Third-Party Websites and Services
• Changes to this Privacy Statement
• How to Contact Us

PERSONAL INFORMATION WE COLLECT

“Personal information” means information about an identifiable individual as described under Canadian privacy laws. Generally, personal information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, work fax number or work e-mail address.

We may collect, use, and disclose different kinds of personal information, depending on our relationship with you.

Generally, the types of personal information we may collect can be grouped into the following categories – and not all of these categories may apply to you:

• Identity Data, such as your first name, last name, salutation, gender and preferred language.
• Contact Data includes e-mail address and telephone numbers.
• Technical and Usage Data when you use our websites, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional Data, such as your professional designations, professional designation member numbers and your employer’s information.
• Educational Data, such as your participation in education and training activities.
• Event Participation Data, such as your enrollment and attendance at our events.
• Images and Recordings, such as photographs, audio recordings and video footage of you that is captured at our programs or events.

We also collect, use and share aggregated and anonymized data, such as statistical or demographic data for any purpose, including for research and development relating to our products and services. Aggregated and anonymized data is not considered personal information as it does not reveal your identity.

HOW WE USE YOUR INFORMATION

We generally use your personal information for the following purposes:

• to determine eligibility for, and use of, services;
• if you use any of our technology applications, to administer your use of those applications;
• to monitor interest in our range of products and to assist us to tailor the content of our platform to your interests and preferences by collecting information about your preferences through tracking of patterns page views on our platform;
• to send you information about us and promotional material about our products together with details of any offers we may have available from time to time;
• to respond to your inquiries, complaints or requests;
• to improve the effectiveness and efficiency of our operations, products, services and programs;
• if you apply for employment with us, to process your application;
• to investigate legal claims;
• to enforce the terms of the agreements for our products and services;
• to protect our rights, operations or property;
• to allow us to pursue available remedies or limit the damages that we may sustain;
• for such other purposes as you may consent from time to time; and
• as otherwise required or permitted by law.

We may engage in interest-based or behavioral advertising in connection with your use of our website, newsletters, and other services, and across third-party websites or service offerings when you leave our website or other services. Interest-based advertising (also known as targeted or behavioral advertising) involves tracking your preferences and interests, which are collected through cookies or otherwise and then used to tailor the advertising and marketing materials you see.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

HOW WE SHARE YOUR PERSONAL INFORMATION

We generally identify to whom, and for what purposes, we disclose your personal information, at the time we collect such information from you and obtain your consent to such disclosure.

Additionally, we may disclose your information when we believe such use or disclosure is permitted, necessary or appropriate:

• to trusted CyberToronto partners who may use your data for other purposes, including recruitment and/or promotional purposes;
• to investigate legal claims;
• to enforce the terms of the agreements for our products and services;
• to protect our rights, operations or property;
• to allow us to pursue available remedies or limit the damages that we may sustain; and
• as otherwise required or permitted by law.

In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets, or other business transaction.

We may also transfer your personal information to service providers that are assisting us with the purposes. We ensure that those service providers are subject to appropriate privacy standards and are required to comply with applicable privacy laws.

YOUR CONSENT AND WITHDRAWAL OF CONSENT TO COLLECTION, USE AND DISCLOSURE

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.

If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Statement.

Where feasible or required by applicable law, we will generally accommodate requests to withdraw consent – subject to legal or contractual restrictions. However, this may mean that you are no longer eligible for certain goods or services, or to participate in certain programs – or otherwise limit our ability to fully meet your needs.

If you wish to withdraw your consent to our collection, use or disclosure of your personal information, please use the contact information in the “How to Contact Us” section below. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

OPTING OUT OF MARKETING COMMUNICATIONS

If you no longer want to receive marketing-related e-mails from us, you may opt-out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt-out by contacting us directly using the contact information in the “How to Contact Us” section below.

We will endeavour to promptly respond to your opt-out request, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related e-mails, we may still need to send you communications about your use of our products or services, or other matters.

RETENTION OF PERSONAL INFORMATION, INTERNATIONAL TRANSFERS

We will retain your personal information for as long as necessary to fulfill the purposes for which that personal information was collected and as permitted or required by law.

In addition, and unless prohibited by law, we may send personal information outside of Canada for the purposes set out in this Privacy Statement, including for process and storage by service providers. While your personal information is outside of Canada, it is subject to the laws of the country in which it is located – which may have different data protection laws than Canada. Those laws may require disclosure of your personal information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, use the contact information in the “How to Contact Us” section below.

INFORMATION SECURITY

We have implemented physical, organizational, contractual and technological security measures in an effort to protect your personal information from loss or theft, unauthorized access, use, or disclosure. For example:

• we restrict access to your personal information to those employees or agents who need access for authorized purposes;
• electronic data is protected by technological means, such as firewalls, access controls, and encryption);
• we sensitize our employees and agents to the importance of safeguarding personal information.

Like most companies, we cannot guarantee that our safeguards will always be effective. A breach of security safeguards can result in such risks as phishing and identity theft. In such cases, we act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.

We may also require you to assist us to safeguard your personal information. For instance, if you require login credentials to access any of our products/services, you should use unique and strong passwords and you should not share your passwords with others.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “How to Contact Us” section below.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

We expect you, from time to time, to supply us with updates to your personal information, when required. We will not routinely update your personal information, unless such a process is necessary.

You may make a written request to review any personal information about you that we have collected, used or disclosed, and we will provide you with any such personal information to the extent required by applicable laws.

You may also challenge the accuracy or completeness of your personal information in our records. If you successfully demonstrate that your personal information in our records is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties having access to your personal information.

We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose.

We will not charge any costs for you to access your personal information in our records without first providing you with an estimate of the approximate costs, if any.

You may have the right to make a complaint to the Privacy Commissioner of Canada or applicable provincial privacy commissioner if you object to how we have handled your request.

THIRD-PARTY WEBSITES AND SERVICES

We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products and online services from third parties with different privacy practices, and those other products and online services are governed by their respective privacy statements and policies. This Privacy Statement does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third-party websites, products or services.

CHANGES TO PRIVACY STATEMENT

From time to time, we may make changes to this Privacy Statement. When changes are made to this Privacy Statement, they will become immediately effective when published in a revised Privacy Statement posted on our website unless otherwise noted. We may also communicate the changes to this Privacy Statement through our services or by other means. The Privacy Statement was last revised as of the date that appears at the top of this page.

HOW TO CONTACT US

All comments, questions, concerns or complaints regarding your personal information or our privacy practices, or to make an access or correction request, should be forwarded to CyberToronto at privacy@cybertoronto.ca